EXCOMP ASSET MANAGEMENT LTD

Excomp Asset Management, LTD Part 2A of Form ADV The Brochure 425 Broadhollow Road, Suite 318, Melville, NY www.excompam.com April 14, 2026 This brochure provides information about the qualifications and business practices of Excomp Asset Management, LTD (“EAM” or “Advisor”). If you have any questions about the contents of this brochure, please contact us at 631-465-9670. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about EAM is also available on the SEC’s website at: Additional www.adviserinfo.sec.gov. 1  Item 2 - Material Changes Since EAM’s last update of Form ADV Part 2A in May 21, 2025, below are the material changes to this Brochure. Other changes have been made to this Brochure. We encourage you to read this Brochure in its entirety. • Updated the AUM disclosed for March 31, 2026. 2  Item 3 -Table of Contents Item 2 - Material Changes.................................................................................................................. 2 Item 3 -Table of Contents .................................................................................................................. 3 Item 4 – Advisory Business ............................................................................................................... 4 Item 5 - Fees and Compensation ........................................................................................................ 4 Item 6 -Performance Based Fees and Side-by-Side Management ..................................................... 6 Item 7 - Types of Clients ................................................................................................................... 6 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 6 Item 9 - Disciplinary Information ...................................................................................................... 8 Item 10 - Other Financial Industry Activities and Affiliations .......................................................... 8 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 8 Item 12 - Brokerage Practices ............................................................................................................ 9 Item 13 - Review of Accounts ......................................................................................................... 10 Item 14 - Client Referrals and Other Compensation ........................................................................ 10 Item 15 - Custody ............................................................................................................................. 11 Item 16 - Investment Discretion ...................................................................................................... 11 Item 17 - Voting Client Securities ................................................................................................... 11 Item 18 - Financial Information ....................................................................................................... 12 3  Item 4 - Advisory Business EAM was founded in 1993 and is principally owned by Timothy Dennis Atkinson. Excomp Asset Management, LTD (“EAM” or “Advisor” or “We” or “Our”) provides Investment Advisory Services to individuals (other than high net worth individuals), high net worth individuals. pension and profit-sharing plans, trust estates, charitable organizations, and corporations. EAM manages advisory accounts on a discretionary basis. We invest client accounts, primarily in mutual fund shares. Account supervision is guided by the stated objective of the client (i.e., maximum capital appreciation, growth, income, or growth and income). In certain instances, where deemed appropriate by EAM, we may invest in exchange traded funds (“ETFs”) for certain client accounts. EAM may purchase or sell an individual security when requested by a client. Such transactions are not part of EAM’s discretionary authority and clients will not be charged an advisory fee for these securities. EAM will not render an opinion regarding such buys or sells, they are provided as a matter of convenience only. Generally, most requests will be to liquidate securities held by the client, with the sale proceeds being “managed” as part of the portfolio. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest 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; • Never put our financial interests ahead of yours when making recommendations; • 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 interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. For more information about our conflicts of interest, please review items 5, 10, 11 and 14 or reach out to us using the contact information on the cover page of this brochure. As of March 31, 2026, EAM managed approximate $140,218,941.00 on a discretionary basis. commencement of each fiscal quarter equal to $50.00 Item 5 - Fees and Compensation For the advisory services provided, each client agrees to pay the advisor a fee for, and in advance at the (Non-refundable Computer/Administrative fee) plus a percentage of the value of the assets of the portfolio as of the close of trading on the last business day of the quarter according to the following schedule: Portfolio Assets $0-$999,999 next $1,000,0000 balance over $2,000,000 Quarterly fee .25% .20% .15% *A minimum account size of $250,000 is required for this service* 4  Typically, fees will be debited quarterly in advance directly from custodial accounts. Clients may pay by check at the discretion of EAM. Should the investor’s relationship with the advisor commence at some date other than the first day of the investors fiscal or calendar quarter, then the advisor’s fee for the first quarter will be pro-rated based upon the number of days Advisory Services are provided during that quarter. Administrative fees are negotiable at the discretion of EAM and may be discounted based on certain family relationships. This agreement may be terminated at any time by either party giving written notice to the other party. Advisory fees are refunded on a pro-rated basis, based upon the number of days the client utilized Our service. Client has the right to terminate the agreement within five business days from inception without penalty. General Information on Fees: Fees are not negotiable for new clients; however, this policy may be changed at the discretion of EAM. In certain circumstances account minimum may be negotiated. All fees paid to EAM for Investment Advisory Services are in addition to the fees and expenses charged at the product level to shareholders of ETFs and mutual fund shares. Clients should be aware that brokers or dealers may impose sales charges, transaction fees, commissions or other expenses for ETF and mutual fund investments. Clients will be responsible for any of the charges, commissions or fees imposed by ETFs, mutual funds or broker/dealers as a result of implementing EAM’s strategy. Descriptions of these fees are generally available from each product or service provider and should be reviewed carefully. Certain mutual funds may charge early redemption fees to investors who hold investments in such funds for less than a specified period of time. In the course of managing a client’s account, EAM could cause clients to incur such fees if it decides to sell a position before the holding period has expired. Additionally, terminated clients who choose to liquidate their holdings may also incur such fees. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. Item 6 -Performance Based Fees and Side-by-Side Management EAM does not charge any performance-based fees. Item 7 - Types of Clients EAM provides this service to individuals, pension and profit-sharing plans, trust estates, charitable organizations, non-profits and corporations. EAM requires a minimum account of $250,000 for Investment Advisory Services clients. Account minimums are negotiable at Our discretion. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss EAM utilizes publicly available research as well as information provided by various internet and television media outlets discussing business and financial news as part of EAM’s on-going research activities. Risk of Loss - General All investing involves a risk of loss and the investment strategy offered by EAM could lose money 5  over short or even long periods. Performance could be negatively impacted by a number of different market risks including, but not limited to, that portfolio management techniques used by EAM may not produce the desired results. This could cause accounts to decline in value. EAM selects investments based, in part, on information provided by issuers to regulators or made directly available to EAM by the issuers or other sources. EAM is not always able to confirm the completeness or accuracy of such information, and in some cases, complete and accurate information is not available. Incorrect or incomplete information increases risk and may result in losses. Potential Risks of Investing in Securities Purchased in Mutual Funds, ETFs, and by Investment Managers: Stock Market Risk - Stock market risk is the possibility that stock prices overall will decline over short or extended periods. Markets tend to move in cycles, with periods of rising prices and periods of falling prices. Investing in small- and medium-sized companies involves greater risk than is customarily associated with more established companies. Stocks of such companies may be subject to more volatility in price than larger company securities. Foreign Securities Risk - Foreign securities are subject to the same market risks as U.S. securities, such as general economic conditions and company and industry prospects. However, foreign securities involve the additional risk of loss due to political, economic, legal, regulatory, and operational uncertainties; differing accounting and financial reporting standards; limited availability of information; currency conversion; and pricing factors affecting investment in the securities of foreign businesses or governments. Interest Rate Risk - Bonds also experience market risk as a result of changes in interest rates. The general rule is that if interest rates rise, bond prices will fall. The reverse is also true: if interest rates fall, bond prices will generally rise. A bond with a longer maturity (or a bond fund with a longer average maturity) will typically fluctuate more in price than a shorter-term bond. Because of their very short-term nature, money market instruments carry less interest rate risk. Credit Risk - Bonds and bond mutual funds are also exposed to credit risk, which is the possibility that the issuer of a bond will default on its obligation to pay interest and/or principal. U.S. Treasury securities, which are backed by the full faith and credit of the U.S. Government, have limited credit risk, while securities issued or guaranteed by U.S. Government agencies or government-sponsored enterprises that are not backed by the full faith and credit of the U.S. Government may be subject to varying degrees of credit risk. Corporate bonds rated BBB or above by Standard & Poor's are generally considered to carry moderate credit risk. Corporate bonds rated lower than BBB are considered to have significant credit risk. Of course, bonds with lower credit ratings generally pay a higher level of income to investors. Liquidity Risk - Liquidity risk exists when a particular security is difficult to trade. A mutual fund’s investment in illiquid securities may reduce the returns of the mutual fund because the mutual fund may not be able to sell the assets at the time desired for an acceptable price, or might not be able to sell the assets at all. Call Risk - Many fixed income securities have a provision allowing the issuer to repay the debt 6  early, otherwise known as a "call feature." Issuers often exercise this right when interest rates are low. Accordingly, holders of such callable securities may not benefit fully from the increase in value that other fixed income securities experience when rates decline. Furthermore, after a callable security is repaid early, a mutual fund would reinvest the proceeds of the payoff at current interest rates, which would likely be lower than those paid on the security that was called. Objective/Style Risk - All of the mutual funds and investment managers are subject, in varying degrees, to objective/style risk, which is the possibility that returns from a specific type of security in which a mutual fund or manager invests will trail the returns of the overall market. U.S. Government Agency Securities Risk - Securities issued by U.S. Government agencies or government-sponsored entities may not be guaranteed by the U.S. Treasury. If a government- sponsored entity is unable to meet its obligations, the securities of the entity will be adversely impacted. Third Party Investment Management Risk – EAM will likely not have the opportunity to evaluate in advance the specific investments made by third-party managers of the actively managed mutual funds selected by EAM. As a result, the rates of return to clients will primarily depend upon the choice of investments of these managers and returns could be adversely affected by unfavorable performance of such managers. Further, EAM depends on these managers to develop the appropriate systems and procedures to control operational risks. Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues - Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading) rapidly around the world since its initial emergence in China in December 2019 and has severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long-term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak). Impact of Tariffs on Investments Risk: Investing in markets affected by tariff policies carries significant risks that may negatively impact the value of investments. The U.S. President has the authority to impose, 7  increase, or modify tariffs on imports and exports, which can lead to higher costs for businesses, supply chain disruptions, and retaliatory trade measures from other countries. Tariffs may cause: Increased costs for companies reliant on imported goods, potentially reducing profitability. • • Market volatility as investors react to trade uncertainties. • Reduced global trade activity, impacting economic growth and corporate earnings. • Sector-specific disruptions, particularly in industries heavily dependent on international supply chains (e.g., technology, manufacturing, agriculture). There is no certainty regarding the duration, scope, or future changes to tariff policies, which may create an unpredictable investment environment. Investors should consider the potential impact of tariffs on specific industries and the broader economy when making investment decisions. Item 9 - Disciplinary Information EAM and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a client’s evaluation of the company or its personnel. Item 10 - Other Financial Industry Activities and Affiliations EAM and its employees do not have any relationships or arrangements with other financial services companies that pose material conflicts of interest. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EAM and their related person(s) may buy or sell for themselves securities that are also recommended to clients. EAM has adopted a Code of Ethics (“COE”), which describes our standard of business conduct and fiduciary duty to you and includes provisions relating to the confidentiality of your information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and entertainment items, and personal securities trading procedures, among other things. The COE requires that all employees act in accordance with all applicable federal and state securities laws. Our COE requires Employees to 1) pre-clear certain personal securities transactions, 2) report personal securities transactions on at least a quarterly basis, and 3) provide a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such Employees have a direct or indirect beneficial interest. A copy of advisor’s COE is available to any client or prospective client upon request. Item 12 - Brokerage Practices For discretionary clients, EAM requires that Clients sign an investment advisory agreement that provides EAM with written authority to determine which securities and the amounts of securities that are bought and sold. Any limitations of this discretionary authority shall be included in the written advisory agreement. Clients may change/amend these limitations by submitting the request in writing. Clients whose assets are invested in non-OneSource mutual funds will incur transaction 8  fees on purchases and redemptions of such funds when executed through Charles Schwab & Company, Inc. (“Schwab”). In these instances, EAM retains the authority to approve the commission rate paid, without obtaining specific client consent. EAM participates in the Schwab Institutional (SI) program offered to Independent Investment Advisors by Schwab, an NASD registered broker dealer. EAM recommends to clients that they choose Schwab as their broker so that they can participate in the One-Source program. Schwab currently provides EAM with access to institutional trading and custody services which may not be available to Schwab retail investors. Schwab’s services include brokerage, custody, research and access to mutual funds and other investments generally available only to institutional investors or would require a significantly higher minimum investment. For client accounts maintained in its custody, Schwab generally does not charge separately for custody, but may be compensated by account holders through commissions or other transaction- related fees for securities trades that are executed through Schwab or settle into Schwab accounts. Schwab may provide software and other technology that provide access to client account data, facilitate trade execution, provide research, pricing information and other market data, facilitate payment of fees to the Advisor from client accounts and assist with back-office functions such as record keeping and client reporting. While as a fiduciary, EAM endeavors to act in its clients best interests, EAM’s recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit EAM receives from the products and services previously mentioned and not solely on the nature, cost or quality of custody and brokerage services by Schwab, which may create a potential conflict of interest. EAM does not currently maintain any formal soft dollar arrangements. However, Schwab provides EAM with proprietary and third-party research and other products and services (i.e., receipt of duplicate trade confirmations and account statements, trading desk access, the ability to aggregate clients’ securities transactions, the ability to directly debit advisory fees from clients’ accounts, receipt of compliance publications, and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors). Registrant has determined that it would obtain Schwab’s research and other products and services regardless of the amount of commissions it generates throughout the year. Therefore, Registrant is not “paying-up” for Schwab’s proprietary and third-party research and other products and services.” Orders for the same Security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating Clients. All Clients participating in each aggregated order shall receive the average price and subject to minimum ticket charges, pay a pro-rata portion of commissions. Item 13 - Review of Accounts Each client account is scheduled for formal review, not less than quarterly. Factors that may result in the immediate review of client accounts include world economic events, change in fund management, or a change in client circumstances. 9  Quarterly reports are made available to clients electronically through the Company’s website. This information includes at least, the results for the quarter ended and the past rolling 12 months. Paper copies of these reports will be mailed to clients upon request. These reports are in addition to custodial statements received by clients from Charles Schwab. Item 14 - Client Referrals and Other Compensation EAM contracts with other unrelated third parties (“solicitors”) to use its best efforts on behalf of EAM to solicit and refer as clients those individuals or entities which it believes are suitable and appropriate for the advisory services provided by EAM. These agreements provide for a percentage of the fees collected by EAM to be paid to the solicitors from those advisory clients who became clients because of the solicitor’s efforts. Subject to existing federal and state securities laws and regulations, solicitors receive such fees on a fully vested basis, so long as the client’s advisory agreement remains in effect. Such agreements are usually for an unspecified duration and are terminable upon notice. Item 15 - Custody All clients’ accounts are held in custody by unaffiliated broker/dealers or banks, but EAM can access clients’ accounts though its ability to debit advisory fees. For this reason, EAM is considered to have limited custody of client assets. Account custodians send statements directly to the account owners on at least a quarterly basis. Clients should carefully review these statements, and should compare these statements to any account information provided by EAM. Item 16 - Investment Discretion For discretionary clients, EAM requires that Clients sign an investment advisory agreement to provide EAM the authority to determine which securities and the amounts of securities that are bought and sold. Any limitations of this discretionary authority shall be included in the written investment advisory agreement. Clients may change/amend these limitations by submitting the request in writing. Item 17 - Voting Client Securities It is EAM’s policy to vote proxies for all mutual fund and ETFs purchased on behalf of client accounts pursuant to EAM’s discretionary authority. We are charged with identifying the proxies upon which Advisor will vote, voting the proxies in the best interest of clients, and submitting the proxies promptly and properly. Our policy is to vote proxies for mutual fund and ETF positions managed by EAM in the interest of maximizing shareholder value. To that end, EAM will vote in a way that it believes, consistent with its fiduciary duty, will cause the issue to increase the most or decline the least in value. Consideration will be given to both the short- and long-term implications of the proposal to be voted on when considering the optimal vote. We have currently identified no conflicts of interest between our client interests and our own within our proxy voting process. Nevertheless, if we determine that EAM is facing a material conflict of interest in voting your proxy, our procedures provide for us to inform any affected clients of the potential conflict in advance and mutually agree on an acceptable manner of handling the potential 10  conflict. Our complete proxy voting policy and procedures are memorialized in writing and are available for your review. In addition, our complete proxy voting record is available to our clients, and only to our clients. Please contact us if you have any questions or if you would like to review either of these documents. In certain instances, client accounts may hold equity securities which are not managed by the EAM. Since equity positions in these accounts are not managed by EAM and fall outside the Advisor’s expertise, EAM will not vote proxies for these securities. Should ECM inadvertently receive proxy or class action information for equity securities held in client accounts, then EAM will forward such information on to Client, but will not take any further action with respect to the voting of such proxy or class action. Since equity positions are not managed by the Advisor, EAM will consider these positions as immaterial to the implementation of the client’s investment strategy and will abstain from voting the proxies in question. Advisor will not exercise class action voting authority over client securities. The obligation to vote client class actions shall at all times rest with client. Client shall in no way be precluded from contacting Advisor for advice or information about a particular class action vote. However, Advisor shall not be deemed to have voting authority solely as a result of providing such advice to client. Should Advisor inadvertently receive class action information for a security held in client’s account, then Advisor will forward such information on to Client, but will not take any further action with respect to the voting of such class action. Item 18 - Financial Information EAM is not aware of any financial condition that would affect its ability to manage client accounts. 11