Firm Description Spivak Asset Management, LLC, (“FIRM NAME”) was founded in 1996. Spivak Asset Management, LLC provides portfolio management serving the investment needs of individuals, corporations, pension and profit sharing plans, trusts, estates and charitable organizations. Spivak Asset Management, LLC provides continuous investment advice and makes investments based on the individual needs of the clients. Spivak Asset Management, LLC is an investment adviser registered with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940. Spivak Asset Management, LLC is strictly a fee-only investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Spivak Asset Management, LLC does not act as a custodian of client assets. The client always maintains asset control. Spivak Asset Management, LLC places trades for clients under a limited power of attorney. Periodic reviews are communicated to clients to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management may be beneficial to the client. Principal Owners Jay S. Spivak is managing member and only owner of the Limited Liability Company Spivak Asset

Management, LLC. Types of Advisory Services Portfolios will be managed on a discretionary (having the ability to determine without the client's prior consent, the securities and amounts of securities to be purchased or sold) basis. Portfolio composition will be determined based on each client's needs and portfolio restrictions, if any. Portfolios will be allocated to assets according to client's financial goals and risk tolerances. Spivak Asset Management, LLC portfolios will generally be comprised of no load mutual funds and exchange traded funds, although other equity or debt securities may also be used. As of December 31, 2023, Spivak Asset Management, LLC manages approximately $358,000,000 in assets for approximately 65 clients. Tailored Relationships The goals and objectives for each client are established with meetings with clients. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Retainer Agreement Retainer Agreements are not used at Spivak Asset Management, LLC. Asset Management Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. Spivak Asset Management, LLC does not receive any compensation, in any form, from fund companies. Termination of Agreement An Investment Advisor Agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. All fees will be prorated based on the time frame the assets are managed.