A. Description of Firm The Clark Group Asset Management is a Dana Point, California-based investment management firm founded in 2005 and registered with the U.S. Securities and Exchange Commission ("SEC") in 2012. CGAM offers customized investment management services to individuals, high net worth clients, pension and profit-sharing plans, trusts, estates, corporations, and other types of business entities. Some of the investment instruments CGAM advises its clientele on include, among other things, investment company securities, equity exchange-traded funds ("ETFs"), equities, and fixed income. CGAM periodically sends newsletters, e-mails, and other correspondence of general market information and items of interest to its clients and prospective clients on a complimentary basis. In addition, CGAM can occasionally hold complimentary informational/educational investment seminars for its clients and prospective clients. CGAM currently is registered with the SEC as an investment adviser as a DBA under the legal name of Pachira Investments, Inc., conducting business in a number of states, which are reflected in Part 1 of our Form ADV, a copy of which can be found on www.adviserinfo.sec.gov. The principal owners of CGAM are Ray Clark, who serves as the Firm’s Founder and CEO, and Eric Cedergreen, President and Chief Compliance Officer. B. Types of Advisory Services Offered CGAM provides its clientele with asset management services on a discretionary and non- discretionary basis. Through this process, complementary financial analysis services also are offered for client’s long-term planning purposes. Complimentary Financial Analysis CGAM’s investment advisory services are comprised of two stages. During the first stage, CGAM gathers essential information from the client in order to conduct a financial analysis of the client’s current financial situation. At the conclusion of this assessment, CGAM will make certain investment recommendations based upon its findings and the client’s expressed needs. In stage two, CGAM will implement those agreed upon recommendations and actively manage the client’s account. 1. Financial Analysis CGAM’s investment advisory services begins with a Financial Analysis. First, CGAM conducts a complimentary initial consultation during which time pertinent information about the client’s financial circumstances and objectives is collected. Next, the Firm reviews and analyzes the information provided by the client and then offers recommendations designed with the intention of achieving the clients’ stated financial goals and objectives. The Financial Analysis is based on the client’s financial situation at the time the analysis is conducted and is supported by the information disclosed by the client to CGAM. As the client’s financial situation, goals, objectives, or needs change, the clients are strongly urged to promptly notify the Firm. At the conclusion of the Financial Analysis, CGAM will make certain recommendations for short- and long-term planning and investments which can or will include advice regarding existing investment accounts and various asset allocation and risk management strategies. Clients are free at all times to accept or reject any or all recommendations made by the Firm. Clients retain the authority and discretion on whether or not to implement CGAM’s recommendations. All Financial Analyses are offered as a complimentary service to CGAM asset management clients. 2. Asset Management Services After the client discusses the proposed recommendations by CGAM, CGAM will implement such recommendations as mutually agreed upon. The client will receive those advisory services as outlined within CGAM’s investment advisory agreement and in Item 4.B of this Brochure. Please note that other investment advisers can offer similar services, with costs that are higher or lower than those obtainable from CGAM. Please refer to Item 5 below for important detailed information on fees. CGAM provides its investment management service by offering clients a tailored investment management solution that encompasses domestic, international and emerging market equities consisting of common stocks, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”), mutual funds, options and publicly traded real estate investment trusts (‘REITs”). In addition, we may invest in fixed income instruments, including government bonds, municipal bonds, corporate bonds, high yield bonds, foreign bonds, CDs, ETFs, ETNs, mutual funds, short-term fixed income instruments and certain preferred stocks. Approximately 2% of a client’s portfolio generally is held in cash. Based on market conditions and the client’s risk tolerance, a client’s cash position could significantly increase (e.g., and have a weighting of up to 100%). Additionally, and when considered appropriate, taking into account a client’s risk tolerance, and suitability information, the Firm can or will recommend the use of Private Equity/Private Funds, and individual private equity issues. The Private Funds recommended will usually be equity based however, other types of funds can be considered or used when appropriate. CGAM manages all client assets on a fully discretionary basis and in some cases, on a non- discretionary basis. In exercising full discretionary authority CGAM selects, without first obtaining client’s permission: the securities to be bought and sold; the amounts of securities to be transacted and whether it will be individually, or block traded. Discretionary authority can be subject to conditions imposed by a client. This can occur when a client restricts or prohibits transactions in a security for a specific company or for an industry sector. While CGAM generally allows clients to impose reasonable restrictions on the types of securities and/or industries they do not want to be included in their portfolio,

each client assumes responsibility for informing CGAM of any changes to these restrictions or to their overall investment objectives. CGAM selects investments based on analysis performed by CGAM, and once implemented, are monitored to ensure the investments continue to meet CGAM's overall investment objective and criteria. For investment selection, CGAM advises on investments based upon research of market data and ongoing market and performance analytics. Once this fundamental analysis is completed, securities can be added to client portfolios and thereafter, are continuously monitored for imbalances or shifts. 3. Financial Planning Services CGAM’s financial planning services range from comprehensive financial planning to more focused consultations, depending on the needs of each client. Generally, CGAM evaluates the client’s financial, business and investment information and makes recommendations designed with the intention of achieving the client’s overall financial goals and objectives. Clients should understand that a conflict of interest exists because CGAM has an incentive to recommend its own investment management services as CGAM receives additional compensation for such services. Advice and recommendations can also be given on non-securities matters. Clients always have the right to accept or reject any or all recommendations made by CGAM. Should clients decide to act on such recommendations, clients always have the right to decide with whom they choose to do so. Financial planning recommendations are based on the client’s financial situation at the time the recommendations are provided and are based on the information provided by the client. In addition, certain assumptions can be made with respect to interest and inflation rates, use of past trends, performance of the market and economy. Past performance is in no way an indication of future performance and CGAM cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As a client’s financial situation, goals, objectives, or needs change, the client is strongly urged to promptly notify CGAM. For more information on the risks associated with investing, please refer to Item 8, below. Please refer to Item 5 below for detailed information on fees and compensation for these services. C. Information Relating to All CGAM Services The investment advice provided by CGAM is customizable, with each client's portfolio managed based upon the individual needs, objectives, and other financial goals of the client. At the onset of the client relationship, CGAM memorializes each client’s investment objectives, risk tolerance, investment guidelines, time horizons and other important and necessary information in an Investment Profile Questionnaire. The information provided, together with any other information relating to the client's overall financial circumstances, will be used by CGAM to determine the appropriate portfolio asset allocation and investment strategy for each client. CGAM will not assume any responsibility for the accuracy of the information provided by the client. CGAM is not obligated to verify any information received from the client or from the client's other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying CGAM in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. Additionally, and when considered appropriate, taking into account a client’s risk tolerance, and suitability information, the Firm can or will recommend the use of Private Equity/Private Funds, and individual private equity issues. The Private Funds recommended will usually be equity based however, other types of funds can be considered or used when appropriate. In the event that a client notifies CGAM of changes in the client’s financial circumstances or to the information in their Investment Profile Questionnaire, CGAM will review such changes and recommend any necessary revisions to the client’s portfolio. CGAM makes every effort to meet with clients in person or over the phone no less than annually to review the client’s investment goals and current advisory portfolios. Advisory representatives are also available during normal business hours to consult with clients. D. Advisory Agreements Prior to engaging CGAM to provide investment advisory services, the client will be required to enter into one or more written agreements with CGAM setting forth the terms and conditions under which CGAM shall render its services (collectively the "Agreement"). In accordance with Rule 204-3 under the Investment Advisers Act of 1940, as amended ("Advisers Act"), CGAM will provide a brochure and one or more brochure supplements to each client or prospective client prior to or contemporaneously with the execution of an investment advisory agreement. The Agreement between CGAM and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. CGAM's annual fee shall be prorated through the date of termination as defined in the Agreement and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither CGAM nor the client can assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of CGAM shall not be considered an assignment. E. Assets Under Management As of December 31, 2023, the following represents the amount of client assets under management by CGAM on a discretionary and non-discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $196,557,160 Non-Discretionary $48,886,980 Total: $245,444,140