Carmichael Capital, Inc. dba Carmichael Creel Investments (“CCI” or the “Adviser”) provides ongoing management of investment portfolios for individuals, corporations, trusts, estates, pensions, and retirement accounts (each referred to as a “Client”). The firm was founded in New York City in 1993 and has been a registered investment advisory firm continuously since then. Claude R. Carmichael CFA, as President and Chief Compliance Officer, supervises and directs the investments of the accounts in accordance with the investment objectives that the clients provide to us from time to time and subject to limitations that the clients may impose by notice in writing. The accounts consist of cash and securities that the clients designate, plus or minus additions or withdrawals that the clients make. We act on behalf of clients to buy, sell, exchange, convert, and otherwise trade in domestically listed stocks, bonds, mutual funds, exchange-traded funds, and other publicly traded securities including exchange-traded options and money market instruments. We do not manage investments in private investments, hedge funds, futures contracts, or currencies and foreign securities not traded in the U.S. We also do not participate in any “wrap fee” programs. We place orders for the execution of securities transactions for our clients’ accounts with unrelated brokerage companies (such as Charles Schwab or Fidelity Investments). Client assets stay at “qualified custodians” (like Charles Schwab, Fidelity Investments, or bank trust departments) in the individual

client’s account. No assets are commingled. All client accounts remain separate and distinct. We provide individualized portfolio management for each client based on our understanding of the client’s desires and circumstances combined with our judgment of investment value. After the end of each calendar quarter, we furnish clients with quarterly reports including performance reports, detailed statements of portfolio holdings, and fee statements showing asset values and the percentage and method used to calculate the management fee. After year end, we also provide clients with a capital gains report for each taxable account managed by us. The capital gains report shows an itemized list of all realized capital gains and losses for the previous year for the clients' review; the custodian’s report shall be used for tax preparation. Clients may terminate the investment advisory agreement without penalty within five (5) business days of entering into the contract. Clients also may terminate the contract upon written notice delivered to us at least ten (10) days prior to the effective date of termination. Before the effective date of termination, clients may provide us with written instructions as to the liquidation or settlement of their accounts. Clients may also limit our discretion to enter into further transactions after the date that those instructions are received. We agree to be bound by those instructions once we have received them. As of December 31, 2023, CCI managed $112,983,662 in assets on a discretionary basis.