OFS is a Puerto Rico limited liability company engaged in securities brokerage and investment banking activities. It has been in business since January 4, 1993. It is a wholly owned subsidiary of OFG Bancorp, a Puerto Rico corporation and a financial holding company whose common stock is traded on the New York Stock Exchange. OFS is also affiliated with Oriental Bank, Oriental Insurance LLC, OFG USA LLC, Oriental International Bank, Inc., OFG Ventures LLC and OFG Reinsurance Ltd. Please refer to Item 10 for information on affiliated entities with which OFS has material relationships and the method by which OFS manages certain conflicts that may arise in such relationships. OFS is registered as a securities broker-dealer and as an investment adviser with the U.S Securities and Exchange Commission (the “SEC”). It is also registered with the Financial Industry Regulatory Authority (“FINRA”). Its investment advisory services are offered through financial consultants that are registered as investment adviser representatives with the Office of the Commissioner of Financial Institutions of Puerto Rico. Registration does not imply a certain level of skill or training. As of December 31, 2023, OFS had approximately $283,584,143.76 in client assets under management on a non‐discretionary basis. Investment advisory services offered by OFS include access to (a) sub-advisory services of Envestnet Asset Management, Inc. (“Envestnet”), a registered investment adviser that is independent of OFS, under its Private Wealth Management Programs (collectively, the “Envestnet Program”), and (b) sub-advisory services of Cyrus J. Laurence LLC (formerly, International Strategy and Investment, Inc.) (“Cyrus”), a registered investment adviser that is independent of OFS, under its Equity Account Advisory Program (the “Cyrus Program”). However, the Cyrus Program is no longer available for new clients. OFS also offers a (i) “dual- contract” advisory arrangement whereby the client enters into an investment advisory agreement with an independent portfolio manager and, in addition, enters into a contract with OFS, and (ii) a “single-contract” advisory arrangement whereby the client enters into an investment advisory agreement with OFS as the portfolio manager. OFS does not exercise discretion as a fiduciary under any of its investment advisory arrangements. Envestnet Program OFS determines which services and programs under the Envestnet Program to use for its clients and may use the services of third‐party service providers in conjunction with the programs offered by Envestnet. Currently, OFS provides its clients with access to the following wrap fee programs under the Envestnet Program: (i) Separately Managed Accounts (“SMA”), (ii) Unified Managed Account (“UMA”), (iii) PMC Sigma Mutual Fund Solutions (“MFS”), (iv) PMC Strategic ETF Solutions, (v) Paradigm Liquid Alternatives, and (vi) Third‐Party Fund Strategists Program (collectively, the “Programs,” or individually, a “Program”). Investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of Envestnet, as opposed to the third-party investment strategies that Envestnet also makes available in the SMA, UMA and Third-Party Fund Strategists programs. For all the Programs, OFS compiles pertinent financial and demographic information as provided by each client to develop an investment program that will meet the client’s goals and objectives. Prior to a client joining a Program, OFS interviews the client to ascertain the client’s financial position, investment goals and objectives, investment

limitations, and risk tolerance. Based on the information provided by the prospective client, OFS determines whether a Program is suitable for, and in the best interest of, the client. Using the Envestnet platform tools, OFS allocates the client’s assets among the different options in the Envestnet Program and determines the suitability of the asset allocation and investment option for each client based on its needs and objectives, investment time horizon, risk tolerance, and any other pertinent factors. Clients that join a Program through OFS (“Program Clients”) may impose reasonable restrictions on the management of their respective accounts. At least on an annual basis, OFS interviews each client who joined a Program to determine whether there has been a change in the client’s financial situation or investment objectives or in any reasonable restrictions imposed by the client for the management of its account. Each Program Client receives a separate wrap‐fee program brochure (Part 2 of Form ADV) prepared by Envestnet describing in detail the services offered within the Envestnet Program (the “Envestnet Wrap Fee Program Brochure”). All Program Clients are encouraged to review the Envestnet Wrap Fee Program Brochure to learn about the characteristics of each service offered within the Programs. Cyrus Program OFS no longer actively offers the Cyrus Program. Currently, under the program there is only one account managed that remains from when the program was offered. Private Bespoke Account Programs Unlike arrangements with wrap fee program sponsors, such as Envestnet and Cyrus, when OFS provides services to an advisory client under a dual-contract arrangement, which we refer to as the “OMI Gateway Program,” the client enters into an investment advisory agreement with an independent portfolio manager, which exercises discretion over the investment assets, and, in addition, the client enters into a separate contract with OFS under which we provide certain services, including portfolio manager oversight and performance reporting. This type of arrangement is offered with (a) a wrap fee structure under which specified fees are not based directly upon transactions in the advisory client’s account, or (b) a transaction-based fee structure under which specified fees for the execution of trades are charged to the client. The investment assets under this arrangement are held by Charles Schwab & Co., Inc. (“Charles Schwab”), as custodian. OFS also provides non-discretionary investment advisory services to clients under a single-contract arrangement pursuant to which OFS acts as the portfolio manager and assists advisory clients in the construction of their asset allocation and investment strategies on a non- discretionary basis following the same process, including, for example, risk tolerance questionnaire, used in the Envestnet Program. Accounts under this arrangement may be administered using the Envestnet platform, but with Envestnet solely providing non-advisory administrative services. The investment assets under this arrangement are held by Pershing LLC (“Pershing”), as custodian, which is also our clearing broker. Under either arrangement, OFS follows the same client intake process, including anti- money laundering, know-your-customer procedures, and analyzes the client’s financial and investment needs, determining which advisory services are suitable for the client, monitoring and evaluating client account performance, and providing the client with periodic reporting of account performance, activity, and the like.