Firm Description Per Stirling Capital Management, LLC, DBA Per Stirling Private Wealth (hereafter “PSCM”) was founded in 2009 and is led by an experienced and proven management team. The firm’s two Directors, John Per O’Sullivan, and Robert Stirling Phipps, III, have decades of managing portfolios together. They have held the positions of President, Director, Chief Investment Officer, or Chief Market Strategist of Registered Investment Advisory and/or Broker-Dealer Firms. PSCM has three core competencies. They include 1) the management of custom-designed portfolios, 2) the management of a series of three proprietary portfolios (a.k.a. “Per Stirling Model Portfolios”), and 3) financial planning services, which are all described in the body of this writing. PSCM is a fee-based Registered Investment Advisor firm and does not sell commissioned products. However, while PSCM is fee-only, some of our registered individuals are dually registered with B. B. Graham & Co., Inc., a registered broker-dealer and member of FINRA/SIPC and can accept commissions for products sold through the broker-dealer. PSCM does not directly or indirectly compensate non-registered individuals for client referrals. PSCM can, on occasion, recommend the services of other professionals (i.e. lawyers, accountants, insurance agents, etc.). However, any such professionals are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. Principal Owners John Per O’Sullivan and Robert Stirling Phipps, III, are majority stockholders of Per Stirling Capital Management, LLC, and Per Stirling Private Wealth, a DBA of Per Stirling Capital Management, LLC, and Richard Alan Jacobs is a minority stockholder. Of note, John Per O’Sullivan is affiliated with B. B. Graham & Co., Inc., as a Registered Representative, and is located in their Austin, Texas, branch office location, which operates as an Office of Supervisory Jurisdiction (an office identified by the broker-dealer as having supervisory responsibilities). Types of Advisory Services Investment Management Services Most clients choose to have Investment Advisor Representatives (“IARs”) of PSCM manage their assets in order to receive ongoing investment advice and continuous investment management, which requires an Investment Management Agreement that details the fee agreement and services provided. The majority of PSCM’s assets under management are invested in custom portfolio accounts that are designed for the client by their IAR based on the investment objectives noted by the client on their New Client Application. In addition to custom-designed portfolios, PSCM also offers three proprietary growth portfolios (a.k.a. “Per Stirling Model Portfolios”) - the Core Growth Portfolio, the Growth Portfolio, and the Conservative Growth Portfolio. These models may be used by PSCM IARs for their clients. These portfolios are managed by PSCM’s two Directors and operate as “model portfolios”, which means that all clients in these strategies will experience similar returns as the other clients in the same portfolio strategy. For more information regarding the Per Stirling Model Portfolios, please refer to the section, “Investment Strategies”. Initial public offerings (“IPOs”) are not available directly through PSCM. As of December 31, 2023, PSCM manages approximately $1,212,435,245 in assets. All the firm’s assets under management are managed on a discretionary basis. Financial Planning Services PSCM believes that there are benefits to a client working

with a financial advisor to craft a financial program, and thus encourage clients to discuss the potential benefits of designing a financial plan with their IAR (i.e. the client’s personal financial advisor). PSCM offers financial planning services that can address everything from your current financial situation to your long-term financial goals and objectives. Financial plans can be either comprehensive or issue specific. A financial plan can include, but is not limited to, areas of:
• Investment management
• Retirement planning
• Estate planning
• Insurance planning
• Tax planning
• Asset protection strategies
• College funding strategies CONSULTING SERVICES In addition to a financial plan or on-going financial planning services, PSCM also provides consulting services for clients who need advice on a limited scope of work. Together with the IAR, it is determined how much time is required to complete the requested consultations and decide whether the services are billed on an hourly or fixed-fee basis. Fees for consulting services are negotiable based upon the complexity of your situation and the actual services requested. Clients can also receive professional advice on a more limited basis. This may include advice only on isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. IARs provide specific consultation services regarding a client’s current or projected financial position or other investment and financial concerns that client may have. Recommendations may be of a generic nature or tailored to specific securities, as outlined in the agreement signed by the client prior to accepting the consulting engagement. Some IARs can also provide consulting services towards clients initiating 1031 exchanges of real property and seeking advice towards re-investment of assets received from the exchange. IARs will provide recommendations regarding the reinvestment of assets into Delaware Statutory Trusts (DST) or any real property instrument. Although IARs may assist clients with the preparation of direct application purchase, PSCM does not facilitate the exchange or purchase of such properties or any investment. Clients may or may not choose to accept the recommendations made by IARs. Some IARs participate in the process of Collaborative Divorce with their clients. In order to engage in these services with their clients, separate Agreement(s) must be signed between the IAR and their client(s) that outlines the IAR’s participation in the process of Collaborative Divorce. These Agreement(s) include, but are not limited to, the services the IAR offers, the fees and how those fees should be paid, how the IAR will interact with their counsel, communication policies, confidentiality of information, and any conflicts of interest that may be present. Please note that none of the aforementioned services include legal or tax advice. You are urged to work closely with your attorney, accountant, or other professionals regarding your financial and personal situation. Tailored Relationships The goals and investment objectives for each client are documented in the firm’s new client documentation. Clients in custom-designed portfolios may impose restrictions on investing in certain securities or types of securities. Any such restrictions must be agreed to in writing by both the client and the IAR. Clients who are invested in any of the Per Stirling Model Portfolios may not impose such restrictions due to the fact that all clients in each respective program must have similar allocations.