Lountzis Asset Management is an independent registered investment adviser founded by its Principal, Paul J. Lountzis, in October 2000 to manage customized portfolios serving families, high net worth individuals, institutions and retirement plans. Prior to engaging Lountzis Asset Management to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Lountzis Asset Management setting forth the terms and conditions under which Lountzis Asset Management renders its services (collectively, the “Agreement”). As of March 20, 2024, Lountzis Asset Management had $504,540,755 in assets under management, all of which was managed on a discretionary basis. This disclosure brochure describes the business of Lountzis Asset Management. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Lountzis Asset Management’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees or any other person who provides investment advice on Lountzis Asset Management’s behalf and is subject to Lountzis Asset Management’s supervision or control. Investment Management Services Lountzis Asset Management manages client investment portfolios on a discretionary basis by primarily allocating client assets among various individual debt and equity securities. In addition, Lountzis Asset Management also recommends that certain clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or pooled investment vehicles (e.g., hedge funds). The Firm also provides advice about any type of legacy position or investment otherwise held in its clients’ portfolios. Clients may also engage Lountzis Asset Management to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Lountzis Asset Management directs or recommends the allocation of client assets among the various investment options available with the product. These assets are maintained at the underwriting insurance company or the custodian designated by the product’s provider. Lountzis Asset Management tailors its advisory services to accommodate the needs of its individual clients and continuously seeks to ensure that its clients’ portfolios are managed in a manner consistent with their specific investment profiles. Lountzis Asset Management consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other factors relevant to the management of their portfolios. Clients are advised to promptly notify Lountzis Asset Management if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Lountzis Asset Management determines, in its sole discretion, the Page 5 © MarketCounsel 2024 conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Financial Planning Services Lountzis Asset Management offers clients limited financial planning services, which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Education Planning These services are generally rendered in conjunction with the firm’s investment management services and are not available on a stand-alone basis. In performing these services, Lountzis Asset Management is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Lountzis Asset Management recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Lountzis Asset Management or

its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Lountzis Asset Management under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Lountzis Asset Management’s recommendations and/or services. Management of Collective Investment Vehicle Lountzis Asset Management is the investment manager of Achtinon Capital Partners, LP (“Achtinon”), a Delaware limited partnership formed in December 2001 to invest and trade in securities. Achtinon’s general partner is Achtinon Capital Management, LP, a Pennsylvania limited partnership (the “General Partner”) which is controlled by Achtinon Capital Management, LLC, a Pennsylvania limited liability Page 6 © MarketCounsel 2024 company. Paul J. Lountzis, the Principal of Lountzis Asset Management, is the managing member of Achtinon Capital Management, LLC and is ultimately responsible for managing the business of Achtinon. Interests in Achtinon are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. Achtinon currently relies on an exemption from registration under Section 3(c)(1) of the Investment Company Act of 1940, as amended. Participation as an investor in Achtinon is restricted to investors that are qualified clients pursuant to the requirements under Rule 205-3 under the Advisers Act, as well as are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended. Achtinon’s investment guidelines are to seek capital appreciation and long term capital gains tax treatment over an intermediate to long term time horizon by primarily investing in equity securities of companies that it believes to be undervalued because the fundamental valuation as determined by Lountzis Asset Management is materially different from the “market’s” perception. The minimum to invest in Achtinon is $1,000,000, subject to waiver at the discretion of the General Partner. To the extent certain of Lountzis Asset Management’s individual advisory clients qualify, they will be eligible to participate as limited partners of Achtinon. Investment in Achtinon involves a significant degree of risk. All relevant information, terms and conditions relative to Achtinon, including the compensation received by Lountzis Asset Management as investment manager and the General Partner as sponsor and administrator, suitability, risk factors and potential conflicts of interest, are set forth in the Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”) and Subscription Agreement, which each limited partner is required to receive and execute prior to being accepted as a limited partner of Achtinon (collectively, the “Offering Documents”). As further discussed in the Offering Documents of Achtinon, Lountzis Asset Management receives an annual investment management fee of 1% (assessed quarterly) for serving as the investment manager of Achtinon. The General Partner, in accordance with the terms and conditions specifically set forth in the Offering Documents, receives performance-based compensation in accordance with the requirements under Rule 205-3 of the Investment Advisers Act of 1940, as amended. While Achtinon itself is Lountzis Asset Management’s client, for purposes of this brochure, the term “client(s)” sometimes refers to the investors in Achtinon. Lountzis Asset Management will devote its best efforts with respect to its management of both Achtinon and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors and qualifications for participation in Achtinon, Lountzis Asset Management may give advice or take action with respect to Achtinon that differs from that for individual client accounts. To the extent that a particular investment is suitable for both Achtinon and certain individual client accounts, such investments will be allocated between Achtinon and the individual client accounts pro rata based on the assets under management or in some other manner which Lountzis Asset Management determines is fair and equitable under the circumstances to all of its clients. Page 7 © MarketCounsel 2024