Shaker Investments LLC (also referred to in this document as Shaker Investments, Shaker, or the Adviser) is an SEC-registered investment adviser with its principal place of business located in Ohio. Shaker Investments LLC began conducting business in 1991. Shaker Investments LLC's sole principal shareholder (individuals and/or entities controlling 25% or more of this company) is Edward P. Hemmelgarn, President and co-CIO. Shaker Investments is primarily an equity manager specializing in the stocks of growth companies. Shaker provides continuous advice to clients regarding the investment of client funds. We manage the majority of client accounts on a discretionary basis and make the investment decisions for the funds. This means we direct the purchase and sale of assets as we deem appropriate, and the reinvestment or holding for reinvestment of any proceeds of sales, trades, or dividends that are paid into the account. The majority of our clients' accounts are individually managed accounts that are invested according to investment portfolio strategies that are defined and managed by our portfolio managers Edward Hemmelgarn, Sasha Kostadinov, Brandon Hemmelgarn, and Chris Hemmelgarn. We currently offer two long-only portfolio investment composites, our Fundamental Growth (FG) composite and Small Cap Growth (SCG) composite. The Fundamental Growth composite invests in growth companies over a wide range of market capitalization that includes large (more than $10 billion in market value), medium ($3 billion to $10 billion in market value) and small ($3 billion or less in market value) capitalization stocks. The Small Cap Growth composite invests in growth companies and is focused on the small capitalization end of the equity markets. In addition to the FG and SCG composites, Shaker offers an Asset Allocation (AA) model strategy which builds a model portfolio consisting of a mix of asset classes to accomplish clients' investment objectives within the constraints of their age, financial condition and risk tolerance. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, capital preservation, growth, income, or growth and income), as well as tax considerations. The asset classes used in the strategy include large cap domestic and small cap domestic equities, developed world equity ex-US, emerging markets equity, corporate bonds, government bonds, agency bonds or other asset classes that are suitable for the client. We use primarily index ETFs as investment vehicles but sometimes also use actively managed investment vehicles including mutual funds or "Smart Beta" ETFs. Shaker also provides recommendations in the form of a model portfolio to Turnkey Asset Manager Program (TAMP) overlay managers which utilizes the recommendations to manage its client's accounts in accordance with the Shaker portfolio strategies. The sponsors or overlay managers act as the investment adviser to clients of such programs. Shaker Investments, LLC does not implement trades, have discretionary investment authority or have custody of the assets/accounts of the TAMP managers. The sponsor or overlay manager exercises investment discretion for the assets in the program. The TAMP assets for 2023 are not included in our AUM. Finally, Shaker Investments, LLC is also the Investment Manager for the Shaker Investments Tower Fund, LP (Tower Fund) which is open only to accredited investors. The Tower Fund is a long - short hedge fund which invests in stocks that trade on a U.S. stock exchange. The Tower Fund is controlled by Shaker Hedge GP which is the general partner of the Tower Fund. Shaker Hedge GP is owned and controlled by the owners and employees of Shaker Investments LLC. Additional information on the portfolio management strategies and the Tower Fund is provided in the section entitled "Investment Strategies." All securities purchased for our clients trade on U.S. stock exchanges, or over the counter, though a number of the companies we invest in are headquartered outside of the United States. Our investment decisions are not limited to any specific product, service or security recommendation offered or sponsored by a broker dealer or insurance company but represent the results of original research conducted at Shaker by our own analysts and portfolio managers. These investment choices include:  Exchange-listed securities  Foreign issuers  Securities traded over-the-counter  Corporate preferred stock and debt securities (other than commercial paper)  United States governmental securities Because some types of investments such as micro-cap stocks or thinly traded stocks of any capitalization involve certain additional degrees of risk, they will only be implemented when consistent with the client's

stated investment objectives, tolerance for risk, liquidity and suitability. All separately managed account (SMA) clients have the opportunity to place reasonable restrictions on the types of investments to be held in their individual account as well as on investing in certain securities, types of securities, or industry sectors. SMA clients retain individual ownership of all securities. Our firm provides continuous advice to clients regarding the investment of client funds in his or her account based on the individual needs and goals of the client. For all clients, we conduct conversations and a review that includes a suitability questionnaire in order to understand each client's investment needs based on a client's particular circumstances. During discussions with our client, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. This information is used to help reach agreement with the client on the type of portfolio strategy or asset allocation approach most suitable for them. We then manage their funds in accordance with that agreement. Client portfolios are reviewed internally at least quarterly and any time a change is made to the individual stocks held in the account, or upon deposit or withdrawal of capital. To ensure that our initial determination of an appropriate portfolio strategy remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we encourage clients to discuss their accounts and any changes in their circumstances that could influence the suitability of the strategy used for managing their account. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. At least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. Be reasonably available to consult with the client; and 3. Maintain any available client suitability information in each client's file. FINANCIAL PLANNING Shaker provides financial planning services to our investment clients upon request. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:  INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.  RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. SUB-ADVISOR INVESTMENT MANAGEMENT Shaker Investments acts as a sub-advisor to advisors and their funds, whereas the primary advisor may delegate some or all of its services to Shaker Investments. The unaffiliated advisor will act as the primary advisor and fiduciary with the option to engage with Shaker Investments as a sub-advisor to provide discretionary investment management and trade execution services. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $227,774,952 of clients' assets on a discretionary basis plus $77,556 of clients' assets on a non-discretionary basis. The firm’s total Assets under Management (AUM) was $227,852,508. An additional $4,590,301 is invested in 4 TAMPS for a total Assets under Advisement (AUA) of $232,442,809.