BMC has been investing funds for clients for over forty years. BMC distinguishes itself by customizing each account to the individual needs of the client and by offering a personal, professional relationship. BMC endeavors to manage accounts according to client appropriate investment parameters and with careful attention to the Firm’s responsibility to act as a fiduciary placing a client’s best interests ahead of its own. BMC offers a variety of advisory services, which include investment management and investment advisory services. Prior to BMC rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with BMC setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). BMC was founded in 1973 as an investment adviser. The Firm is wholly owned by Christopher Benin. As of April 30, 2023, BMC had approximately $444,752,581 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of BMC, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on BMC’s behalf and is subject to the Firm’s supervision or control. Investment Advisory Services The Firm manages client investment portfolios on a discretionary basis. BMC tailors investment advice to the needs of each individual client. The Firm primarily provides clients with investment management services, but may also provide or advise on areas such as Business Planning, Investment Consulting, Charitable Giving, Retirement Planning, Insurance Planning and Tax Planning. In performing these services, BMC 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. In providing certain of these services, clients retain discretion over decisions regarding implementation. 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 BMC’s recommendations and/or services. With regard to our portfolio management services, BMC manages client investment portfolios on a discretionary basis. This discretionary authority allows BMC to determine which securities to buy and sell, or other positions to take for the client’s account, in what quantities and to allocate client assets based on the client’s investment objectives as communicated to BMC from time to time. The Firm primarily allocates client assets among individual debt and equity securities, options and various mutual funds 5 | P a g e and exchange-traded funds (“ETFs”) in accordance with their stated investment objectives. The Firm also offers ongoing management to qualified tuition plans (i.e., 529 plans). Where appropriate, the Firm may also provide advice about any

type of legacy position or other investment held in client portfolios. As some of these legacy positions may include assets held away, clients may engage BMC 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. In these situations, BMC does not provide ongoing management, but may recommend the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. BMC tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on an ongoing basis, that client portfolios are managed in a manner consistent with those needs and objectives. BMC consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify BMC 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 on the management of their accounts if BMC determines such conditions would not be overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services BMC provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized. As disclosed in the Advisory Agreement, certain of the foregoing services are provided by BMC as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of BMC’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Sub Advisor Services BMC offers a platform of management services to other investment advisers through sub-advisory relationships. Pursuant to these arrangements, an unaffiliated investment adviser may engage BMC to provide advisory services to their clients, or they may refer their clients to BMC, as appropriate, to directly engage us to provide services in addition to those provided by their adviser. BMC provides its subadvisory services in accordance with each such client’s financial circumstances and investment goals and objectives. 6 | P a g e Adviser clients that engage the Firm directly must promptly notify BMC if there are changes in their clients’ financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon the Firm’s management services. There is no material difference between the manner in which assets are managed for subadvisor clients and those managed directly.