Description of Advisory Services Alden Capital Management, Inc. (“Alden”, “we” or “us”) became registered as an investment adviser with the Securities and Exchange Commission (SEC) on April 2, 2018. On July 20, 2018, we filed with the states of Pennsylvania and New York to become a state registered investment advisor. The firm then registered with the SEC on July 9, 2019, once asset count exceeded $100,000,000. Our total assets under management as this filing is $657,249,584. Alden Capital Management is a Pennsylvania S Corporation and is fully owned by Alden Partners, LLC., a Pennsylvania LLC. We provide a variety of asset management services, including the discretionary management of separate accounts, limited partnership funds, retirement plans and non-discretionary asset management services. We focus on providing a customized allocation for each client using both internally managed strategies as well as offerings from other RIAs, mutual funds and private investment funds. In some cases, we may recommend third party money managers who have an expertise in a particular investment strategy. Prior to introducing any Pennsylvania clients to another investment advisor, we will be responsible for determining if we are properly licensed, notice filed, or exempt from registration with the Pennsylvania Department of Banking and Securities. We also offer customized asset allocation and portfolio management strategies to individual clients. ACM also offers sub-advisory investment services to other registered investment advisor client accounts. The introducing advisor will speak with the client to choose the best ACM investment strategy and ACM will deploy the client assets. All communication with the clients are through the introducing IA. Alden specializes in evaluating, designing, and implementing retirement programs and executive benefits packages for small and mid-sized companies. Using information such as corporate objectives, industry specific data, competitive dynamics, and budgetary considerations, Alden assists employers to design retirement packages to attract, retain, and motivate employees. Alden may act as a fiduciary to retirement and benefit plans and will have clients that include non- profit entities such as hospitals, churches, schools, credit unions, endowments and others. We have several Investment Adviser Representatives who do business at a separate registered investment advisor, Bluestone Capital, an RIA that is focused on managing investment strategies and funds. This business name and logo may appear on marketing materials as approved by us. Bluestone Capital provides its own asset management services and when appropriate we may elect it as the investment manager of a client account. Asset Management Services The investment management services that we provide to individuals involves determining the risk/return profile of the client, as well as their goals and objectives, then selecting the appropriate strategy. Clients are free to impose restrictions or limitation on our selection of investments in certain securities, or types of securities. Our recommendations are based on information that you provide to us regarding your financial needs, retirement and financial goals, investment objectives, net worth, time horizon, risk profile, tax situation, and liquidity needs. We generally manage individual client accounts on a fully discretionary basis, which allows us to change your portfolio allocation as we deem prudent without your prior authorization. However, you may choose to have your account managed on a non-discretionary basis. If you chose a non-discretionary account, we will need to discuss any changes to your account before repositioning your assets, which may delay our ability to reallocate your assets in response to market conditions. Alden COVE Platform Alden Capital Management provides IARs and RIAs with access to its Alden COVE platform (“Alden COVE”). Alden COVE offers these IARs/RIAs access to a broad array of institutional asset managers, and the ability to construct unified managed accounts (UMAs) including strategies from these asset managers, and advisor-directed strategies. By utilizing Alden COVE, advisors can service their clients more efficiently. Before onboarding a client to the Alden COVE platform, advisors obtain information about their financial circumstances, investment objectives, financial goals, risk tolerance, investment time horizon and liquidity needs. This will generate a risk score which allows the advisor to appropriately manage the client account. The client’s risk score will be easily accessible to the advisor, as well as their current portfolio’s risk score, as an additional tool to ensure the client’s profile is managed appropriately. Alden requires that at least annually, the client is contacted to determine whether there have been any changes to any of the above items which may impact their risk tolerance, investment objective, or other. Clients of the Alden COVE platform are subject to Alden Capital Management’s regular fee schedule. Alden bills one client fee and compensates the individual advisor on a schedule negotiated at the time of advisor onboarding. The client will see one line item bill for this fee on their custodial statement. Alden will directly compensate any technology platform or integration partner from its remaining fee. Additional fees may be charged by institutional asset managers and/or sub-advisors. These fees will be charged separately, outside and above, the agreed upon client fee between Alden and the client. These fees are not distributed to Alden. There may also be custodial fees charged to individual

clients that are no different to other Alden accounts managed at those custodians. Platform Services With Alden COVE, advisors and/or clients may receive assistance with:
• Client account opening (including paperwork review, custodial review/liaison, tracking funding and platform setup) and servicing (such as standing/periodic instruction setup, contributions, distributions, RMD calculations, and more).
• Asset management strategy or strategies such as investment manager introductions, investment strategy recommendations, assistance creating models and/or UMAs at the advisor-level or for individual clients on a case- by-case basis, through consultations with Alden’s investment team.
• Technology services such as a multi-custodial trade order management system (TOMS) and customized client portals for ongoing performance reporting. Use of Technology Platform and Sub-Advisor Alden COVE sits on top of the Amplify Platform and leverages its services as a technology provider. This allows Alden to focus primarily on helping advisors and clients with the investment management and middle/back-office services outlined above. Amplify Platform provides Alden COVE with a technology chassis, back-office operational support services such as administrative, trading and reporting services as well as access to independent third-party managers. Alden has executed a platform agreement which allows it, as a platform member, to receive the back-office services outlined above on a sub-advisory basis. This allows advisors using Alden COVE to allocate all or a portion of their underlying client’s assets among the different institutional asset managers available through the platform on a discretionary basis. Each client has a direct contractual relationship with Alden for access to Alden COVE platform, which allows both Alden and Amplify Platform to renders its services to the client. Alden engages unaffiliated investment advisors to service its advisors and client accounts as sub-advisors. These sub-advisors will perform discretionary investment management services and shall manage, invest and reinvest the underlying client assets designated by the advisor. As such, selected manager(s) shall be authorized, without prior consultation to the advisor or client, to buy, sell, trade or allocate the underlying client’s assets in accordance with the underlying client’s investment objectives and to deliver instructions in furtherance of this responsibility to the underlying client’s broker-dealer or custodian. Advisors retain responsibility for their underlying client relationships, including the initial and ongoing suitability determination, and shall also retain the responsibility for implementing client investment recommendations in accordance with their fiduciary duty to the client. Advisors are responsible for obtaining and furnishing information pertaining to asset management strategy selection and underlying client account guidelines along with any reasonable account restrictions. In a typical advisor relationship with Alden COVE, Alden will compensate Amplify Platform directly from its remaining fee. Management of Held-Away Accounts Alden COVE helps advisors and clients to expand their breadth of service by receiving professional discretionary management on held-away accounts/assets such as defined contribution plan participant accounts. Alden leverages a technology platform, Pontera to do so. Pontera allows Alden and its affiliated advisors through Alden COVE to avoid being considered to have custody of client funds as they do not have direct access to client log-in credentials to effect trades. Alden has integrated Pontera into its Alden COVE platform and may receive compensation for this integration as well as similar investment management, technology and client services outlined above. A link is provided to clients allowing them to connect accounts to Pontera. Once client accounts are connected, the advisor will review the current account allocations. When deemed necessary and based on information also gathered during the Alden COVE client account onboarding, the advisor will rebalance the account, considering client investment goals and risk tolerance, and in any change in allocations will consider current economic conditions and market trends. This holistic approach allows advisors to expand their professional management for clients. The goal of this additional integration is to improve account performance over time, minimize loss during difficult market, manage internal fees that harm account performance, and factor in all client accounts to create an appropriate asset allocation and portfolio, regardless of where the account is currently held. It is the advisor’s responsibility to review the account(s) at least quarterly and make allocation changes they deem necessary. Clients using the Pontera integration of Alden COVE will also be subject to Alden Capital Management’s regular fee schedule. Alden bills one client fee and compensates the individual advisor on a schedule negotiated at the time of advisor onboarding. Alden will compensate Pontera directly from its retained fee. Permitting access to a data feed, Pontera-based accounts will be linked into Alden COVE’s advisor platform and client portals for optimized unified managed household reporting, though it is the advisor’s responsibility to request this feed. Alden Capital Management Strategies Alden Capital Management has its own proprietary investment strategies available for clients on Alden COVE. Alden acknowledges a conflict exists when clients and/or their advisors select an Alden managed model for either all or part of a client’s portfolio.