About Our Business Lyon Capital Management, LLC (hereafter also known as the “Firm”) was established in 1994 by its principal owner, Douglass C. Lyon, CFA®. Investment Management Services The Firm provides portfolio management services to individuals, high-net-worth individuals, corporate retirement savings plans, organizations, trusts, estates, and small businesses. Lyon Capital Management, LLC’s services are tailored to each client’s needs. The portfolio management process begins with an evaluation of the specific investment needs of the client based on, but not limited to, these factors: the client’s tolerance for risk, investment time horizon, cash flow needs, tax considerations, and such reasonable restrictions as a client may wish to impose on the management of the account. Following an evaluation of each client’s specific needs, an investment plan is formulated, an asset allocation strategy is developed, and the investment portfolio is structured. Typically, clients engage the Firm to manage their investment portfolios on a discretionary basis, which involves the execution of a contract and the execution of an account application and/or limited power of attorney with a qualified account custodian. The Firm will select investments it deems most appropriate for a client’s situation. Client portfolios may include the following types of investments: common stocks, preferred stocks, municipal bonds, corporate bonds, publicly-traded real estate investment trusts, U.S. Treasury securities, U.S. Agency securities, mutual funds, exchange-traded funds, certificates of deposits, and cash equivalents. The securities purchased are generally

traded on major U.S. exchanges. The Firm monitors securities portfolios continuously and rebalances portfolios when, in the opinion of the portfolio manager, adjustments are warranted as a result of changing economic or market conditions or other relevant factors, including a change in the client’s circumstances. Client assets are held by qualified account custodians that are registered broker-dealers. The Firm places account trades through these brokerage firms and, from time to time, with other brokers. Clients have full access to and control over their accounts at all times. Lyon Capital Management, LLC also employs a CFP professional. As a result, the Firm’s portfolio management services incorporate some limited aspects of financial planning; however, the Firm does not prepare financial plans. The Firm’s financial planning services are generally incidental and are only offered to existing clients. Upon a client’s request, the Firm will prepare a high-level summary report that explains the impact of a client’s anticipated course of action (e.g., retirement withdrawals, withdrawal for a down payment on a new home, college tuition payments, car purchase, debt reduction, or receipt of a recent inheritance, etc.) on his/her portfolio. There are no separate or additional fees assessed to prepare such reports. Wrap Fee Programs The Firm does not participate in wrap fee programs. Assets Under Management As of December 31, 2022, the Firm’s assets under management were $76,147,702. Of this total, $75,059,621 was managed on a discretionary basis, and $1,088,081 was managed on a non-discretionary basis.