A. Description of Advisory Business and Ownership of Livian & Co. - We are an investment management firm providing investment consulting as well as discretionary portfolio management services. Our typical clients are high net worth investors with a liquid net worth between one and fifty million US dollars. Our company was formed in March 2010 by Michael Livian, CFA. In November 2010, additional investors contributed capital to Livian & Co. The principal owner(s) of our firm is (are): MICHAEL M. LIVIAN, CFA B. Our Advisory Services - We provide the following services to our clients: (i) Investment Supervisory Services (ii) Investment Consulting Services and (iii) Investment Consulting Services to other Investment Advisers. DISCLOSURE FOR RETIREMENT INVESTORS Pursuant to the Employee Retirement Income Security Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), Livian & Co., LLC and individuals providing investment advice on our behalf will be deemed to be investment advice fiduciaries when we render individualized investment advice to retirement investors (a participant or beneficiary of a Plan with authority to direct the investment of assets in his or her account or to take a distribution, the beneficial owner of an IRA acting on behalf of the IRA, or a fiduciary of a Plan or an IRA) for a fee or other compensation, whether direct or indirect. While we are already fiduciaries for all of your advisory accounts under the Investment Advisers Act of 1940, we are required to acknowledge our fiduciary status under ERISA and the Code. (i) INVESTMENT SUPERVISORY SERVICES We manage advisory accounts on a discretionary and non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). We will create a portfolio of no-load, load-waived, and front-load mutual funds, Exchange Traded Funds (“ETFs”), Exchange Traded Notes (“ETNs”), debt securities as well as common and preferred shares. We may occasionally utilize listed option contracts to hedge investment portfolios or to generate income. We will allocate the client's assets among various investments taking into consideration the overall management style selected by the client.  We select mutual funds on the basis of any or all of the following criteria: the fund's performance history, the industry sector in which the fund invests, the track record of the fund's manager, the fund's investment objectives, the fund's management style and philosophy, and the fund's management fee structure.

 We select ETFs and ETNs on the basis of any or all of the following: geographic, sector and industry exposure, diversification in the underlying securities, size and liquidity of the instrument, and expense ratio.  We select debt securities on the basis of any or all of the following criteria: issuer, credit rating, maturity of the security, price and yield, duration, liquidity of the security and special features (i.e. embedded options).  We select common and preferred shares on the basis of any or all of the following criteria: fundamentals of the company, valuation ratios (price-earnings, price-sales, price to book value ratio, dividend yield), and certain quantitative/technical metrics of the price of the shares. We also offer advice on a more limited basis for securities not recommended by Livian & Co. but included in the client’s portfolio at the client’s request. In this situation, we will provide reporting services and we will advise the client on the merits of a particular security at the client’s request; however, we will not monitor such investments, nor will Livian & Co. take any action regarding the security, even in extreme market conditions, unless contacted by the client and specifically instructed as to the appropriate action to take. (ii) INVESTMENT CONSULTING SERVICES We also provide consulting services, in which we may be engaged by a client to provide advice on such areas as asset allocation, review of existing investments and suggestions for future investments, and structuring of investment portfolios. REV 3/25/2024 Page 4 of 17 C. Individual Client Needs and Restrictions - We provide advice to clients regarding the investment of their funds based on their individual needs. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments, which will be made on the client's behalf. Clients will retain individual ownership of all securities. D. Wrap fee programs – This item is not applicable; we do not participate in wrap fee programs. E. Assets under management – the asset under management (AUM) of our firm as of February 29, 2024 are: Type Assets ($mil) Discretionary AUM 110.1 Non-Discretionary AUM 15.8 Total 125.9