Orca Investment Management, LLC (Orca) has been a Registered Investment Advisor (RIA) since June 2007. Until December 24, 2009, Orca's name was Cygnus Capital, LLC. On December 31, 2009, Orca acquired the advisory assets of KLD Investment Management, LLC (KLD) which had been a Registered Investment Advisor since 1993. Effective January 1, 2013, Orca acquired the advisory assets of Bane Barham & Holloway Assets Management Inc. (BB&H) which had been a Registered Investment Advisor since 1982. Shawn P. Willard was the principal owner and acted as Managing Member and President for Orca from inception until Paulson Capital Holding Company, LLC (Paulson) acquired Orca effective January 1, 2024, thus becoming the principal owner. With this change in ownership, Orca became a wholly owned subsidiary of Paulson. Shawn P. Willard continues to act as Manager for Orca. Paulson also owns Paulson Investment Company, LLC (PIC), a registered Broker-Dealer, thus PIC is an affiliate of Orca. In addition, Paulson owns Paulson Investment Advisers, LLC (PIA), a state-registered investment adviser, and Paulson General Insurance Services, LLC, an insurance agency, also making them affiliates of Orca. Orca offers asset management services tailored to meet your stated investment objective. This objective may be to grow the value of your account, to provide a source of income from your account, or a combination of growth and income. We offer investment objectives which range from conservative capital preservation to aggressive capital appreciation. This is discussed in more detail in Item 8 of this brochure. We tailor our asset management services to the needs of our clients. You can request, in writing, restrictions on investing in certain securities or type of securities in your account with the exception of individual stocks held in any given fund (Orca will not accept the responsibility of ensuring a certain security or type of security is not held in a fund purchased within any of our strategies). Any client directed purchases will be treated as restricted assets, and the monitoring of such assets will be the responsibility of the client. Due to the specific needs or requests of certain clients, there will be instances where one account does not hold the same securities or perform similarly to other managed accounts. Unless instructed otherwise,

clients grant Orca discretionary authorization, the ongoing and continuous authority to invest their money without consulting or prior approval from the client about the price, the type of security, the amount, and when to buy or sell to carry out their investment recommendations. These recommendations are based on the responses the client provides on the Client Investment Objectives & Suitability or Statement of Investment Policy form and/or during personal conversations with the client and on the Advisory Agreement. Under this authority, you allow us to:  Purchase and sell securities, including - but not limited to - stocks, bonds, mutual funds, exchange traded funds, money market funds (or other cash equivalent holdings) in your accounts,  Arrange for delivery and payment in connection with such purchases and sells, and  Act on your behalf in most matters necessary or incidental to handling your account, including monitoring certain assets. It is the responsibility of the client to give us complete information and to notify us of any changes in financial circumstances or goals. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. As of December 31, 2023, Orca managed the following client assets: Discretionary Client Assets: $ 160,858,491 Non-Discretionary Client Assets: $ 1,250,628 Total Client Assets: $ 162,109,119