The Adviser is an investment adviser with its principal place of business in Norwalk, Connecticut. The Adviser commenced operations as an investment adviser on March 12, 2008. Richard L. Selvala, Jr. and Curtis Brockelman are the owners of the Adviser. The Adviser provides investment advisory services on a discretionary basis to its clients, which include but is not limited to separately managed accounts (the “Accounts”), investment companies, and corporations (collectively referred to herein as, “Clients”). The Adviser provides advice to Clients based on the specific investment objectives and strategies that are set forth in the investment management agreement (“IMA”) or other governing documents applicable to each Client (collectively “Governing Documents”). The Adviser generally does not provide investment advice, nor accept investment restrictions, based on the individual objectives of investors (“Investors”). The Adviser has built a team of veteran investment professionals with decades of experience in advising, structuring and managing option strategies and solutions. The Adviser maintains broad investment discretion as set forth in the Governing Documents. In addition, the Adviser utilizes distinct investment strategies, including: Collateral Yield Enhancement Strategy (“CYES”), Dynamic Delta Overlay Strategy (“DDOS”), and Delta Lite (“DLIT”). CYES is an index option-based overlay strategy seeking to generate incremental cash flow and improve risk-adjusted returns on existing portfolio holdings. CYES seeks to generate returns by “harvesting” the time decay of option premium by actively managing a portfolio of short-dated index option spreads on the S&P500 index (“SPX”). CYES sells options to generate premium/income while simultaneously purchasing further out-of-the-money strikes to contain

and quantify risk. The Adviser has a disciplined investment process combined with active management that seeks to defensively adjust positions at specific risk thresholds to strive to mitigate market directional risk. Additionally, the Adviser proactively adjusts positions seeking to reduce exposure to event risk ahead of large potential market-moving events and seeks to opportunistically close out positions ahead of option expiration (assuming return objectives have been achieved or risk management benefits have been depleted). DDOS is an options-based overlay strategy that seeks to deliver S&P 500 equity market exposure with an actively managed hedge and minimal capital commitment. Ultimately, DDOS seeks to be down less than SPX in the most negative months, while seeking to keep up with SPX in the most positive months. In calmer months DDOS seeks to outperform SPX via time decay of option premium. DLIT is an option-based overlay that seeks to deliver incremental returns that are correlated to SPX but with an actively managed hedge (leading to lower volatility and smaller potential drawdowns). It seeks to take advantage of option skew, asymmetric risk/reward and time decay while being net long vega (volatility). It is actively managed seeking to maintain the above – especially as options approach expiration and/or the strategy faces the known unknowns of key data releases, Federal Open Market Committee (“FOMC”) decisions and potential political events. To the extent Accounts are managed under wrap fee programs, the Adviser manages such Accounts the same as non-wrap fee Accounts and receives a portion of the wrap fees for its services. As of December 31, 2023, the Adviser had approximately $216,622,498 of regulatory assets under management, all of which is managed on a discretionary basis.