A. Description of the Advisory Firm KYUR, Inc. (hereinafter “KYUR”) is a Corporation organized in the State of Connecticut. KYUR is registered with the SEC and the State of California. The firm was formed in 2016 and the principal owner is Pinehill Capital LLC. B. Types of Advisory Services Portfolio Management & Subadvisor Services KYUR offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KYUR creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring KYUR evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KYUR will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. KYUR uses proprietary mathematical algorithms and quantitative screens, which are primarily derived from modern portfolio theory and behavioral economics, to appraise risk tolerances of individual investors and formulate investment advice for them accordingly. KYUR seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KYUR’s economic, investment or other financial interests. To meet its fiduciary obligations, KYUR attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KYUR’s policy is to seek fair and equitable allocation of investment opportunities/transactions among

its clients to avoid favoring one client over another over time. It is KYUR’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. KYUR may also act as a subadvisor to advisers unaffiliated with KYUR. These third-party advisers would outsource portfolio management services to KYUR. This relationship will be memorialized in each contact between KYUR and the third-party adviser. Services Limited to Specific Types of Investments KYUR generally limits its investment advice to fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities, although KYUR primarily recommends ETFs and U.S. equities to a majority of its clients. KYUR may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions KYUR will tailor a program for each individual client. This will include questions about the client’s personal finances, investment goals, and risk tolerances, and information collections, electronic or otherwise, to get to know the client’s specific needs and requirements as well as a plan that will be executed by KYUR on behalf of the client. KYUR may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. KYUR does not participate in any wrap fee programs. E. Assets Under Management KYUR has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $3,729,000 $ 0 February 7, 2023