This Disclosure document is being offered to you by Lane Brothers Investment Counsel (“LBIC”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. We are an investment management firm located in Prescott, Arizona. LBIC is the Managing Member of Groton Partners, LLC, Bond House Partners, LLC and Chebacco Partners, LLC, private partnerships which are made available to accredited investors only. Kevin P. Lane is the President, Chief Executive Officer, Majority Shareholder and Director of Lane Brothers Investment Counsel. These three private funds are currently closed to new investors. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. Non-discretionary portfolio management services are currently limited to our private partnerships, guided by private offering memorandums. Private funds are currently closed to new investors. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, 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:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Financial Planning Services We offer financial planning services both as an incorporation to our portfolio management services, and as a standalone service. Financial planning services typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, if included in we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your

financial situation, goals, objectives, or needs change. Financial Consulting Services We offer financial consulting services that primarily involve advising clients on specific financial-related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Selection of Other Advisers For certain legacy accounts, we have recommend the services of a third party money manager ("TPMM") to manage all, or a portion of, the client’s portfolio in municipal bonds. At this time, we do not utilize this third party for new clients. For accounts subject to this selection, the client is not charged any advisory fees from LBIC and is considered an account under advisement. Further, LBIC retains the right to hire or fire this third party adviser at any time. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. Pension and Retirement Plan Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan- level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. In some cases we are the 3(38) Investment Fiduciary for the plan, on behalf of the plan sponsor. The individual investment selection is reserved to the participants. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as · Diversification; · Asset allocation; · Risk tolerance; and · Time horizon Our educational seminars may include other investment-related topics specific to the particular plan. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Either party to the pension consulting agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client. Private Funds LBIC manages, on a non-discretionary basis, that qualified clients allocate a portion of their investment assets among a private investment funds, Groton Partners, LLC, Chebacco Partners LLC both real estate funds and Bond House Partners, LLC a fixed income fund (together, the “Partnership”). LBIC and/or its designee(s) manages the partnership assets on a non-discretionary basis. The terms and conditions for participation in the Partnership are set forth in the Partnership offering documents (discussing fees-including fees paid to the Managing Member, conflicts of interest, risk factors, and liquidity constraints), which each investor client received, and completed and submitted to the Managing Member in order to demonstrate qualification for the Partnership. Three funds currently closed. Private investment funds (including the Partnership) generally involve various risk factors and liquidity restraints, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Wrap Fee Program Please note that the firm does not act as an investment manager pursuant to any wrap fee program. Assets As of April 23, 2024, LBIC managed assets in the amount of $ 156,420,171 on a discretionary basis and $ 5,837,805 on a non-discretionary basis.