BENJAMIN SECURITIES, INC.

Description of the Advisory Firm: Benjamin Securities, Inc. was founded on August 5, 1977, by Leo & Ann Benjamin. The Firm is registered with the Securities and Exchange Commission as a registered investment advisor and is also a member of the Financial Industry Regulatory Authority (FINRA), the Municipal Securities Rule Making Board (MSRB), and the Securities Investors Protection Corporation (SIPC). The firm is a correspondent of RBC Capital Markets, LLC, who provides securities execution, clearing services, and custodial services. In addition, the firm has a custodial arrangement with Interactive Brokers, LLC for advisory client accounts. Our Services: Benjamin Securities, Inc. (Benjamin) manages investment accounts for individuals, trusts, businesses, and foundations. The following services are offered to our clients where appropriate:

Traditional brokerage cash and margin accounts held by RBC Capital Markets, LLC Portfolio design and management of securities on a fee basis, on a commission basis, or under a separately managed account arrangement Focused investment strategies on a performance fee-based account arrangement

Our accounts are individually managed, and client funds are not co-mingled. We are able to customize accounts to address the needs of individual clients, including tax considerations, investment objectives, and socially conscious restrictions. Benjamin offers its clients both discretionary and non-discretionary Investment Management Services that include Separately Managed Accounts. Discretionary authorization will permit us to determine the specific securities and the number of securities to be purchased or sold for your account without obtaining your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. Benjamin also offers non-discretionary portfolio management services. If you enter into nondiscretionary arrangements with our firm, we will need to obtain your approval prior to executing any transactions on behalf of your account. Assets Under Management: As of August 31, 2026, we manage $32,496,528 in assets on a discretionary basis and $6,969,788 on a non-discretionary basis.

Fees: Our fee is calculated as a percentage of assets under management. The fee charged by Benjamin Securities, Inc. is 2% or less annually for advisory clients. We do not have a fixed fee schedule, but consider account size and investment objectives, and services required in determining our fee. We may negotiate lower management fees on a case-by-case basis.

For Example: $100,000 at 2% = $2000 per year in fees, which is billed monthly at $167 $100,000 at 1.5 % = $1500 per year in fees which is billed monthly at $125 Payment of Fees: Fees may be collected or deducted directly from client accounts monthly in arrears. Fees may also be invoiced and billed directly to the client monthly or quarterly in arrears. Clients may select the method in which they are billed. We calculate the amount due based on the closing value of the account at the end of the previous period. Additional Fees and Expenses: Clients are responsible for the payment of all third-party fees (i.e., Custodian fees, mutual fund fees, transaction fees, etc.) Those fees are separate and distinct from the fees and expenses charged by Benjamin Securities, Inc. Please see the section titled “Brokerage Practices” of this brochure regarding brokers/custodians. Money Market Sweep Revenue Sharing. The firm uses RBC Capital Markets, LLC (“RBC”) as a clearing and custody firm. The firm receives revenue from sweep programs/money market funds that RBC makes available as a cash sweep option, and the firm shares in some of that revenue. Any payment the firm receives reduces the interest you receive. This additional compensation received by the firm creates a conflict of interest with our clients. This compensation is retained by the firm. Your advisory fee is not reduced or offset as a result of any revenue sharing the firm receives.

Method of Analysis: Benjamin Securities, Inc.’s methods of analysis include fundamental and cyclical analysis. We may use our own analysis or third-party research to identify attractive investment opportunities. Through our analysis we seek to identify companies that appear to be undervalued in our opinion based on cash flows, earnings, growth potential, or assets. Investment Strategies: Benjamin Securities, Inc. uses primarily a long-term investment strategy in portfolio planning. as well as our performance fee-based strategies. Risk of Loss: All investments in securities include a risk of loss that you, as a client, should be prepared to bear. Other risks include but are not limited to: Interest-rate Risk. Fluctuations in interest rates can cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk. The advisor’s investment approach can fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific

asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio can suffer. Options Trading. The risks involved with trading options are that they are very time sensitive investments. An options contract is generally for a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. Trading on Margin. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to bring the account back up to maintenance levels. Clients who cannot comply with such a margin call will be sold out or bought in by the brokerage firm. Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices do not correlate perfectly with changes in the underlying reference units; and(ii) the risk of possible trading halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the overall stock market. Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices of common stock react to the economic condition of the company that issued the security, industry and market conditions, and other factors which can fluctuate widely. Investments related to the value of stocks can rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities, including preferred stock, warrants, and options may also vary widely. Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers. Securities of small-cap issuers may present greater risks than those of

large-cap issuers. For example, some small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be subject to high volatility in revenues, expenses, and earnings. Their securities can be thinly traded, and be followed by fewer investment research analysts, and can be subject to wider price swings and thus can create a greater chance of loss than when investing in securities of larger-cap issuers. The market prices of securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, to corporate developments, and to market rumors than are the market prices of large-cap issuers. Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk that the category can be out of favor due to current market conditions or investor sentiment. Market Risks. Turbulence in the financial markets and reduced liquidity can negatively affect the Companies, which could have an adverse effect on each of them. If the securities of the Companies experience poor liquidity, investors will be unable to transact at advantageous times or prices, which can decrease the Company’s returns. In addition, there is a risk that policy changes by central governments and governmental agencies, including the Federal Reserve or the European Central Bank, which could include increasing interest rates, could cause increased volatility in financial markets, which could have a negative impact on the Companies.

We provide investment advice and services to the following types of clients:

Individuals

High-Net-Worth Individuals Trusts, Estates, and Charitable Organizations Corporations or Business Entities Pension and Profit-Sharing Plans

Benjamin Securities, Inc. requires a minimum account of $50,000 for advisory clients, although we make exceptions on a case-by-case basis

Benjamin Securities, Inc. charges performance-based fees on certain investment strategies for qualified investors. The firm currently charges a 20% performance fee on these strategies, charged quarterly in arrears. This performance fee is charged on a share of capital gains on or capital appreciation of the assets in these accounts. These fees are subject to a high-water mark. You should be aware that performance-based fee arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. We also have an incentive to favor accounts that pay performance-based fees because compensation we receive from these clients is more directly tied to the performance of their accounts. Benjamin Securities, Inc. has compliance policies and procedures in place that it believes are reasonably designed to mitigate these conflicts of interest. The strategies subject to this arrangement are distinct and separate from our investment strategies subject to a fee based on a percentage of assets under management.

Benjamin Securities, Inc. is an SEC registered investment advisor and a FINRA registered broker dealer. Some Benjamin Securities, Inc. advisors are licensed as registered representatives with Benjamin Securities, Inc. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products may conflict with the fiduciary duties of a registered investment advisor. Benjamin Securities, Inc., always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Benjamin Securities, Inc. in their capacity as a registered representative. However, if they implement the advice through Benjamin Securities, Inc, the commissions they pay may be higher or lower than at other broker dealers.

Benjamin Securities, Inc. has adopted a Code of Ethics that governs a number of potential conflicts of interest that we may have in providing services to our clients. This Code of Ethics has been designed to ensure that we meet our fiduciary obligation to our clients and to prevent violations of securities laws. Our Code of Ethics is comprehensive and is distributed to each

employee at the time of hire. We also supplement the Code with an annual compliance meeting and ongoing monitoring of personal trading activity by employees of the firm. Our Code of Ethics includes the following:

Prohibitions on insider trading and other prohibited activities Requirements on client confidentiality Guidelines on priority of transactions when trading for personal accounts Procedures for monitoring employee holdings Limitations on receiving or giving gifts from colleagues or clients

We believe it is important for members of the firm to own the same securities as we purchase for clients. However, we recognize the potential conflicts that this creates. Benjamin Securities, Inc. will always document any transactions that could be construed as conflicts of interest and will always put client interests before their own when similar securities are being bought or sold. Our code requires investment professionals to exercise judgment and sensitivity to avoid conflicts of interest, and always put the interest of our clients first.

Selecting Brokers: Our advisory clients are not obligated to implement our advice through Benjamin Securities, Inc. and may utilize a brokerage firm of their choosing. They also are not obligated to implement our advice through any particular brokerage firm and may utilize a firm of their choosing. By implementing our advice through Benjamin Securities, Inc. or Interactive Brokers, LLC, clients pay higher or lower commissions and transaction fees than they can negotiate elsewhere. In all cases, Benjamin Securities, Inc., will seek to ensure that the firms’ fiduciary and supervisory obligations can be met. If we feel that the use of a particular broker dealer would hinder the firm’s ability to meet either of these obligations, Benjamin Securities, Inc. will not be able to accept the account. We receive research and software tools through Benjamin Securities, Inc.’s correspondent relationship with RBC Capital Markets, LLC. These services assist Benjamin Securities, Inc with managing and administering clients’ accounts. The research and software may benefit all our advisory clients, not just those utilizing Benjamin Securities, Inc for their brokerage services. The fact that we receive these services through Benjamin Securities, Inc. creates a conflict of interest and may cost clients more money. Benjamin Securities, Inc. does not have any soft-dollar arrangements. We have the ability to aggregate orders for multiple accounts, in which case each client receives the same average price in a transaction, but we rarely do so. While aggregating orders may benefit clients by purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of our custodians.

Other than items discussed in the Brokerage Practices section above, Benjamin Securities, Inc. does not receive any economic benefit outside of our advisory fees, commissions, and cash sweep/money market revenue either directly or indirectly for advice rendered to our advisory clients. In addition, Benjamin Securities, Inc. does not have any marketing arrangements outside of its own Advisors for client referrals. We occasionally receive client referrals from outside of the firm; however, we do not compensate the source of those referrals.

We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. Benjamin does not have any disclosures under this item.

Portfolio Advisory client accounts are monitored daily, and a portfolio review is performed at least quarterly. Monthly account statements are generated by the custodian. Clients receive monthly account statements generated by the custodian and the advisor makes recommendations as circumstances present themselves. All accounts are also reviewed in response to various events, such as deposits or withdrawals, transfers, client contact, major market events, individual security events, or changes in clients’ financial situations (such as retirement, termination of employment, physical move, or inheritance). Accounts are reviewed by William T. Baker, President, Thomas Laundrie, Investment Advisor, and Catharine Chandler, Investment Advisor.

Benjamin Securities, Inc. does not take custody of client accounts at any time. Custody of clients’ accounts is held primarily at RBC Capital Markets, LLC and Interactive Brokers, LLC. Clients may elect other custodians as explained in “Brokerage Practices” above. Clients will receive account statements directly from the custodian and should carefully review those statements for accuracy. Benjamin Securities, Inc. urges clients to compare the account statements received from the custodian with the periodic portfolio reviews they receive from Benjamin Securities, Inc. The only time Benjamin Securities, Inc. is able to access client funds is to deduct our management fees in accordance with our Advisory Fee Agreement.

Benjamin Securities, Inc. has limited discretionary authority for some client accounts. A Limited Trading Authorization form must be signed before Benjamin Securities, Inc. can assume discretion as to the selection of securities, amount, and timing of transactions.

Benjamin Securities, Inc. will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security.

Benjamin Securities, Inc., does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and we do not require the prepayment of more than $1,200 in fees six or more months in advance.

Part 2B of form ADV- Brochure Supplement This brochure supplement is provided on William T. Baker Mr. Baker’s contact information is: William T. Baker Benjamin Securities, Inc. 3 West Garden Street, Suite 407 Pensacola, FL 32502 wbaker@benjaminsecurities.com 516-931-1090

This brochure supplement provides information about William T. Baker that supplements the Benjamin Securities, Inc. brochure. You should have received a copy of that brochure. Please contact William Baker at 516-931-1090 if you did not receive Benjamin Securities, Inc.’s brochure or if you have any questions about the contents of this supplement. Additional information about William T. Baker is available on the SEC’s website at www.adviserinfo.sec.gov

Educational Background and Business Experience Name: Date of Birth: Education: Background:

William T. Baker August 9, 1962 US Coast Guard Academy Suffolk Community College Hofstra University Senior Portfolio Manager, Benjamin Securities, Inc. Head Trader, Obsidian Financial Group, LLC Director of Trading at EKN Services, Inc. Institutional Sales Trader at Fagenson & Co., Inc

Mr. Baker is a FINRA registered representative at Benjamin Securities, Inc. and may offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products may conflict with the fiduciary duties of a registered investment advisor. Benjamin Securities, Inc. always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Benjamin Securities, Inc. in their capacity as a registered representative. However, if they implement the advice through Benjamin Securities, Inc, the commissions they pay may be higher or lower than at other broker dealers. Money Market Sweep Revenue Sharing. The firm uses RBC Capital Markets, LLC as a clearing and custody firm. The firm receives revenue from sweep programs/money market funds that the firm makes available as a cash sweep option, and the firm shares in some of that revenue. Any payment the firm receives reduces the interest you receive. This additional compensation creates a conflict of interest with our clients. This compensation is retained by the firm, as an owner Mr. Baker benefits from the revenue generated by this revenue sharing arrangement. Your advisory fee is not reduced or offset as a result of any revenue sharing the firm receives. In 2006, William Baker was the subject of a regulatory investigation while a director at EKN Financial Services, Inc. The NASD alleged the firm purchased restricted PIPE shares and arranged to establish short positions in the stocks without either owning the securities, or borrowing unrestricted shares. Mr. Baker, without admitting or denying the findings, consented to described sanctions and entry of findings. He was fined $15,000 jointly and severally with the firm and suspended from acting in a supervisory capacity for 10 business days. Mr. Baker does not receive compensation for providing advisory services outside of those fees and commissions earned at Benjamin Securities, Inc. Mr. Baker is monitored and reviewed by Thomas Laundrie may be reached at 516-931-1090 or tlaundrie@benjaminsecurities.com

Part 2B of form ADV – Brochure Supplement

This brochure supplement is provided on Catharine Chandler. Catharine Chandler’s contact information is: Catharine Chandler Benjamin Securities, Inc. 3 West Garden Street, Suite 407 Pensacola, FL 32502 cc@benjaminsecurities.com 516-931-1090

This brochure supplement provides information about Catharine Chandler that supplements the Benjamin Securities, Inc. brochure. You should have received a copy of that brochure. Please contact Catharine at 516-931-1090 if you did not receive Benjamin Securities, Inc.’s brochure or if you have any questions about the contents of this supplement. Additional information about Catharine Chandler is available on the SEC’s website at www.adviserinfo.sec.gov

Educational Background and Business Experience Name: Date of Birth: Education: Background:

Catharine Chandler November 7, 1964 Randwick Sydney Australia - BA Series 65 registered investment advisor Investment Advisor Representative at Benjamin Securities, Inc. since May 2012

Ms. Chandler comes from a business and investment background in real estate, both residential and commercial. She ran her own Interior Design company for 16 years in the Caribbean, worked in the industry for a total of 23 years and has also developed a successful residential rental income property business since 2003. Ms. Chandler has never been the subject of any material investment-related legal or disciplinary actions. Ms. Chandler is a Registered Investment Adviser Representative at Benjamin Securities, Inc. and may offer clients advice or products from those activities on a fee only basis. Ms. Chandler is monitored and reviewed by William Baker. Mr. Baker may be reached at 516-931-1090 or wbaker@benjaminsecurities.com

Part 2B of form ADV – Brochure Supplement

This brochure supplement is provided on Thomas Laundrie. Thomas Laundrie’s contact information is: Thomas Laundrie Benjamin Securities, Inc. 3 West Garden Street, Suite 407 Pensacola, FL 32502 tlaundrie@benjaminsecurities.com 516-931-1090

This brochure supplement provides information about Thomas Laundrie that supplements the Benjamin Securities, Inc. brochure. You should have received a copy of that brochure. Please contact Thomas at 516-931-1090 if you did not receive Benjamin Securities, Inc.’s brochure or if you have any questions about the contents of this supplement. Additional information about Thomas Laundrie is available on the SEC’s website at www.adviserinfo.sec.gov

Educational Background and Business Experience Name: Date of Birth: Education: Background:

Thomas Laundrie September 4, 1950 St. Johns University Vice President, Portfolio Manager, Benjamin Securities, Inc. since 2009

Have been a licensed registered representative since 1983 Have also acted in a licensed supervisory capacity since 1985 President, Institutional Equity Corp. President, Basic Investors, Inc. In 2009, Mr. Laundrie was the subject of a regulatory investigation while President of Basic Investors, Inc. FINRA alleged I failed to supervise the firm’s, consulting business by failing to take any action to determine whether the firm was providing services to its clients pursuant to its business consulting agreements or was being paid solely for its market making activities. They alleged that I failed to take any action to review or monitor the firm’s market making in the securities of the firm’s clients. Without admitting or denying the findings, I consented to the described sanctions and to the entry of findings; I was fined $15,000 and suspended from association with any FINRA member in any principal capacity for 45 days. The suspension was in effect from April 20, 2009, through June 3, 2009. Fines paid on 04/14/2009. I then needed to file for bankruptcy on 9/2009 to restructure my finances. Mr. Laundrie is a FINRA registered representative at Benjamin Securities, Inc. and may offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products may conflict with the fiduciary duties of a registered investment advisor. Benjamin Securities, Inc. always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of Benjamin Securities, Inc. in their capacity as a registered representative. However, if they implement the advice through Benjamin Securities, Inc, the commissions they pay may be higher or lower than at other broker dealers. Mr. Laundrie does not receive compensation for providing advisory services outside of those fees and commissions earned at Benjamin Securities, Inc. Mr. Laundrie is monitored and reviewed by William T Baker may be reached at 516-931-1090 or wbaker@benjaminsecurities.com