Firm Description We are both a registered investment adviser and a branch office of broker/dealer Raymond James Financial Services, Inc. (RJFS), member FINRA/SIPC. Employees may provide advice for an asset-based fee through the Firm or sell securities for commission through RJFS. RJFS has a corporate affiliate, Raymond James & Associates, Inc. (RJA) member NYSE/SIPC. RJA is a dually registered broker/dealer and investment advisor. RJFS accounts are custodied with RJA, and RJA executes and clears transactions. RJA also facilitates various advisory programs. For further information refer to the Raymond James & Associates Wrap Fee Program Brochure. Principal Owners The Firm is owned by Malcolm A. Makin, President, Chief Executive Officer and Chief Compliance Officer. We, and our predecessors, were founded in 1975. Types of Advisory Services We provide discretionary and non-discretionary investment advisory services, financial planning services, a selection of other investment management services and educational workshops/seminars. We offer services to individuals, high net worth individuals, trusts, estates, charitable organizations, corporations, endowments, and foundations. Accounts Managed by your Investment Advisor Representative (IAR): Ambassador Ambassador is an investment advisory program which allocates your assets based upon your financial objectives and risk tolerances. We are the advisor providing investment advisory services and RJA administers the program providing support services for both clients and our financial advisors. Ambassador offers clients the opportunity to (1) maintain full investment authority and direct the individual investments made within their account(s), or (2) delegate investment discretion to their financial advisor. Accounts Managed by Other Asset Managers: Freedom Freedom is an investment program in which your assets are allocated to meet your financial objectives and risk tolerances. Your IAR may assist you in selecting the appropriate Freedom strategy. RJA acts as wrap-fee sponsor and manager providing portfolio management, selecting the representative funds and monitoring their performance on a continuous basis. Your IAR receives a portion of the asset-based fee. Raymond James Consulting Service (RJCS) RJCS is an investment program in which your assets are allocated to meet your financial objectives and risk tolerances. Your IAR may assist you in selecting an appropriate program based on your financial objectives and risk tolerance. RJA acts as wrap-fee sponsor and manager providing portfolio management, selecting certain portfolio managers, monitoring performance, providing other administrative services and assisting portfolio managers with certain trading activities. Your IAR receives a portion of the asset-based fee. Other Services: Raymond James Trust We utilize Raymond James Trust, N.A. which offers personal trust services, including serving as trustee or as an agent or custodian for individual trustees. Raymond James Trust serves living trusts, charitable remainder trusts, life insurance trusts and specialty trusts. We make suggestions regarding asset allocation and individual investment transactions required to implement, monitor, and adjust the trust portfolio. Raymond James Trust serves as the trustee (or co-trustee) and has final approval on all investment suggestions. Financial Planning We offer financial planning services. This service reviews aspects of a client’s financial situation, which may include cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax considerations, and capital needs planning. We meet with the client to review risk tolerance, financial goals and objectives and time horizon. Meetings may include a review of additional financial information including sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family

obligations. The scope of financial planning services may vary, and clients should understand that when the scope is limited, that certain financial components may not be taken into consideration. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. We offer the Ambassador program where we manage the investment portfolio. We actively solicit advisory clients for this program and are responsible for marketing the program. We also participate in Freedom and RJCS, both wrap fee programs where you appoint RJA as the subadvisor to manage your investment strategy. In evaluating the programs, clients should consider that, depending on the wrap fee charged, the amount of portfolio activity in the client’s account, the broker dealer's usual commission rates and other factors, the wrap fee may be more or less than the aggregate cost of such services if they were to be provided separately and if we were to negotiate commissions and seek best price and execution of transactions for the client's account. Tailored Relationships We tailor investment advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management system. Investment policy statements may be created that reflect the stated goals and objectives. Our clients are allowed to impose restrictions on the investments in their account. We may accept any reasonable limitation or restriction to discretionary authority placed on the account by the client. All limitations and restrictions must be presented to us in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Client Assets As of December 31, 2023, assets under management on a fee basis were $1,055,252,906. Assets managed on a discretionary basis were $983,198,733 and assets managed on a non- discretionary basis were $72,054,173.