Stableford Capital LLC (“we” or “Stableford Capital”) is an Arizona Limited Liability Company that was formed in 2016, and provides financial planning, portfolio management and retirement plan advisory services to its clients. Andrew J. Brinkman, through Andrew Brinkman Holdings, LLC, is the principal owner of Stableford Capital, LLC. Investment Advisory Services At the outset of our relationship, we spend time with you, asking questions, discussing your investment experience and financial circumstances and reviewing your options. Based on our reviews, together we generally develop: ● a financial outline based on your financial circumstances and goals, and your risk tolerance level (the “Financial Profile” or “Profile”); and ● your investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile reflects your current financial picture and a look at your future goals. The Investment Plan outlines the types of investments we will make on your behalf to meet those goals. The Profile and the Plan are discussed regularly with you but are not necessarily written documents. Portfolio Management As described above, at the beginning of a relationship, we meet with you, gather information, and perform research and analysis as necessary to develop your Investment Plan. The Investment Plan will be updated from time to time when you request, or when we determine it to be necessary or advisable based on updates to your financial or other circumstances. To implement your Investment Plan, we will manage your investment portfolio on a discretionary basis. As a discretionary investment adviser, we will have the authority to supervise and direct your portfolio without prior consultation with you. Financial Planning One of the services we offer is financial planning, described below. This service is generally provided as part of ongoing portfolio management. Financial planning generally includes advice that addresses one or more areas of your financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. Depending on your situation, financial planning will include some or all of the following: ● Gathering information concerning your personal and financial situation; ● Assisting you in establishing financial goals and objectives; ● Analyzing your present situation and anticipated future activities in light of your financial goals and objectives; ● Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; ● Making recommendations to help achieve retirement plan goals and objectives; ● Designing an investment portfolio to help meet your goals and objectives; ● Providing estate planning; ● Assessing risk and reviewing basic health, life, and disability insurance needs; and/or ● Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, you may choose to have us implement your financial plan and manage the investment portfolio on an ongoing basis. However, you are under no obligation to act upon any of our financial planning recommendations and/or to engage the services of any recommended professional. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. We will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The services provided will be detailed in an agreement. The appropriate Plan Fiduciary designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and make the ultimate decision as to accepting any of the recommendations that we provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, we will be considered a fiduciary under ERISA. For example, we will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain us to act as an investment manager within the meaning of ERISA § 3(38), we will provide discretionary investment management services to the Plan. With respect to any account for which we meet the definition of a fiduciary under Department of Labor rules, we acknowledge that both Stableford Capital and its Related

Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in our written agreement with you. Discretionary Management Services When retained as an investment manager within the meaning of ERISA § 3(38), we provide continuous and ongoing supervision over the designated retirement plan assets. We will actively monitor the designated retirement plan assets and provide ongoing management of the assets. We will have discretionary authority to make all decisions to buy, sell or hold securities, cash, or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets. Discretionary Investment Selection Services We will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. We will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants. Investment Management via Model Portfolios We will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the mutual funds or exchange traded fund options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services Participant Education and Enrollment We will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan and assist with group enrollment meetings designed to increase retirement plan participation among employees. Education presentations will not consider the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages us for such services. Plan Participants are responsible for implementing transactions in their own accounts. Sub-Advisory Services Other registered investment advisers and investment professionals (the “primary advisers”) may recommend or hire us to manage their clients' assets. In these arrangements, we will implement and manage an investment strategy in the client’s account; however, we do not serve as the primary adviser to the client. The primary adviser will retain direct contact with the client and will manage the client relationship. We may contract directly with the primary adviser to provide the client investment advisory services or alternatively, depending on the contractual arrangement the client has with the primary adviser, the client will enter an advisory contract directly with us. We will have exclusive investment discretion as to which securities shall be purchased or sold in the sub-advised client’s account in a manner consistent with the client’s selected product, investment objectives, policies, and restrictions (if any) and the capabilities of the broker-dealer. To determine whether the strategy is suitable for a client, the primary adviser and the client are responsible for ascertaining the goals and objectives of the portfolio in question. In addition, we will obtain initial documentation of the client’s risk parameters and investment objectives. However, it is the responsibility of the primary adviser and/or the client to promptly notify us of any changes in the financial condition of the client that would necessitate a change in the client’s investment objective. Notwithstanding the foregoing, you may impose certain written restrictions on us in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. You should note, however, that if you impose restrictions, it may adversely affect the composition and performance of your investment portfolio. You should also note that your investment portfolio is treated individually by considering each purchase or sale for your account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and you should not expect that the composition or performance of your investment portfolio would necessarily be consistent with our similar clients. Wrap-Fee Program We do not participate in or sponsor a wrap-fee program. Assets Under Management As of December 31, 2023, our total assets under management were approximately $270,590,000. We managed approximately $263,693,000 on a discretionary basis, and approximately $6,898,000 on a non-discretionary basis.