A. Description of the Advisory Firm Bespoke Investment Group, LLC (hereinafter “Bespoke”) is a Limited Liability Company organized in the State of New York. The firm was formed in March 2007, and the principal owners are Justin Todd Walters and Paul Timothy Hickey. B. Types of Advisory Services Portfolio Management Services Bespoke offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Bespoke creates an investment policy statement for each client, which outlines the client’s current situation (income, net worth, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Bespoke evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Bespoke will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the investment policy statement, which is given to each client. Bespoke seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Bespoke’s economic, investment or other financial interests. To meet its fiduciary obligations, Bespoke attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Bespoke’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. Bespoke’s policy is to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Subscription Services Bespoke offers several online subscription services that provide financial markets research. Through these services, Bespoke provides general financial markets research related to equities, sectors, asset classes, and economics. Bespoke subscription services do not provide personalized advice because they are specifically not tailored to individual subscribers’ investment needs. None of Bespoke’s subscription services include recommendations to buy or sell specific securities. Services Limited to Specific Types of Investments Bespoke primarily invests in equities in its portfolio

management services but may use other securities such as fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), and ETNs to help diversify a portfolio. Written Acknowledgement of Fiduciary Status When Bespoke provides portfolio management services for retirement plans or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Bespoke makes money creates some conflicts with portfolio management client interests, so Bespoke operates under a Department of Labor rule that requires us to act in the best interest of clients and not put our interest ahead of clients. Under this rule’s provisions, Bespoke must:
• Meet a professional standard of care when making investment recommendations (give prudent advice),
• Never put our financial interests ahead of portfolio management clients when making recommendations (give loyal advice),
• Avoid misleading statements about conflicts of interest, fees, and investments,
• Follow policies and procedures designed to ensure that Bespoke gives advice that is in portfolio management clients’ best interest,
• Charge no more than is reasonable for our portfolio management services, and
• Give clients basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Bespoke offers the same suite of services to all of its portfolio management clients. However, specific client investment strategies and their implementation are dependent upon the client investment policy statement which outlines each client’s current situation (income, net worth, and risk tolerance levels). Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Bespoke from properly servicing the client account, or if the restrictions would require Bespoke to deviate from its standard suite of services, Bespoke reserves the right to end the portfolio management services relationship, in accordance with the terms of the client’s Investment Advisory Agreement. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, custodial fees, and transaction costs where applicable. Bespoke does not participate in nor sponsor wrap fee programs. E. Assets Under Management Bespoke has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 51,215,128 $0 December 2023