Identify your principal owner(s). Farley Capital L.P. (“Farley Capital”), including its predecessor of the same name, was founded in November 1989. Farley Capital currently provides discretionary investment advisory services to its clients, which include, but not limited to, managing and directing the investment and reinvestment of assets for the following private investment funds: o Labrador Partners L.P., a Delaware limited partnership (“Labrador Partners”) o Newfoundland Partners L.P., a Delaware limited partnership (“Newfoundland Partners”) o Gymkhana Partners L.P., a Delaware limited partnership (“Gymkhana Partners”) Each of Labrador Partners, Newfoundland Partners and Gymkhana Partners may be referred to individually in this brochure as a “Fund” and together as the “Funds.” The terms for each Fund are disclosed in detail in that Fund’s confidential offering documents and its limited partnership agreement (collectively, the “Offering Documents”) that are provided to prospective investors prior to investment. Farley Capital acts as the management company of each Fund. Farley Associates II LLC, a Delaware limited liability company, is the general partner of Labrador Partners and Gymkhana Partners. FA Newfoundland LLC, a Delaware limited liability company (FA Newfoundland LLC together with Farley Associates II LLC, the “General Partners”), is the general partner of Newfoundland Partners, and the General Partners are affiliates of Farley Capital. Stephen Farley LLC, a limited liability company principally owned by Mr. Stephen Farley, is the General Partner and controlling owner of Farley Capital. Mr. Farley may also provide advisory services to a limited number of other accounts, including those of his family members. Mr. Farley also acts as Co- Trustee to a trust, on a non-fee basis, for the benefit of a third party and may also engage in other business or investment activities in the future. However, Mr. Farley's principal activity has been and will continue to be the management of the Funds. specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Farley Capital is a fundamental value investor. Its investment philosophy is based upon the

belief that every security has an intrinsic value. Farley Capital seeks to earn for its Advisory Clients superior rates of return in the securities markets by buying securities at significant discounts to their intrinsic values. Farley Capital seeks generally to invest in the securities of high-quality businesses with competitive advantages. Such sustainable competitive advantages may include, but are not limited to, strong brand names, dominant market shares, unique corporate cultures, technological expertise, patent protections, unique distribution systems or government charters. Also, Farley Capital looks for companies that it deems to have strong management teams composed of individuals whom Farley Capital believes to be honest, intelligent and shareholder-oriented and who can prudently reinvest the capital generated by their businesses. Farley Capital may also acquire, on behalf of the Advisory Clients, securities of companies that sell at a discount to current assets net of all debt or that are in other special situations such as restructurings. Furthermore, Farley Capital may pursue in its discretion other opportunities that it believes can achieve a superior return for its Advisory Clients. individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Farley Capital neither tailors its advisory services to the individual needs of investors in the Funds nor accepts investor-imposed investment restrictions with respect to the Funds. When deemed appropriate for a large or strategic investor, Farley Capital may establish a managed account and may tailor its investment objectives to those of the specific investor and/or be subject to different terms and/or fees than those of the other investors in the Funds. Such investment objectives, fee arrangements and terms would be individually negotiated, and it should be noted that any such managed account relationships would generally be subject to significant account minimums. services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Not applicable. discretionary basis and the amount of client assets you manage on a non- discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2023, Farley Capital has approximately $204,690,058 of regulatory assets under management, all of which are managed on a discretionary basis.