ARAM provides investment management services. Prior to engaging ARAM to provide any investment management services, the client is required to enter into one or more written agreements with ARAM setting forth the terms and conditions under which ARAM renders its services (collectively the “Agreement”). ARAM has been in business since March 19, 1982. Arnold S. Rosenstein and Anita M. Rosenstein are the principal owners of ARAM. ARAM has $542,105,577 of assets under management as of June 30, 2023, all of which are managed on a discretionary basis. This Disclosure Brochure describes the business of ARAM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of ARAM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on ARAM’s behalf and is subject to ARAM’s supervision or control. Investment Management Services Clients can engage ARAM to manage all or a portion of their assets on a discretionary basis. ARAM primarily allocates clients’ investment management assets among individual debt and equity securities, options, mutual funds, and exchange-traded funds (“ETFs”) in accordance with the investment objectives of the client. In addition, ARAM may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement securities, which include debt, equity, and/or pooled investment vehicles when consistent with the clients’ investment objectives. ARAM also provides advice about any type of investment held in clients' portfolios. ARAM tailors its advisory services to the individual needs of clients. ARAM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that impact the clients’ investment needs. ARAM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify ARAM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon ARAM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in ARAM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 5 © MarketCounsel 2023 Management of Collective Investment Vehicle An affiliate of ARAM, Anita M. Rosenstein, is the general partner of El

Camino Europe Fund, Ltd., El Camino Fund, Ltd., and Maple Income and Growth Fund, L.P., (the “Private Funds”), all of which are California Limited Partnerships formed to engage primarily in the business of investing and trading in securities. Interests in the Private Funds are privately offered pursuant to Regulation D under the Securities Act of 1933, as amended. The Private Funds currently rely on an exemption from registration under the Investment Company Act of 1940, as amended, that is available to pooled investment vehicles that do not have more than 100 beneficial owners. ARAM’s affiliate has discretionary authority to determine the broker or dealer to be used by the Private Funds. Participation as an investor in the Private Funds is restricted to investors that are qualified clients as defined in Rule 205-3 under the Investment Advisers Act of 1940, as amended, and “accredited investors” as defined in Rule 501(a) under the Securities Act of 1933, as amended. To the extent certain of ARAM’s individual advisory clients qualify, they will be eligible to participate as limited partners of the Private Funds. Investment in the Private Funds involves a significant degree of risk. All relevant information, terms and conditions relative to the Private Funds, including the compensation received by ARAM or any affiliate as the general partner and/or investment manager, suitability, risk factors, and conflicts of interest, are set forth in the Confidential Private Offering Memorandum (the “Memorandum”), Limited Partnership Agreement (the “Agreement”), and Subscription Agreement (together, the “Offering Documents”), which each investor is required to receive and/or execute prior to being accepted as an investor in the Private Funds. While the Private Funds are generally ARAM’s client, the term “client(s)” sometimes refers to the investors in the Private Funds. ARAM will devote its best efforts with respect to its management of both the Private Funds and its individual client accounts. Given the above discussion relative to the objectives, suitability, risk factors, and qualifications for participation in the Private Funds, ARAM may give advice or take action with respect to the Private Funds that differs from that for individual client accounts. To the extent that a particular investment is suitable for both the Private Funds and certain individual client accounts, such investments will be allocated amongst the Private Funds and the individual client accounts pro rata based on the assets under management or in some other manner which ARAM determines is fair and equitable under the circumstances to all of its clients.