Firm Description We are a New Jersey limited liability company formed in 2009 with a single objective - to preserve and grow our clients’ wealth. We believe that the best way to achieve this goal is to prudently allocate capital to assets that offer attractive risk/reward characteristics, while minimizing taxes and transaction costs. Our investment philosophy is anchored in the belief that purchase price is the key to determining the investment’s outcome. We believe that a mediocre asset, be it a stock, a bond, or a house, if purchased at a terrific price will likely result in a satisfactory return. Conversely, even a great business, if purchased at too high of a price, might turn out to be a poor investment. Principal Owner Yevgeny Neginsky Types of Advisory Services We serve as a financial advisor to a limited number of individuals, institutions and high net worth families. We work with clients to establish appropriate investment objectives and create customized portfolios tailored to each client’s needs. After implementing a suitable investment strategy, we monitor our clients’ asset allocation, portfolio performance and investment objectives on an ongoing basis. Additionally, we implement a special situations investment strategy with the objective of generating superior risk-adjusted absolute returns while attempting to avoid permanent loss of capital. Accounts managed pursuant to this special situations strategy are generally managed in the same manner and own the same securities with essentially the same position sizes. However, one or more such accounts may be managed differently in order to meet certain specific needs of the applicable client account (e.g., to address tax considerations, cash availability and other considerations). We may offer certain consultancy services to institutions, providing investment advice on a periodic basis. We do not manage any

assets through our consultancy services. Finally, we may, on occasion, be retained to provide limited advisory services on an ad hoc basis. Tailored Relationships With respect to our financial advisory services, we will manage clients’ wealth in a comprehensive manner, including: a) working with clients to establish appropriate investment objectives, b) implementing an investment strategy suitable to those objectives and c) reviewing clients’ portfolios, performance and investment objectives at appropriate intervals. We will select mutual funds and individual securities (including, but not limited to, common and preferred stocks, corporate and municipal bonds, closed-end funds and exchange-traded funds, listed domestically and internationally) with an emphasis on appropriate diversification and low cost. A portion of our clients’ assets may be invested in securities that have limited trading liquidity and thus are more likely to experience higher price volatility. Clients can choose to impose restrictions on investing in certain securities or types of securities. With respect to our special situations services, clients agree to allow us to invest as we deem best, and we have no restrictions on what specific securities or types of securities we can buy on behalf of our clients, subject to certain specific needs of the applicable client account, such as tax considerations or cash availability. With respect to our consultancy services, we do not engage in any kind of tailored relationships with our consultancy clients. With respect to certain limited advisory services that we may perform on an ad hoc basis, such services shall be provided in accordance with the individually tailored program to address the needs of any such client. Wrap Fee Programs Not Applicable. Client Assets As of March 6, 2024, we manage approximately $42,285,741 of client assets on a discretionary basis. No assets are managed on a non-discretionary basis.