MALVERN CAPITAL MANAGEMENT

Item 1: Cover Page F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 5 Great Valley Parkway, Suite 226 Malvern, PA 19355 Tel: 610-979-1462 Website: www.malverncap.com Email: michael@malverncap.com February 19, 2026 This brochure provides information about the qualifications and business practices of Malvern Capital Management, LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 610-979-1462, or by email at: compliance@malverncap.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. A D D I T I O N A L I N F O R M A T I O N A B O U T M A L V E R N C A P I T A L M A N A G E M E N T , L L C ( C R D # 2 9 2 3 9 6 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V i  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing on February 6, 2025, the following material changes have occurred: Item 4 to update the assets under management for the firm. • • We are no longer offering Outsourced Chief Investment Officer Services. Full Brochure Available This Firm Brochure is being delivered as the complete brochure for the Firm. ii  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................. i Item 2: Material Changes ............................................................................................................... ii Annual Update ................................................................................................................................... ii Material Changes since the Last Update ................................................................................... ii Full Brochure Available .................................................................................................................. ii Item 3: Table of Contents ............................................................................................................. iii Item 4: Advisory Business ............................................................................................................. 1 Firm Description ............................................................................................................................... 1 Types of Advisory Services ............................................................................................................ 1 Client-Tailored Services and Client-Imposed Restrictions ................................................ 5 Wrap Fee Programs ......................................................................................................................... 5 Client Assets Under Management ............................................................................................... 5 Item 5: Fees and Compensation ................................................................................................... 5 Method of Compensation and Fee Schedule ............................................................................ 5 Client Payment of Fees .................................................................................................................... 7 Additional Client Fees Charged .................................................................................................... 8 Prepayment of Client Fees ............................................................................................................. 9 External Compensation for the Sale of Securities to Clients ............................................. 9 Item 6: Performance-Based Fees and Side-by-Side Management ................................... 9 Sharing of Capital Gains ................................................................................................................. 9 Item 7: Types of Clients .................................................................................................................. 9 Description ......................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .......................... 9 Methods of Analysis ......................................................................................................................... 9 Investment Strategy...................................................................................................................... 10 iii  Security Specific Material Risks ............................................................................................... 11 Item 9: Disciplinary Information ............................................................................................. 17 Criminal or Civil Actions ............................................................................................................. 17 Administrative Enforcement Proceedings ........................................................................... 17 Self- Regulatory Organization Enforcement Proceedings ............................................... 17 Item 10: Other Financial Industry Activities and Affiliations ........................................ 17 Broker-Dealer or Representative Registration .................................................................. 17 Futures or Commodity Registration ....................................................................................... 18 Material Relationships Maintained by this Advisory Business and Conflicts of Interest .............................................................................................................................................. 18 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest .............................................................................................................................................. 18 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................... 18 Code of Ethics Description .......................................................................................................... 18 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest ......................................................................................................................................... 19 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ......................................................................................................................................... 19 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .............................................................. 19 Item 12: Brokerage Practices .................................................................................................... 19 Factors Used to Select Broker-Dealers for Client Transactions .................................... 19 Aggregating Securities Transactions for Client Accounts ............................................... 20 Item 13: Review of Accounts ...................................................................................................... 21 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ........................................................................................................................... 21 Review of Client Accounts on a Non-Periodic Basis .......................................................... 21 Content of Client-Provided Reports and Frequency ......................................................... 21 iv  Item 14: Client Referrals and Other Compensation .......................................................... 21 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ....................................................................................................................... 21 Advisory Firm Payments for Client Referrals ...................................................................... 21 Item 15: Custody ............................................................................................................................ 21 Account Statements ...................................................................................................................... 21 Item 16: Investment Discretion ................................................................................................ 22 Discretionary Authority for Trading ...................................................................................... 22 Item 17: Voting Client Securities .............................................................................................. 22 Proxy Votes ...................................................................................................................................... 22 Item 18: Financial Information ................................................................................................. 23 Balance Sheet .................................................................................................................................. 23 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients .............................................................................................................. 23 Bankruptcy Petitions during the Past Ten Years ............................................................... 23 Supervised Person Brochure (Part 2B of Form ADV) ....................................................... 24 Principal Executive Officer – Michael Czajka ....................................................................... 25 Item 2 - Educational Background and Business Experience .......................................... 25 Item 3 - Disciplinary Information ............................................................................................ 25 Item 4 - Other Business Activities ............................................................................................ 26 Item 5 – Additional Compensation .......................................................................................... 26 Item 6 - Supervision ...................................................................................................................... 26 Supervised Person Brochure (Part 2B of Form ADV) ....................................................... 27 Principal Executive Officer – James Lawrence Olsen, CFP®, CFA ................................. 28 Item 2 - Educational Background and Business Experience .......................................... 28 Item 3 - Disciplinary Information ............................................................................................ 29 Item 4 - Other Business Activities ............................................................................................ 30 v  Item 5 - Additional Compensation ........................................................................................... 31 Item 6 - Supervision ...................................................................................................................... 31 Supervised Person Brochure (Part 2B of Form ADV) ....................................................... 32 Supervised Person – Louis J. Iovannone Jr., CIMA .............................................................. 33 Item 2 - Educational Background and Business Experience ....................................................................... 33 Item 3 - Disciplinary Information ........................................................................................................................... 33 Item 4 - Other Business Activities ............................................................................................ 34 Item 5 - Additional Compensation .......................................................................................................................... 34 Item 6 - Supervision ..................................................................................................................................................... 34 Supervised Person Brochure (Part 2B of Form ADV) ....................................................... 35 Supervised Person – John W. Eisele ........................................................................................ 36 Item 2 - Educational Background and Business Experience ....................................................................... 36 Item 3 - Disciplinary Information ........................................................................................................................... 36 Item 4 - Other Business Activities .......................................................................................................................... 37 Item 5 - Additional Compensation .......................................................................................................................... 37 Item 6 - Supervision ..................................................................................................................................................... 37 vi  Item 4: Advisory Business Firm Description Malvern Capital Management (“MCM” or the “Advisor”) is a Delaware limited liability company, headquartered in Malvern, Pennsylvania. MCM was formed on January 2, 2018, and is jointly owned by Michael P. Czajka and James L. Olsen. Types of Advisory Services Investment Management Services (IMS) MCM offers Investment Management Services based on the client’s individual objectives, goals, risk tolerance, time horizon, and liquidity needs. We will also review and discuss a client’s prior investment history, as well as family composition and background. For non- Financial Planning clients, MCM will develop a personal investment policy/risk tolerance statement (“IPS”) which MCM uses to construct an investment plan with an appropriate allocation of the client’s managed assets among Malvern Investment Portfolios (MIPs), other investments, or a combination of the two that, in our opinion, is appropriate. Investment recommendations are typically limited to registered open-ended investment companies (mutual funds) and exchange-traded funds (ETFs) or other investments appropriate for the Client. The MIPs are varying asset allocation portfolios designed to meet a certain client objective. These accounts are managed on a discretionary trading basis. When MCM is engaged to provide Investment Management Services, it does so solely on a discretionary basis. MCM will monitor your accounts on an ongoing basis to ensure your portfolio is meeting your asset allocation requirements. Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients have the option of imposing reasonable restrictions on investing in certain securities, types of securities, or industry sectors. As a result of the discussions, a written IPS will be created for the client. MCM does not offer Investment Management Services on a non-discretionary basis. Sub-Advisor Services (SAS) In some instances, MCM IMS accounts may be managed by independent Sub-advisors pursuant to a sub-advisory agreement with a Sub-advisor. In such circumstances, the Sub- advisor will have discretionary power and trading authority for the investment of the Account. MCM shall be responsible for making the suitability determination of the investment strategy that will be implemented in the management of Client’s Account by the Sub-advisor. MCM receives no financial compensation from the Sub-advisor it recommends. If MCM believes a Sub-advisor is no longer suited to provide services to a Client, MCM has the authority under the investment management agreement to terminate and replace such Sub-advisor. MCM will distribute to Clients a copy of the Form ADV Part 2A (“Disclosure Brochure”) for each Sub- advisor managing a portion of the Client’s assets, so that the Client may see additional details regarding the investment strategy and fees payable to such Sub-advisor. Financial Planning Services (FPS) MCM provides advisory services in the form of financial planning. Financial planning in and of itself does not involve the active management of client accounts. MCM’s Financial Planning service assists individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. Financial planning services will take into consideration either individually or a - 1 -  combination of information such as your objectives, overall financial situation, personal and financial goals, risk tolerance and objectives, risks that you are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions, social security, children/relative funding issues, estate issues, and living expenses needed for retirement. It is suggested that Clients continually update us with any changes so that if the updates require changes to your plan, we can make those changes. Otherwise, your plan may no longer be accurate. Based on the data and information compilation, financial planning recommendations are made based on your individual needs. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas generally include, but are not limited to, the following: • Executive Financial Planning • Cash Flow and Debt Management • College Savings • Employee Benefits Optimization • Estate Planning • Financial Goals Insurance • Investment Analysis • • Retirement Planning • Retirement Income & Distribution Planning • Risk Management • Tax Planning Strategies We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We will provide you with contact information for attorneys who specialize in estate planning if you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. In addition, we also recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we will provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. If requested by a Client, MCM will recommend the services of other professionals for the implementation of your Financial Plan. The client always has the right to decide whether to act upon our financial planning recommendations. If the client elects to act on any of the - 2 -  recommendations, the client always has the right to affect the transactions through anyone of their choosing. Financial planning services do not include the implementation of the plan’s investment plan on your behalf. To the extent you want MCM to implement the investments on your behalf, you will need to contract with MCM for Investment Management Services. If a conflict of interest exists between the interests of MCM and the interests of the Client, the Client is under no obligation to act upon MCM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through MCM. Financial plans will be completed and delivered within sixty (60) days, contingent upon the timely delivery of all required documentation. Financial Consulting Services (FCS) MCM provides Financial Consulting Services in the form of project-specific work. Financial consulting in and of itself does not involve the active management of client accounts. MCM’s FCS assists individuals in determining guidelines and outcomes in response to specific client interests or topics. Unlike MCM’s Financial Planning Services, Financial Consulting Services does not include a comprehensive plan and is designed to address specific topics that are of interest to the client. Similar to Financial Planning Services, topics could include personal and financial goals, risk tolerance and objectives, investment knowledge, net worth calculations, income requirements, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions, social security, children/relative funding issues, estate issues, and living expenses needed for retirement. Retirement Plan Services (RPS) MCM provides investment management services to retirement Plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), referred to here as “ERISA Plan Clients”. Each ERISA Plan Client is required to enter into an investment management agreement with MCM describing the services that MCM will perform for the ERISA Plan and agree to by the ERISA Plan Client. Plan Level Fiduciary Services MCM provides investment management services to ERISA Plan Clients that are participant- directed Plans on a discretionary basis as an investment manager under ERISA Section 3(38), and in that capacity, MCM’s investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. MCM offers services in some or all of the following areas, as agreed upon between the ERISA Plan Client and MCM in the written investment management agreement. MCM’s investment management services can include the following: Participant-Directed Plans • MCM will develop an investment policy statement (IPS) for the ERISA Plan Client. The IPS establishes the investment policies and objectives for the ERISA Plan. • MCM will select a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. • MCM will provide ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the ERISA Plan in accordance with the IPS. Under this - 3 -  • authority, MCM may remove and replace the investment alternatives available under the ERISA Plan at its discretion. If the ERISA Plan Client decides to have a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election under the ERISA Plan, MCM will select the investment to serve as the QDIA. The ERISA Plan Client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). • MCM does not provide fiduciary advice (as defined in ERISA) to the ERISA Plan participants. Trustee-Directed / Non-Participant-Directed Plans • MCM will develop an investment policy statement (IPS) for the ERISA Plan Client. The IPS establishes the investment policies and objectives for the ERISA Plan. • MCM will develop asset allocations and portfolio modeling consistent with the • Plan objectives expressed in the IPS. In accordance with the IPS, MCM will identify and select specific investments to populate the asset allocation categories. • As investment results and/or cash flow change the percentage of Plan assets represented by the different asset allocation categories, MCM will provide periodic rebalancing as deemed appropriate in accordance with the IPS. • MCM will adjust the asset allocations as deemed appropriate in accordance with the IPS. • MCM will monitor and measure investment performance and adherence to the IPS. MCM can make changes in the selected investments, if appropriate, and will provide the Client with periodic reporting of investment performance and results. • MCM does not provide fiduciary advice (as defined in ERISA) to the ERISA Plan participants. Potential for Conflict of Interest MCM is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA Clients, IRA owners, and IRAs (collectively, Retirement Account Clients). As such, MCM is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules that are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a Prohibited Transaction Exemption (“PTE”). A conflict of interest would arise, and the prohibited transaction rules would be implicated if MCM were to provide fiduciary advice about Plan distributions and rollovers if it resulted in MCM receiving compensation that it would not have received absent the advice. In that instance, MCM would mitigate this conflict by acting in the best interest of the client. Retirement Rollovers - No Obligation / Conflict of Interest A client or prospective client is under no obligation to engage MCM as the investment adviser for his/her employer-sponsored retirement account. Rather, a client can continue to self-direct his/her retirement account at his/her employer. If the client determines that he/she would like MCM's assistance, MCM shall charge a separate and additional advisory fee for its ongoing - 4 -  advisory services. The client will not incur this separate and additional advisory fee if he/she determines to continue to self-direct his/her account. As a result, any recommendation by MCM that a client engage MCM to manage his/her retirement account presents a conflict of interest since MCM shall derive an economic benefit from such engagement. Again, a client is under absolutely no obligation to engage MCM as the investment adviser for his/her retirement account. Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs MCM does not sponsor any wrap-fee programs. Client Assets Under Management MCM has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $258,119,057 $0 December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule Financial Planning Fees The rate for Comprehensive Financial Planning Services is $2,500. Financial Planning Fees require a $1,200.00 initial deposit paid in advance. These fees and terms are negotiable on a case-by-case basis at the discretion of MCM. The fees to be paid will be outlined in each client’s written agreement. The delivery date of the Financial Plan will be based in part on the date all required pertinent information is received and will be mutually agreed upon with each client. The client may terminate the Agreement at any time before the delivery of the Financial Plan for a full refund. Services are completed and delivered within sixty (60) days, contingent upon timely delivery of all required documentation. MCM reserves the right to waive a portion of the fee should the Client implement the plan through MCM. Financial Consulting Service Fees MCM is compensated for our Financial Consulting Services by receiving fees from clients based on an hourly rate of $500 or a single fixed fee that typically can range from $1,000 to $100,000. FCS Fees are paid in arrears. The hourly fee rate is negotiable on a case-by-case basis at the discretion of MCM. A single fee rate is negotiated on a case-by-case basis with each client and is based on the scope of the services to be provided by MCM. The hourly rate or single fixed fee to be paid, and terms will be outlined in each client’s written agreement. A client may terminate the Financial Consulting Service at any time. - 5 -  Investment Management Fees: MCM offers discretionary direct asset management services to advisory Clients. MCM is compensated for our investment management services by receiving fees from clients based on a percentage of assets under management per the following tiered rate schedule: Total Assets Under Management Up to $500,000 $500,001 to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $3,000,000 $3,000,001 to $5,000,000 $5,000,001 to $10,000,000 Over $10,000,000 Annual Advisor Fee 1.25% 1.00% 0.85% 0.70% 0.60% 0.50% 0.25% The minimum annual fee is $5,000. This fee will not exceed the 3% safe harbor. Investment Management Fees are either charged quarterly in advance, based upon the market value of the assets being managed by MCM on the last day of the previous billing period, or the initial asset value deposit for a new account or billed quarterly, in arrears, and are based on the amount of assets under management on the last day of the prior calendar quarter (“Valuation Date”) as valued by the Client’s Custodian. If margin is utilized, the fees will be billed based on the net asset value of the account. Significant contributions or withdrawals of more than 5% of assets under management to or from the Client’s account during any calendar quarter are prorated daily for the period such funds were actually in the Client’s account. The assets under management of the Client’s account on the Valuation Date shall be correspondingly increased or decreased, as the case may be, for purposes of calculating the Management Fee for the Quarter. In the event of early termination, the client will receive reimbursement of prepaid, unearned fees. Fees and terms are negotiable on a case-by-case basis at the discretion of MCM, resulting in some clients being charged fees that are lower than the fee listed above. Fees are calculated in accordance with the fee schedule outlined in each client’s written agreement. Legacy clients resulting from a merger, acquisition, assignment, or any other transfer of ownership from another advisory firm to Malvern Capital Management may experience higher fees than those disclosed in our standard fee schedule. Their accounts also may not be eligible for householding. Sub-Advisor Services (SAS) Clients having their accounts managed by an independent Sub-advisor pay MCM Investment Management Service fee plus the Sub-advisor fee. In certain circumstances, you will pay a higher Investment Management Service fee if a Sub-advisor is used. The total Investment Management Service fee plus Sub-advisor fee shall not exceed 2.00% per year. Sub-advisor fees are deducted from the Client’s account with MCM’s fee as outlined above. The Sub- advisor’s fee is calculated in the same manner. Retirement Plan Services Fees MCM is a fiduciary under ERISA with respect to investment management services and investment advice provided to ERISA Plan Clients. As such, MCM is subject to specific duties - 6 -  and obligations under ERISA and the IRC that include, among other things, restrictions concerning certain forms of compensation. The fees described below for both Participant Directed Plans and Non-Participant Directed Plans are payable quarterly or monthly in arrears as agreed to under the investment management agreement between MCM and the ERISA Plan Client. Either MCM or the ERISA Plan Client can terminate the investment management or advisory agreement at any time, without penalty, by sending the other party 30 days' prior written notice. Both parties remain responsible for obligations arising under any transactions initiated before the agreement was terminated. MCM is entitled to a fee, prorated for the number of days in the billing period before the effective date of termination, based on the market value of the included assets on the effective date of termination. 3(38) Investment Management for Participant-Directed Plans: The MCM fee for investment management services provided to ERISA participant-directed plans is calculated as of the last business day of each calendar quarter or month by charging the following tiered fee schedule, based on the annual rate, subject to a minimum fee of $5,000 per year: Plan Assets Up to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $5,000,000 Over $5,000,000 Annual Advisor Fee 0.80% 0.60% 0.40% 0.20% 3(38) Investment Management for Non-Participant-Directed Plans: The MCM fee for investment management services provided to ERISA non-participant- directed plans is calculated as of the last business day of each calendar quarter or month by charging the following tiered fee schedule, based on the annual rate, subject to a minimum fee of $10,000 per year: Plan Assets Up to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $5,000,000 Over $5,000,000 Annual Advisor Fee 0.95% 0.80% 0.60% 0.40% Fees and terms are negotiable on a case-by-case basis at the discretion of MCM, resulting in some clients being charged fees that are lower than the fees listed above. Fees are calculated in accordance with the fee schedule set forth in each client’s written agreement. Client Payment of Fees Payment of Investment Management Fees As described in each client’s Investment Management Agreement, each Client shall elect from one of the two options to pay for Investment Management Services: - 7 -  Direct Debit of Fees by Custodian: the applicable account(s). MCM’s • The Custodian will withdraw the amount of the advisory fee due and payable to MCM from Investment Management Agreement authorizes the Custodian to debit the account for the amount of the advisory fee and to directly remit that fee to MCM in compliance with regulatory procedures. MCM will send each Client an invoice itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was assessed. Statements sent to the Client by the Custodian for the period following the applicable billing cycle will reflect the advisory fee paid by the Client to MCM. Pay by Invoice Direct to Client: • MCM will issue an invoice itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was assessed to the Client for MCM services, and the Client pays MCM by check, Electronic Funds Transfer (EFT) or Automated Clearing House (ACH) payment. To elect this option, the Client must select this method of payment from MCM’s Investment Management Agreement and complete the necessary paperwork when electing to pay by EFT or ACH. MCM aggregates assets of clients with multiple accounts when calculating the amount of assets under management, for which fees are applied. Payment of Financial Planning Fees For clients who engaged MCM for Financial Planning Services, MCM will issue an invoice itemizing the Financial Planning Fee. The Client shall pay MCM by check, Electronic Funds Transfer (EFT), or Automated Clearing House (ACH) payment. Payment of Retirement Plan Services Fees For clients who engaged MCM for Retirement Plan Services, MCM will issue or receive from the plan an invoice itemizing the Investment Management Fee. The Client shall pay MCM by check, Electronic Funds Transfer (EFT), or Automated Clearing House (ACH) payment. Payment of Financial Consulting Service Fees For clients who engaged MCM for Financial Consulting Services, MCM will issue an invoice itemizing the FCS fee and the time period covered. The Client shall pay MCM by check, Electronic Funds Transfer (EFT), or Automated Clearing House (ACH) payment. Other Fees Additionally, MCM’s fee does not include the fees charged by mutual funds selected by MCM to be held from time to time in a client’s account. All such fees and expenses will be borne by the client’s account. In addition, certain costs or charges associated with certain securities transactions, including custody, dealer mark-up or mark-downs, and normal broker commissions, are separately charged to the Account by your custodian. MCM’s brokerage practices are discussed more fully in Item 12 of this Brochure. Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options, and exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds also charge internal management fees, which are - 8 -  disclosed in the fund’s prospectus. MCM does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to MCM. For more details on the brokerage practices, see Item 12 of this brochure. Margin interest may also apply for the Client electing to utilize margin on their account(s). Prepayment of Client Fees MCM does not require any prepayment of fees of more than $1200 per Client and six months or more in advance. Fees for financial plans require a $1,200 deposit in advance. Investment management fees are billed monthly or quarterly in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to MCM. External Compensation for the Sale of Securities to Clients MCM does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of MCM. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. MCM does not use a performance-based fee structure because of the conflict of interest. Performance-based compensation may create an incentive for MCM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description MCM currently provides investment management, financial planning, and financial consulting services to a variety of different types of clients, including individuals and high-net-worth individuals. MCM also focuses its marketing efforts on attracting pension and profit-sharing plans, trusts, estates, endowments, foundations, charitable organizations, corporations, and other registered investment advisory firms. Account Minimums MCM requires a minimum of $500,000 to open and maintain an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis In providing discretionary investment management, advisory, and services, and in providing recommendations to non-discretionary clients, we use the investment strategies and methods of analysis, as described below. A discussion of the primary risks associated with these investment strategies is below, although it is not possible to identify all the risks associated with investing. The risks applicable to your account will depend on the nature of the account, its investment strategy or strategies, and the types of securities you hold. Any investment involves a risk of loss and there can be no guarantee that a particular level of return will be - 9 -  achieved. You should understand that you could lose some or all your investment and should be prepared to bear the risk of such potential losses, including through diversification. Our primary method of investment analysis involves developing our macroeconomic and market outlook, considering both short and long-term views. MCM focuses however, on a long-term, strategic approach to developing its asset allocation methodology. Shifts in allocations are driven by changing investment fundamentals and our economic outlook. MCM will adjust its allocation models, typically with relatively small changes rather than significant shifts between asset classes. Exposure to an asset class or investment style is driven by key economic and market-related factors, which may include shifts in valuations, expected earnings growth, or the impact of changing interest rates. MCM employs fundamental valuations and applies its models to evaluate expected returns, risk, and correlation for the asset classes it includes in its investment strategies. Investment Strategy The Malvern Investment Portfolios (“MIPs”) are fully discretionary portfolios that include multiple asset classes and investment vehicles managed within a single account. Strategies may include exposure to both traditional and/or non-traditional asset classes, as described more fully below. MCM manages these diversified strategies with specified investment objectives ranging in risk from conservative to aggressive growth. MCM also manages more concentrated strategies that are designed to complement the Client’s diversified portfolio assets that may be managed away from MCM. As the portfolio manager, MCM determines the specific investment vehicles based on its economic outlook, investment due diligence, and proprietary modeling strategies. The Malvern Investment Portfolios (MIPs) may include allocations to non-traditional investment vehicles (vehicles that generally employ more complex trading strategies, such as selling securities short in anticipation of a drop in their price, using leverage, and purchasing options and futures) if appropriate for a Client. MCM may include non-traditional asset classes, often paired with traditional asset classes, to reduce the volatility of the overall portfolio. The MIPs are generally comprised of mutual funds, ETFs, and select individual securities. In determining a suitable MIP investment strategy for a Client portfolio, several factors are evaluated, including but not limited to: age, job security, savings, income needs, risk tolerance, tax circumstances, charitable giving, debt ratio, and real estate holdings. These are just a few factors considered when determining a Client-specific investment risk tolerance. The amount allocated to an investment style may determine which type of vehicle may be used to manage that portion of the portfolio. A vehicle, such as a passive mutual fund or ETF, will be utilized to allow broad market exposure for lower dollar values. Active mutual funds, individual securities, or other appropriate investments will be used for allocations where MCM seeks active security selection. MCM does not engage in Initial public offerings (IPOs) and IPOs are not available through MCM. - 10 -  Security Specific Material Risks All investment programs offered by MCM have certain risks that the investor bears. MCM’s investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: • General: Investors should carefully consider their risk tolerance before investing. As with all investments, loss of money is a risk of investing that clients should be prepared to bear. • Market Risk: Market risk involves the possibility that investments in equity securities will decline because of falls in the stock market, reducing the value of individual companies' stocks regardless of the success or failure of an individual company's operations. 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. • 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. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Value Style Risk: Investing in "value" stocks presents the risk that the stocks may never reach what the adviser believes are their full market values, either because the market fails to recognize what the adviser considers to be the companies' true business values or because the adviser misjudged those values. In addition, value stocks may fall out of favor with investors and underperform growth stocks during given periods. • Growth Style Risk: To the extent that the portfolio invests in companies that appear to be growth-oriented, the adviser's perceptions of a company's growth potential may be wrong, or the securities purchased may not perform as expected, causing losses to the portfolio. • Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium-cap companies may face a greater risk of business failure, which could increase the volatility of the portfolio. • Management Risk: MCM’s strategy and the strategies employed by the portfolio managers of the underlying investments may fail to produce the intended results. • Company Risk: The value of a portfolio may decrease in response to the activities and financial prospects of an individual company in the portfolio. The value of an individual company can be more volatile than the market as a whole. • Sector/Industry Risk: From time to time, the portfolio may have over-weighted positions in particular market sectors and/or industries, which can be more volatile or underperform relative to the market as a whole. - 11 -  • REIT Risk: When the portfolio invests in REITs, it is subject to risks generally associated with investing in real estate and risks related specifically to their structure and focus, less market liquidity, and greater price volatility. • Foreign Securities Risk: Foreign securities can be more volatile than domestic (U.S.) securities. Securities markets of other countries are generally smaller than U.S. securities markets. Many foreign securities may also be less liquid than U.S. securities, which could affect the portfolio's investments. • Mutual Fund Risk: Mutual funds may not be able to replicate the past performance that was relied upon by MCM in making an investment decision. MCM does not control the underlying investments in a fund therefore, managers of different funds held by a client may purchase the same security, increasing the risk to the client if that security were to fall in value. Additionally, a fund may deviate from the stated investment mandate or strategy which could make the fund less suitable for a client’s portfolio. When the portfolio invests in a mutual fund, including a money market fund, the portfolio will indirectly bear its proportionate share of any fees and expenses payable directly by the mutual fund. Therefore, the portfolio will incur higher expenses, which may be duplicative, and investment returns are reduced by these fees. • Transaction Fee (TF) Mutual Funds: In some cases, MCM may select a TF fund that will incur additional fees. If so, the client will be charged an additional fee. All other fees and expenses described in a fund's prospectus still apply. • Concentration: A strategy that concentrates its investments in a particular sector of the market (such as the utilities or financial services sectors) or a specific geographic area (such as a country or state) may be impacted by events that adversely affect that sector or area, and the value of a portfolio using such a strategy may fluctuate more than a less concentrated portfolio. In addition, certain funds and strategies are “non- diversified,” meaning they focus their investments on a small number of issuers, making them more susceptible to risks affecting such issuers than a more diversified fund or strategy. • Use of Interval Funds: When consistent with a client’s investment objectives, MCM may allocate investment assets to Interval Funds. Investment companies structured as interval funds are generally designed for long-term investors who do not require daily liquidity. Shares in interval funds typically do not trade on the secondary market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds recommended by MCM offer a two to three-week notice period, every quarter, during which the client may seek the redemption of previously purchased interval funds. Sale or transfer may need to await the quarterly permitted sale date. Moreover, the eventual net asset value for the Interval Fund could be substantially different (positive or negative) from the Interval Fund value on the date that the sale was requested. There can be no assurance that any such strategy will prove profitable or successful. o Interval Funds are Illiquid, Long-Term Investments. Interval funds do not provide daily liquidity. Redemption requests are accepted quarterly, and in the event of a full redemption, a portion of the value may be held back - 12 -  pending completion of the fund’s annual audit. Additionally, a substantial portion of the fund’s investments is illiquid, and therefore, the fund itself imposes limitations on investor withdrawals. The fund will only allow a limited number of shares to be redeemed through the share repurchase program, which is subject to the discretion of the Board of Trustees of the interval fund. o Interval Funds May Invest in Private Funds. Investing in private securities carries a variety of risks that are embedded in the interval fund when it makes such private investments. Private Funds are not registered with the Securities and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private investment company at an advantageous price and time. o Since shares of private investment companies are not publicly traded, from time to time, it may be difficult to establish a fair value for the client’s investment in these companies. Private Funds often engage in leveraging and other speculative investment practices that increase the risk of investment loss. A Private Fund’s performance can be volatile. An investor could lose all or a substantial portion of his or her investment. There may be no secondary market for the investor’s interest in the fund. Private Funds can be highly illiquid, and there may be restrictions on transferring interests in the fund. Private Funds are not required to provide periodic pricing or valuation information to investors. Private Funds may have complex tax structures. There may be delays in distributing important tax information. Private Funds are not subject to the same regulatory requirements as mutual funds. Private Funds often charge high fees. The fund's high fees and expenses may offset the fund's trading profits. o Interval Funds Can Hold Investments That Are Difficult to Value. A portion of the portfolio holdings in our funds may be difficult to value because they are not quoted daily or traded on any financial market or exchange. As such, valuation adjustments only occur quarterly and are generally not available until six weeks after the quarter close. Additionally, due to the nature of interim valuation methods employed by investment managers, the realized value of an underlying holding may differ from its carrying value at the time the investment is sold. o Interval Funds May Use Leverage. Our interval funds are permitted to use leverage (i.e., debt) in connection with certain investments or participate in investments with highly leveraged capital structures. Although the use of leverage may enhance returns and increase the number of investments that can be made, leverage also involves a high degree of financial risk and increases the exposure of such investments to factors such as rising interest rates, downturns in the economy, or deterioration in the condition of the assets underlying such investments. Leverage can also amplify losses. - 13 -  • Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF is designed to offer downside protection for a specified period. These ETFs are modeled after options-based structured notes, but are generally cheaper and offer more liquidity. Buffer ETFs are designed to safeguard against market downturns by employing complex options strategies. Buffer ETFs typically charge higher management fees that are considerably more than the index funds whose performance they attempt to track. Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features of these complex products. • Alternative Investments and Derivatives: Alternative investment strategies or derivatives that are often more volatile than other investments and may magnify the vehicle’s gains and losses. A derivative is a security or contract (futures, options, etc.), the value of which fluctuates with the value of another security (i.e., its value is “derived” from the value of another). An investment vehicle that uses derivatives could be negatively affected if the change in the market value of its securities fails to correspond as expected to the underlying securities. Alternative investment products are not for everyone and entail risks that are different from more traditional investments. Alternative investment strategies are intended for sophisticated investors and involve a high degree of risk, including, among other things, the risks inherent in investing in securities and derivatives, using leverage, and engaging in short sales. An investment in an alternative investment product or strategy may be considered speculative and should not constitute a complete investment program, but should be used in conjunction with an overall asset allocation strategy. Diversification and strategic asset allocation do not assure a profit or protect against loss in declining or volatile markets. The potential for a commodity investment vehicle to use derivative instruments, such as futures, options, and swap agreements, to achieve its investment objective may create additional risks that would not be present in the underlying securities themselves, thus raising the potential for greater investment loss. • Private Investments: Investments in Private Investments are subject to unique and additional risks that differ from more traditional investments. Below we provide some of the most relevant risks associated with these investments, which are not designed to be a comprehensive list of all the possible risks. You should review any offering documents associated with a Private Investment before investing to understand the complete list of risks. o Unregistered and Lack of Regulatory Review. Because private placement offerings are exempt from registration requirements at both the state and federal levels, no regulator has reviewed the offerings to make sure the risks associated with the investment and all material facts about the entity raising money are adequately disclosed. o Increased Risk. Private Investments, including real estate investments, notes & debentures, hedge funds, and private equity funds involve a high degree of risk, often engage in leveraging and other speculative investment - 14 -  tax information, are not subject to practices that may increase the risk of investment loss, can be highly illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important the same regulatory requirements as mutual funds, often charge high fees which may offset any trading profits, and, in many cases, the underlying investments are not transparent and are known only to the investment manager. Alternative investment performance can be volatile. An investor could lose all or a substantial amount of the investment. Often, alternative investment funds and account managers have total trading authority over their funds or accounts; the use of a single adviser applying generally similar trading programs could mean a lack of diversification and, consequently, higher risk. There is often no secondary market for an investor’s interest in alternative investments, and none is expected to develop. There may be restrictions on transferring interests in any alternative investment. Alternative investment products often execute a substantial portion of their trades on non-U.S. exchanges. Investing in foreign markets may entail risks that differ from those associated with investments in U.S. markets. Additionally, alternative investments often entail commodity trading, which involves a substantial risk of loss. o Liquidity Risk. We may recommend Private Investments that may not allow withdrawals or redemptions for significant periods, especially if such investments are in illiquid instruments. Furthermore, if faced with significant withdrawal or redemption requests, investment partnerships and other investment entities may elect to suspend redemptions or delay redemption payments. In the event of suspensions or delays, a client may be exposed to an increased risk of illiquidity. o Private Investments with No Track Record. We may recommend Private Investments that may be in an early stage of development, may not have a proven operating history, may be operating at a loss or have significant variations in operating results, may be engaged in a rapidly changing business, may require substantial additional capital to support their operations to finance expansion or to maintain their competitive position, or may otherwise have a weak financial condition. o Real Estate - Investments in real estate properties are subject to the risks associated with changes in the general economic climate, changes in the overall real estate market, local real estate conditions, dependency on management skill, heavy cash flow dependency, overbuilding, extended vacancies of properties, increased taxes and operating expenses, changes in zoning laws, losses due to costs and liability resulting from the clean-up of environmental problems, casualty or condemnation losses, limitations on rents, changes in neighborhood values and the appeal of properties to tenants, the financial condition of tenants, supply of or demand for in an area, accelerated construction activity, competing properties technological innovations that dramatically alter space requirements, the availability of financing, changes in interest rates, competition based on rental rates, energy and supply shortages, various uninsured and uninsurable risks (including possible terrorist activity) and government - 15 -  regulations. In particular, real property owners in the U.S. are subject to federal and state environmental laws which impose joint and several liability on past and present owners and users of real property for hazardous substance remediation and removal costs. Investments in real estate or interests in real estate are generally illiquid. • Margin Borrowings: The use of short-term margin borrowings may result in certain additional risks. For example, if securities pledged to brokers to secure a margin account decline in value, the account of the Client could be subject to a “margin call”, according to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. A mandatory liquidation could result in negative tax consequences. • Covered Calls: The selling (or writing) of covered calls may involve a high degree of risk and may not be suitable for all investors. For a call option that is sold (written), if that option is exercised, the upside potential is limited to the premium received plus the difference between its stock price and the stock purchase price. If the option is not exercised and expires out of the money and has no value, the upside potential is any gain in share value plus the premium received. On the downside, limited protection is provided by the premium received from the call’s sale. The loss potential may be substantial and is limited only by the stock declining to zero. • Long/Short Positions: Long and short investment positions may involve risks different from those normally associated with other types of investment vehicles. It is possible that a mutual fund’s long positions will decline in value at the same time that the value of the securities sold short increases, thus raising the potential for greater investment loss. Market-neutral investing, in using long and short positions, provides no guarantee that it will be successful in limiting the fund’s exposure to domestic stock market movements, capitalization, sector swings or other risk factors. Investment in a strategy involving long and short selling may have higher portfolio turnover rates, which may result in additional tax consequences. Short selling involves certain risks, including additional costs associated with covering short positions and the possibility of unlimited loss on certain short sale positions. • Exchange Traded Funds (ETFs) Risk: When you purchase an ETF share, you purchase an interest in an underlying basket of securities, designed to obtain investment results that correspond generally to the price and yield performance of a particular index of securities, such as the S&P 500. There is no assurance that the ETF investments will match the index it aims to replicate. Investors in ETFs are subject to different risks than investors in mutual funds, as some of these instruments do not issue and redeem shares continuously. As a result, these securities may not be as liquid as open-end mutual funds. The price of these securities trading on an exchange can move independently of, and at a discount to, the net asset value (NAV) of securities comprising the fund's portfolio. • Junk Bond/High-Yield Security Risk: We may invest your assets in Junk Bonds or High-Yield Bond ETFs, or lower-rated securities. Investments in fixed-income securities that are rated below Investment grade can be subject to a greater risk of loss of principal and interest than investments in higher-rated fixed-income securities. The market for high-yield securities may be less liquid than the market for higher-rated securities. High-yield securities are also generally considered to be subject to greater - 16 -  market risk than higher-rated securities. The capacity of issuers of high-yield securities to pay interest and repay principal is more likely to weaken than is that of issuers of higher-rated securities in times of deteriorating economic conditions or rising interest rates. • Non-Traditional Asset Class Funds: Investing in non-traditional funds is similar to the risks associated with investing in mutual funds or ETFs with traditional investment strategies. However, non-traditional funds are also subject to certain risks that are similar to those of alternative investment products. To the extent that a non-traditional fund exercises its investment strategies on a leveraged basis—using debt to enhance returns—the risk of loss is increased and can create large changes in performance results. As in the case of any investment, an investor in non-traditional funds can lose all or a substantial amount of his or her investment. In addition, non-traditional funds are subject to unique strategy-specific risks. Non-traditional asset classes may have restricted liquidity and may be less transparent than listed securities. Non-traditional products may have a much longer time horizon to experience the entire benefit of investing compared to traditional asset classes. MCM does not guarantee that any investment strategy will meet its investment objective or that an account will not suffer a loss. The risks associated with utilizing Sub-Advisors include: • Manager Risk o Sub-Advisor fails to execute the stated investment strategy • Business Risk o Sub-Advisor has financial or regulatory problems • The specific risks associated with the portfolios of the Sub-Advisor, which are disclosed in the Sub-Advisor’s Form ADV Part 2. Item 9: Disciplinary Information Criminal or Civil Actions MCM and its management have not been involved in any criminal or civil action. its management have not been involved in administrative enforcement Administrative Enforcement Proceedings MCM and proceedings. Self- Regulatory Organization Enforcement Proceedings MCM and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of MCM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration MCM is not registered as a broker-dealer, and no affiliated representatives of MCM are registered representatives of a broker-dealer. - 17 -  Futures or Commodity Registration Neither MCM nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest The firm does not maintain any material relationships. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest MCM may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub- Advisor and MCM. Sub-Advisors execute all trades on behalf of MCM in Client accounts. MCM will be responsible for the overall direct relationship with the Client. MCM retains the authority to terminate the Sub-Advisor relationship at MCM’s discretion. In addition to the authority granted to MCM, Clients will grant MCM full discretionary authority and authorize MCM to select and appoint one or more independent investment advisors (“Advisors”) to provide investment advisory services to Client without prior consultation with or the prior consent of Client. Such Advisors shall have all of the same authority relating to the management of Client’s investment accounts as is granted to MCM in the Agreement. In addition, at MCM’s discretion, MCM may grant such Advisors full authority to further delegate such discretionary investment authority to additional Advisors. MCM ensures that before selecting other advisors for the Client, the other advisors are properly licensed or registered as an investment advisor. This practice represents a conflict of interest as MCM may select Sub-Advisors who charge a lower fee for their services than other Sub-Advisors. This conflict is mitigated by disclosures, procedures, and by the fact that MCM has a fiduciary duty to place the best interest of the Client first and will adhere to its code of ethics. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The affiliated persons (affiliated persons include employees and/or independent contractors) of MCM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of MCM affiliated persons and to address conflicts that may arise. The Code defines acceptable behavior for affiliated persons of MCM. The Code reflects MCM and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. MCM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of MCM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. - 18 -  MCM’s Code is based on the guiding principle that the interests of the Client are our top priority. MCM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. recommendations to Clients, or who have access The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Client's purchase or sale of securities, or non- public information regarding the portfolio holdings of any reportable fund, who are involved in to such making securities recommendations that are non-public. MCM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest MCM and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest MCM and its affiliated persons may buy or sell securities that are also held by Clients. To mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide MCM with copies of their brokerage statements. The Chief Compliance Officer of MCM is Michael Czajka. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest MCM does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. To mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide MCM with copies of their brokerage statements. The Chief Compliance Officer of MCM is Michael Czajka. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions MCM will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of - 19 -  considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker, and the financial strength and stability of the broker. MCM will select appropriate brokers based on a number of factors, including but not limited to their relatively low transaction fees and reporting ability. MCM relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by MCM. MCM does not receive any portion of the trading fees. MCM will recommend the use of Fidelity Custody and Clearing Solutions, LLC (“FCCS" or “Fidelity”) or Charles Schwab (“Schwab”). • Research and Other Soft Dollar Benefits to the broker-dealer. Although MCM has no The Securities and Exchange Commission defines soft dollar practices as arrangements under which products or services other than execution services are obtained by MCM from or through a broker-dealer in exchange for directing Client transactions formal soft dollar arrangements, MCM may receive products, research, and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, MCM receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of MCM. MCM cannot ensure that a particular client will benefit from soft dollars or that the client’s transactions paid for the soft dollar benefits. MCM does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. A conflict of interest exists when MCM receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that MCM has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Brokerage for Client Referrals MCM does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. • Directed Brokerage MCM does not allow directed brokerage accounts. Not all advisors require their clients to direct brokerage. Aggregating Securities Transactions for Client Accounts MCM is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of MCM. All Clients participating in the aggregated order shall receive an average share price, with all other transaction costs shared on a pro-rated basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. - 20 -  Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of MCM, Michael Czajka. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, MCM suggests updating at least annually. Review of Client Accounts on a Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client’s own situation. Content of Client-Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by MCM’s custodian. Client receives confirmations of each transaction in the account from the custodian and an additional statement during any month in which a transaction occurs. Performance reports will be provided by MCM at least quarterly to Clients with assets under management. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest MCM receives additional economic benefits from external sources as described above in Item 12. Advisory Firm Payments for Client Referrals MCM does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by MCM. MCM is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of MCM. If MCM is authorized or permitted to deduct fees directly from the account by the custodian: • MCM will provide the Client with an invoice concurrent to instructing the custodian to deduct the fee, stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee; • MCM will obtain written authorization signed by the Client allowing the fees to be deducted; and - 21 -  • The Client will receive quarterly statements directly from the custodian, which disclose the fees deducted. MCM is also deemed to have limited custody due to its Third-Party Standing Letters of Authorization (“SLOA”). MCM and its qualified custodian meet the following seven (7) conditions in order to avoid maintaining full custody and be subject to the surprise exam requirement: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes MCM, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization, and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. MCM has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. MCM maintains records showing that the third party is not a related party nor located at the same address as MCM. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Discretionary Authority for Trading MCM requires discretionary authority to manage securities accounts on behalf of Clients. MCM has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. MCM's discretionary authority is stated within the Investment Advisory Agreement. MCM allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to MCM in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. MCM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes MCM does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, MCM will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires - 22 -  assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because MCM does not serve as a custodian for Client funds or securities, and MCM does not require prepayment of fees of more than $1200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients MCM has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years MCM has not had any bankruptcy petitions in the last ten years. - 23 -  Item 1 Cover Page Supervised Person Brochure (Part 2B of Form ADV) F O R M A D V P A R T 2 B Michael P. Czajka Office Address: 5 Great Valley Parkway, Suite 226 Malvern, PA 19355 Tel: 610-979-1462 Website: www.malverncap.com Email: michael@malverncap.com This brochure supplement provides information about Michael Czajka and supplements the Malvern Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact Michael Czajka if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T M I C H A E L C Z A J K A ( C R D # 1 5 2 9 1 3 7 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . - 24 -  Principal Executive Officer – Michael Czajka • Year of birth: 1963 Item 2 - Educational Background and Business Experience Educational Background: • No formal education after high school. Business Experience: Malvern Capital Management, LLC: • Managing Member, Chief Executive Officer, and Chief Compliance Officer; March 1, 2019 through present • Chief Executive Officer; January 2018 through February 28, 2019 Symons Capital Management, Inc.: • Chief Executive Officer; April 2007 through December 2017 • President and Chief Executive Officer; April 2007 through March 2013 • Managing Director; August 2005 through April 2007 Fred Alger Management: • Vice President of Institutional Marketing; November 2000 through August 2005 ADOC Vending Services: • Chief Executive Officer and Founder; April 1998 through November 2000 Pilgram, Baxter & Associates: • Vice President of Institutional Marketing; April 1997 through April 1998 Crabbe Huson Group: • Vice President of Institutional Marketing; September 1995 through April 1997 Charles Schwab & Company: • Regional Marketing Manager; November 1986 through August 1995 Item 3 - Disciplinary Information A. Mr. Czajka has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: a. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement, or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; b. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; c. Was found to have been involved in a violation of an investment-related statute or regulation; or - 25 -  d. Was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. B. Mr. Czajka never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; b. Was found to have been involved in a violation of an investment-related statute or regulation, or was the subject of an order by the agency or authority a. (a)denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. C. Mr. Czajka has never been the subject of a self-regulatory organization (SRO) proceeding in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or b. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. D. Mr. Czajka has not been involved in any other hearing or formal adjudication in which professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Czajka does not engage in any outside business activities. Item 5 – Additional Compensation Mr. Czajka does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Since Mr. Czajka is the Chief Compliance Officer of MCM and as such he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at michael@malverncap.com or 610- 979-1462. - 26 -  Item 1 Cover Page Supervised Person Brochure (Part 2B of Form ADV) F O R M A D V P A R T 2 B James L. Olsen, CFP®, CFA Office Address: 5 Great Valley Parkway, Suite 226 Malvern, PA 19355 Tel: 610-979-1462 Website: www.malverncap.com Email: jim@malverncap.com This brochure supplement provides information about James Olsen and supplements the Malvern Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact James Olsen if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T J A M E S O L S E N ( C R D # 1 5 9 9 5 1 1 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V - 27 -  Principal Executive Officer – James Lawrence Olsen, CFP®, CFA • Year of birth: 1959 Item 2 - Educational Background and Business Experience Educational Background: • Temple University, MBA in finance, 1988 • Macalester College, BA in English, 1982 Professional Certifications James Olsen has earned certifications and credentials that are required to be explained in further detail. CERTIFIED FINANCIAL PLANNER™ (CFP®) I am certified for financial planning services in the United States by the Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may use these and the CFP Board’s other certification marks (the “CFP Board Certification Marks”). CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold CFP® certification. You may find more information about CFP® certification at www.cfp.net. CFP® professionals have met the CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirements through other qualifying credentials. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, always when providing financial advice - 28 -  and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education hours every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the CFA Institute. CFA certification requirements: • Hold a bachelor’s degree from an accredited institution or have equivalent educational or work experience. • Successful completion of all three exam levels of the CFA Program. • Have 48 months of acceptable professional work experience in the investment decision-making process. • Fulfill society requirements, which vary by society. Unless you are upgrading from an affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors. • Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Business Experience: Malvern Capital Management, LLC: • Managing Member, President, & Chief Investment Officer; April 2018 through present OneSource Retirement Advisors: • Chief Investment Officer; May 2016 through March 2018 First Niagara Bank (formerly Harleysville National Bank): • Chief Market Strategist; April 2010 through May 2016 • Director of research; September 2008 through April 2010 • Portfolio Manager; November 2006 through September 2008 Smart Financial Advisors: • Director of Financial Planning; February 2005 through August 2006 Radnor Financial Advisors: • Vice President and Sr Financial Consultant; January 1993 through February 2005 • Financial Analyst; October 1989 through January 1993 Item 3 - Disciplinary Information E. Mr. Olsen has never been involved in a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction for which he: e. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement, or omissions, wrongful taking of property, - 29 -  bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; f. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; g. Was found to have been involved in a violation of an investment-related statute or regulation; or h. Was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. F. Mr. Olsen never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: c. Was found to have caused an investment-related business to lose its authorization to do business, or the subject of an order by the agency or authority; d. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. G. Mr. Olsen has never been the subject of a self-regulatory organization (SRO) proceeding in which he: c. Was found to have caused an investment-related business to lose its authorization to do business; or d. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. H. Mr. Olsen has not been involved in any other hearing or formal adjudication in which professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Olsen is the treasurer for the Kenworth Open Space Association, a community homeowners' association. This activity accounts for less than 1% of his time, and he is not compensated for this role. This role is not a conflict of interest as it does not involve clients. - 30 -  Item 5 - Additional Compensation Mr. Olsen does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Since Mr. Olsen is supervised by Michael Czajka, Chief Compliance Officer of MCM. Mr. Czajka reviews Mr. Olsen’s work through client account reviews, quarterly personal transaction reports, as well as face-to-face and phone interactions. Mr. Czajka can be reached at Michel P. Czajka or 610-979-1462. - 31 -  Item 1 Cover Page Supervised Person Brochure (Part 2B of Form ADV) F O R M A D V P A R T 2 B Louis J. Iovannone Jr., CIMA Office Address: 5 Great Valley Parkway, Suite 226 Malvern, PA 19355 Tel: 610-979-1462 Website: www.malverncap.com Email: lou@malverncap.com This brochure supplement provides information about Louis J. Iovannone Jr. and supplements the Malvern Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact Louis J. Iovannone Jr. if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T L O U I S I O V A N N O N E J R . ( C R D # 2 9 7 4 6 8 4 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . - 32 -  Supervised Person – Louis J. Iovannone Jr., CIMA • Year of birth: 1956 Item 2 - Educational Background and Business Experience Educational Background: • University of Pennsylvania/The Wharton School; Bachelor of Arts in Marketing; 1986 Professional Certifications Louis J. Iovannone Jr. has earned certifications and credentials that are required to be explained in further detail. Certified Investment Management Analyst (CIMA): Issued by the Investments & Wealth Institute. CIMA designations requirements: • Prerequisites o Three years of financial services experience; and o A satisfactory record of ethical conduct, as determined by the Investments & Wealth Institute Admissions Committee. • Education Requirements o Educational component offered by one of the approved Registered Education o Providers. In-class program at The Wharton School, University of Pennsylvania, or online through Yale School of Management. • Continuing Education Requirements o 40 hours every two years Business Experience Malvern Capital Management, LLC: • Executive Vice President; August, 2019 through present Symons Capital Management, Inc.: • President; April 2013 through May 2019 Manchester Advisors/BPAS- HB&T: • Senior Vice President; July 1999 through April 2013 Item 3 - Disciplinary Information I. Mr. Iovannone has never been involved in a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction for which he: i. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement, or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; j. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; - 33 -  k. Was found to have been involved in a violation of an investment-related statute or regulation; or l. Was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order. J. Mr. Iovannone never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: e. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; f. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending, or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. K. Mr. Iovannone has never been the subject of a self-regulatory organization (SRO) proceeding in which he: e. Was found to have caused an investment-related business to lose its authorization to do business; or f. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. L. Mr. Iovannone has not been involved in any other hearing or formal adjudication in which professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Iovannone is a Committee Member of the Sidney Kimmel Comprehensive Cancer Center (SKCCC) Advocacy Council. The mission is to promote the awareness of Jefferson South Jersey’s ability to provide quality cancer care on its Southern New Jersey campuses for residents of Southern New Jersey. Item 5 - Additional Compensation Mr. Iovannone does not receive any performance-based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Mr. Iovannone is supervised by Michael Czajka, Chief Compliance Officer of MCM. Mr. Czajka reviews Mr. Iovannone’s work through client account reviews, quarterly personal transaction reports, as well as face-to-face and phone interactions. Mr. Czajka can be reached at michael@malverncap.com or 610-979-1462. - 34 -  Item 1 Cover Page Supervised Person Brochure (Part 2B of Form ADV) F O R M A D V P A R T 2 B John W. Eisele Office Address: 5 Great Valley Parkway, Suite 226 Malvern, PA 19355 Tel: 610-979-1462 Website: www.malverncap.com Email: John@malverncap.com This brochure supplement provides information about John W. Eisele and supplements the Malvern Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact John W. Eisele if you did not receive the brochure or if you have any questions about the contents of this supplement. A D D I T I O N A L I N F O R M A T I O N A B O U T J O H N W . E I S E L E ( C R D # 7 6 5 1 9 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . - 35 -  Supervised Person – John W. Eisele • Year of birth: 1941 Item 2 - Educational Background and Business Experience Educational Background: • UCLA; Bachelor of Arts – Political Science; 1963 Business Experience Malvern Capital Management, LLC: Investment Advisor Representative; August, 2024 through present • LPL Financial LLC: Investment Advisor Representative; June 2013 through August 2024 • • Registered Representative; June 2013 through August 2024 First Cornerstone Bank • Vice President; June 2013 through May 2016 Item 3 - Disciplinary Information M. Mr. Eisle has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: m. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; n. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; o. Was found to have been involved in a violation of an investment-related statute or regulation; or p. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. N. Mr. Eisle never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: g. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; h. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his - 36 -  association with an investment-related business; (c) otherwise significantly limiting his investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. O. Mr. Eisle has never been the subject of a self-regulatory organization (SRO) proceeding in which he: g. Was found to have caused an investment-related business to lose its authorization to do business; or h. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. P. Mr. Eisle has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Mr. Eisle has no outside business activities at this time. Item 5 - Additional Compensation Mr. Eisle does not receive any additional compensation or any performance-based fees. Item 6 - Supervision Since Mr. Eisle is supervised by Michael Czajka, Chief Compliance Officer of MCM. Mr. Czajka reviews Mr. Eisle’s work through client account reviews, quarterly personal transaction reports, as well as face-to-face and phone interactions. Mr. Czajka can be reached at michael@malverncap.com or 610-979-1462. - 37 -