LCM is a fee-based, SEC-registered, investment adviser with its principal place of business located in Holladay, Utah. We have been in business since 2003. The owners of LCM are: John Lunt, President and Shareholder, Ryan Hessenthaler, COO and Shareholder, Larry Lunt, Shareholder, and Susan Lunt, Shareholder. Sub-Advisory Services LCM provides Model Portfolio Management Services as a sub-adviser. In other words, a client may engage an independent registered investment adviser, or an adviser associated with a Broker-Dealer (hereinafter, "Adviser") which, in turn, will engage our firm (and possibly other investment advisers) to provide portfolio management services to all or part of its clients' portfolios. In this situation, the client is a client of the Adviser and not LCM, and, therefore, the Adviser and not our firm will be responsible for collecting and analyzing client investment goals and objectives and determining the suitability of one or more of our investment models. Once such an assessment takes place, the Adviser will instruct us as to which investment model to use for each sub-advised account. The Adviser will be responsible for updating client suitability information and reassessing the suitability of the selected LCM investment model on an ongoing basis. Our firm will receive a fee charged to the client in accordance with the agreement between us and the Adviser. Clients of Advisers should refer to the Adviser's disclosure document for additional information regarding its advisory services, total fees, conflicts of interest and other important information. LCM has discretion to implement recommendations made in the performance of these services. Model Portfolio Services LCM provides access to our investment model portfolios and provide advice and continuous and regular management services to other investment advisers who are clients of LCM. Under this service, we will provide investment advisers with allocations and holdings in our proprietary investment models and send them updates any time changes are made to the models. 401k Plan Model Services and Consulting LCM acts as a consultant and advisor to certain retirement plans. Portfolio Management Services and Model Portfolio Management Services LCM provides investment advice or has trading authority over accounts for individuals, entities, and retirement plans. Our portfolio management services range from regular portfolio monitoring and recommending and/or arranging purchases or sales of particular investments to complete trading authority for an account. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions regarding a client's particular circumstances, we recommend investment solutions. During our discussions, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs, whether the client be an individual, entity, or retirement plan. We may also review and discuss a client’s prior investment history, as well as family composition and background. We will manage advisory accounts on a discretionary or non-discretionary basis, as agreed with each client. We customize portfolios to meet the individual client’s needs. Our firm also provides portfolio management services to clients using model portfolios, outside investments, or a combination of the two. We work with each client to determine which model portfolio or combination of model portfolios and other investments meet the client’s needs. Through discussions with the client or written materials

in which the client's goals and objectives are established, we will determine if and which model portfolio is suitable to the client's circumstances. The model portfolio will be managed based on the portfolio's strategy, rather than on each client's individual needs. Clients will retain individual ownership of all securities. 7Twelve® Partners LCM provides various products and services to other investment advisors that have entered into collaboration and sublicense agreements with us relating to our license of certain intellectual properties and know-how embodied in the 7Twelve® investment and portfolio methodology. Index Provider for ETFs LCM is the index provider for ETFs and receives a fee for providing this service. While the ETFs are available to all investors including LCM Clients, LCM only invests in the ETFs for those Clients for whom the ETFs are suitable. LCM does not charge a management fee on the Client assets in the ETFs. The fees that LCM receives for providing this service is based on total assets in the ETFs, and LCM Client assets are included in that total. The fee received by LCM for providing this service is typically lower than the Client management fee. Though the actual Client assets invested in the ETFs are included in LCM’s assets under management, other assets in the ETFs are not counted as assets under management by LCM. LCM may charge a management fee on these ETFs in accounts for which LCM acts as the third-party investment manager for other financial advisors. Other Advisory Services LCM also offers advisory services to financial professionals that includes consulting, investment research, and tactical signals. The scope of these services varies by client. Services in General Our advisory recommendations are not limited to any specific product or service. Our Model Portfolios follow a strategic or a tactical, quantitative, relative strength management process. The Model Portfolios are typically composed of the following Instruments:
• Exchange Traded Funds (ETFs)
• Exchange Traded Notes (ETNs)
• Equity securities
• Corporate debt securities
• Mutual funds We also regularly use these instruments in recommendations outside of model portfolios. Occasionally, we may also recommend or manage the following instruments:
• Closed-end funds
• Collective Investment Funds
• Preferred stock
• Unit investment trusts
• Securities of foreign issuers
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable annuities
• Variable life insurance
• United States government securities
• Option contracts on securities and commodities
• Futures contracts on tangibles and intangibles
• Interests in private placement offerings and/or limited investment partnerships, such as, hedge funds and other pooled investment partnerships, including those investing in real estate and oil and gas interests. Additional information about the fees related to such investments is included in the offering documents provided to prospective investors. Because these types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Discretionary assets under our firm’s management were $227,669,911 as of 2/29/2024. Non-discretionary assets under our firm’s management were $293,399,203 as of 2/29/2024. Total assets under our firm’s management were $521,069,114 as of 2/29/2024.