Firm Ownership and Structure Opus Capital Management, Inc. was founded in March 1996 and is the predecessor to Opus Capital Group, LLC which was established in May 2006. We conduct our business under the name Opus Capital Management. Since its founding, our firm has provided investment advisory services to a variety of clients. The sole owner of Opus Capital Group, LLC is:
• Opus Capital Management, Inc. The principal owners of Opus Capital Management, Inc. are:
• Kevin P. Whelan
• Nathan A. Bishop
• Joseph P. Condren
• Nathan M. Bailey The chart below illustrates our ownership and corporate structure: Advisory Services We offer wealth management and pension consulting advisory services. Our Wealth Management product consists of investment advisory services and financial planning based upon an evaluation of each client’s investment objectives, as determined through meetings between Opus and the client and/or through an evaluation of instructions or documents made available to Opus, such as investment advisory agreements, client information data sheets and/or trust agreements. As appropriate, the advisory services will also reflect changes in investment objectives communicated to Opus by the client or its representatives. Wealth Management clients may impose restrictions on investing in certain securities or types of securities. We have traditionally provided pension consulting services as an ERISA Section 3(21) consultant. Under that section, we make recommendations to our plan sponsor clients, but the clients are ultimately responsible for accepting or rejecting our advice and making all final decisions. We also offer pension consulting services as an ERISA Section 3(38) consultant. Under Section 3(38), the consultant assumes full discretionary authority for designing the IPS and selecting and implementing the menu of investment options made available to plan participants. The plan- sponsor client is no longer legally responsible for making

these decisions, and the consultant accordingly assumes a higher level of fiduciary responsibility and exposure to potential legal liability. Even when acting as a Section 3(38) consultant, however, we do not assume responsibility from plan participants for allocating their plan accounts among the various investment options we have selected for the plan. The investment services which Opus offers do not include services such as estate planning, tax advice or addressing insurance needs. Assets Under Management As of December 31, 2023, our firm had the following assets under management: Discretionary: $ 770,845,829 Non-discretionary: $ 286,993,155 Total: $1,057,838,984 As of December 31, 2023, we had $286,993,155 of clients' assets under management on a non- discretionary basis. Although when acting as an ERISA Section 3(38) investment manager we will have certain broad discretionary authority over the design of plan investment options, we do not choose among the available options for plan participants and do not consider such plans’ assets to be under discretionary management. ERISA Accounts We are deemed to be a 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, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, we may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset our advisory fees.