A. Firm Information Heron Bay Capital Management, LLC (“HBCM” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Michigan. HBCM was founded in March 2019 and is jointly owned by the staff of HBCM and is operated by Paul Seizert (Chief Compliance Officer) and Gerald Seizert (Managing Partner and Managing Member). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Heron Bay Capital. B. Advisory Services Offered HBCM offers investment advisory services to individuals, high net worth individuals, trusts, retirement plans, and estates each referred to as a “Client”. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Heron Bay Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services HBCM provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. HBCM works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. HBCM will then construct an investment portfolio, consisting of primarily stocks to achieve the Client’s investment goals. The Advisor may also utilize bonds, preferred stock, options, and closed-end funds to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Heron Bay Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. HBCM will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance of the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. HBCM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. HBCM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. HBCM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. HBCM may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Institutional Investment Management: HBCM provides investment management services to Institutional Clients such as Pensions, Endowments, Foundations, and Taft-Hartley Funds. Institutional Clients typically provide an Investment Policy Statement (IPS), prepared by the institution or through an institutional investment consultant. HBCM will then purchase, sell, or hold individual equity securities, as appropriate,

for the client’s specific needs and circumstances, including, but not limited to, cash flow needs, time horizons for benefit payments, and investment objectives. Sub-Advisory Relationships: HBCM offers discretionary sub-advisory services to separately managed accounts for certain Clients. Generally, the sponsor of the program will provide the Client with servicing, including but not limited Page 5 to, ongoing monitoring of investment positions and portfolio reporting, while HBCM is responsible for the management and investment of assets provided. At no time will HBCM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning: As part of the investment management services, the Advisor may provide an incidental financial plan or consultation which may include general recommendations for a course of activity or specific actions to be taken by the Client, based on Client requests. Recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, charitable giving programs, or engage a third party for tax or accounting purposes. Retirement Accounts- When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. C. Client Account Management Prior to engaging HBCM to provide investment advisory services, each Client is required to enter into an agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Heron Bay Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – HBCM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – HBCM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – HBCM will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs HBCM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Heron Bay Capital. E. Assets Under Management As of December 31, 2023, HBCM manages $562,506,200 in Client assets, $544,025,510 of which are managed on a discretionary basis, and $18,480,690 is managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.