Overview

Assets Under Management: $606 million
Headquarters: WALTHAM, MA
High-Net-Worth Clients: 141
Average Client Assets: $4 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (10 23 2025 EMC FORM ADV PART 2A AND 2B FINAL)

MinMaxMarginal Fee Rate
$0 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $100,000 1.00%
$50 million $500,000 1.00%
$100 million $1,000,000 1.00%

Clients

Number of High-Net-Worth Clients: 141
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 82.26
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 827
Discretionary Accounts: 777
Non-Discretionary Accounts: 50

Regulatory Filings

CRD Number: 110836
Last Filing Date: 2024-10-31 00:00:00
Website: https://complianceadv.com

Form ADV Documents

Primary Brochure: 10 23 2025 EMC FORM ADV PART 2A AND 2B FINAL (2025-10-30)

View Document Text
Item 1: Cover Page Form ADV Part 2A Investment Adviser Brochure Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 (617) 916-9669 – phone (617) 916-9554 – fax www.excalmgmt.com October 2025 This brochure provides information about the qualifications and business practices of Excalibur Management Corporation. If you have any questions about the contents of this brochure, please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Excalibur Management Corporation is also available on the SEC’s website at www.adviserinfo.sec.gov. Please note that use of the term “registered investment advisor” and a description of Excalibur and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure, and a Brochure Supplement, Form ADV Part 2B, for each of the Firm’s associates who advises you, for more information on the qualifications of the Firm and our associates and employees. Item 2: Summary of Material Changes Annual Update In this Item of Excalibur’s (the "Firm,” “we,” “us,” “ours”) Form ADV 2, the Firm is required to discuss any material changes that have been made to Form ADV since the last Annual Amendment. Material Changes since the Last Update Since the last Annual Amendment on March 26, 2024, the Firm has no Material Changes to report. Full Brochure Available Our Form ADV may be requested at any time, without charge, by contacting Ellen M. Bruno, Chief Compliance Officer, at (508) 828-1410 x1 or compliance@excalmgmt.com. Additional information about the Firm is also available on the SEC’s website at www.adviserinfo.sec.gov. 2 Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................ 1 Item 2: Summary of Material Changes .......................................................................................... 2 Item 4: Advisory Business ............................................................................................................. 4 Item 5: Fees and Compensation .................................................................................................... 8 Item 6: Performance-Based Fees and Side-by-Side Management............................................... 11 Item 7: Types of Clients ............................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 13 Item 9: Disciplinary Information.................................................................................................. 16 Item 10: Other Financial Industry Activities and Affiliations ....................................................... 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 18 Item 12: Brokerage Practices ...................................................................................................... 19 Item 13: Review of Accounts ....................................................................................................... 21 Item 14: Client Referrals and Other Compensation .................................................................... 22 Item 15: Custody ......................................................................................................................... 23 Item 16: Investment Discretion ................................................................................................... 24 Item 17: Voting Client Securities ................................................................................................. 25 Item 18: Financial Information .................................................................................................... 26 Form ADV Part 2B – Investment Adviser Brochure Supplement ................................................. 27 3 Item 4: Advisory Business Information about the Firm We are an independent and privately-owned registered investment advisor founded in Boston in 1979. Our sole business is serving high-net-worth individuals and families of substantial wealth, as well as foundations, business entities, and endowments. Our team of seasoned investment management and wealth planning specialists gives each client customized strategies and solutions for preserving and growing their irreplaceable assets. Our principal owners are Michael W. Delduchetto and Marc H. Ohler. Advisory Services Investment Management Services We believe our primary investment criterion is the safety of each client’s irreplaceable assets while maximizing risk-adjusted returns over a multi-year horizon. Our disciplined investing style employs a consistent and rigorous analytical work ethic where equal amounts of time are spent on risk assessment as well as return. Many clients utilize our investment experience to help develop, plan and implement prudent investment strategies across assets that we both manage and those that we do not manage. These services often include tax-efficient investing, strategic gifting, concentrated asset strategies, risk management, and cash flow analysis. We are accustomed to working with clients’ other service providers including other asset managers, financial planners, trustees, lawyers, and accountants. We develop a specifically tailored investment strategy for each individual client and portfolio through a rigorous analysis of the client’s financial needs and appropriate risk profile. Factors considered include the level of investment assets, current asset allocation, liquidity of investment and other assets, investment time horizon, asset concentration, cash flow needs, income level, employment situation, contingent assets, risk tolerance, and tax situation. An initial asset allocation and investment strategy is developed from this review and analysis. We continually monitor the investment strategy along with the client’s broader evolving financial situation so that adjustments can be made in the context of a constantly changing capital markets environment. We offer expertise for client investment management accounts as follows: • Customized Multi-Asset portfolios utilizing our macro-economic research, and equity and fixed income analytics to produce diversified high-quality portfolios tailored to each client’s individual needs. • Custom Equity Investing in mainly mid and large-capitalization companies. • Custom Fixed Income investing in corporate, municipal and government bonds, and cash/liquidity management strategies. 4 We may offer management and counsel on U.S. equities (common and preferred stocks), international equities, American depository receipts, debt securities of the U.S. government and its agencies, municipal bonds, corporate bonds, floating rate and variable rate obligations, inflation-protected debt securities, structured notes, exchange traded funds and notes (ETFs/ETNs), derivatives, hedge strategies, option strategies, private equity analysis, oil & gas limited partnerships, and family business ownership. While we do not seek to invest in mutual funds for discretionary managed accounts, some clients may hold mutual funds in their accounts as a legacy inherited asset or as part of a non- discretionary account that we manage. We may also help select other independent managers for clients upon request. These assets are typically held as part of a client’s non-discretionary account. Integrated Financial Planning Services As clients request, we will provide advice in the form of a written financial plan and through ongoing execution and monitoring of the plan. We gather required information through in- depth personal interviews. Meetings are expected to be held on a regular basis. Each meeting will focus, as necessary, on retirement planning, investments, estate planning, and insurance needs. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including tax returns, current financial specifics (i.e., W2s or 1099s), information on current retirement plans, insurance information, mortgage information, insurance policies, statements reflecting current investments in the client’s retirement and non-retirement accounts, copies of wills and trusts, as well as any other document that may be deemed pertinent by us. Upon receipt of such documents, we will review the client’s current financial situation and make recommendations based on the client’s current situation, financial expectations, investment objectives, risk tolerance and investment time horizon. A written financial plan will then be prepared and presented to the client along with an outline of suggestions to improve the client’s current financial situation together with suggested steps to help the client reach their investment goals. In general, the written financial plan will address any or all of the following areas of concern: Personal: Family records, budgeting, personal liability, estate information and financial goals. Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. We will illustrate the impact of various investments on a client’s current income tax and future tax liability. Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. 5 Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. In performing our services, we will not be required to verify any information received from the client or from the client’s other professionals, and we are expressly authorized to rely thereon. If requested by the client, we may recommend the services of other professionals for implementation services. The client is under no obligation to engage the services of any such recommended professional. As part of the integrated financial planning services that we offer, a client may also opt to have us provide asset allocation and portfolio monitoring services. At a client’s request investments chosen can be mutual funds offered by a selection of mutual fund families. These mutual funds will be purchased on a “no-load” or “load-waived” basis or exchange-traded funds (ETFs). As part of the integrated financial planning services that we offer, a client may also opt to have us provide money manager search and monitoring services. A selection of managed account programs is also available through our relationships with outside money managers. The programs and fees will be described in detail in the individual money manager’s Form ADV Part 2 and related schedules. The management fee charged by the money manager recommended to the client is separate from the fee charged by us and is disclosed in the money manager’s disclosure document (Form ADV Part 2). Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Additionally, we provide advice on non- securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Individual Advice; Restrictions on Investing The core of our business is the creation and management of customized multi-asset and high- quality custom portfolios. Each portfolio is customized according to client-specific objectives and is managed by our team of portfolio managers. We are experienced in handling the distinct needs of high-net-worth individuals, complex families, trusts, foundations, and endowments. Clients may impose restrictions on investing in certain industry sectors and types of securities purchased. Such restrictions must be provided to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective 6 components of the total service. We do not sponsor, manage or participate in a Wrap Fee Program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client: • To render impartial advice; • To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives; • To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead; • To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations; • Disclose any material conflict of interest in writing; and • Treat clients fairly and equitably. Regulations prohibit us from: • Employing any device, scheme, or artifice to defraud a client; • Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client; • Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or • Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31, 2024, we have $657,022,630 of regulatory assets under management. Of these, $648,421,389 are managed on a discretionary basis and $8,601,241 are managed on a non-discretionary basis. 7 Item 5: Fees and Compensation Investment Management Services We offer discretionary investment management and advisory services for a percentage of assets under management and/or on a fixed fee basis. We do not sell investment products, and our only source of income is fees paid by clients. Our fees for investment management and advisory services range up to 1.0% (100 basis points) annually of account market value, including cash, as determined by the custodian, billed quarterly in arrears. Clients choose whether to have their fees deducted from accounts custodied with qualified custodians or to be billed directly. Integrated Financial Planning Services Clients will pay a fixed fee based on the nature and complexity of each client’s individual circumstances. We do not maintain a standardized fee schedule for these additional services. All terms, including the additional services to be rendered, the fee for such services, the method(s) of payment and termination provisions, are negotiated on a client-by-client basis. Details of the fee charged for these additional services are more fully described in the advisory agreement entered into with each client. Termination A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. Upon termination of any account, any earned, unpaid fees will be due and payable. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. Accounts initiated or terminated during a calendar quarter may be charged a prorated fee. Upon termination of an account, any earned, unpaid fees will be due and payable. Cash Balances Some of your assets may be held as cash and remain uninvested. Holding a portion of your assets in cash and cash alternatives, i.e., money market fund shares, may be based on your desire to have an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for asset protection during periods of volatile market conditions. Your cash and cash equivalents will be subject to our investment advisory fees unless otherwise agreed upon. Retirement Plan Rollover Recommendations As part of our investment advisory services to our clients, we may recommend that clients roll assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account 8 (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 advise on the client’s 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. If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the client an asset-based fee as set forth in the advisory agreement the client executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA advised on 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 our clients’ best interests and not put our interests ahead of our clients’. 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 our clients’ 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 our clients’ best interests; • charge no more than a reasonable fee for our services; and • give clients 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, clients 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 the 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 clients with an explanation of the advantages and disadvantages of both account types and document the basis for our belief that the rollover transaction we recommend is in your best interests. 9 General Information on Compensation and Other Fees In certain circumstances, fees, account minimums and payment terms are negotiable depending on client’s unique situation – such as the size of the aggregate related party portfolio size, family holdings, low-cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation. Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall not receive any portion of these commissions, fees, and costs. All fees paid to us for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive our services, which are designed, among other things, to assist the client in determining which mutual funds are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by us to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. Mutual Fund Share Class Selection Similar investment management services may (or may not) be available from other investment advisers for a lower fee. Investment management fees, which include investment management and transaction costs, may be more or less costly than paying for the services separately, depending upon the investment advisory fees charged, the number of transactions for the account, the mutual fund share class you purchase and the underlying 12(b)-1 fee, and the level of brokerage and other fees that would be payable if you obtained the services available individually. 10 Item 6: Performance-Based Fees and Side-by-Side Management “Performance-based fees” are fees based on the capital gains or capital appreciation in an account. We do not charge performance-based fees. “Side-by-side management” refers to the practice of managing accounts that are charged a performance-based fee and accounts that are charged other types of fees, such as asset-based fees and hourly fees. Because we do not charge performance-based fees, we do not engage in side-by-side management. 11 Item 7: Types of Clients We provide investment management and strategic wealth management services to a wide range of clients. Our clients include high-net-worth individuals, individuals, and families, trusts: revocable and irrevocable, family limited partnerships, estates, charitable organizations, closely held business entities, not-for-profit entities, including foundations, retirement and profit- sharing plans including IRAs, Roth IRAs, and SEP IRAs. Account minimums We require a minimum net worth of $1,000,000 for investment advisory services and financial planning services. Waivers or exceptions from the minimum may be granted at our discretion. 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We are a research-based company, and we utilize both “top-down” macroeconomic analysis and “bottom-up” securities analysis to identify investment and trade ideas that are likely to benefit from the projected capital markets environment. Our investment approach includes a continual analysis of monetary and economic conditions in order to identify those well- managed companies that stand to benefit from the changing environment. Every portfolio’s asset allocation is customized based on each client’s overall investment objectives. We seek to create liquidity and risk-appropriate client portfolios that are broadly diversified to maximize wealth creation and minimize volatility. Our investment approach utilizes an in-depth and on- going research process to achieve long-term risk-appropriate returns through due diligence, analysis, and tactical rebalancing. Client investment goals vary greatly and so do our portfolios characteristics. Every portfolio follows a well-researched, disciplined, risk & return approach to achieving each client’s goals. We use both fundamental and technical analytical methods of security analysis and selection. Fundamental Analysis: Fundamental analysis is used to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the security is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements, which may present an additional risk since the price of a security may move up or down with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis: Using technical analysis, we analyze past market movements and use the analysis to recognize recurring patterns of investor behavior to predict future price movement. Technical analysis does not consider the intrinsic value of a security, which may present a risk since a poorly managed or financially unsound company may underperform regardless of market movement. We do not use margin or leverage in client portfolios. Investment Strategies Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. 13 Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. Although we manage assets in a manner consistent with your investment objectives and risk tolerance, there can be no guarantee that our efforts will be successful. You should be prepared to bear the following risks of loss: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to • tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties (i.e., Non-traded REITs and other alternative investments) are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events that may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. 14 • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. • Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill its contractual obligations either due to technological errors, control failures, malfeasance, or potential regulatory liabilities. 15 Item 9: Disciplinary Information We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary events that would be material to your evaluation of the Firm or the integrity of our management. There have never been any legal, regulatory or disciplinary actions against the Firm or our management persons. 16 Item 10: Other Financial Industry Activities and Affiliations We are required to disclose to our clients any relationship or arrangement with certain related persons that is material to our advisory business. Financial Industry Activities We are not registered as a broker-dealer, and none of our management persons are registered representatives of a broker-dealer. Neither we, nor any of our management persons, is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor. Neither we nor any of our management persons, have a material relationship or arrangement with any related person or financial industry entities. Accountants and Accounting Firm David N. Leggett and Kimberly L. Leggett are Investment Advisor Representatives of Excalibur, and owners of the accounting firm, Leggett & Leggett, PC. Other Investment Advisors As described above in Items 4 and 5, we may help select another outside investment manager for clients; however, we do not share in compensation with those advisors. 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics We have a duty to exercise our authority and responsibility for the benefit of our clients, to place the interests of our clients first, and to refrain from having outside interests that conflict with the interests of our clients. We and our employees avoid any circumstances that might adversely affect, or appear to affect, our duty of loyalty. We have adopted a Code of Ethics (the Code); the Code’s key provisions include: • Statement of general principles; • Policy on and reporting of personal securities transactions; • A prohibition on insider trading; • Restrictions on the acceptance of significant gifts; • Procedures to detect and deter misconduct and violations; and • Requirement to maintain confidentiality of client information. Our employees must acknowledge the terms of the Code at least annually. Any individual not in compliance with the Code may be subject to termination. We will provide a copy of our Code upon request. Participation or Interest in Client Transactions – Personal Securities Transactions Both the Firm and our employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of our clients. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between the Firm and its clients. Participation or Interest in Client Transactions and Principal/Agency Cross Trades We do not recommend any securities to our clients in which we have a material financial interest. We do not affect any principal or agency cross securities transactions for client accounts. We also do not cross trades between client accounts. 18 Item 12: Brokerage Practices Research and Other Soft Dollar Benefits We have no written or verbal arrangements whereby we receive soft dollars. Brokerage for Client Referrals We do not receive client referrals from broker/dealers. Client Directed Brokerage In a limited number of cases, clients have requested that we use a specified broker-dealer when executing trades for their accounts. In those instances, the client will negotiate terms and arrangements for the account with that broker-dealer, and we will not seek better execution services or prices from other broker-dealers or be able to “batch” client transactions for execution through other broker-dealers with orders for other accounts managed by us. By directing brokerage, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Not all advisers require or allow their clients to direct brokerage. Subject to our duty of best execution, we may decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Directed Brokerage We have a list of approved broker-dealers that we deal with in executing client trades. The factors considered in selecting brokers are as follows: philosophy in accordance with our philosophy regarding clients and investment advice, fees associated with the various types of portfolios, performance reporting capabilities, variety of portfolios available, trust service, and investment options. We review the list periodically and make changes when necessary to seek best execution for all clients. We require clients to select a third-party bank or other financial institution to serve as the qualified custodian for their assets being managed. We have existing client relationships with many of the largest custodian institutions in the U.S., and we have the ability to accommodate client requests to work with another custodian of their choice. • , reporting and settling transacted orders. Brokerage – Other Economic Benefits We may have the opportunity to receive traditional “non-cash benefits” from brokers such as customized statements; receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk servicing advisors exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client portfolios; ability to have investment advisory fees deducted directly from client portfolios; access to an electronic communication network for client order 19 entry and portfolio information; access to mutual funds which generally require significantly high minimum initial investments or those that are otherwise only generally available to institutional investors; reporting features; receipt of industry communications; and perhaps discounts on business-related products. We may also receive general access to research and perhaps discounts on research products. Any research received is used for the benefit of all clients. As noted above, we have no written or verbal arrangements whereby we receive soft dollars. While we endeavor at all times to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of any additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. Trade Aggregation At our sole discretion, aggregate purchases or sales of the same security, instrument or obligation may be transacted on the same day for multiple accounts of one or more of our clients. Although such aggregations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they will be affected only when we believe that to do so will be in the best interest of the affected accounts. When transactions are so aggregated the actual prices applicable to the aggregation transaction will be deemed to have purchased or sold its share of the security, instrument or obligation at the average price. If a partial execution is attained at the end of the trading day, we will generally allocate shares on a pro rata basis but may fill small orders entirely before applying the pro rata allocation. 20 Item 13: Review of Accounts Reviews Portfolios are reviewed and monitored continuously. The nature of the review focuses on the client’s investment objectives and structure of the account including its asset allocation and holdings. Integral to this review are the client’s risk profile, cash flow needs, tax bracket, growth objectives, other assets, etc. Reviews could also occur at the time of new deposits, material changes in client’s financial information, changes in economic cycles. Reviews entail analyzing securities, sensitivity to overall markets, economic changes, investment results and asset allocation, etc., to ensure the investment strategy and expectations are structured to continue to meet clients’ objectives. Reviews are performed by the client’s team of investment advisors, which include Michael W. Delduchetto, Marc H. Ohler, Matthew M. Delduchetto, Brendan C. Herlihy, Wayne D. Wetzel, Jr., David N. Leggett and Kimberly L. Leggett. The review process is overseen by Marc H. Ohler, CFA, Managing Director, and Michael W. Delduchetto, President and Managing Director. Clients are obligated to promptly notify us of any changes in their client’s financial status to ensure that investment strategies continue to meet their client’s changing needs. Review Triggers Other conditions that may trigger a review are changes in market, political or economic conditions, tax laws, new investment information, and changes in a client's own situation. Reporting We prepare periodic reports for clients which generally include holdings, performance and market information. At least quarterly, the qualified custodian provides clients with an account statement for each client account, which may include individual holdings, cost basis information, deposits and withdrawals, accrued income, dividends, and performance. Depending on the qualified custodian selected, the client may or may not receive trade confirmations for each position bought and sold. 21 Item 14: Client Referrals and Other Compensation Other Compensation for Advisory Services See disclosure in Item 12 regarding compensation, including economic benefits received in connection with giving advice to clients. Compensation – Client Referrals We have been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. We do not compensate referring parties for these referrals. 22 Item 15: Custody Our number one goal is to ensure the safety of client assets. We do not have physical custody over client accounts or funds. Client assets shall be held in the custody of a bank, trust company or brokerage firm (“qualified custodian”) agreed upon by the client and the Firm. We do have forms of “constructive” or “deemed” custody as disclosed below. Custody - Fee Debiting Clients may authorize us (in the client agreement) to debit fees directly from their account at the broker dealer, bank or other qualified custodian (“custodian”). The custodian is advised in writing of the limitation of our access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to the Firm. Custody - Access to Client Funds and/or Securities We have deemed custody over certain client assets as follows: • When an employee personally acts as either a Trustee or Co-Trustee of a client portfolio. • As a consequence of the authority granted under the terms and conditions of the client’s custodian contract to disperse funds or securities on the client’s behalf. These forms of custody are offered on a limited basis. We comply with the SEC’s Custody Rule with regard to the custody of the trust / estate assets; annually the Firm is subject to a Surprise Examination by an independent accountant. Custody – Account Statements Clients receive at least quarterly statements from the custodian that holds and maintains client’s investment assets. Clients are urged to carefully review such statements and compare such official custodial records to the reports that we provide. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 23 Item 16: Investment Discretion We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A limited power of attorney allows us to execute trades on behalf of clients. When such limited powers exist between the Firm and the client, we have the authority to determine, without obtaining specific client consent, both the amount and type of securities to be bought to satisfy client account objectives. If we have not been given discretionary authority, we consult with the client prior to each trade. We do not have the discretion to hire an independent money manager without a client’s written consent. 24 Item 17: Voting Client Securities Proxy Voting We vote proxies for securities over which we maintain discretionary authority. Our utmost concern is that all decisions be made solely in the client's best interest. We will act in a prudent and diligent manner intended to enhance the economic value of the assets of the client’s portfolio. Although many proxy proposals can be voted in accordance with our established guidelines, we recognize that some proposals require special consideration, which may dictate that we make an exception to the guidelines. Clients may direct our vote; however, direction must be received in writing. Clients may contact us for information about proxy voting. 25 Item 18: Financial Information We have no financial commitments that impair our ability to meet contractual and fiduciary commitments to clients and we have not been the subject of a bankruptcy proceeding. We do not require prepayment of fees of both more than $1,200 per client, and more than six months in advance; and therefore, we are not required to provide a balance sheet to clients. 26 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Michael W. Delduchetto October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 27 Item 2: Educational Background and Business Experience Born 1965 Michael W. Delduchetto CRD # 2389721 2003 to Present Business Background: Excalibur Management Corporation President and Managing Director 2002 to 2003 J.P. Morgan Securities, Inc. Vice-President of Fixed Income Institutional Sales 1993 to 2002 Merrill Lynch Vice-President of Fixed Income Institutional Sales Formal Education after High School: Columbia University Master of Business Administration in International Finance St. Lawrence University Bachelor of Arts in Economics Item 3: Disciplinary Information Michael W. Delduchetto has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Michael W. Delduchetto serves as a board member for a non-profit organization which supports developmentally disabled adults. This activity is investment-related, as the board discusses and oversees the endowment’s investment strategy to support the organization’s mission. The organization is a client of the Firm’s. While Michael W. Delduchetto’s role on the board is unpaid and limited in scope, this dual relationship may present a potential conflict of interest. The Firm addresses this by requiring full disclosure of such relationships and by implementing policies that ensure all investment decisions are made in the best interest of each client, without favoritism or undue influence. Item 5: Additional Compensation 28 Michael W. Delduchetto does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 29 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Marc H. Ohler, CFA October2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 30 Item 2: Educational Background and Business Experience Born 1972 Marc H. Ohler CRD #: 4318901 2004 to Present Business Background: Excalibur Management Corporation Managing Director and Principal 2000 to 2004 Fleet Securities, Inc. Senior Associate of Mergers and Acquisitions Formal Education after High School: Babson College, F.W. Olin Graduate School of Business Master of Business Administration DePauw University Bachelor of Arts in Economics Professional Designations: Chartered Financial Analyst (CFA) Professional Certifications Our Supervised Person maintains professional designations, which required the following minimum requirements: Chartered Financial Analyst (CFA) Issued By CFA Institute Candidate must meet one of the following requirements prior to enrollment: • Hold a bachelor’s or equivalent degree from a college/university; • Be within 11 months of the graduation month for a bachelor’s degree or equivalent program by the date of sitting for the Level I exam; or Prerequisites • Have a combination of 4,000 hours of work experience and/or higher education that was acquired over a minimum of three sequential years by the date of enrolling for the Level I exam; • Have 4,000 hours of qualified work experience in the investment decision-making process (accrued before, during, or after participation in the CFA Program); and • Submit two-to-three professional reference letters. 31 Candidate must complete the following: • Self-study program (250 hours of study for each of the 3 Education Requirements levels) Three in-person, proctored, closed-book, computer-based exams None Exam Type Continuing Education Requirements Item 3: Disciplinary Information Marc H. Ohler has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Marc H. Ohler is not involved in any material outside business activities. Item 5: Additional Compensation Marc H. Ohler does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 32 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Matthew M. Delduchetto October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 33 Item 2: Educational Background and Business Experience Born 1976 Matthew M. Delduchetto CRD # 4845864 2021 to Present Business Background: Excalibur Management Corporation Director 2015 to 2020 BNP Paribas Securities Corp. Director Deutsche Bank Securities, Inc. Director Vice President Associate 2011 to 2015 2008 to 2011 2004 to 2008 Formal Education after High School: Columbia University Master of Business Administration in Accounting Colgate University Bachelor of Arts in Mathematics Item 3: Disciplinary Information Matthew M. Delduchetto has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Matthew M. Delduchetto is not involved in any material outside business activities. Item 5: Additional Compensation Matthew M. Delduchetto does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. 34 Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 35 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com David N. Leggett Ph.D., CPA October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 36 Item 2: Educational Background and Business Experience Born 1948 David N. Leggett CRD #: 5337887 2019 to Present Business Background: Excalibur Management Corporation Managing Director 2010 to 2020 Sierra Financial Management Corporation President 1985 to Present Leggett And Leggett, PC Principal 1988 to 2016 The Sierra Group, Inc. President Formal Education after High School: University of Arizona Doctor of Philosophy in Business Administration University of Arizona School of Law Doctoral Minor in Law University of Arizona Master of Studies in Accountancy University of Arizona Bachelor of Science in Business Administration Professional Designations: Certified Public Accountant (CPA) Professional Certifications Our Supervised Person maintains professional designations, which required the following minimum requirements: Certified Public Accountant (CPA) Issued By State Boards of Accountancy Candidate must meet the following requirements: Prerequisites • Minimum experience levels (most states require at least one year of experience providing services that involve the use of 37 accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA); • Successful passing of the Uniform CPA Examination Education Requirements Exam Type Continuing Education Requirements At minimum, a college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting) Uniform CPA Examination Completion of 40 hours of continuing professional education each year (or 80 hours over a two-year period) in order to maintain a CPA license Item 3: Disciplinary Information David N. Leggett has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities David N. Leggett is a Certified Public Accountant, and is a shareholder of Leggett & Leggett, PC., a certified public accounting firm, which provides traditional accounting and tax consulting services. David N. Leggett provides accounting services to clients of Leggett & Leggett, PC. on a part-time basis. Item 5: Additional Compensation David N. Leggett does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts aside from compensation received from his activities as an accountant for Leggett & Leggett, PC. None of these services or relationships creates any material conflict of interest with the advisory services provided by Excalibur. Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 38 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Kimberly L. Leggett, CPA/PFS October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 39 Item 2: Educational Background and Business Experience Born 1960 Kimberly L. Leggett CRD #: 5340071 2019 to Present Business Background: Excalibur Management Corporation Managing Director 2010 to 2020 Sierra Financial Management Corporation Principal 1985 to Present Leggett And Leggett, PC President 1998 to 2016 The Sierra Group, Inc. Treasurer Formal Education after High School: University of Arizona Bachelor of Science in Business Administration and Accounting Professional Designations: Certified Public Accountant (CPA) Personal Financial Specialist (PFS) Professional Certifications Our Supervised Person maintains professional designations, which required the following minimum requirements: Certified Public Accountant (CPA) Issued By State Boards of Accountancy Candidate must meet the following requirements: Prerequisites • Minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA); • Successful passing of the Uniform CPA Examination Education Requirements Exam Type At minimum, a college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting) Uniform CPA Examination 40 Continuing Education Requirements Completion of 40 hours of continuing professional education each year (or 80 hours over a two-year period) in order to maintain a CPA license Personal Financial Specialist (PFS) Issued By American Institute of Certified Public Accountants (AICPA) Candidate must meet the following requirements: • Must hold an unrevoked CPA license; • Fulfill 3,000 hours of personal financial planning business experience; Prerequisites • Complete 80 hours of personal financial planning continuing professional education credits; • Pass a comprehensive financial planning exam (PFS Exam); and • Be an active member of the AICPA Must meet minimum education requirements for CPA. Education Requirements Exam Type Continuing Education Requirements PFS Exam Completion of 60 hours of financial planning continuing professional education credits every three years Item 3: Disciplinary Information Kimberly L. Leggett has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Kimberly L. Leggett is a Certified Public Accountant and is a shareholder of Leggett & Leggett, PC., a certified public accounting firm, which provides traditional accounting and tax consulting services. Kimberly L. Leggett provides accounting services to clients of Leggett & Leggett, PC. on a part-time basis. Item 5: Additional Compensation Kimberly L. Leggett does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts aside from compensation received from her activities as an accountant for Leggett & Leggett, PC. None of these services or relationships creates any material conflict of interest with the advisory services provided by Excalibur. 41 Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 42 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Brendan C. Herlihy October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 43 Item 2: Educational Background and Business Experience Born 1969 Brendan C. Herlihy CRD #: 2620937 2019 to Present Business Background: Excalibur Management Corporation Managing Director 2001 to 2019 The Herlihy Company Owner Formal Education after High School: Babson College Bachelor of Science in Management Professional Designations: CERTIFIED FINANCIAL PLANNER™ (CFP®) Professional Certifications Our Supervised Person maintains professional designations, which required the following minimum requirements: CERTIFIED FINANCIAL PLANNER™ (CFP®) Issued By Certified Financial Planner Board of Standards, Inc. Candidate must meet the following requirements: • A bachelor’s degree (or higher) from an accredited college or Prerequisites university, and • 3 years of full-time personal financial planning experience Candidate must complete a CFP®-board registered program, or hold one of the following: Education Requirements • CPA • ChFC® • Chartered Life Underwriter® (CLU®) • CFA® • Ph.D. in business or economics • Doctor of Business Administration • Attorney's License CFP® Certification Examination 30 hours every 2 years Exam Type Continuing Education Requirements 44 Item 3: Disciplinary Information Brendan C. Herlihy has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Brendan C. Herlihy is not involved in any material outside business activities. Item 5: Additional Compensation Brendan C. Herlihy does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 45 Form ADV Part 2B – Investment Adviser Brochure Supplement Form ADV Part 2B Brochure Supplement Bay Colony Corporate Center 950 Winter Street North, Suite 4100 Waltham, MA 02451 Phone: (617) 916-9669 Fax: (617) 916-9554 www.excalmgmt.com Wayne D. Wetzel, Jr. October 2025 This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees that supplements our Brochure. You should have received a copy of that Brochure. Please contact Ellen M. Bruno, Chief Compliance Officer, at (617) 916-9669 or compliance@excalmgmt.com if you did not receive our Brochure or if you have any questions about the contents of this Supplement. Additional information about our employee(s) referenced above is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each employee. 46 Item 2: Educational Background and Business Experience Born 1942 Wayne D. Wetzel, Jr. CRD #: 1356174 1993 to Present Business Background: Excalibur Management Corporation Managing Director Formal Education after High School: Harvard University Master of Business Administration Cornell University Bachelor of Mechanical Engineering Item 3: Disciplinary Information Wayne D. Wetzel, Jr. has not been involved in any activities resulting in a disciplinary disclosure. Item 4: Other Business Activities Wayne D. Wetzel, Jr. is not involved in any material outside business activities. Item 5: Additional Compensation Wayne D. Wetzel, Jr. does not receive any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts. Item 6: Supervision Michael W. Delduchetto, President, supervises the person named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Michael W. Delduchetto supervises this person by holding regular staff, investment, and other ad hoc meetings. Michael W. Delduchetto can be reached at (617) 916-9669. 47