A. Description of the Advisory Firm Reagan Companies Asset Management, Inc is a corporation organized in the state of New York. This firm was formed in March of 2012, and the principal owner and president is Richard P. Reagan. B. Types of Advisory Services Reagan Companies Asset Management, Inc (hereinafter “RCAM”) offers the following services to advisory clients: Investment Supervisory Services RCAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RCAM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring RCAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RCAM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Financial Planning When creating a financial plan RCAM generally follows the following CFP financial planning process: 1. Agree on how to work together 2. Gather information about your finances and set goals 3. Analyze and strategize 4. Develop recommendations 5. Put plan into motion 6. Monitor progress and stay on track Financial plans and financial planning may include, but are not limited to: investment planning, life insurance, tax concerns, retirement planning, college planning, and debt/credit planning. These services may be included within the Investment Supervisory Services offered above. At the option of the advisor, financial planning may be available separately for fixed fees or hourly fees and the final fee structure

is documented in Exhibit II of the Financial Planning Agreement. Pension, Profit Sharing, & Retirement Plan Consulting Services RCAM provides consulting services to other employee benefit plans (including but not limited to 401(k) plans, and/or pooled profit-sharing plans). Some of these services consist of 3(38) fiduciary services such as platform investment options, ongoing investment monitoring, participant education and enrollment services. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments RCAM generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, ETFs, REITs, and government securities. RCAM may use other securities as well to help diversify a portfolio when applicable. Educational Seminars and Workshops RCAM provides educational seminars and workshops on market updates to all clients. C. Client Tailored Services and Client Imposed Restrictions RCAM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RCAM from properly servicing the client account, or if the restrictions would require RCAM to deviate from its standard suite of services, RCAM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. RCAM DOES NOT participate in any wrap fee programs. D. Amounts Under Management RCAM has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $818,070,197 $ 0.00 December 2023