LYNCH ASSET MANAGEMENT, INC.

Lynch Asset Management, Inc. 16 Creekview Lane Yardley, PA 19067 215-801-1550 (Office) 215-801-5230 (Cell) www.lynchassetmanagement.com Form ADV Part 2A Brochure 2/6/2026 Hours by Appointment Only This brochure provides information about the qualifications and business practices of Lynch Asset Management, Inc. If you have any questions about the contents of this brochure, please contact us at 215-801-1550 or at mark.lynch@lynchassetmanagement.com. 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. Lynch Asset Management, Inc. is a Registered Investment Adviser. Registration of an Investment Adviser does not imply a certain level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them. Additional information about Lynch Asset Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Lynch Asset Management, Inc.’s CRD number is: 159938.  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 MATERIAL CHANGES This brochure is our disclosure document prepared in accordance with the United States Securities and Exchange Commission’s (SEC) current requirements and rules. This brochure provides a summary of Lynch Asset Management, Inc. (“LAM” or the “Adviser”) services and fees, as well as certain business practices and policies, including actual or potential conflicts of interest, among other relevant information. This section provides our clients with a summary of new and/or updated information. • Annual Update: We are required to update certain information at least annually, within 90 days of our firm’s fiscal year end of December 31st. We will provide you with either a summary of the revised information with an offer to deliver the full revised brochure within 120 days of our fiscal year end, or we will provide you with our revised brochure that will include a summary of the changes in this section. • Material Changes: Should a material change in our operations occur, depending on its nature, we will promptly communicate this change to clients (and it will be summarized in this section). “Material changes” requiring prompt notification will include changes of ownership or control, location, disciplinary proceedings, significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s complete understanding of who we are, how to find us, and how we do business. Please note the following material change(s) to our business since our last annual filing on February 6, 2025: • LAM’s regulatory assets under management and the number of accounts serviced have been updated as of January 11, 2026. • In consultation with Vigilant Compliance, LLC, LAM’s Policies and Procedures Manual has been updated to conform to SEC rules and regulations. Other routine updates may have been made to this brochure. To receive a current copy of this brochure at any time, please contact us by telephone at (215) 801-1550 or via email at mark.lynch@lynchassetmanagement.com. 2  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 TABLE OF CONTENTS Material Changes 2 Table of Contents 3 Item 1: Advisory Business Introduction 4 Item 2: Written Acknowledgement of Fiduciary Status 6 Item 3: Fees and Compensation 6 Item 4: Performance-Based Fees and Side-by-Side Management 7 Item 5: Types of Clients 7 Item 6: Methods of Analysis, Investment Strategies, and Risk of Loss 7 Item 7: Disciplinary Information 12 Item 8: Other Financial Industry Activities and Affiliations 12 Item 9: Code of Ethics 12 Item 10: Brokerage Practices 13 Item 11: Review of Accounts 14 Item 12: Client Referrals and Other Compensation 14 Item 13: Custody 14 Item 14: Investment Discretion 14 Item 15: Voting Client Securities 15 Item 16: Financial Information 15 3  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 1. ADVISORY BUSINESS INTRODUCTION LAM is a corporation formed under the laws of the Commonwealth of Pennsylvania. We are an SEC-registered investment advisory firm based in Pennsylvania. LAM was founded by Mark R. Lynch, CFA, who has over 40 years of investment experience as a security analyst and portfolio manager. Mr. Lynch is responsible for all investment strategy, security analysis, and portfolio management decisions for LAM. A graduate of Bucknell University, Mr. Lynch also holds an M.B.A. from Fordham University. He has been a Chartered Financial Analyst (CFA) since 1991. He is a member of the CFA Institute of New York and the CFA Institute of Philadelphia. Services We provide investment advisory services. Clients seek our counsel on a broad spectrum of investment advisory services, including general wealth management, IRA rollover accounts, and corporate accounts. Our focus is on managing your investment assets in a professional, unbiased manner, catering to your unique needs and circumstances. We will help you develop and execute a plan designed to build and preserve your wealth. As of December 31, 2025, we provided asset management services for 23 accounts, with $330,607,455 in regulatory assets under management. This amount is managed on a discretionary basis, which means you have given us the authority to determine the following without your consent: Securities to be bought or sold for your account; • • Amount of securities to be bought or sold for your account; • Price and timing of security transactions. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will have the opportunity to meet with us periodically to review the assets in your account. Investment Advisory Services The objective of LAM is to generate superior, long-term investment returns with controlled risk exposure by creating diversified, high-quality asset portfolios. Portfolios are structured with three asset classes: equities, fixed income, and cash equivalents, based on the client’s objectives, risk preference, and evaluation of current macroeconomic and financial market trends. The process is disciplined yet flexible enough to achieve each client's goals. We begin by defining the client’s objectives and risk tolerance. Consideration is also given to each client’s tax situation and investment time horizon. We will ask you to provide statements summarizing your current investments, income, and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and any other pertinent information. Based on this information and our global market outlook, LAM develops a customized portfolio for each client to achieve their goals, consistent with their risk tolerance. The investments in the portfolio account may include stocks, bonds, mutual funds, and exchange- traded funds. The next step is to implement our recommendations. This step may involve the sale of existing securities and/or utilization of cash reserves. Once the portfolio is established, we monitor it daily for potential developments and take action as necessary. Finally, we meet with clients periodically to evaluate the relationship, assess their performance, and adjust strategy as needed. You will also receive our Advisory Agreement, which outlines the services you will receive and the associated fees. 4  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 We will: • Review your present financial situation; • Assist you in setting and monitoring goals and objectives; • Advise on asset allocation; • Monitor and evaluate assets under management; • • • Provide research and information on performance; Provide portfolio statements, individual holdings reports, and asset allocation statements as needed; Provide personal consultations as necessary upon your request or as needed. A successful investment management relationship typically involves a clearly defined investment profile, thorough analysis, and regular communication. Steps in our investment management and asset allocation process include, but are not limited to: We will meet with you to define your investment profile. We will ask you questions and listen to what you have to say. Our discussion helps to clarify your investment goals, time horizon, and risk tolerance. In most cases, we’ll meet at your home, business, or another location convenient for you. We will analyze your current holdings. After developing your investment profile, we will examine your existing holdings to determine if the current asset allocation aligns with your objectives. Each of your individual holdings will also be analyzed to identify which assets you may want to keep or eliminate. We will design an investment plan and portfolio tailored to your needs. Since your financial situation is unique, we will develop a customized portfolio tailored to your individual needs. We will also present recommendations regarding the procedures we plan to use to build your portfolio. We will repeat this step until you are comfortable with an investment program tailored to your unique situation. Once your portfolio is established, our ongoing asset management may include monitoring market conditions and periodically communicating with you to determine if your investment profile has changed. If we agree that adjustments to your portfolio are appropriate, we will implement those adjustments. You must notify us promptly when your financial situation, goals, objectives, or needs change. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks, or other securities. These restrictions may be specific to a company, industry sector, asset class, or any other restriction you request. We do not provide tax advice or tax management services. You should always consult with your tax advisor for specific tax advice. Certain assumptions may be made about interest and inflation rates, as well as about past trends and market and economic performance. Past performance is not an indication of future performance. If you decide to engage LAM to provide our services, we will assist you in opening one or more custodial accounts. The funds in your account will be held in a separate account in your name with an independent custodian, not with us. You will enter into a separate custodial agreement with the custodian. This agreement, among other things, authorizes the custodian to take instructions from us regarding all investment decisions for your account. The custodian will affect transactions. You are notified of any purchases or sales through trade confirmations and monthly statements that are provided by the custodian. You will maintain full and complete ownership rights to all assets held in your account at all times, including the right to withdraw securities or cash, participate in proxy voting, and receive transaction confirmations. You will receive, at least quarterly, a statement containing a description of all the activity in your account from the custodian. This statement lists the total value at the start of the month, itemizes all transaction activity during the month, and lists the types, amounts, and total value of securities held as of the end of the month. You may request reviews of your account more frequently. A wrap fee program is an investment program in which the investor pays a single stated fee that covers management fees, transaction costs, fund expenses, and other administrative fees. LAM does not participate in any wrap fee program. 5  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 2. WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS 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 govern retirement accounts. The way we generate revenue may create conflicts with your interests, so we operate under a special rule that requires us to act in your best interests and not put our own ahead of yours. Under this special rule’s provisions, we must: 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 • Meet a professional standard of care when making investment recommendations (give prudent advice), • Never put our financial interests ahead of yours when making recommendations (give loyal advice), • Avoid misleading statements about conflicts of interest, fees, and investments, • • • Give you basic information about conflicts of interest. 3. FEES AND COMPENSATION We provide investment advisory services for a fee. Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third-party investment companies, and other third parties. These include fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other fees and taxes associated with brokerage accounts and securities transactions. Mutual funds, money market funds, and exchange-traded funds also charge internal management fees, which are disclosed in their prospectuses. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees to understand the total amount you will pay. Services similar to ours may be available elsewhere for more or less than the amounts we charge. Our Investment Advisory Agreement outlines the fees charged and their frequency. In investment advisory relationships, we will bill you quarterly, with payment due at the beginning of each quarter. If the advisory contract is terminated before the end of the billing period, you will receive a prorated refund of your quarterly fee within 30 days of termination. The client has the right to terminate this agreement without penalty within 5 business days of entering into it. Investment Advisory Services You may engage us to provide investment advisory services. We will review your financial circumstances, provide recommendations on asset allocation, and implement the appropriate agreed-upon investment strategy. The fee is based on the amount you invest. Payments are assessed at the close of business on the last day of each prior quarter, based upon the value of the assets under management. Clients will receive an invoice shortly thereafter, with payment due 30 days from receipt. Fees will be calculated as follows: Fee:* 0.50% 0.25% Assets Under Management: First $15 million Next $30 million Above $50 million Negotiated Note: In some instances, and in consideration of its relationship with its client, LAM may provide pro bono advisory services. In certain circumstances, advisory fees and account minimums may be negotiable based on prior relationships and related account holdings. Services for charitable organizations may be provided on a pro bono basis or at a fee. 6  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 Some of the strategies we offer involve investing in mutual funds. Load and no-load mutual funds may incur annual distribution charges, sometimes referred to as “12(b) (1) fees”. These 12 (b) (1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. The 12(b) (1) fees, deferred sales charges, and other fee arrangements will be disclosed upon your request and are typically described in the applicable fund’s prospectus. Your account with the custodian may also be charged for certain additional assets we manage on your behalf that are not held by the custodian (e.g., mutual funds, 401(k) plans). Either party may terminate the agreement at any time by giving written notice to the other party. In such cases, fees will be refunded on a pro-rated basis for work that has already been paid for but not completed. 4. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE FEES We do not charge any performance-based fees. These fees are based on a share of capital gains or capital appreciation of the client's assets. 5. TYPES OF CLIENTS We provide investment advisory services to individuals, charitable foundations, and corporations. LAM's principal business is meeting the investment needs of a single family and its various interests. Any new referrals or accounts may be subject to minimum account-size requirements. Several Lynch family accounts are also managed. 6. METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS Equity Style LAM’s objective is to identify great companies at attractive valuations. Our strategy focuses on companies with strong competitive positions, solid management, excellent balance sheets, consistent earnings growth, and the potential to grow revenue through new products and markets. Companies that exhibit these qualities are sustainable, making them attractive long-term investments. This fundamental, company-focused research is the essence of our investment approach. Our focus on valuation mitigates downside risk while increasing potential returns. This discipline avoids popular trends or momentum investing, as seen in the late 1990s with technology stocks. However, we will sell a stock if long-term fundamentals deteriorate, management loses credibility, or the investment thesis becomes invalid. In assessing each company, we examine measures of both absolute and relative valuation. We are, however, disciplined about the price we pay for these companies. Our research process uses many resources, such as: • • • • • • SEC filings and annual reports; Fundamental statistical analysis; Third-party research; Financial periodicals; Corporate rating services; Company websites/Investor Relations Contacts. Fixed-Income Style LAM believes that preserving capital, generating current income, and maintaining liquidity are key objectives in managing fixed income portfolios. Proper positioning along the yield curve, based on economic analysis, interest rate forecasts, and credit analysis, is an essential component of our fixed income management. The firm focuses on the short- and intermediate-term portions of the yield curve, where investors can capture the majority of the market’s returns with significantly less price volatility. Our security selection is centered on creating a diversified portfolio of high-quality bonds rated A or better by 7  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 Moody’s and/or Standard and Poor’s. The objective of our fixed-income portfolios is to generate current income, preserve capital, dampen the volatility of other asset classes, and provide liquidity if needed. Risks We cannot guarantee our analysis methods will yield a return. In fact, a loss of principle is always a risk. Investing in securities involves a risk of loss that you should be prepared to handle. You need to understand that the investment decisions we make for your account are subject to various market, currency, economic, political, and business risks. The investment decisions we make on your behalf may not always yield a profit, and we cannot guarantee a specific level of performance. Exchange-Traded Funds – A type of Investment Company (either an open-end company or UIT) whose objective is to achieve the same return as a particular market index. ETFs differ from traditional open-end companies and UITs because, pursuant to SEC exemptive orders, ETF shares trade on a secondary market and are redeemable only from the fund itself in very large blocks (e.g., 50,000 shares). Index Funds – Describes a type of mutual fund or Unit Investment Trust (UIT) whose investment objective is typically to achieve the same return as a particular market index, such as the S&P 500 Composite Stock Price Index, the Russell 2000 Index, or the Wilshire 5000 Total Market Index. Mutual Funds – The common name for an open-end investment company. Like other types of investment companies, mutual funds pool money from many investors and invest the money in stocks, bonds, short-term money market instruments, or other securities. Mutual funds issue redeemable shares that investors purchase directly from the fund (or through a broker acting on behalf of the fund) rather than from other investors on a secondary market. No-Load Fund – A fund that does not charge any sales load, but not every type of shareholder fee is a “sales load,” and a no-load fund may charge fees that are not sales loads. No-load funds also charge operating expenses. Open-End Company – The legal name for a mutual fund. An open-end company is a type of investment company. Option Contracts – The right, but not the obligation, to buy (for a call option) or sell (for a put option) a specific amount of a given stock, commodity, currency, index, or debt, at a specified price (the strike price) during a specified period of time. For stock options, the number of shares is usually 100. Each option contract has a buyer, referred to as the holder, and a seller, known as the writer. If the option contract is exercised, the writer is responsible for fulfilling the contract by delivering the shares to the appropriate party. In the case of a security that cannot be delivered, such as when an option is index, the contract is settled in cash. For the holder, the potential loss is limited to the p rice paid to acquire the option. When an option is not exercised, it expires. No shares change hands, and the money spent to purchase the option is lost. For the buyer, the upside is unlimited. Option contracts, like stocks, therefore have asymmetric payoff patterns. For the writer, the potential loss is unlimited unless the contract is covered, meaning that the writer already owns the security underlying the option. Option contracts are most frequently used as either leverage or protection. As leverage, optio ns allow the holder to control equity in a limited capacity for a fraction of the cost of the shares. The difference can be invested elsewhere until the option is exercised. As a form of protection, options can guard against near-term price fluctuations by giving the holder the right to buy the underlying stock at a fixed price for a limited time. Risk is limited to the option premium (except when writing options on a security not already owned). However, the costs of trading options (including commissions and bid-ask spreads) are higher on a percentage basis than trading the underlying stock. Additionally, options are highly complex and require significant observation and maintenance. A list of all risks associated with the strategies, products, and methodology we offer is listed below: 1. Fundamental analysis, when used in isolation, has a number of risks: • There are an infinite number of factors that can affect the earnings of a company and its stock price over time. These can include economic, political, and social factors, as well as various company statistics. 8  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 • When using this method with mutual funds, the funds are composed of many companies, and not all of them will be undervalued. • The data used may be at least six months out of date. • It is difficult to give appropriate weightings to the factors. • In the early 1970s and 1980s, price/earnings multiples of 80 or 90 were considered acceptable by some for “blue chip” stocks in the United States. • In the 1980s, in the United States, some biotechnology stocks sold at “50 times sales”. The companies had no earnings and paid no dividends. The new yardstick to value these became “products in the pipeline”. By the late 1980s, most had lost three-quarters of their stock price. • It assumes that the analyst is competent. • A fundamental analyst assumes that other fundamental analysts will form the same view about the company and buy the stock, thus restoring its value and returning the trader or investor a capital gain. In practice, an undervalued company’s stock price can stay at approximately the same level (or decline) for years. • It ignores the influence of random events such as oil spills, product defects , exposure, and acts of God, and so on. • It assumes that there is no monopolistic power over markets. • Even when fundamental analysis reveals an undervalued company or a stock with high growth prospects, it does not tell us anything about the timing of the purchase of the stock. In other words, we may have identified a stock that is grossly undervalued, whose price has been declining for some time, and may continue to do so. 2. Mutual Funds Risk - Mutual funds can offer the advantages of diversification and professional management. As with other investment choices, investing in mutual funds involves risk, and fees and taxes will diminish a fund’s returns. Mutual funds also have features which some clients may view as disadvantages, such as: • Costs Despite Negative Returns – Clients must pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending on when they invest, clients may also be required to pay taxes on any capital gains distributions they receive, even if the fund underperforms after they purchase shares. • Lack of Control – Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells at the timing of those trades. • Price Uncertainty – With an individual stock, you can obtain real-time (or close to real-time) pricing information with relative ease by checking financial websites or by calling your adviser. You can also monitor how a stock’s price changes from hour to hour. With a mutual fund, the price you purchase or redeem shares for will typically depend on the fund’s NAV, which the fund may not calculate until many hours after you have placed your order. In general, mutual funds must calculate their NAV at least once every business day, typically after the major U.S. exchanges close. The following is a list of some general risks associated with investing in mutual funds: 9  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 • Country Risk – The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country’s economy and cause investments in that country to decline. • Currency Risk – The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. This is also called exchange-rate risk. • Income Risk – The possibility that a fixed-income fund’s dividends will decline as a result of falling overall interest rates. • Industry Risk – The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk – The possibility that increases in the cost of living will reduce or eliminate a fund’s real inflation-adjusted returns. • Manager Risk – The possibility that an actively managed mutual fund’s investment adviser will fail to execute the fund’s investment strategy effectively, resulting in the failure of stated objectives. • Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk – The possibility that an investment will go down in value, or “lose money,” from the original or invested amount. 3. Bond Fund Risk - Bond funds generally have higher risks than money market funds, mainly because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds which may include: • Call Risk – The possibility that falling interest rates will cause a bond issuer to redeem, or call, its high-yielding bond before the bond’s maturity date. • Credit Risk – The possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk isles of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those who invest in bonds issued by companies with poor credit ratings will generally face higher risk. • Interest Rate Risk – The risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or treasury bonds. • Prepayment Risk – The chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or “retire”) its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. 4. Stock Fund Risk - Although a stock fund’s value can rise and fall quickly over the short term, historically, stocks have performed better over the long term than other types of investments – including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the greatest risk to investors in stock funds. Stock prices can fluctuate for a wide range of reasons, including the overall strength of the economy and demand for particular products or services. 10  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 Not all stock funds are the same. For example: • Growth funds focus on stocks that may not pay a regular dividend but have the potential for large capital gains. • Income funds invest in stocks that pay regular dividends. • Index funds aim to achieve the same return as a particular market index, such as the S&P 500 Composite Stock Price Index, by investing in all – or perhaps a representative sample – of the companies included in an index. • Sector funds may specialize in a particular industry segment, such as technology or consumer products stocks 5. Alternative Investment Risk - Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • Loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices • Lack of liquidity in that there may be no secondary market for the fund, and none is expected to develop • Volatility of returns • Restrictions on transferring interests in the fund • Absence of information regarding valuations and pricing • Delays in tax reporting • Less regulation and higher fees than mutual funds 6. Overall Fund Risk • Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund go up and down in value. Dividend or interest payments may also fluctuate or stop altogether as market conditions change. • Before you invest, be sure to read a fund’s prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. • While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you will need your money to meet a financial goal in the near term, you probably cannot afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. • Unit Investment Trust (UIT) – A type of investment company that typically makes a one-time “public offering” of only a specific, fixed number of units. A UIT will terminate and dissolve on a date established when the UIT is created (although some may terminate more than fifty years after they are created). UITs do not actively trade their 11  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 investment portfolios. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 7. DISCIPLINARY INFORMATION Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We have no information to disclose here about the firm or any of our investment advisors. We adhere to high ethical standards for all advisors and associates. We strive to do what is in your best interests. 8. OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS Neither LAM nor its representatives are registered as, or have pending applications to become, a broker-dealer or a broker- dealer representative. Neither LAM nor its representatives are registered as, or have pending applications to become, either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor, or an associated person of the foregoing entities. We do not use outside advisors. Mark Lynch is a member of the Chartered Financial Analyst Institute (CFA Institute), the CFA Society of New York, and the CFA Society of Philadelphia. 9. CODE OF ETHICS We adhere to the Chartered Financial Analyst (CFA) Institute’s Code of Ethics. At LAM, we maintain high standards of business conduct and honor our fiduciary duty to you, our client. We do not recommend that clients buy or sell any security in which LAM or a related person has a material financial interest. We may recommend securities to you that we have purchased for our own accounts. We may trade securities in our account that we have recommended to you, provided we place our orders after you have placed yours. This policy is designed to prevent us from benefiting from transactions placed on behalf of advisory accounts. We have established the following restrictions to ensure our fiduciary responsibilities to you are met: • We shall not buy or sell securities for our personal portfolio(s) where this decision is substantially derived, in whole or in part, from our role as an investment advisory representative of LAM unless the information is also available to the investing public on reasonable inquiry. In no case shall we put our own interests ahead of yours. • We emphasize your unrestricted right to decline to implement any advice rendered. However, some securities trade in sufficiently broad markets to permit transactions by clients to be completed without an appreciable impact on the markets of the securities. Under certain circumstances, exceptions may be made to the policies stated above. Records of these trades, including the reasons for the exceptions, will be maintained with our records as required. Responsibility It is the responsibility of all supervisory personnel to ensure that we conduct business with the highest level of ethical standards and in keeping with our fiduciary duties to you. We must put your interests first and avoid outside interests that conflict with them. 12  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal financial information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal to restrict the use of your information. Our Privacy Policy will be sent to you annually or on request. Prohibited Acts The following acts are prohibited: • Employing any device, scheme, or artifice to defraud • Making any untrue statement of a material fact • Purposely omitting to state a material fact necessary to make a statement, in light of the circumstances under which it is made, not misleading • Engaging in any fraudulent or deceitful act, practice, or course of business • Engaging in any manipulative practices Conflicts of Interest We have a duty to disclose potential and actual conflicts of interest. We have a duty to report potential and actual conflicts of interest to management. Gifts (other than de minimis gifts, which are usually defined as having a value under $250.00) should not be accepted from persons or entities doing business with us. Mark Lynch and the employees of LAM may employ the same strategy for their personal investment account as they do for our clients. However, we do not place our orders in a way that benefits from the purchase or sale of a security. We have a fiduciary responsibility to put client interests first. Use of Disclaimers We shall not attempt to limit liability for willful misconduct or gross negligence through the use of disclaimers. Suitability We shall only recommend those investments that we believe are suitable for you based upon your particular situation and circumstances. We have a fiduciary responsibility to our clients, and we strive to act in your best interests. 10. BROKERAGE PRACTICES LAM does not recommend custodians/broker-dealers. When choosing a custodian/broker-dealer, we will adhere to its fiduciary duty to seek "best execution," which is the obligation to execute securities transactions for a client on terms that are most favorable to the client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent. We may also consider the market expertise and research access provided by commissions, including, but not limited to, access to written research, oral communication with analysts, admission to research conferences, and other resources provided by the brokers to aid LAM's research efforts. LAM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. 13  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 Soft Dollars LAM does not engage in soft-dollar commission arrangements. Brokerage for Client Referrals We do not receive any compensation or incentive for referring you to broker-dealers for brokerage trades. Directed Brokerage We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost, but rather whether the transaction represents the best qualitative execution, considering the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Therefore, we will seek competitive commission rates; however, we may not be able to obtain the lowest possible commission rates for account transactions. You may direct us to use a specific broker or custodial firm. In these situations, we may not have the ability to obtain best execution or pricing of services. In a directed brokerage account, you may pay higher brokerage commissions. LAM does not aggregate the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during periods of market volatility. 11. REVIEW OF ACCOUNTS Reviews We will conduct reviews daily. Generally, we will monitor changes in the economy, shifts in the management and structure of a mutual fund or company where your assets are invested, and market shifts or corrections. You should notify us promptly of any changes to your financial goals, objectives, or financial situation, as these may require a review of your portfolio and recommendations for adjustments. Reports You will be provided with account statements from the custodian reflecting the transactions in the account at least quarterly. These confirmations will be delivered to you by your account custodian. You will receive a quarterly review of your portfolio from LAM. You must notify us of any discrepancies in your account or any concerns you may have regarding it. 12. CLIENT REFERRALS & OTHER COMPENSATION We do not receive compensation for referring clients to other firms or managers, and we do not pay anyone to refer clients to us. 13. CUSTODY LAM does not have direct or indirect custody of client assets. We encourage all clients to review their quarterly statements, which they will receive from their custodian. 14. INVESTMENT DISCRETION LAM receives discretionary authority from the client at the outset of an advisory relationship to select the timing, identity, and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular account. Accounts are managed in accordance with LAM’s stated 14  LYNCH ASSET MANAGEMENT, INC. Form ADV Part 2A Brochure Updated February 6, 2026 strategy and typically do not impose limitations on LAM’s investment discretion. LAM observes the investment policies, limitations, and restrictions of its clients when selecting securities and determining transaction amounts and positions. 15. VOTING CLIENT SECURITIES As a matter of firm policy and practice, we do not have the authority to vote proxies on behalf of advisory clients. You remain responsible for receiving and voting proxies for all securities held in your portfolios. We are authorized to instruct the custodian to forward you copies of all proxies and shareholder communications relating to your account assets. 16. FINANCIAL INFORMATION We may be required to provide certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary obligations to you, our client. We have not been the subject of any bankruptcy proceedings. 15