Ironview Capital Management, LLC (hereinafter “ICM”) is a registered investment adviser based in Conshohocken, Pennsylvania. We are a limited liability company, organized under the laws of the Commonwealth of Pennsylvania. We have been providing investment advisory services since 2009. Ironview FLA LLC is the principal owner of ICM. Benjamin C. Roberts is the principal owner of Ironview FLA LLC. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. Currently, we offer the following investment advisory services, personalized for each individual client:
• Portfolio Management Services
• Pension Consulting services Portfolio Management Services Our firm offers discretionary portfolio management services, which means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and help you decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals. ICM provides advice on various types of securities, such as exchange listed equities, foreign issues, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities, and interests in partnership investing in private equity and other alternative investments. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. As part of our overall portfolio management service, we offer clients a complementary financial plan. Financial plans address various topics such as cash flow analysis, retirement analysis and planning, general business consulting, insurance analysis and planning, education savings analysis, estate analysis, and elder care planning among others. Clients who choose to accept our offer for the complementary financial plan are required to inform us of their decision in writing. Capital Integration Systems LLC Clients may also request that we consider certain investments offered on the Capital Integration Systems LLC (“CAIS”) Alternative Investments Portal as potential investments for the client’s Account. Please see Item 8 below for more information about CAIS, and risks associated with alternative investments. Pension Consulting Services ICM provides several pension consulting related services. While the primary clients for these services will be pension, profit sharing and 401(k) plans, ICM will also offer these services, where appropriate, to individuals and trusts,

estates and charitable organizations. Pension Consulting Services are comprised of the following components. Clients may choose to use any or all of these services. Investment Policy Statement Preparation (''IPS''): ICM will meet with the client (in person, over the telephone or online) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. ICM then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles ICM will create or review the plan’s investment lineup, primarily consisting of mutual funds (both index and managed) and clients will select the lineup that is most appropriate for their investment needs. The plan’s investment lineup may also include individual equities, bonds, and other investment products. The number of investments to be recommended will be determined by the plan, based on the plan’s stated goals. Monitoring of Investment Performance Client investments will be monitored and reviewed based on the procedures and timing intervals outlined in the agreement with the client. Where ICM has no access to client account statements, the client is instructed to make such statements available to the firm. Although ICM will not be involved in any way in the purchase or sale of these investments, ICM will make recommendations to the client as market factors and the client's needs dictate. Employee Communications For pension, profit sharing and 401(k) plans where the individual account participant exercises control over assets in their own account (hereinafter ''self-directed plans''), ICM also provides educational support designed for the plan participants. The nature of the topics to be covered will be determined by ICM and the client under the guidelines established in Employee Retirement Income Securities Act (“ERISA”). Educational support services will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. Other pension consulting services are available on request. All of our pension consulting services, whether general or customized, will be outlined in an agreement that shows the services that will be provided and the fees that will be charged for those services. In providing pension consulting services, our firm does not provide advice with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-Publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with ERISA and applicable state laws. Our firm represents that it is not subject to any disqualification as set forth in ERISA. To the extent ICM performs Fiduciary Services, ICM acts as a fiduciary of the plan as defined in Section 3(21) or 3(38) of ERISA. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management As of December 31, 2023, ICM manages $839,825,866 in client assets on a discretionary basis and $11,157,595 in client assets on a non-discretionary basis. Important Note: Information related to tax and legal matters that is provided as part of our services is for informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized advice.