A. Description of the Advisory Firm Hilton Head Capital Partners LLC (hereinafter “HHCP”) is a Limited Liability Company organized in the State of South Carolina. The firm was formed in December 2016, registered as an investment adviser in January 2019 and the principal owner is Bruce Brenner Wood. B. Types of Advisory Services Portfolio Management Services HHCP offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. HHCP creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring HHCP evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. As accepted in each client agreement, HHCP will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. HHCP seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HHCP’s economic, investment or other financial interests. To meet its fiduciary obligations, HHCP attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HHCP’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is HHCP’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. HHCP will charge each account an administration fee which includes but is not limited to accounting and fee processing, enhanced reporting, and other administrative services. Consulting Services HHCP will offer clients an ongoing consulting relationship where the representative will provide advice and guidance on a client’s overall financial situation. This service can include

investment advice, financial planning, or other service agreed upon between the client and HHCP. This service is available to existing Portfolio Management clients as an added service, or as a standalone service to new clients. The scope of each engagement will be detailed in a separate Consulting Services agreement between the client and HHCP. Selection of Other Advisers Services HHCP will direct clients to third-party investment advisers to manage all or a portion of the client's assets. The decision to use a third-party investment adviser will be determined by HHCP and is dependent on each client’s unique goals and objectives. Before selecting other advisers for clients, HHCP will always ensure those other advisers are properly licensed or registered as an investment adviser. HHCP conducts due diligence on any third-party investment adviser, which will involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. HHCP then makes investments with a third-party investment adviser by referring the client to the third-party adviser. HHCP will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Services Limited to Specific Types of Investments HHCP generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs and treasury inflation protected/inflation linked bonds, although HHCP primarily recommends equities. HHCP will use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions HHCP will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by HHCP on behalf of the client. HHCP will use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. HHCP does not participate in wrap fee programs. E. Assets Under Management HHCP has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $228,215,313 $0 April 2024