Owners Shufro, Rose & Co., LLC (“SRC”, the “Adviser”, the “Firm”, “we”) was founded in 1938 and was converted to an LLC in 1997. SRC is not affiliated with any other active business entity and is owned entirely by SRC's Working Members, each of whom is a Principal & Senior Financial Advisor and, also serves as a Portfolio Manager. The current Principal & Senior Financial Advisors are: STEPHEN LEIT, born 1945, received his B.A. from the University of Rochester in 1967 and his M.A. from Northwestern University in 1970. He became a Chartered Financial Analyst (“CFA”) in 1978, joined the Firm in 1984, and became a Principal in 1989. STEVEN J. GLASS, born 1967, received his B.S. in Business Administration from the University of Hartford in 1988 and joined the Firm in the same year. He became a Principal in 1997. HARVEY WACHT, born 1945, received his B.B.A. from Baruch College in 1967. He became a Certified Public Accountant (“CPA”) in 1972 and was a Principal at Herzog Heine Geduld for thirty years in senior executive and investment positions. He joined the Firm in 2001 and became a Principal in 2003. JOHN M. CONTANT, born 1974, received his B.S. in Finance from Lehigh University in 1996 and joined the Firm that same year. He became a Principal in 2004. GREGORY D. SHUFRO, born 1969, received his B.A. in English from the University of Pennsylvania in 1991 and his J.D. from Fordham University School of Law in 1997. Prior to joining the Firm in 2003, he practiced law in New York and specialized in securities litigation and bankruptcy. He became a Principal in 2008. TONIA L. KAMINSKY, born 1968, received her B.S. in Business Administration from the University of Massachusetts Amherst in 1991 and joined the Firm in 1999. She became a Principal in 2009. Additional information is available to clients in SRC’s brochure supplements (e.g., SEC ADV Form 2B), in accordance with SEC requirements. Types of Advisory Services Shufro, Rose & Co., LLC was founded as a partnership in 1938 and converted to a Limited Liability Company (“LLC”) under the laws of the state of New York in 1997. The firm is among the oldest wealth management firms in the United States specializing in the discretionary management of investment portfolios. We are independent and owned entirely by our working principals, each of whom is a Senior Financial Advisor and Portfolio Manager. The Principals of SRC have worked together for many years; two have been in the investment business for more than forty years. Foremost in our minds is that putting our clients’ interests first and producing good investment results are the most important services we can provide. In numerous instances we now advise the fourth successive generation of a family. Because we are focused on the overall financial health of our clients, we often help clients anticipate and plan for future needs by working closely with their accountants, other advisors, and attorneys. These lasting relationships as well as the growth in our assets under management attest to our diligence on behalf of our clients. SRC provides investment management and advisory services to separately managed accounts of individuals, high‐net worth individuals, trusts and estates, retirement accounts, businesses and charitable organizations (each referred to as the “Client”, collectively the “Clients”) on a discretionary and non-discretionary basis. Although all Portfolio Managers share investment ideas, some primary Portfolio Managers are also supported by, and work closely with, one or more other Portfolio Managers in the management of accounts. Each account is assigned to an individual Portfolio Manager—or in some cases a pair of Portfolio Managers. These Portfolio Managers or teams of Portfolio Managers have primary responsibility for formulating investment advice and exercising discretion for their Client’s separately managed accounts. Portfolio Managers meet with Clients to discuss Client’s financial goals and objectives, as well as establishing a risk tolerance. Such information is considered by the Portfolio Manager when initially structuring a Client’s portfolio and for ongoing monitoring and managing portfolios. The Portfolio Managers primarily invest client assets in stocks, exchange-traded securities, closed- end funds, mutual funds and various types of fixed income securities. Portfolio Managers typically maintain cash equivalent positions (e.g., money market funds) through a “sweep” program as well. Some Portfolio Managers use short-term bond mutual funds or U.S. Treasury bills to generate more interest income than is available from money market funds. Short-term bond funds generally involve a greater interest rate and credit quality risk than money market funds. In addition, Portfolio Managers can recommend college savings account plans to Clients if appropriate. One Portfolio Manager also routinely utilizes options, primarily with the intention of increasing income and/or reducing downside risk. The Portfolio Managers can also recommend selected alternative private investment funds (“Funds”) to qualified investors. Prior to investing in Funds, Clients will receive and/or execute a private placement memorandum, subscription documents and/or limited partnership agreements (“Offering Materials”). SRC may also engage one or more third-party sub-advisors (“Independent Managers”) to manage a portion of client assets if deemed in the best interest of the Clients, subject to the Client’s executed Investment Management Agreement (“IMA”), and if the Independent Manager’s strategy aligns with the Client’s investment objectives and risk tolerance. SRC will generally execute a sub-advisory agreement with the Independent Manager. SRC will ensure a sub-adviser’s Form ADV Part 2A, Part 2B, Form CRS and Privacy Policy are delivered to the relevant Clients. There may be instances whereby SRC may require Client to sign separate written agreements directly with those Independent Managers instead of SRC doing so on a Client’s behalf. The Client agrees to timely execute any such agreements. Clients may be asked to open new custodian accounts with a third-party custodian to separate sub-advised assets from the remaining Client assets advised by SRC. Independent Managers shall have limited power-of-attorney and shall have only trading authority over those assets SRC directs to them for management. Independent Managers shall be authorized to buy, sell and trade (in accordance with applicable law and consistent with the client’s objectives) and to give instructions, related to their authority, to the broker-dealer and custodian. Unless otherwise disclosed to Clients prior to the engagement of an Independent Manager, SRC will be responsible for compensating the Independent Manager for any investment management fees due for advisory services performed on SRC Client accounts by Independent Managers subject to the IMA with SRC. Generally, the Client will not incur additional management fees for the investment advisory services rendered by the Independent

Manager. In the event fees to an Independent Manager shall result in increased fees to Clients, Clients shall be notified in writing and such increased fees shall become effective no earlier than 30 days after written notice is sent to the Client, unless a written objection is sent to the Adviser prior to the expiration of that time. The Client may still incur transaction and any custodial fees on assets managed by the Independent Manager. SRC will remain the primary investment advisor on such sub-advised managed accounts. SRC reasonably monitors and reviews performance of all Client account activity managed by Independent Managers and is responsible for all consolidated Client reporting. SRC, if requested by its Clients, may provide non-discretionary asset management services. Under this relationship, SRC consults with the Client prior to executing trades in the Client’s account. In addition, SRC may monitor and manage Client investments and provide consolidated portfolio reporting and portfolio management to the Client. Individualized Advisory Services SRC has expanded the options of portfolio management strategies that Portfolio Managers can implement in order to meet a Clients’ investment objectives, risk tolerance and potential tax exposure. SRC has engaged the services of outside investment research providers and electronic portfolio management and rebalancer platforms to assist with the development and implementation of such strategies and guidelines. Each strategy offers diversified securities that provide exposure to various sectors and asset classes. Portfolio Managers consider these diversified strategies, if appropriate, when managing a Client’s portfolios. The adoption of these portfolio allocation strategies is designed to better address SRC’s Client investment needs. At account inception and any time thereafter, a Client may impose reasonable restrictions on what assets can be purchased for, or sold from, their accounts. SRC does not issue lists of ‘recommended’ securities. Portfolio Managers exercise their individual judgment regarding all purchases, sales and investment advice for the accounts they supervise using those investment techniques and methods which they believe are appropriate. Different Portfolio Managers: (i) employ different investment techniques, (ii) produce different outcomes, and (iii) may have differences in their fee schedules. Further, the highly individualized, hands-on investment management approach means that even accounts with similar investment profiles, which are managed by the same Portfolio Manager, may own different securities from one another and have different results. In some cases, Portfolio Managers will manage several accounts together as a household or ‘family group’ of accounts. ERISA Accounts SRC is deemed to be a 3(21) fiduciary to advisory Clients that are employee benefit plans or individual retirement accounts (“IRAs”) pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (the “Code”), respectively. As such, SRC is subject to specific duties and obligations under ERISA and the Code that include, among other things, restrictions concerning certain forms of compensation. In addition, SRC has adopted policies and procedures designed to comply with the ERISA fiduciary standards when advising retirement asset rollovers as set forth in the Department of Labor Fiduciary Rule. When SRC provides investment advice to you regarding your retirement plan account or individual retirement account(s), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: o Meet a professional standard of care when making investment recommendations (give prudent advice); o Never put our financial interests ahead of yours when making recommendations (give loyal advice); o Avoid misleading statements about conflicts of interest, fees, and investments; o Follow policies and procedures designed to ensure that we give advice that is in your best interest; o Charge no more than is reasonable for our services; and o Give you basic information about conflicts of interest. 529 Plan Accounts SRC has partnered with American Funds to offer access to 529 Plan college savings accounts to a select group of clients who have a need for college savings. Accounts will be invested in American Funds opened-ended mutual funds or target date funds. Financial Planning Services SRC is available for a fee to provide certain financial planning services as well as financial advice on non‐investment related matters such as general financial oversight, balance sheet, cash flow management, mortgage refinancing, estate planning, insurance planning, annuity and pension planning and charitable gift planning. Under this arrangement, any recommendations provided by SRC may be implemented at the Client’s sole discretion with the professional consultants of the Client’s choosing, and there is no obligation to engage SRC for investment advisory services. With respect to any financial planning provided by SRC, each Client must acknowledge to us that: (i) such Client is free at all times to accept or reject any of our recommendations, and such Client acknowledges that such Client has the sole authority with regard to the implementation, acceptance, or rejection of any recommendation or advice from us; (ii) our recommendations (i.e., estate planning, retirement planning, insurance, etc.) may be discussed and/or implemented, at such Client’s sole discretion, with the corresponding professional adviser(s) (i.e., broker, accountant, attorney, etc.) of such Client’s choosing; (iii) in respect to estate planning and tax planning matters, our role shall be that of a facilitator between such Client and his/her corresponding professional adviser(s); (iv) we are not acting in the capacity of an attorney or accountant, and no portion of our services should be interpreted by such Client as legal or tax advice (rather, such Client should defer to such Client’s attorney and/or accountant with respect to all legal or tax matters); and (v) such Client will maintain sole responsibility to notify us if there is a change in such Client’s financial situation or investment objective(s) for the purpose of reviewing/evaluating/revising our previous recommendations and/or services and/or to address new planning or consulting matters. Assets under Management (Regulatory Assets under Management) As of December 31, 2023, our Regulatory Assets Under Management (“RAUM”) were $2,000,848,944 of which $1,940,427,275 are managed on a discretionary basis and $60,421,669 are managed on a non-discretionary basis.