EASLEY INVESTMENT CONSULTANTS, INC.

EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Item 1 – Cover Page FIRM BROCHURE – FORM ADV PART 2A EASLEY INVESTMENT CONSULTANTS INC. 1050 Northpark Drive Suite D Ridgeland, MS 39157 Phone: (601) 992-4101 Website: www.easleyinvest.co January 30, 2026 This firm brochure provides information about the qualifications and business practices of Easley Investment Consultants Inc. If you have any questions about the contents of this firm brochure, please contact us at (601) 992-4101. The information in this firm brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this firm brochure and any brochure supplements (“brochure supplements”) for more information on the qualifications of our firm and our associates. Additional information about Easley Investment Consultants Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Easley Investment Consultants Inc. is 307258. 1  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Item 2 – Material Changes We have made the following material changes to this firm brochure since our last filing dated March 18, 2025: Our new office address is: 1050 Northpark Drive, Suite D Ridgeland, MS 39157 We will ensure that all current clients receive a Summary of Material Changes to this and subsequent firm brochures within 120 days of the close of our fiscal year. A Summary of Material Changes is also included within our firm brochure available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Easley Investment Consultants Inc. is set forth on the cover page of this firm brochure. Clients will further be provided with disclosure about material changes affecting our firm or a new firm brochure as may become necessary or appropriate at any time, without charge. Currently, a copy of our firm brochure may be requested, free of charge, by contacting Cal R. Easley, Jr. at the telephone number reflected on the cover page of this firm brochure. 2  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Item 3 – Table of Contents Page Item 1 – Cover Page ........................................................................................................................ 1 Item 2 – Material Changes .............................................................................................................. 2 Item 3 – Table of Contents.............................................................................................................. 3 Item 4 – Advisory Business ............................................................................................................ 4 Item 5 – Fees and Compensation .................................................................................................... 8 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................. 13 Item 7 – Types of Clients .............................................................................................................. 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 13 Item 9 – Disciplinary Information ................................................................................................ 18 Item 10 – Other Financial Industry Activities and Affiliations .................................................... 18 Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 19 Item 12 – Brokerage Practices ...................................................................................................... 20 Item 13 – Review of Accounts...................................................................................................... 23 Item 14 – Client Referrals and Other Compensation .................................................................... 24 Item 15 – Custody ......................................................................................................................... 24 Item 16 – Investment Discretion ................................................................................................... 25 Item 17 – Voting Client Securities................................................................................................ 26 Item 18 – Financial Information ................................................................................................... 26 3  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Item 4 – Advisory Business A Easley Investment Consultants Inc. is a Mississippi corporation founded in 2018 by Carl “Cal” R. Easley, Jr. and Carl Ray Easley. Effective as of August 31, 2023, Cal R. Easley, Jr. is the sole shareholder of the firm. We are registered as an investment advisor with the SEC and our principal offices are located in Ridgeland, Mississippi. The information contained in this brochure describes our investment advisory services, practices, and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our services to the needs of our clients. As used throughout this firm brochure, the words “we,” “our,” “firm,” “EIC” and “us” refer to Easley Investment Consultants Inc., and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. Prior to forming an investment advisor-client relationship, we may offer you a complimentary general consultation to discuss the nature of our service offerings and to determine how we can best assist you in meeting your financial goals and objectives. Investment advisory services begin only after the prospective client and EIC formalize their relationship by the execution of a written advisory agreement. B C We offer a wide range of investment advisory services to our clients. Our investment advice is custom tailored according to each client’s unique investment profile. Clients typically deposit their assets at a custodial firm (the “Custodian”), typically a licensed broker-dealer, and grant us limited authority to buy and sell securities either on a discretionary or non-discretionary basis. The full scope of our authority will be set forth in a written advisory agreement entered with the client. We act as your fiduciary, responsible for the management of your investment account(s) at the Custodian, where assets are held in your name.  Where you engage us on a discretionary basis, you authorize our firm and our investment advisor representatives to implement our investment recommendations directly within your account held at the Custodian without obtaining your specific consent prior to each transaction.  Where you engage us on a non-discretionary basis, we will provide you with investment recommendations which you are free to accept or reject, in whole or in part. We will only implement our investment recommendations within your account held at the Custodian upon your request and with your prior approval. Clients always have the ability to impose reasonable restrictions on our management of their account(s), including the ability to instruct us not to purchase certain specific securities, industry sectors, and/or asset classes. All such requests must be provided to us in writing. While we generally attempt to accommodate such restrictions, we reserve the right to reject such investment limitations if they would frustrate our management of your account, or for any other reason, in our sole discretion. We will notify you promptly if we are unable to honor any of your investment restrictions or limitations. 4  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE A description of the individual investment advisory services offered by our firm is set forth below. Portfolio Management. Our firm offers ongoing and continuous portfolio management services that are uniquely tailored to your financial circumstances. These services are offered exclusively as part of the EIC Wrap Fee Program under which you will pay a single asset-based fee that covers the costs of advisory services, trade execution, custody, and certain other standard brokerage services and costs generated in connection with our management of your account (a “Wrap Fee”). Please see our separate wrap fee brochure (“Wrap Brochure”) and the account opening documentation of your selected Custodian for further details regarding the EIC Wrap Fee Program and the list of fees and costs not covered by our Wrap Fee. A copy of our Wrap Brochure will be provided to you at the inception of our relationship. Please call us at the telephone number found on the cover of this firm brochure if you did not receive a copy of our Wrap Brochure. When you participate in the EIC Wrap Fee Program, we will gather information from you through periodic consultations regarding your financial goals, investment objectives, tolerance for risk, and the time horizon for investments. The information we typically request in this process will include your current and expected income level, tax information, investment experience, current and expected cash needs, current portfolio construction/asset allocation, and risk tolerance level, among other items. Based on our analysis of these factors, we will prepare an investment policy statement (or similar documentation used to establish your investment objectives and suitability) outlining parameters for our management of your account(s). We will then implement an initial investment strategy and portfolio intended to align with your unique financial situation and goals. Client portfolios are typically constructed utilizing a diversified combination of mutual funds, exchange traded funds (“ETFs”), individual bonds, stocks, and other instruments, as may be appropriate for the individual client. In some instances, we may also engage certain independent third-party money managers (“TPMMs”) to directly manage all or a portion of your account on a discretionary basis. You will be provided with a copy of each recommended TPMM’s Form ADV Part 2 firm brochure (or the equivalent) prior to the allocation of your assets to any TPMM managed account(s) (each a “TPMM Account”). Where a TPMM is engaged, we will continue to act as your fiduciary and a “co-advisor” to your TPMM Accounts. We will determine the suitability of the TPMM’s investment program, communicate any changes in your investment profile to the TPMM, and recommend changes in your TPMM allocations as we believe to be in your best interests. The TPMM shall be responsible for all portfolio management and trading functions related to your TPMM Accounts. Following implementation of your initial investment portfolio, we will monitor the performance of your investments (including any held in TPMM Accounts) and implement changes within your account as needed or appropriate, in consideration of current economic conditions, our market opinions and assumptions, and your individual financial circumstances and goals. It is your ongoing responsibility to advise us in writing of any material changes to your financial circumstances. 5  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Our portfolio management services are typically offered on a discretionary basis only. However, we may offer this service on a non-discretionary basis upon client request. At our discretion, portfolio management clients may also receive complimentary financial planning services in the form described below. Financial Planning and Consulting Services. Our firm offers traditional financial planning and consulting services to clients which may address, without limitation, some or all of the following topics, based on your financial needs and concerns: • • • estate planning; • • retirement planning; investment planning/asset; allocation/portfolio design; • financial, budgeting and cash management; risk management, insurance planning, and analysis; financial planning relating to divorce and marriage; • educational funding; and • investment goal setting. We will consult with you and assist you in identifying areas of potential financial concern and provide you with a discrete set of short and/or long-term financial goals and actions designed to address your unique financial circumstances. Our recommendations will take the form of a written report delivered to the client. Our financial planning and consulting services are offered on an annual retainer basis or on a one-time consulting basis. • For annual retainer financial planning engagements, we will deliver an initial written financial plan and meet with you at least once annually thereafter to review the plan, track progress towards your financial goals, and update the plan accordingly. Our annual financial planning engagements will renew automatically in each successive year, unless the client wishes to terminate the engagement and does so on notice to our firm. • For one-time financial planning/topical consulting engagements, the client may select a discrete financial topic or topics upon which they would like to receive our financial advice. One-time financial planning and consulting services are narrower in scope than annual retainer services and do not include comprehensive financial planning. We will deliver our recommendations in the form of a written financial report or checklist at the conclusion of the engagement, after which time, no further update or review of the financial report or checklist is provided (unless specifically requested by the client and agreed to in writing by EIC) and the engagement is deemed to be concluded. This is a non-discretionary service - you retain the sole discretion to accept or reject any of EIC’s financial planning or consulting recommendations, in whole or in part, and to determine the service providers to be utilized for their implementation. You will also be responsible for the monitoring of your assets. Upon request, we may assist you with 6  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE implementation of our investment advice - additional fees may apply. Clients are never obligated to use our firm to implement any recommendations under this service and are never charged more than $1,200, six (6) or more months in advance, for these services. We may recommend the use of certain third-party professionals (e.g., attorneys, tax professionals, insurance agents, and others) to assist you in implementing our financial planning advice. We do not receive referral fees of any kind when we refer clients to such third-party professionals. You may elect to engage any such third party professional(s) at your own discretion and risk for additional fees to be negotiated independently with the chosen service provider. We do not provide legal or tax advice of any kind. Pension Consulting Services. We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review, formulation of the investment policy statement, asset allocation advice, non- discretionary portfolio management services, investment performance monitoring, on- going consulting and communication and education services. Upon request, we will assist the plan sponsor in providing meaningful information, education, and seminars regarding the retirement plan to plan participants. NOTE: Certain plans/clients that we may provide services to are regulated under the Employee Retirement Income Securities Act of 1974 (“ERISA”). We will provide pension consulting services to the plan sponsor and/or fiduciaries as described above for the fees set forth in Item 5 of this brochure. The consulting services we provide are advisory in nature. In providing services to any plan and its underlying participants, our status is that of an investment adviser registered with the SEC. We are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting as a fiduciary of the plan as defined in Section 3(21) under ERISA, only. In all cases, our status as a fiduciary under ERISA is clearly disclosed in a written advisory agreement. If there is any discrepancy between the disclosures in this paragraph and the agreement, the agreement shall govern. D Wrap Fee Program. As described above, EIC offers its portfolio management services exclusively as part of the EIC Wrap Fee Program. Under a wrap fee, you will pay EIC a single asset-based advisory fee (i.e., a fee based on a percentage of the value of your assets) which covers the combined the costs of advisory services, trade execution, custody, and certain other standard brokerage services and costs generated in connection with our management of your account (a “Wrap Fee”). In a Wrap Fee account, the brokerage commissions generated in your account are absorbed within our Wrap Fee, with EIC retaining the remainder of the fees paid by the client. This creates an incentive for us to trade your account less frequently and/or to invest your account in assets that may be subject to waived or reduced brokerage commissions (if available), resulting in EIC retaining a greater portion of the Wrap Fee paid by the client. Additionally, you should consider that the Custodian we typically recommend to clients enrolled in our wrap fee program, Charles Schwab & Co., Inc. (“Schwab”), Member 7  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE FINRA/SIPC, does not charge commissions (or transaction fees) for certain online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. To address the foregoing conflicts, we manage your account in strict accordance with your investment policy statement and our ongoing fiduciary duty to you. You are further advised that the Wrap Fee applicable to your account may represent a premium relative to what you might otherwise pay in a similar investment program operated as a non-wrap fee arrangement (i.e., where our advisory fees and the separate costs of transaction-based charges and commissions, custodial fees, and other related costs are each billed separately to you) (a “Non-Wrap Fee”). Please consider that depending upon the level of our Wrap Fee, the amount of portfolio activity in your account, the value of the services that we provide to you, and other factors, the Wrap Fee we charge you may or may not exceed the aggregate cost of services if they were to be provided and charged to you separately. Stated differently, by participating in Wrap Fee arrangement, you may end up paying more or less than you would through a Non-Wrap Fee arrangement where a lower advisory fee is charged, but the brokerage commissions and transaction-based fees are passed directly to you by the broker. As a general matter, wrap fee arrangements are relatively less expensive for actively traded accounts. However, they may result in higher overall costs to the client in accounts that experience little trading activity. Accordingly, we encourage clients to discuss with EIC whether a wrap fee arrangement is appropriate for their account at the inception of the advisory relationship. Types of Investments Recommended. While we do not recommend one particular type of investment or asset class over any other, we primarily advise our clients regarding investments in equity securities, mutual funds, ETFs, corporate debt securities, and variable products (life insurance and annuities). Depending on the client’s financial circumstances, our investment advice may also concern other instruments, including, without limitation, municipal securities, exchange traded notes, money market accounts, and U.S. government securities. We may also provide advice regarding investments held in the client’s portfolio at the inception of our advisory relationship or advice concerning other investment instruments specifically requested by the client. Please see Item 8 of this brochure or a description of the investment strategies we typically implement in client accounts. E Assets Under Management. As of January 15, 2026, we managed approximately $211,131,214 of client assets on a discretionary basis and approximately $12,648,176 of assets on a non-discretionary basis. Item 5 – Fees and Compensation A Fees for Portfolio Management. As described above, EIC’s portfolio management services are subject to a Wrap Fee arrangement. Please see our Wrap Brochure for full details regarding our Wrap Fees. 8  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Fees for Financial Planning Services. We typically charge hourly fees at a maximum rate of $300 per hour for financial planning and consulting services. Our hourly fee rate is negotiable and the specific rate applicable to your engagement will be determined prior to the commencement of services based on our expectation of the complexity, time, research, and resources required to provide services to you, and other factors we deem relevant. For annual retainer financial planning engagements, our hourly fees are invoiced to the client either monthly or quarterly and are payable to us within thirty (30) days of invoicing. For one-time financial planning and consulting engagements, hourly fees are invoiced to the client monthly and are payable to us within thirty (30) days of invoicing. Full payment of any unpaid fees is due upon delivery of the written financial plan, report, or checklist to the client. Fees for Pension Consulting Services. Where our pension consulting services include non- discretionary portfolio management services, we charge Wrap Fees as set forth in our separate Wrap Brochure. Please see our Wrap Brochure for full details. For any non-fiduciary pension consulting services (e.g., existing plan review, formulation of the investment policy statement, performance monitoring, education services, etc.) we typically charge hourly fees at a maximum rate of $300 per hour. These fees may be invoiced to the client and paid either quarterly or monthly, in arrears or in advance, as may be agreed with the client in our written advisory agreement. The specific hourly fee structure and rate applicable to the client’s account will vary based upon the nature of the pension consulting services selected, complexity of the engagement, and our expectation of the time and resources necessary to provide services to the client, among other factors. B Direct Deduction of Fees; Account Statements. Our Wrap Fees are directly deducted from your account held at the Custodian upon your written approval of such arrangement and our periodic submission to the Custodian of a written invoice reflecting the amount of advisory fees to be charged to your account. Your authorization for direct fee deduction is set forth in our written advisory agreement and/or the account opening documents with the Custodian. We will liquidate money market shares or use cash balances from your account to pay our Wrap Fee, however, if money market shares or cash value are not available other investments may be liquidated. Please note that unexpected or premature liquidation of investments to pay our advisory fees may impair the performance of your account. We do not offer direct paper or electronic invoicing of our Wrap Fees. The Custodian will send an account statement to you typically monthly, but no less than quarterly, identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid directly to us. We encourage you to review our invoices and the Custodian’s account statements carefully and promptly upon receipt. If you believe we have miscalculated our fees or if there is any other issue with your account, you should contact us immediately at the phone number listed on the cover page of this firm brochure. 9  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Fees for financial planning and consulting services and for non-fiduciary pension consulting services are directly invoiced in paper or electronic form to the client as described above. C Additional Fees and Expenses Associated with Portfolio Management Services. Our Wrap Fee covers the combined the costs of EIC’s advisory services, trade execution, custody, and certain other standard brokerage services and costs generated in connection with our management of your account. Most portfolio management client accounts are expected (but not required) to engage the custodial and brokerage services of our recommended Custodian, Schwab. Where you select Schwab as your Custodian, you are advised that our Wrap Fee does not cover fees charged by other brokers for execution of trades that settle into the client’s Schwab account (i.e., “trade-away” fees), markups, markdowns, bid-ask spreads, and selling concessions, custody charges for non-publicly traded securities, margin interest charges (if applicable), electronic funds and wire transfer fees, transfer taxes, odd-lot differentials, and other similar fees and charges, which shall be paid separately by the client. If you elect to use a Custodian other than Schwab, there may be material differences in the specific brokerage costs and charges that are covered within our Wrap Fee. As part of our portfolio management services, we may invest your account in mutual funds and/or ETFs. The Wrap Fee that you pay to our firm is separate and distinct from the internal management fees and other expenses that may be charged by mutual funds and/or ETFs to their shareholders, for which you will be separately responsible. Additional Fees and Expenses Associated with Financial Planning and Consulting Services and Non-fiduciary Pension Consulting Services. The hourly advisory fees we charge for financial planning and consulting services and non-fiduciary pension consulting services only cover the costs of our investment advice. Separate and in addition to our advisory fees, the client shall be solely responsible to bear the costs of all internal management fees and other expenses that may be charged by mutual funds and/or ETFs to their shareholders, together with the costs of any management fees or other charges imposed by any TPMMs. You will also pay the Custodian of your account transaction charges, custodial, and/or brokerage fees and commissions, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes associated with activity in your brokerage account. We do not share in any portion of the additional fees and expenses described above. To fully understand the total costs you will incur by engaging our services, you should review the prospectus of each mutual fund, ETF, and/or TPMM advisory program in which you are invested and the contractual arrangement with the Custodian of your account. For information on our brokerage practices, please refer to Item 12 of this brochure. While we believe our advisory fees to be reasonable for the services provided, you are advised that lower fees for comparable services may be available from other sources. Our fees are negotiable and we may enter into fee arrangements that are materially different than those described above with certain clients. 10  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE D Our Termination and Refund Policy. Any of our advisory services may be terminated at any time by either party, within five (5) business days of entering an advisory agreement, without penalty. Thereafter, any of our advisory services may be terminated by either party on thirty (30) days’ written notice to the non-terminating party. Where we are compensated by means of an asset-based advisory fee (e.g., our Wrap Fee), upon termination, we shall be compensated a pro-rated portion of such fee based on the number of days in the terminating period during which services were provided, with any excess pre-paid fees returned to the client promptly following termination. Where we are compensated by means of hourly fees, all hourly fees incurred but not yet paid through termination shall become immediately due and payable to our firm, with any excess pre-paid fees returned to the client promptly following termination. E Compensation for Sale of Securities or Insurance Products. Certain associated persons of EIC are independently licensed to sell insurance in one or more states acting as a direct agent representative of a specific insurance company or companies. Insurance related business may be transacted with advisory clients and licensed individuals may receive commissions from insurance products sold to clients. Clients are advised that the fees paid to EIC or its associated persons for investment advisory services are separate and distinct from any commissions earned by EIC or its associated persons for selling insurance products to clients. If requested by a client, we will disclose the amount of commissions expected to be paid. The receipt of insurance related commissions by any individual associated with our firm presents a conflict of interest. As fiduciaries we must act primarily for the benefit of our investment advisory clients. As such, we will only transact insurance related business with clients when fully disclosed, suitable, and appropriate. Further, we must determine in good faith that any commissions paid to our associated persons are appropriate. Clients are informed that they are under no obligation to use any individual associated with our firm for the purchase of insurance products or services. Clients may use any insurance firm or agent they choose for purchase of these products and services. We encourage you to ask us about the conflicts of interest presented by the insurance licensing of our associated persons. Rollover Recommendations As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. 11  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee-based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests ahead of yours. Under this special rule’s provisions, we must:  meet a professional standard of care when making investment recommendations (give prudent advice);  never put our financial interests ahead of yours when making recommendations (give loyal advice);  avoid misleading statements about conflicts of interest, fees, and investments;  follow policies and procedures designed to ensure that we give advice that is in your best interests;  charge no more than a reasonable fee for our services; and  give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in your employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. As an alternative to providing you with a rollover recommendation, we may instead take an entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1. Under this approach, our role will be limited only to providing you with general educational materials regarding the pros and cons of rollover transactions. We will make no recommendation to you regarding the prospective rollover of your assets 12  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE and you are advised to speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this educational approach, we may provide you with materials discussing some or all of the following topics: the general pros and cons of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement withdrawals on retirement income; the investment options available inside your Plan Account; and high level discussion of general investment concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide you with questionnaires and/or interactive investment materials that may provide a means for you to independently determine your future retirement income needs and to assess the impact of different asset allocations on your retirement income. You will make the final rollover decision. Item 6 – Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees for our services or engage in side-by-side management of client accounts. EIC and/or individuals associated with our firm may manage accounts which belong either to themselves, individually, or to their family or their affiliates (collectively, “Proprietary Accounts”) while simultaneously managing client accounts. It is possible that orders for Proprietary Accounts may be entered simultaneously (but typically only as part of a block trade) with or opposite to orders for client accounts, pursuant to, for instance, a neutral allocation system, a different trading strategy, or trading at a different risk level. The management of any Proprietary Account is subject to our Code of Ethics and the duty of our firm and its personnel to exercise good faith and fairness in all matters affecting client accounts. Item 7 – Types of Clients We typically provide investment advice to individuals, high net worth individuals, pension and profit sharing plans and their participants, trusts, partnerships, corporations, and other business entities. Because each client is unique, they must be willing to be involved in the planning and ongoing processes of our management of their account. Such involvement does not have to be time consuming, however we want our clients to remain informed and have a sense of security about their investments. We do not require any minimum account size to engage our services. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A Our Methods of Analysis and Investment Strategies The types of investments we typically recommend are discussed in Item 4 of this brochure. We may use some or all of the following methods of analysis in providing investment advice to you: 13  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Fundamental Analysis. In using fundamental analysis, we attempt to determine the intrinsic value of target securities through a review of, among other things, company specific financial disclosures, the strength and track record of management personnel, industry sector financial health, and at a macro level, the overall direction of the economy at large. We use this information as a basis to determine if such securities are underpriced or overpriced relative to current market prices and then to make a buy or sell recommendation to you. Relying on this type of analysis leaves open the risk that the price of a security may move along with the overall direction of the market, irrespective of the economic and financial factors which may have indicated that an opposite movement would have been expected. The main sources of information we rely upon when researching and analyzing securities using fundamental analysis include research materials prepared by others, annual reports, corporate rating services, prospectuses, and company press releases. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company or security. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of overall market movement. Asset Allocation. Rather than focusing on selecting the particular securities or other assets to invest for your account, we attempt to identify an appropriate ratio of various types of investments (for example, stocks, fixed income, and cash) suitable to investment goals, time horizon, and risk tolerance. A risk of asset allocation is that you may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate to meet with your investment goals. Mutual Fund and ETF Selection and Analysis. We evaluate and select mutual funds and/or ETFs for your account based on several factors which may include, without limitation, (1) the experience and track record of the underlying portfolio manager(s), (2) the performance of the mutual fund or ETF over time and through various market conditions; (3) expected market conditions that might impact the underlying holdings of the mutual fund or ETF or applicable market sector; and (4) whether and to what extent the underlying holdings of the mutual fund or ETF overlap with other assets held in your account. We also monitor the mutual fund or ETF in an attempt to determine if the fund is continuing to follow its stated investment strategy. A risk of mutual funds and ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A fund manager’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of the fund are determined by independent fund managers and may change overtime without advance warning, creating the potential for overlap with other 14  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. TPMM Selection and Analysis. This is the analysis of the experience, investment philosophies, and past performance of independent TPMMs in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Key factors we consider when evaluating TPMMs are their investment process and philosophy, risk management methods and procedures, historical performance, investment strategy and style, fees and operating expenses, assets under management and number or clients, and tax‐efficiencies. Our evaluation also incorporates both qualitative and quantitative fundamental analysis to validate and confirm a TPMM’s investment style and skill, as well as to compare them to other managers of similar style. We may utilize various research databases, proprietary models, financial periodicals, prospectuses and filings with the SEC, industry contacts and manager data, among other items, as part of the research process. Monitoring the TPMM’s underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment completes the analysis. As part of the due-diligence process, the TPMM’s compliance and business enterprise risks may be surveyed and reviewed. Methods of analysis such as charting, fundamental, technical, or cyclical analysis may be used by the TPMMs we help select or recommend to clients. Please refer to the disclosure brochure of the TPMM for more information. We typically use the following investment strategies in managing client accounts: Long-term Purchases. We may recommend a long term, passive, “buy and hold” approach to investing client assets. In this type of investment strategy, we suggest the purchase of securities with the idea of holding them in a portfolio for a year or longer. Typically, we employ this strategy when (1) we believe the securities to be currently undervalued, and/or (2) we want the portfolio to have exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the recommendation to sell. Short-term purchases. When utilizing this strategy, we may suggest the purchase of securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we recommend for purchase. 15  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Trading. A trading program rather than an investment program may not be suitable for all clients. “Trading” refers to purchasing and selling securities on a short-term basis with the intention of achieving quick profits. Trading is, by definition, a form of speculating as distinguished from investing. A trading strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. For these reasons, we will use trading strategies only in client accounts we believe will benefit from the strategy and which can assume the increased risk of loss. B We use our best judgment and good faith efforts in rendering investment advice to our clients. We cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Not every investment recommendation we make will be profitable. Investing in securities involves risk of loss that clients should be prepared to bear. You assume all market risk involved in the investment of your account assets. Investments are subject to various market, currency, economic, political, and business risks. Except as may otherwise be provided by law, we are not liable to you for: • any loss that you may suffer by reason of any investment recommendation we made with that degree of care, skill, and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; or • any independent act or failure to act by a Custodian of your account(s). C Summary of Investment Risks. While all investing involves risks and losses can and will occur, our advisory services generally recommend a broad and diversified allocation of mutual funds and other securities intended to reduce the specific risks associated with a concentrated or undiversified portfolio. Nonetheless, you should consider the following high-level summary of investment risks. This list is not intended to be an exhaustive description of all risks you may encounter in engaging our firm for advisory services. We encourage you to inquire with us frequently about the risks related to any investments in your account. 16  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. As with any investment manager that invests in common stocks and other equity securities, our investment recommendations are subject to market risk—the possibility that securities prices will decline over short or extended periods of time. As a result, the value of your account(s) will fluctuate with the market, and you could lose money over short or long periods of time. You should recognize whenever you determine to invest in the securities markets your entire investment is at risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments. Economic Risk. The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk. Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Market Risk. The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. TPMM Risks. A TPMM’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of your TPMM account(s) are determined by the TPMM directly and may change overtime without advance warning to our firm, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a TPMM may deviate from the stated investment mandate or strategy of the account, which could make the holding(s) less suitable for the client’s portfolio. We do not control any TPMM’s daily 17  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE business and compliance operations, and thus our firm may be unaware of any lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Risks Related to Analysis Methods. Our analysis of securities relies in part on the assumption that the issuers whose securities we recommend for purchase and sale, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Securities Transactions at the Direction of Clients. Irrespective of whether you engage us on a discretionary or non-discretionary basis, depending on your arrangement with the Custodian of your assets, you may maintain the concurrent ability to direct transactions within your account held at the Custodian. We are not responsible for the consequences of your self-directed investment decisions. Interim Changes in Client Risk Tolerance and Financial Outlook. The particular investments recommended by our firm are based solely upon the investment objectives and financial circumstances disclosed to us by the client. While we strive to meet with clients at regular intervals (at least annually, unless otherwise agreed, either in person, telephonically, or by electronic means) to discuss any changes in the client’s financial circumstances, the lack of constant and continuous communication presents a risk insofar as your liquidity, net worth, risk tolerance and/or investment goals could change abruptly, with no advance notice to our firm, resulting in a mis-aligned investment portfolio and the potential for losses or other negative financial consequences. It is your continuing and exclusive responsibility to give us complete information and to notify us of any changes in your financial circumstances, income level, investment goals or employment status. We encourage you to contact us regularly and promptly to discuss any such changes. Item 9 – Disciplinary Information EIC is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. No principal or person associated with our firm has any information to disclose which is applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations A Registration as a Broker-Dealer or Registered Representative of a Broker-Dealer. Neither EIC nor its associated persons are or intend to become registered as a broker-dealer or registered representative of a broker-dealer. B Futures or Commodities Registration. Neither EIC nor its associated persons are or intend to become registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of any of the foregoing. 18  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE C Material Relationships. Except as outlined in Item 5E with respect to the licensure of certain of our associated persons as independent insurance agents and as outlined in Item 12A with respect to our receipt of certain benefits as a result of recommending Custodians to clients, EIC does not have any relationships, activities, affiliations, or arrangements that create a material conflict of interest with its clients. D Recommendation of Other Advisors. While EIC may recommend or allocate a client’s asset to certain TPMMs, we do not receive any additional compensation, either directly or indirectly, in connection with such recommendations or allocations. We do not act as a solicitor or promoter for any TPMM. Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading A Our Code of Ethics. We subscribe to an ethical and high standard of conduct in all our business activity in order to fulfill the fiduciary duty we owe to our clients. Included in these ethical obligations is the duty to put our client’s interests ahead of our own along with duties of loyalty, fairness, and good faith towards our clients. We disclose to clients material conflicts of interest which could reasonably be expected to impair our rendering of unbiased and objective advice. EIC has a Code of Ethics (“Code”) which all employees are required to follow. The Code outlines proper conduct related to all services provided to clients and will be made available to you, free of charge, upon request by contacting us at the phone number listed on the cover page of this brochure. Prompt reporting of internal violations is mandatory. EIC’s Chief Compliance Officer, Cal R. Easley, Jr., evaluates employee performance to ensure compliance with our Code. Designed to prevent conflicts of interest between the financial interests of clients and the interests of the firm and its staff, the Code requires, among other procedures, our “access persons” to report their personal securities transactions quarterly and to report all securities positions in which they have a beneficial interest at least annually. These reporting requirements allow supervisors at the firm to determine whether to allow or prohibit certain employee securities purchases and sales based on transactions made, or anticipated to be made, in the same securities which may be purchased or sold for client accounts. The Code is required to be reviewed annually and updated as necessary. B-D Material/Proprietary Interests in Securities Recommended to Clients. Our firm and individuals associated with our firm do not have any proprietary or material interests in or any role in the management of any companies or investments that we recommend to our clients. Personal Trading; Participation or Interest in Client Transactions. As described in Item 6 of this firm brochure, EIC and/or individuals associated with our firm may manage Proprietary Accounts. Proprietary Accounts may buy and sell some the same securities as we buy or sell for client accounts. This practice creates an actual conflict of interest with 19  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE our clients insofar as our firm or individuals associated with our firm may have a financial incentive to trade in securities for Proprietary Accounts in advance of or opposite to transactions in the same securities for client accounts. To address this conflict, our policy is that, assuming the purchase or sale is otherwise appropriate for the subject client accounts, we will purchase or sell securities for our clients’ accounts, as the case may be, before purchasing or selling any of the same securities for any Proprietary Accounts. In some cases we may buy or sell securities for our own account for reasons not related to the strategies adopted by our clients. The only exception to this general rule is where our Proprietary Accounts may participate in an aggregate (“block”) trade simultaneously with client accounts. In summary, our practice of buying and selling for Proprietary Accounts the same securities that we buy or sell for client accounts is restricted by the following controls:  We are required to uphold our fiduciary duty to our clients;  We are prohibited from misusing information about our clients’ securities holdings or transactions to gain any undue advantage for ourselves or others;  We are prohibited from buying or selling any security that we are currently recommending for client accounts, unless we participate in an aggregated trade with clients or we place our orders after client orders have been executed; and  We are required to periodically report our securities holdings and transactions to the firm’s Chief Compliance Officer, who must review those reports for improper trades. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interest of all the accounts we advise. We will disclose to advisory clients any material conflict of interest relating to us, our representatives, or any of our employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Item 12 – Brokerage Practices A Recommendation of Broker-Dealers. Clients maintain the discretion to select the Custodian(s) and broker-dealer(s) to be used for custody of their assets and for the execution of transactions within their account(s). Clients independently engage the Custodian(s) and broker-dealers of their desire by executing the appropriate account opening documentation of the selected firm(s), and in doing so, authorize our firm to direct 20  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE the execution of transactions for the client’s account through the selected Custodian and broker-dealer firm(s). We typically recommend that clients participating in the EIC Wrap Fee Program engage the brokerage and custodial services of Charles Schwab & Co., Inc., 3000 Schwab Way, Westlake, Texas 76262 (“Schwab”), an independent SEC-registered broker-dealer and Member FINRA/SIPC. Conflicts of interest associated with our recommendation of Schwab are described below as well as in Item 14 of this brochure. You should consider these conflicts of interest when selecting your Custodian. EIC is independently owned and operated and not affiliated with Schwab. Schwab does not monitor or control the activities of our firm or its personnel. If selected as your Custodian, Schwab will act solely as the Custodian of your assets and the executing broker for transactions in your account, and not as your investment advisor. Schwab will hold your assets in a brokerage account or accounts and buy and sell securities and execute other transactions when instructed to do so by you or EIC. We do not have the discretion to determine the commission rates at which transactions are to be affected for your account and we may recommend that clients engage different Custodians and executing brokers in the future. Best Execution. In recommending broker-dealers, we have an obligation to seek the “best execution” of transactions for client accounts. This duty requires us to seek to execute securities transactions for clients such that the total costs or proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the recommended broker-dealer’s services. Some of the factors we may consider when evaluating a broker-dealer for best execution include, without limitation, the broker- dealer’s execution and custodial capabilities, commission rates, financial responsibility, responsiveness and customer service, research services/ancillary brokerage services provided, and other factors that we consider relevant. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for specific account transactions. With this in consideration, we will continue to recommend that clients engage Schwab until their services do not result, in our opinion, in best execution of client transactions. Directed Brokerage. If the client selects a custodian other than Schwab for custody and execution of transactions (i.e., client directed brokerage), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those experienced by clients who elect to utilize our recommended Custodian. For example, in a directed brokerage account, you may pay higher brokerage commissions and/or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using our recommended Custodians. We reserve the right 21  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE to reject your request to use a particular Custodian other than Schwab if such selection would frustrate our management of your account, or for any other reason. Soft Dollars. Broker-dealer and Custodian firms may provide us with certain brokerage and research products and services that qualify as “brokerage or research services” under Section 28(e) of the Securities Exchange Act of 1934 (“Exchange Act”). This is commonly referred to as a “soft dollar” arrangement. These research products and/or services will assist us in our investment decision making process. Such research generally will be used to service all of our client accounts, but brokerage charges paid by the client may be used to pay for research that is not used in managing that specific client’s account. Your account may pay to a broker-dealer a charge greater than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the charge is reasonable in relation to the value of the brokerage and research services received. Benefits Received from Schwab. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide our firm and clients with access to Schwab’s institutional brokerage platform – trading, custody, reporting, and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge as long as our firm keeps a specific amount of client assets in accounts at Schwab. If our firm has less than this amount of client assets at Schwab, our firm may be charged quarterly service fees. Here is a more detailed description of Schwab’s support services: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provides access to client account data (such as duplicate trade confirmations and account statements);  facilitates trade execution and allocation of aggregated trade orders for multiple client accounts;  provides pricing and other market data; 22  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE  facilitates payment of our fees from our clients’ accounts; and  assists with back-office functions, recordkeeping, and client reporting. Schwab also offers other services intended to help manage and further develop our business enterprise. These services include:  educational conferences and events;  technology, compliance, legal, and business consulting;  publications and conferences on practice management and business succession; and  access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third-party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Clients are advised that as a result of receiving the services and benefits discussed above for no additional cost (or discounted cost), we may have an incentive to continue to recommend, use, or expand our use of Schwab’s custodial and execution services. Our firm examined this potential conflict of interest when we chose to enter into our relationship with Schwab and we have determined that this relationship is in the best interests of our clients and satisfies our client obligations, including our duty to seek best execution. Except as described above in this Item 12, we do not receive any compensation or incentive for recommending that you engage any Custodian or broker-dealer for trade execution or custodial services. We do not receive client referrals in exchange for directing client transactions to any Custodian or broker-dealer. B Trade Aggregation. Our firm aggregates (combines) orders for client accounts. Please see Item 16 below for information on the conditions under which we may include your account in a “block trade” and the manner in which we price and allocate securities purchased or sold in this manner. Item 13 – Review of Accounts A Account Review Policy. Portfolio management and pension consulting accounts are generally reviewed by Cal R. Easley, Jr., who is responsible for overseeing all investment advisory activities for the firm. However, individuals conducting reviews may vary from time-to-time, as personnel join or leave our firm. The frequency of reviews is determined based on each client’s investment objectives and investment profile. Accounts are generally reviewed quarterly, but in any event, no less than annually. 23  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE Annual retainer financial planning and consulting clients receive comprehensive, written financial plans that are formally reviewed and updated annually. Our investment advisor representatives conduct these reviews in person, over the phone and/or via the internet. One-time financial planning and consulting client do not receive updates or account reviews following delivery of our written investment recommendations unless the client specifically requests such review, EIC agrees to the additional review in writing, and the client pays an additional advisory fee. B More Frequent Account Reviews. More frequent reviews of portfolio management and pension consulting accounts may be triggered by a change in client’s investment objectives; risk/return profile; tax considerations; contributions and/or withdrawals; large sales or purchases; security specific events; or changes in the economy more generally. C Reporting to Clients. Clients will receive standard account statements and trade confirmations from their Custodian typically monthly, but no less than quarterly. We will provide you with independently prepared written reports on a quarterly basis and additional reports as you may reasonably request. Reports we provide to you will contain relevant account and/or market-related information such as an inventory of account holdings and account performance, as examples. Item 14 – Client Referrals and Other Compensation A As referenced in Item 12 above, Schwab provides services and products to us without cost or at a discount that we may use to service some or all of our client accounts. We may enter into similar arrangements with other broker-dealers and Custodians in the future. As part of its fiduciary duties to clients, EIC endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by our firm and/or our associated persons in and of itself creates a potential conflict of interest and may indirectly influence our choice to recommend that clients engage Schwab for brokerage and custodial services. B We have no arrangements, written or oral, in which we compensate others or are compensated for client referrals. Item 15 – Custody With the exception of our ability to directly debit fees as outlined in Item 5, we do not hold, directly or indirectly, client funds or securities, or have any authority to obtain possession of them. All client assets are held at the qualified Custodian, usually Schwab. We currently recommend Schwab to act as your qualified Custodian to hold your assets and execute securities transactions for your account. We shall have no liability to you for any loss or other harm to any property in your account held by the Custodian, including any harm to any property in the account resulting from the insolvency of the Custodian (including, without limitation, Schwab) or any acts of the agents or employees of the Custodian, whether or not the full amount of such loss is covered by the SIPC or any other 24  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE insurance which may be carried by the Custodian. Clients understand that the SIPC provides only limited protection for the loss of property held by a Custodian. Item 16 – Investment Discretion Investment Discretion. When you engage us for portfolio management services you will typically be required to grant us ongoing and continuous discretionary authority to execute our investment recommendations within your account held at the Custodian without obtaining your prior approval for each specific transaction. In a discretionary arrangement, you authorize us to purchase and sell securities and instruments in your account(s), arrange for delivery and payment in connection with the foregoing, engage and terminate TPMM relationships, and act on your behalf in all matters necessary or incidental to the handling of the account, including monitoring of your assets. Except for direct deductions of its advisory fees, EIC will not be permitted to initiate transfers of funds in or out of client accounts. Our discretionary management of your account will be conducted in strict accordance with your investment policy statement (or similar document used to establish each client’s objectives and suitability). We may agree to provide portfolio management services on a non-discretionary basis, upon client request. Order Aggregation. We may aggregate client orders, so long as it is done for purposes of achieving best execution, and so long as no client is systematically advantaged or disadvantaged. Before aggregating client orders, we document the participating accounts and the allocation instructions. We submit allocation instructions to the broker-dealer before the market closes on the day of the order. We allocate aggregated orders to client accounts at the average price obtained. We allocate partially filled orders pro-rata based on the size of the order placed by each account. If we judge that we cannot or should not allocate a partially filled order pro rata (e.g., if the quantity of securities obtained is too small or would not have a material impact if distributed among each account), then we apply the following procedures:  we allocate the order to client accounts only (i.e., no employees that participated in the order may receive any allocation); and  we document our allocation decision. Trade Errors. We have adopted the following policies and procedures to address the potential of trade errors:  we will document and promptly correct all trade errors;  we will not pass along to our clients any costs of correcting trade errors;  subject to the terms and conditions of the client’s agreement with the Custodian, our policy is to allow clients to keep any gains resulting from trade errors;  we will promptly notify a client if a trade error results in reimbursement to the client; 25  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A – FIRM BROCHURE  we will not use a client’s account to correct a trade error unless the trade was originally intended for that client’s account; and  we will not use soft dollars to correct trade errors. Item 17 – Voting Client Securities A We will not vote proxies on behalf of clients and will not provide advice to clients on how the client should vote. B We do not have or accept authority to vote client securities. Most clients will receive proxies and other solicitations directly from the Custodian or transfer agent. If any proxy materials are received on behalf of a client, they will be sent directly to the client or a designated representative of the client, who is responsible to vote the proxy. Item 18 – Financial Information A EIC does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B Advisors who have discretionary authority over client accounts, custody of client assets, or who require or solicit pre-payment of more than $1,200 in fee per client, six months or more in advance, are required to disclose any financial condition that is reasonably likely to impair their ability to meet contractual commitments to clients. EIC maintains discretionary authority over client funds and securities. We have no financial commitments that would impair our ability to meet contractual and fiduciary commitments to our clients. C Neither EIC nor any principal of our firm has been the subject of a bankruptcy petition at any time in the past. 26 

EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 1 – Cover Page WRAP FEE BROCHURE – FORM ADV PART 2A APPENDIX 1 EASLEY INVESTMENT CONSULTANTS INC. 1050 Northpark Drive Suite D Ridgeland, MS 39157 Phone: (601) 992-4101 Website: www.easleyinvest.co January 30, 2026 This wrap fee program brochure (“Wrap Fee Brochure”) provides information about the qualifications and business practices of Easley Investment Consultants Inc. If you have any questions about the contents of this brochure, please contact us at (601) 992-4101. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Please note that the use of the term “registered investment advisor” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this brochure and any brochure supplements (“brochure supplements”) for more information on the qualifications of our firm and our associates. Additional information about Easley Investment Consultants Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Easley Investment Consultants Inc. is 307258. 1  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 2 – Material Changes We have made the following material changes to this firm brochure since our last filing dated March 18, 2025: Our new office address is: 1050 Northpark Drive, Suite D Ridgeland, MS 39157 We will ensure that all current clients receive a Summary of Material Changes to this and subsequent Wrap Fee Brochures within 120 days of the close of our business’ fiscal year. A Summary of Material Changes is also included within our Wrap Fee Brochure available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Easley Investment Consultants Inc. is set forth on the cover page of this Wrap Fee Brochure. Clients will further be provided with disclosure about material changes affecting our firm or a brochure as may become necessary or appropriate at any time, without charge. Currently, copies of our firm brochures may be requested, free of charge, by contacting Cal R. Easley, Jr. at the telephone number reflected on the cover page of this Wrap Fee Brochure. 2  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 3 – Table of Contents Page Item 1 – Cover Page ........................................................................................................................ 1 Item 2 – Material Changes .............................................................................................................. 2 Item 3 – Table of Contents.............................................................................................................. 3 Item 4 – Services, Fees, and Compensation ................................................................................... 4 Item 5 – Account Requirements and Types of Clients ................................................................. 13 Item 6 – Portfolio Manager Selection and Evaluation .................................................................. 13 Item 7 – Client Information Provided to Portfolio Managers ....................................................... 19 Item 8 – Client Contact with Portfolio Managers ......................................................................... 19 Item 9 – Additional Information ................................................................................................... 20 3  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 4 – Services, Fees, and Compensation A Description of Our Firm, Portfolio Management Services, and Wrap Fees Easley Investment Consultants Inc. is a Mississippi corporation founded in 2018 by Carl “Cal” R. Easley, Jr. and Carl R. Easley. Effective as of August 31, 2023, Cal R. Easley, Jr. is the sole shareholder of the firm. We are registered as an investment advisor with the SEC and our principal offices are located in Ridgeland, Mississippi. We are the sponsor and portfolio manager of the EIC Wrap Fee Program. This program allows you to pay a single fee that covers the costs of EIC’s advisory services, in addition to trade execution, custody1, and other standard brokerage services and costs2 (our “Wrap Fee”). EIC’s portfolio management services are provided to clients exclusively as part of the EIC Wrap Fee Program. The information contained in this Wrap Fee Brochure describes our investment advisory services, practices, and fees as they relate to your engagement of EIC for portfolio management services under the EIC Wrap Fee Program. As used throughout this Wrap Fee Brochure, the words “we,” “our,” “firm,” “EIC” and “us” refer to Easley Investment Consultants Inc., and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. EIC offers portfolio management services that are tailored to the investment objectives and financial circumstances of our clients. The client will deposit their assets at an independent custodial firm (the “Custodian”), typically a licensed broker-dealer, and grant us limited authority to buy and sell securities either on a discretionary or non-discretionary basis. The full scope of our authority regarding the client’s account will be set forth in a written advisory agreement entered with the client. We act as your fiduciary, responsible for the management of your investment account(s) held at the Custodian, where assets are held in your name. Our portfolio management services are typically offered on a discretionary basis only, however, we may agree to provide such services on a non-discretionary basis, upon client request.  Where you grant us discretionary authority, you authorize our firm and our investment advisor representatives to implement our investment recommendations 1 Custodial fees may not be covered where the client elects to utilize a Custodian other than those recommended by EIC. 2 The specific brokerage costs covered within our Wrap Fee vary depending on the Custodian selected by the client. For example, where the client elects to engage Charles Schwab & Co., Inc. as the Custodian for the client’s wrap fee account, the costs of markups, markdowns, and spreads are not covered by EIC’s Wrap Fee, and the client will bear such costs separately. Clients are urged to review the account opening documentation of their selected Custodian for full details on any costs and fees that may be excluded from EIC’s Wrap Fee. 4  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE directly within your account held at the Custodian without obtaining your specific consent prior to each transaction. in whole or in part. We will only implement our  Where we agree to manage your account on a non-discretionary basis, we will provide you with investment recommendations which you are free to accept or investment reject, recommendations within your account held at the Custodian upon your request and with your prior approval. Clients always have the ability to impose reasonable restrictions on our management of their account(s), including the ability to instruct us not to purchase certain specific securities, industry sectors, and/or asset classes. All such requests must be provided to us in writing. While we generally attempt to accommodate such restrictions, we reserve the right to reject such investment limitations if they would frustrate our management of your account, or for any other reason, in our sole discretion. We will notify you promptly if we are unable to honor any of your investment restrictions or limitations. A description of our portfolio management services and applicable Wrap Fee is as follows: Portfolio Management Services. Our firm offers ongoing and continuous portfolio management services that are uniquely tailored to your financial circumstances. Through periodic consultations with you, we will gather information regarding your financial goals, investment objectives, tolerance for risk, and the time horizon for your investments. The information we typically request in this process will include your current and expected income level, tax information, investment experience, current and expected cash needs, current portfolio construction/asset allocation, and risk tolerance level, among other items. Based on our analysis of these factors, we will prepare an investment policy statement (or similar documentation used to establish your investment objectives and suitability) outlining parameters for our management of your account(s). We will then implement an initial investment strategy and portfolio intended to align with your unique financial situation and goals. Client portfolios are typically constructed utilizing a diversified combination of mutual funds, exchange traded funds (“ETFs”), individual bonds, stocks, and other instruments, as may be appropriate for the individual client. In some instances, we may also engage certain independent third party money managers (“TPMMs”) to directly manage all or a portion of your account on a discretionary basis. You will be provided with a copy of each recommended TPMM’s Form ADV Part 2 firm brochure (or the equivalent) prior to the allocation of your assets to any TPMM managed account(s) (each a “TPMM Account”). Where a TPMM is engaged, we will continue to act as your fiduciary and a “co-advisor” to your TPMM Accounts. We will determine the suitability of the TPMM’s investment program, communicate any changes in your investment profile to the TPMM, and recommend changes in your TPMM allocations as we believe to be in your best interests. The TPMM shall be responsible for all portfolio management and trading functions related to your TPMM Accounts. 5  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Following implementation of your initial investment portfolio, we will monitor the performance of your investments (including any held in TPMM Accounts) and implement changes within your account as needed or appropriate, in consideration of current economic conditions, our market opinions and assumptions, and your individual financial circumstances and goals. It is your ongoing responsibility to advise us in writing of any material changes to your financial circumstances. At our discretion, portfolio management clients may also receive complimentary financial planning services. These services are described in detail in our firm brochure. If you did not receive a copy of our firm brochure, we will provide one to you, free of charge, by contacting us at the telephone number on the cover page of this Wrap Fee Brochure. Wrap Fees. EIC charges annual Wrap Fees which are calculated as a percentage of the market value of your account in accordance with the below fee schedule. Our Wrap Fees may be negotiated on a per client basis, and some clients may pay fees at a higher or lower rate than those stated below. For purposes of our billing and fee schedule, we may elect, in our sole discretion, to combine the value of all of your related accounts (including any accounts held individually or jointly by you, your spouse, your minor children, or your business, including retirement accounts) for purposes of determining the applicable fee level. These “household” account values would be combined and assessed the same fee rates under our fee schedules below. Wrap Fee Schedule – Discretionary Accounts Assets Under Management $0 – $500,000 $500,001 - $2,000,000 $2,000,001 - $5,000,000 $5,000,001 and above Annualized Fee 1.25% 1.00% 0.75% Negotiable Wrap Fee Schedule – Non-Discretionary Accounts Assets Under Management All Accounts Annualized Fee 0.50% Our Wrap Fee covers the costs of advisory services, trade execution, custody, and certain other standard brokerage services and costs generated in connection with our management of your account held at the Custodian. Our Wrap Fees are calculated and payable monthly, in advance, based on the value of your account (including any cash balances) at the end of the prior billing period as calculated by the Custodian of your account. Wrap Fees are charged on a blended basis (e.g., a discretionary portfolio management account valued at $600,000 will pay a 1.25% per 6  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE annum fee on the first $500,000 of assets and a 1.00% per annum fee on the balance). The initial advisory fee applicable to your account will be based on the opening value of your account as of the date on which we begin to provide services and shall be pro-rated for partial periods at the beginning or end of our engagement. Clients may make additions or withdrawals from their account at any time, however, Wrap Fees for funds added during a billing period will be charged the following month, without pro-ration. Clients should note that some or all of the investments in their account may be intended as long-term investments and withdrawals of cash and premature liquidations of securities positions may impair the achievement of your investment objectives. All security pricing is done by the Custodian that will maintain your account(s) titled in your name. We will rely on this pricing in determining the Wrap Fee attributable to your account(s). The Custodian may use various pricing services such as Reuters and Standard & Poor’s to price securities held in your account. For actively traded securities, these services use the actual last reported sale price. For less actively traded securities such as bonds, these services will use the appropriate valuation methodology to determine the value of the security. Our Wrap Fees are directly deducted from your account held at the Custodian upon your written approval of such arrangement and our periodic submission to the Custodian of a written invoice reflecting the amount of advisory fees to be charged to your account. Your authorization for direct fee deduction is set forth in our written advisory agreement and/or the account opening documents of your Custodian. We will liquidate money market shares or use cash balances from your account to pay our Wrap Fee, however, if money market shares or cash value are not available other investments may be liquidated. Please note that unexpected or premature liquidation of investments to pay our advisory fees may impair the performance of your account. We do not offer direct paper or electronic invoicing of our Wrap Fees. The Custodian will independently send an account statement to you, typically monthly, but no less than quarterly, identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid to us. We encourage you to review our reports and the Custodian’s account statements carefully and promptly upon receipt. If you believe we have miscalculated our fees or if there is any other issue with your account, you should contact us immediately at the phone number listed on the cover page of this Wrap Fee Brochure. Portfolio management services may be terminated at any time by either party, within five (5) business days of entering an advisory agreement, without penalty. Thereafter, our portfolio management services may be terminated by either party on thirty (30) days’ written notice to the non-terminating party. In the event of termination, we shall be compensated by a pro-rated advisory fee based on the number of days in the terminating 7  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE period during which services were provided. A refund of any excess pre-paid advisory fees shall be returned to you promptly following termination of our services. While we believe our Wrap Fees to be reasonable for the services provided, lower fees for comparable services may be available from other sources. Our fees are negotiable and we may enter into fee arrangements that are materially different than those described above with certain clients. Any change in fees applicable to your account (outside of normal movement between fee tiers) will not go into effect unless we provide you with thirty (30) days’ notice of any proposed change and the opportunity to terminate our services. Broker-Dealer Selection and Recommendation. Clients maintain the discretion to select the Custodian(s) and broker-dealer(s) to be used for custody of their assets and for the execution of transactions within their portfolio management account(s). Clients independently engage the Custodian(s) and broker-dealers of their desire by executing the appropriate account opening documentation of the selected firm(s), and in doing so, authorize our firm to direct the execution of transactions for the client’s account through the selected Custodian and broker-dealer firm(s). We typically recommend that clients participating in the EIC Wrap Fee Program engage the brokerage and custodial services of Charles Schwab & Co., Inc., 3000 Schwab Way, Westlake, Texas 76262 (“Schwab”), an independent SEC-registered broker-dealer and Member FINRA/SIPC. EIC is independently owned and operated and not affiliated with Schwab. Schwab does not monitor or control the activities of our firm or its personnel. If selected as your Custodian, Schwab will act solely as the Custodian of your assets and the executing broker for transactions in your account, and not as your investment advisor. Schwab will hold your assets in a brokerage account or accounts and buy and sell securities and execute other transactions when instructed to do so by you or EIC. We do not have the discretion to determine the commission rates at which transactions are to be affected for your account and we may recommend that clients engage different Custodians and executing brokers in the future. In recommending broker-dealers, we have an obligation to seek the “best execution” of transactions in your account. This duty requires that we seek to execute securities transactions for clients such that the total costs or proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the recommended broker-dealer’s services. Some of the factors we may consider when evaluating a broker-dealer for best execution include, without limitation, the broker- dealer’s execution and custodial capabilities, commission rates, financial responsibility, responsiveness and customer service, research services/ancillary brokerage services provided, and other factors that we consider relevant. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for specific account transactions. With this in consideration, our 8  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE firm will continue to recommend that clients engage Schwab until their services do not result, in our opinion, in best execution of client transactions. If the client selects a Custodian other than Schwab for execution of transactions (i.e., directed brokerage), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those experienced by clients who elect to utilize our recommended Custodian. For example, in a directed brokerage account, you may pay higher brokerage commissions and/or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using our recommended Custodians. We reserve the right to reject your request to use a particular Custodian other than Schwab if such selection would frustrate our management of your account, or for any other reason. Clients are advised that we receive certain benefits (typically in the form of access to technology or services that assist us in the management and administration of client accounts and/or other free or discounted services or products) in connection with our recommendation of Schwab’s brokerage and custodial services to clients. For a full description of our brokerage practices, including the benefits we receive from Schwab and the related conflicts of interest, please see Item 12 in our firm brochure. Certain Conflicts of Interest Related to Wrap Fees B As described above, the costs of advisory services, trade execution, custody, and certain other standard brokerage services and costs generated in connection with our management of your account held at the Custodian will be absorbed by and are included within the Wrap Fee paid to our firm. EIC will retain the remaining amount of the Wrap Fee you pay for our advisory services after our payment of the brokerage commissions and certain other costs generated in your account. This creates an incentive for us to trade your account less frequently and/or to invest your account in assets that may be subject to waived or reduced brokerage commissions (if available), resulting in EIC retaining a greater portion of the Wrap Fee paid by the client. Additionally, you should consider that the Custodian we typically recommend to clients enrolled in our wrap fee program, Schwab, does not charge commissions (or transaction fees) for certain online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. To address the foregoing conflicts, we manage your account in strict accordance with your investment policy statement and our ongoing fiduciary duty to you. Since the Wrap Fee associated with your account covers the costs of advisory services, trade execution, custody, and certain other standard brokerage services and costs incurred in your account, it may represent a premium relative to what you might otherwise pay in a similar investment program operated as a non-wrap fee arrangement (i.e., where our 9  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE advisory fees and the separate costs of transaction-based charges and commissions, custodial fees, and other related costs are each billed separately to you) (a “Non-Wrap Fee”). Specifically, you should consider the following:  The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees.  In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Fee and any other costs associated with participating in the EIC Wrap Fee Program with the amounts that would be charged by other advisors, broker-dealers, and Custodians, for advisory fees, brokerage, and execution costs, and custodial services comparable to those provided under the EIC Wrap Fee Program. Please consider that, depending upon the level of our Wrap Fee, the amount of portfolio activity in your account, the value of the services that we provide to you, and other factors, the Wrap Fee we charge you may or may not exceed the aggregate cost of the advisory and brokerage services you will receive if they were to be provided and charged to you separately. Stated differently, by participating in Wrap Fee arrangement, you may end up paying more or less than you would through a Non-Wrap Fee arrangement where a lower advisory fee is charged, but the brokerage commissions are passed directly to you by the broker. As a general matter, Wrap Fee arrangements are relatively less expensive for actively traded accounts. However, they may result in higher overall costs to the client in accounts that experience little trading activity. Accordingly, we encourage clients to discuss with EIC whether a wrap fee arrangement is appropriate for their account at the inception of the advisory relationship. C Additional Costs and Expenses Our Wrap Fee covers the combined costs of EIC’s investment advice and the costs of trade execution, custody, and certain other standard brokerage services and costs incurred in your account. Most portfolio management client accounts are expected (but not required) to engage the custodial and brokerage services of our recommended Custodian, Schwab. Where you select Schwab as your Custodian, you are advised that our Wrap Fee does not cover fees charged by other brokers for execution of trades that settle into the client’s Schwab account (i.e., “trade-away” fees), markups, markdowns, bid-ask spreads, and selling concessions, custody charges for non-publicly traded securities, margin interest charges (if applicable), electronic funds and wire transfer fees, transfer taxes, odd-lot differentials, and other similar fees and charges, which shall be paid separately by the 10  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE client. If you elect to use a Custodian other than Schwab, there may be material differences in the specific brokerage costs and charges that are covered within our Wrap Fee. As part of our portfolio management services, we may invest your account in mutual funds and/or ETFs. The Wrap Fee that you pay to our firm is separate and distinct from the internal management fees and other expenses that may be charged by mutual funds and/or ETFs to their shareholders, for which you will be separately responsible. We do not share in any portion of the foregoing additional fees and expenses. To fully understand the total costs you will incur by engaging our services, you should review the prospectus of each mutual fund, ETF, and/or TPMM advisory program in which you are invested and the contractual arrangement with the Custodian of your account. D No Compensation Paid For Referrals We do not pay any referral fees or additional compensation of any kind with respect to referrals of clients to our firm for portfolio management services offered under the EIC Wrap Fee program. Rollover Recommendations As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee-based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests ahead of yours. Under this special rule’s provisions, we must:  meet a professional standard of care when making investment recommendations (give prudent advice); 11  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE  never put our financial interests ahead of yours when making recommendations (give loyal advice);  avoid misleading statements about conflicts of interest, fees, and investments;  follow policies and procedures designed to ensure that we give advice that is in your best interests;  charge no more than a reasonable fee for our services; and  give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in your employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. As an alternative to providing you with a rollover recommendation, we may instead take an entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1. Under this approach, our role will be limited only to providing you with general educational materials regarding the pros and cons of rollover transactions. We will make no recommendation to you regarding the prospective rollover of your assets and you are advised to speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this educational approach, we may provide you with materials discussing some or all of the following topics: the general pros and cons of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement withdrawals on retirement income; the investment options available inside your Plan Account; and high level discussion of general investment concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide you with questionnaires and/or interactive investment materials that may provide a means for you to independently determine your future retirement income needs and to assess the impact of different asset allocations on your retirement income. You will make the final rollover decision. 12  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 5 – Account Requirements and Types of Clients We typically provide portfolio management services to high net worth individuals, pension and profit sharing plans and their participants, trusts, partnerships, corporations, and other business entities. Because each client is unique, they must be willing to be involved in the planning and ongoing processes of our management of their account. Such involvement does not have to be time consuming, however we want our clients to remain informed and have a sense of security about their investments. We do not require any minimum account size to engage our portfolio management services. There is no minimum Wrap Fee to engage us for portfolio management services. Item 6 – Portfolio Manager Selection and Evaluation A Selection and Review of Portfolio Managers All portfolio management services are typically managed, directed, and performed exclusively by EIC’s in-house portfolio managers. Our portfolio managers are registered as investment advisor representatives of our firm and are retained based on their demonstrated skill and experience in managing client portfolios. On occasion, our in-house portfolio managers may recommend that certain TPMMs be engaged to sub-advise all or a portion of your account. In recommending TPMMs to you, we may take into account a number of considerations, including, without limitation, the length of time the TPMM has been operating; the qualifications of the TPMM’s management and analytical team and their bench strength; whether the TPMM’s strategy fits your investment needs; the TPMM’s track record of executing well and consistently on their stated investment strategy; whether the TPMM’s reporting system is timely and user- friendly; and the TPMM’s commitment to customer service and problem resolution. Portfolio manager performances, including those of any TPMMs, are evaluated in light of generally accepted benchmarks and/or our expectation of their performance level within the client’s overall investment portfolio. We will consider replacing portfolio managers if they fail to meet the selected benchmark or otherwise fail to meet the expected level of performance we designate for your account. B Conflicts of Interest Related to Use of In-House Portfolio Managers You should be aware that because our in-house portfolio managers will manage your account, we have an incentive to evaluate their performance more favorably than we might otherwise if they were not affiliated with our firm. Likewise, because your portfolio manager is affiliated with our firm, we have a disincentive to terminate their services to your account or to take other negative action as a result of their failure to perform to our expectations. You should be further aware that our firm cannot actively monitor TPMMs’ conflicts of interest, daily trading activity, and other operational issues. 13  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE C Additional Disclosures Related to our Advisory Business; Performance-based Fees and Side-by-side Management; Methods of Analysis, Investment Strategies and Risk of Loss; and Voting of Client Securities We do not charge any performance-based fees for our services or engage in side-by-side management of accounts. While we do not recommend one particular type of investment or asset class over any other, we primarily advise our clients regarding investments in equity securities, mutual funds, ETFs, corporate debt securities, and variable products (life insurance and annuities). Depending on the client’s financial circumstances, our investment advice may also concern other instruments, including, without limitation, municipal securities, exchange traded notes, money market accounts, and U.S. government securities. We may also provide advice regarding investments held in the client’s portfolio at the inception of our advisory relationship or advice concerning other investment instruments specifically requested by the client. We may use some or all of the following methods of analysis in providing investment advice to you: Fundamental Analysis. In using fundamental analysis, we attempt to determine the intrinsic value of target securities through a review of, among other things, company specific financial disclosures, the strength and track record of management personnel, industry sector financial health, and at a macro level, the overall direction of the economy at large. We use this information as a basis to determine if such securities are underpriced or overpriced relative to current market prices and then to make a buy or sell recommendation to you. Relying on this type of analysis leaves open the risk that the price of a security may move along with the overall direction of the market, irrespective of the economic and financial factors which may have indicated that an opposite movement would have been expected. The main sources of information we rely upon when researching and analyzing securities using fundamental analysis include research materials prepared by others, annual reports, corporate rating services, prospectuses, and company press releases. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company or security. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of overall market movement. 14  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Asset Allocation. Rather than focusing on selecting the particular securities or other assets to invest for your account, we attempt to identify an appropriate ratio of various types of investments (for example, stocks, fixed income, and cash) suitable to investment goals, time horizon, and risk tolerance. A risk of asset allocation is that you may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate to meet with your investment goals. Mutual Fund and ETF Selection and Analysis. We evaluate and select mutual funds and/or ETFs for your account based on several factors which may include, without limitation, (1) the experience and track record of the underlying portfolio manager(s), (2) the performance of the mutual fund or ETF over time and through various market conditions; (3) expected market conditions that might impact the underlying holdings of the mutual fund or ETF or applicable market sector; and (4) whether and to what extent the underlying holdings of the mutual fund or ETF overlap with other assets held in your account. We also monitor the mutual fund or ETF in an attempt to determine if the fund is continuing to follow its stated investment strategy. A risk of mutual funds and ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A fund manager’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of the fund are determined by independent fund managers and may change overtime without advance warning, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. TPMM Selection and Analysis. This is the analysis of the experience, investment philosophies, and past performance of independent TPMMs in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Key factors we consider when evaluating TPMMs are their investment process and philosophy, risk management methods and procedures, historical performance, investment strategy and style, fees and operating expenses, assets under management and number or clients, and tax‐efficiencies. Our evaluation also incorporates both qualitative and quantitative fundamental analysis to validate and confirm a TPMM’s investment style and skill, as well as to compare them to other managers of similar style. We may utilize various research databases, proprietary models, financial periodicals, prospectuses and filings with the SEC, industry contacts and manager data, among other items, as part of the research process. Monitoring the TPMM’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment 15  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE completes the analysis. As part of the due-diligence process, the TPMM’s compliance and business enterprise risks may be surveyed and reviewed. Methods of analysis such as charting, fundamental, technical, or cyclical analysis may be used by the TPMMs we help select or recommend to clients. Please refer to the disclosure brochure of the TPMM for more information. We typically use the following investment strategies in managing client accounts: Long-term Purchases. We may recommend a long term, passive, “buy and hold” approach to investing client assets. In this type of investment strategy, we suggest the purchase of securities with the idea of holding them in a portfolio for a year or longer. Typically, we employ this strategy when (1) we believe the securities to be currently undervalued, and/or (2) we want the portfolio to have exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the recommendation to sell. Short-term purchases. When utilizing this strategy, we may suggest the purchase of securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we recommend for purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Trading. A trading program rather than an investment program may not be suitable for all clients. “Trading” refers to purchasing and selling securities on a short-term basis with the intention of achieving quick profits. Trading is, by definition, a form of speculating as distinguished from investing. A trading strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. For these reasons, we will use trading strategies only in client 16  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE accounts we believe will benefit from the strategy and which can assume the increased risk of loss. We use our best judgment and good faith efforts in rendering investment advice to our clients. We cannot warrant or guarantee any particular level of account performance, or that an account will be profitable over time. Not every investment recommendation we make will be profitable. Investing in securities involves risk of loss that clients should be prepared to bear. You assume all market risk involved in the investment of your account assets. Investments are subject to various market, currency, economic, political, and business risks. Except as may otherwise be provided by law, we are not liable to you for: • any loss that you may suffer by reason of any investment recommendation we made with that degree of care, skill, and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; or any independent act or failure to act by a Custodian of your account(s). • Summary of Investment Risks. While all investing involves risks and losses can and will occur, our advisory services generally recommend a broad and diversified allocation of mutual funds and other securities intended to reduce the specific risks associated with a concentrated or undiversified portfolio. Nonetheless, you should consider the following high-level summary of investment risks. This list is not intended to be an exhaustive description of all risks you may encounter in engaging our firm for advisory services. We encourage you to inquire with us frequently about the risks related to any investments in your account. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. As with any investment manager that invests in common stocks and other equity securities, our investment recommendations are subject to market risk—the possibility that securities prices will decline over short or extended periods of time. As a result, the value of your account(s) will fluctuate with the market, and you could lose money over short or long periods of time. You should recognize whenever you determine to invest in the securities markets your entire investment is at risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments. Economic Risk. The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument 17  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk. Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Market Risk. The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. TPMM Risks. A TPMM’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of your TPMM account(s) are determined by the TPMM directly, and may change overtime without advance warning to our firm, creating the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that a TPMM may deviate from the stated investment mandate or strategy of the account, which could make the holding(s) less suitable for the client’s portfolio. We do not control any TPMM’s daily business and compliance operations, and thus our firm may be unaware of any lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Risks Related to Analysis Methods. Our analysis of securities relies in part on the assumption that the issuers whose securities we recommend for purchase and sale, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Securities Transactions at the Direction of Clients. Irrespective of whether you engage us on a discretionary or non-discretionary basis, depending on your arrangement with the Custodian of your assets, you may maintain the concurrent ability to direct transactions within your account held at the Custodian. We are not responsible for the consequences of your self-directed investment decisions. 18  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Interim Changes in Client Risk Tolerance and Financial Outlook. The particular investments recommended by our firm are based solely upon the investment objectives and financial circumstances disclosed to us by the client. While we strive to meet with clients at regular intervals (at least annually, unless otherwise agreed, either in person, telephonically, or by electronic means) to discuss any changes in the client’s financial circumstances, the lack of constant and continuous communication presents a risk insofar as your liquidity, net worth, risk tolerance and/or investment goals could change abruptly, with no advance notice to our firm, resulting in a mis-aligned investment portfolio and the potential for losses or other negative financial consequences. We do not have authority to vote and therefore do not vote client securities. Additionally, we do not provide advice to clients on how the client should vote. Clients will receive proxies and other solicitations directly from the Custodian or transfer agent. If any proxy materials are received on behalf of a client, they will be sent directly to the client or a designated representative of the client, who is responsible to vote the proxy. Item 7 – Client Information Provided to Portfolio Managers We are required to describe the information about you that we communicate to your portfolio manager(s), and how often or under what circumstances we provide updated information. Our in- house portfolio managers will have access to your suitability information, written financial plan (if any), and all other information provided to us by you and contained in your client file with the firm. We will communicate with any TPMMs selected to manage your account on an as needed basis (daily, weekly, monthly, quarterly, etc.) to ensure that your most current investment goals and objectives are understood by such TPMMs. In most cases, we will communicate such information as part of our regular investment management duties. Nevertheless, we will also communicate information to your TPMMs when you ask us to, when they ask us to, when market or economic conditions make it prudent to do so, etc. Item 8 – Client Contact with Portfolio Managers There are no limitations on the client’s ability to contact our firm and speak with the in-house portfolio manager of their account. It is your continuing and exclusive responsibility to give us complete information and to notify us of any changes in your financial circumstances, income level, investment goals or employment status. We encourage you to contact us regularly and promptly to discuss any such changes. With respect to any TPMMs, clients should contact us prior to communicating with the portfolio manager directly. However, clients are free to directly contact their TPMMs with any questions or concerns they have about their portfolios or other matters. 19  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE Item 9 – Additional Information A Disciplinary Information; Conflicts of Interest; Financial Industry Activities and Affiliations EIC is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. No principal or person associated with EIC has any information to disclose which is applicable to this Item. Neither our firm nor our personnel receive any compensation for the sale of any securities. Certain associated persons of EIC are independently licensed to sell insurance in one or more states acting as a direct agent representative of a specific insurance company or companies. Insurance related business may be transacted with advisory clients and licensed individuals may receive commissions from insurance products sold to clients. Clients are advised that the fees paid to EIC or its associated persons for investment advisory services are separate and distinct from any commissions earned by EIC or its associated persons for selling insurance products to clients. If requested by a client, we will disclose the amount of commissions expected to be paid. The receipt of insurance related commissions by any individual associated with our firm presents a conflict of interest. As fiduciaries we must act primarily for the benefit of our investment advisory clients. As such, we will only transact insurance related business with clients when fully disclosed, suitable, and appropriate. Further, we must determine in good faith that any commissions paid to our associated persons are appropriate. Clients are informed that they are under no obligation to use any individual associated with our firm for the purchase of insurance products or services. Clients may use any insurance firm or agent they choose for purchase of these products and services. We encourage you to ask us about the conflicts of interest presented by the insurance licensing of our associated persons. B Code of Ethics; Participation or Interest in Client Transactions and Personal Trading; Account Reviews; Client Referrals and Other Compensation; and Financial Information We subscribe to an ethical and high standard of conduct in all our business activity in order to fulfill the fiduciary duty we owe to our clients. Included in these ethical obligations is the duty to put our client’s interests ahead of our own along with duties of loyalty, fairness, and good faith towards our clients. We disclose to clients material conflicts of interest which could reasonably be expected to impair our rendering of unbiased and objective advice. EIC has a Code of Ethics (“Code”) which all employees are required to follow. The Code outlines proper conduct related to all services provided to clients and will be made available 20  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE to you, free of charge, upon request by contacting us at the phone number listed on the cover page of this Wrap Fee Brochure. Prompt reporting of internal violations is mandatory. EIC’s Chief Compliance Officer, Cal Easley, Jr., evaluates employee performance to ensure compliance with our Code. Designed to prevent conflicts of interest between the financial interests of clients and the interests of the firm and its staff, the Code requires, among other procedures, our “access persons” to report their personal securities transactions quarterly and to report all securities positions in which they have a beneficial interest at least annually. These reporting requirements allow supervisors at the firm to determine whether to allow or prohibit certain employee securities purchases and sales based on transactions made, or anticipated to be made, in the same securities which may be purchased or sold for client accounts. The Code is required to be reviewed annually and updated as necessary. Our firm and individuals associated with our firm do not have any proprietary or material interests in or any role in the management of any companies or investments that we recommend to our clients. EIC and/or individuals associated with our firm may manage accounts which belong either to themselves, individually, or to their family or their affiliates (collectively, “Proprietary Accounts”) while simultaneously managing client accounts. It is possible that orders for Proprietary Accounts may be entered simultaneously (but typically only as part of a block trade) with or opposite to orders for client accounts, pursuant to, for instance, a neutral allocation system, a different trading strategy, or trading at a different risk level. The management of any Proprietary Account is subject to our Code of Ethics and the duty of our firm and its personnel to exercise good faith and fairness in all matters affecting client accounts. The practice of trading in Proprietary Accounts creates an actual conflict of interest with our clients insofar as our firm or individuals associated with our firm may have a financial incentive to trade in securities for Proprietary Accounts in advance of or opposite to transactions in the same securities for client accounts. To address this conflict, our policy is that, assuming the purchase or sale is otherwise appropriate for the subject client accounts, we will purchase or sell securities for our clients’ accounts, as the case may be, before purchasing or selling any of the same securities for any Proprietary Accounts. In some cases we may buy or sell securities for our own account for reasons not related to the strategies adopted by our clients. The only exception to this general rule is where our Proprietary Accounts may participate in an aggregate (“block”) trade simultaneously with client accounts. In summary, our practice of buying and selling for Proprietary Accounts the same securities that we buy or sell for client accounts is restricted by the following controls:  we are required to uphold our fiduciary duty to our clients; 21  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE  we are prohibited from misusing information about our clients’ securities holdings or transactions to gain any undue advantage for ourselves or others;  we are prohibited from buying or selling any security that we are currently recommending for client accounts, unless we participate in an aggregated trade with clients, or unless we place our orders after client orders have been executed; and  we are required to periodically report our securities holdings and transactions to the firm’s Chief Compliance Officer, who must review those reports for improper trades. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interest of all the accounts we advise. We will disclose to advisory clients any material conflict of interest relating to us, our representatives, or any of our employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Portfolio management accounts are generally reviewed by Cal R. Easley, Jr., who is responsible for overseeing all investment advisory activities for the firm. However, individuals conducting reviews may vary from time to time, as personnel join or leave our firm. The frequency of reviews is determined based on each client’s investment objectives and investment profile. Accounts are generally reviewed quarterly, but in any event, no less than annually. More frequent reviews of accounts may be triggered by a change in a client’s investment objectives; risk/return profile; tax considerations; contributions and/or withdrawals; large sales or purchases; security specific events; or changes in the economy more generally. Clients will receive standard account statements and trade confirmations from their Custodian typically on a monthly basis, but no less than quarterly. We will provide you with independently prepared written reports on a quarterly basis and additional reports as you may reasonably request. Reports we provide to you will contain relevant account and/or market-related information such as an inventory of account holdings and account performance, as examples. We have no arrangements, written or oral, in which we compensate others or are compensated for client referrals. 22  EASLEY INVESTMENT CONSULTANTS INC. FORM ADV PART 2A APPENDIX 1 – WRAP FEE BROCHURE EIC does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. EIC does have discretionary authority over certain client funds and securities, but we have no financial commitments that would impair our ability to meet contractual and fiduciary commitments to our clients. Neither EIC nor any of its principals, have been the subject of a bankruptcy petition at any time in the past. 23