A. Firm Information SeaCrest Investment Management, LLC (“SIM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware, with a principal office location in the State of New York. SIM was founded in May 2006 and is a wholly-owned subsidiary of SeaCrest Management, LLC, which is owned by Ronald Lenihan (Managing Partner and Chief Compliance Officer) and Rajesh K. Gupta (Partner Emeritus). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SIM. B. Advisory Services Offered SIM offers investment advisory services to individuals, high net worth individuals, trusts, estates, organizations, corporations, businesses, charitable organizations, and insurance companies (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. SIM’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. SIM provides customized investment advisory solutions for its Clients. This is achieved through regular personal Client contact and interaction while providing discretionary investment management and related advisory services. SIM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to identify and place assets within one or more of SIM’s investment strategies as defined in Item 8 below. These strategies may consist of diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, bonds, master limited partnerships (“MLPs”), real estate investment trusts (“REITs”) and options to achieve the Client’s investment goals. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. SIM’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client and strategy or due to market conditions. SIM will place assets within the strategies to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. SIM evaluates and selects investments for inclusion in its strategy[ies] only after applying its internal due diligence process. SIM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SIM may recommend specific positions to increase sector

or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. SIM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet the Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will SIM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the agreement, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging SIM to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – SIM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – SIM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Investment Management and Supervision – SIM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs SIM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SIM. E. Assets Under Management As of December 31, 2023, SIM manages $104,837,788 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.