Description of Firm JAG Capital Management, LLC (“JAGCM,” “we”, “Firm”) is a boutique investment advisory firm providing portfolio management services to institutions and individuals, primarily in the United States. JAGCM has been registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser since its founding in 2011. JAGCM is a wholly owned subsidiary of J.A. Glynn & Co. which is 100% employee owned. Norman B. Conley III is the controlling shareholder. Asset Management JAGCM provides discretionary asset management and related services to institutions and individuals. On a limited basis, we also provide non-discretionary investment management services. JAGCM also serves as the Adviser to the JAG Large Cap Growth Fund (the “Fund”) and is responsible for selecting the Fund’s investments according to the Fund’s investment objectives, policies, and restrictions, as outlined in the Fund’s prospectus. Our investment team provides a full suite of investment management and advisory services for corporations, individuals, and other entities as described in Item 7. Clients are provided with individualized portfolio reports including asset allocation, portfolio returns, market values, income, etc. We primarily offer advice on the following types of investments: common stock, preferred stock, stock options, publicly traded partnerships, non-traded REITs, American depositary receipts, mutual funds and exchange-traded funds, convertible securities, certificates of deposit, U.S. Treasurys, U.S. agencies, municipal securities, mortgage-backed securities, asset-backed securities, and dollar-denominated corporate bonds. JAGCM works with individual clients to administer an investment program and strategy based upon the client's goals and needs. Depending upon the type of advisory program selected, clients may participate in an investment strategy based upon a model investment portfolio (a “Model”). Clients shall inform JAGCM of any specific investment policies, limitations, or restrictions and JAGCM decisions will be made in accordance with those directives. If clients have their own investment policy, JAGCM will review it to determine if those guidelines and restrictions are compatible with our investment strategies. Model Provider Services JAGCM has entered into separate agreements with unaffiliated broker-dealers and investment advisers (“Platform Sponsors”) enabling them to offer some of our Model based investment strategies to their clients (“Platform Clients”) via their product platforms. JAGCM may enter into additional separate agreements with Platform Sponsors at their mutual discretion. Pursuant to the terms of our agreement, JAGCM provides Platform Sponsors with the composition of one or more of our Models and notifies Plan Sponsors of transactions or re-allocations or both within each Model as applicable. No personalized investment advice is provided by JAGCM to the Platform Sponsors or any participating Platform Client. In the event that a Platform Client chooses to invest in one of our Model based investment strategies through the Platform Sponsor, JAGCM will receive a fee directly from the Platform Sponsor. The terms of any such fee arrangement are governed by the contract between the Platform Sponsor and JAGCM and differ from the fee schedules detailed in Section 5 of this document. Financial Planning & Consulting JAGCM provides financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of the clients’ current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the clients’ financial goals and objectives. This planning or consulting encompasses one or more of the following areas: retirement planning, estate planning, charitable planning, planning for education, corporate and personal tax planning, insurance analysis, and business and personal financial planning. Rollover to IRA Clients considering rolling assets over from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options and may engage in a combination of these options: (1) Leave the assets in the former employer’s Employer Plan (if permitted); (2) Roll the assets over to a new employer’s plan (if available and permitted); (3) Roll the assets over to an IRA; or, (4) Take distribution of the Employer Plan assets and pay the required taxes. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement

accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. At a minimum, clients should consider fees and expenses, investment options, services provided and available, withdrawal options and penalties, protection from creditors and legal judgments, required minimum distributions, and employer stock. JAGCM encourages clients to discuss their options and review the considerations listed above with any or all of the following: an accountant, third-party administrator, investment adviser to their Employer Plan (if available), or legal counsel, to the extent they consider necessary. ERISA JAGCM provides investment management services to retirement plan assets subject to the Employee Retirement Income Security Act of 1974 (ERISA). Through this service, we provide clients with continuous and ongoing supervision over the designated retirement plan assets consistent with the plan’s investment policy statement (if available). We actively monitor the designated retirement plan assets and provide advice regarding the buying, selling, reinvesting in, or holding of securities, cash, or other assets of the plan. When discretionary authority is granted by the client, JAGCM makes all decisions to buy, sell, or hold securities, cash, or other assets for the designated retirement plan at our sole discretion without first consulting with the client. Again, when granted authority by the client, we have the power and authority to carry out these decisions by giving instructions to brokers and dealers and the qualified custodian or custodians of the plan. If a client elects to utilize our advisory services, JAGCM acts as an investment manager to the plan, as defined by ERISA section 3(38) and JAGCM hereby acknowledges that it is a fiduciary with respect to the plan assets. Sub-Adviser – Non-affiliated Third-Party Investment Advisers JAGCM provides advisory services to non-affiliated third-party registered investment advisers and their investment adviser representatives through a discretionary, sub-advisory agreement. Under this agreement, our relationship is primarily with the non-affiliated investment adviser and not the end client. We rely on the non-affiliated investment adviser to obtain the client’s financial information and assess if our advisory services are suitable for the client. Wrap Fee Programs JAGCM serves as an investment manager to several wrap fee programs which are sponsored by unaffiliated firms. Wrap fee programs generally charge clients a specified “bundled” fee (typically a percentage of assets under management) for discretionary investment management services and trade execution costs. This may include other services such as custody, reporting, and recordkeeping. Wrap fees are typically payable to the program sponsor who administers the program and selects investment advisers to participate in the program. More important, there is generally no difference in JAGCM’s portfolio management services with respect to wrap fee accounts and the services provided to other accounts. JAGCM typically receives a portion of the wrap fee from the program sponsor for the portfolio management services JAGCM provides to the program which is lower than our standard fee schedule. Importantly, the overall client cost of a wrap fee program may exceed the cost a client would otherwise pay for our standard management fee schedule and negotiated separate (“un- bundled”) transaction and custody services through a client’s broker, through a client’s custodian, or through both. Orders placed on clients’ behalf by JAGCM in fixed income securities that are not executed by the wrap program sponsor’s broker typically settle via prime brokerage or step-out transactions and a client’s wrap sponsor or broker may assess additional charges or fees for these types of transactions. Further information is available in the wrap program sponsor’s wrap program brochure. The sponsors of wrap fee programs provide clients with a copy of the sponsor’s wrap fee program brochure that sets forth important information about their specific program. Assets Under Management As of December 31, 2023, regulatory assets under management (“RAUM”) by JAGCM on discretionary and non-discretionary bases were: Type of Account RAUM Discretionary $1,437,425,582 Non-Discretionary $114,400,777 Total $1,551,826,359