SCHULMERICH & ASSOCIATES ASSET MANAGEMENT, LLC

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: 3030 Grand Bay Blvd. Unit 332 Longboat Key, FL 34228-4171 Tel: 503-672-7750 Email: Website: schulmerich@comscast.net www.schulmerichandassoc.com January 22, 2026 This brochure provides information about the qualifications and business practices of Schulmerich & Associates Asset Management, LLC, 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 503-672-7750. The information in this brochure has not been approved or verified by the United States Securities and Exchange ADDITIONAL INFORMATION ABOUT SCHULMERICH & ASSOCIATES ASSET Commission, or by any state securities authority. MANAGEMENT, LLC, LLC (CRD #112547) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV i  Item 2: Material Changes Annual Update Material Changes since the Last 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. • Since the last filing of this brochure on October 30, 2025, the following has been updated: Full Brochure Available Item 4 assets under management updated to reflect year end calculation. This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page .................................................................................................................................. i Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 3 Wrap Fee Programs ......................................................................................................................................................... 3 Item 5: Fees and Compensation ....................................................................................................... 4 Client Assets Under Management .............................................................................................................................. 4 Method of Compensation and Fee Schedule .......................................................................................................... 4 Client Payment of Fees ................................................................................................................................................... 5 Additional Client Fees Charged ................................................................................................................................... 5 Prepayment of Client Fees ............................................................................................................................................ 5 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6 External Compensation for the Sale of Securities to Clients ........................................................................... 5 Item 7: Types of Clients ....................................................................................................................... 6 Sharing of Capital Gains ................................................................................................................................................. 6 Description .......................................................................................................................................................................... 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 6 Account Minimums .......................................................................................................................................................... 6 Methods of Analysis ......................................................................................................................................................... 6 Investment Strategy ........................................................................................................................................................ 6 Item 9: Disciplinary Information ..................................................................................................... 9 Security Specific Material Risks .................................................................................................................................. 7 Criminal or Civil Actions ................................................................................................................................................ 9 iii Administrative Enforcement Proceedings ............................................................................................................. 9  Item 10: Other Financial Industry Activities and Affiliations ............................................. 10 Self- Regulatory Organization Enforcement Proceedings ............................................................................... 9 Broker-Dealer or Representative Registration ................................................................................................. 10 Futures or Commodity Registration ...................................................................................................................... 10 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10 Trading ................................................................................................................................................... 10 Code of Ethics Description ......................................................................................................................................... 10 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 11 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 11 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ......................................................................................................... 11 Transactions and Conflicts of Interest .................................................................................................................. 11 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 11 Item 13: Review of Accounts ........................................................................................................... 13 Aggregating Securities Transactions for Client Accounts ............................................................................. 13 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 13 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 13 Item 14: Client Referrals and Other Compensation ................................................................ 13 Content of Client Provided Reports and Frequency ........................................................................................ 13 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 13 Item 15: Custody .................................................................................................................................. 14 Advisory Firm Payments for Client Referrals .................................................................................................... 13 Item 16: Investment Discretion ..................................................................................................... 14 Account Statements ...................................................................................................................................................... 14 Item 17: Voting Client Securities ................................................................................................... 14 Discretionary Authority for Trading...................................................................................................................... 14 Item 18: Financial Information ...................................................................................................... 14 Proxy Votes ...................................................................................................................................................................... 14 Balance Sheet .................................................................................................................................................................. 14 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 15 Item 19: Requirements for State Registered Advisors .......................................................... 15 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 15 Principal Executive Officers and Management Persons ................................................................................ 15 Outside Business Activities ........................................................................................................................................ 15 Performance Based Fee Description...................................................................................................................... 15 Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving Management Persons ................................................................................................................................................... 15 Material Relationship Maintained by this Advisory Business or Management persons with Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17 Issuers of Securities ...................................................................................................................................................... 15 Principal Executive Officer – Stephen Schulmerich ........................................................................................ 17 Item 2 - Educational Background and Business Experience ....................................................................... 17 Item 3 - Disciplinary Information ........................................................................................................................... 17 Item 4 - Other Business Activities ........................................................................................................................... 18 Item 5 - Additional Compensation .......................................................................................................................... 18 Item 6 - Supervision ..................................................................................................................................................... 18 v  Item 4: Advisory Business Firm Description Types of Advisory Services Schulmerich & Associates Asset Management, LLC, LLC (“Schulmerich & Associates”) was founded in 2004. Stephen Schulmerich is 100% owner and CCO. Investment strategies, ASSET MANAGEMENT Schulmerich & Associates offers discretionary asset management services to advisory Clients. Schulmerich & Associates will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Schulmerich & Associates discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. ERISA PLAN SERVICES Schulmerich & Associates provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred Limited Scope ERISA 3(21) Fiduciary. compensation plans as either a 3(21) or 3(38) advisor: Schulmerich & Associates may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor Schulmerich & Associates has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Schulmerich & Associates can help the plan sponsor delegate liability by following a diligent process. 1. • Fiduciary Services are: • Provide investment advice to the Client about asset classes and investment options available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Schulmerich & Associates acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. • Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. - 1 -  • Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. • Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands Schulmerich & Associates’ assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Schulmerich & Associates is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Schulmerich & Associates will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Schulmerich & Associates may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Schulmerich & Associates and Client. 3. Schulmerich & Associates has no responsibility to provide services related to the • following types of assets (“Excluded Assets”): • • • • • • Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or not Other hard-to-value or illiquid securities or property. Excluded Assets will be included in calculation of Fees paid to Schulmerich & Associates on the ERISA Agreement. Specific services will be outlined in detail to each plan ERISA 3(38) Investment Manager. in the 408(b)2 disclosure. Schulmerich & Associates can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Schulmerich & Associates would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. • Fiduciary Services are: • Schulmerich & Associates has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. - 2 -  • • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. • Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands the Schulmerich & Associates’ assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Schulmerich & Associates is not providing fiduciary advice as defined by ERISA to the Plan participants. Schulmerich & Associates will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Schulmerich & Associates may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Schulmerich & Associates and Client. 3. Schulmerich & Associates has no responsibility to provide services related to the • following types of assets (“Excluded Assets”): • • • • • • not Employer securities; Real estate (except for real estate funds or publicly traded REITs); Stock brokerage accounts or mutual fund windows; Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or Other hard-to-value or illiquid securities or property. Client Tailored Services and Client Imposed Restrictions Excluded Assets will be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Wrap Fee Programs 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 Client consent. Schulmerich & Associates does not sponsor any wrap fee programs. - 3 -  Client Assets Under Management Schulmerich & Associates has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $128,512,193 $0 December 31, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT Schulmerich & Associates charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management First $1,000,000 Next $1,000,000 Over$3,000,000 Annual Fee 1.00% 0.75% 0.30% This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Schulmerich & Associates. Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by Schulmerich & Associates with thirty (30) days written notice to Client and by the Client at any time with written notice to Schulmerich & Associates. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to Schulmerich & Associates. If there is insufficient cash in your account to pay our fees, we will confirm with you the liquidation of securities to the pay the fees. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. When an agreement is terminated, all assets may need to be transferred from the current custodian. You will be responsible for paying all fees, including full quarterly custodial administrative fees, account closure fees, mutual fund fees and all trading costs due to termination. A custodian may assess additional fees for transfer of illiquid investments. If there is insufficient cash in the account, the liquidation of some securities may be used to pay the fees. We will confirm with you the liquidation of securities to pay the fees. Prior to termination of an agreement, we can provide a good-faith estimate of these fees. ERISA PLAN SERVICES - 4 -  The annual fee is negotiable and will be charged based on the total assets under management as follows: Assets Under Management First $1,000,000 Next $1,000,000 Over$3,000,000 Annual Fee 1.00% 0.75% 0.30% Fees will be charged quarterly in arrears based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets). If the services to be provided start any time other than the first day of a quarter, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the billing cycle, Schulmerich & Associates shall be entitled to a prorated fee based on the number of days during the fee period services were provided in the billing cycle. Client Payment of Fees The fee schedule, which includes compensation of Schulmerich & Associates for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. Schulmerich & Associates does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, Schulmerich & Associates will disclose this compensation, the services rendered, and the payer of compensation. Schulmerich & Associates will offset the compensation against the fees agreed upon under the Agreement. Additional Client Fees Charged Fees for asset management services and ERISA 3(21) and/or 3(38) services are either billed from Plan assets or paid directly to Schulmerich & Associates. Prepayment of Client Fees 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 disclosed in the fund’s prospectus. Schulmerich & Associates does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to Schulmerich & Associates. For more details on the brokerage practices, see Item 12 of this brochure. External Compensation for the Sale of Securities to Clients Schulmerich & Associates does not require any prepayment of fees. Investment Advisor Representatives of Schulmerich & Associates receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and Schulmerich & Associates’ fiduciary obligation to place the - 5 -  best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. 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. Schulmerich & Associates does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for Schulmerich & Associates to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description Account Minimums Schulmerich & Associates generally provides investment advice to individuals, high net worth individuals, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Schulmerich & Associates requires a minimum of $100,000 to open and maintain an account. This minimum does not apply to retirement accounts and exceptions may be made for new accounts that are expected to reach that level in a reasonable period of time. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Investment Strategy Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern Portfolio Theory Schulmerich & Associates uses Modern Portfolio Theory (“MPT”) as the foundation of its investment approach. MPT is an investment decision that theoretically permits an investor Asset Allocation to classify, estimate, and control both the type and amount of expected risk and return. a portfolio's assets according to an individual's Asset allocation is an investment strategy that aims to balance risk and reward by apportioning goals, risk tolerance and investment horizon. The three main asset classes - equities, fixed-income, and cash and equivalents - have different levels of risk and return, so each will behave - 6 -  differently over time. Schulmerich & Associates believes that asset allocation is the Diversification dominant factor in determining total portfolio return. Schulmerich & Associates believes that diversifying a portfolio can both reduce volatility (risk) and increase the potential for higher investment returns. To achieve an appropriate level of diversification in an effort to achieve these objectives, Schulmerich & Associates believes investment portfolios should include a mix of asset classes, including domestic and Rebalancing foreign equities, fixed income securities, real estate, and cash or cash equivalents. Each client portfolio maintains a target asset allocation. At minimum, client portfolios are reviewed each quarter to evaluate the extent to which the actual allocation deviates from the target allocation. Where the deviation is considered excessive, Schulmerich & Associates will recommend the appropriate actions in order to bring the actual allocation back within acceptable range of the target allocation. this process is referred to as "rebalancing" and is utilized with the intent of (1) helping maintain an expected risk level for the portfolio that should be more consistent over time, and (2) systematizing a way to Investment Policy Statements aid the client in "buying low and selling high". It is Schulmerich & Associates objective to have an Investment Policy Statement (“IPS”) for each client. The IPS is a document that outlines the policies and procedures to be followed by Schulmerich & Associates on behalf of the client and is individualized for each client. Topics addressed in a typical IPS may include the client’s investment goals, time horizon, risk tolerance, tax considerations, criteria or investment selection, target asset allocation, overall investment strategy, the trigger for rebalancing procedures to be implemented and Investment Vehicles frequency and type of monitoring and reporting. Schulmerich & Associates selection of investment vehicles supports the asset allocation process. Schulmerich & Associates makes use of broadly diversified, passively managed asset class or index funds in order to obtain exposures to the desired asset classes. Passively managed funds benefit from low costs and minimal trading activity, avoiding market timing and human judgement problems and the tax implications arising from each security trade. By combining individual investments into the overall portfolio’s asset allocation, the objective is to create a well-diversified portfolio with broad market exposures. Security Specific Material Risks The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to Schulmerich & Associates. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment • Market Risk risks and should discuss these risks with Schulmerich & Associates: : The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general - 7 -  • economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines Interest-rate Risk in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as • Reinvestment Risk exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an - 8 -  • Cash and Cash Equivalents Risk: underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Long-term purchases Cash and cash equivalents consist of investments like money market funds, certificates of deposit (CDs), Treasury bills, and short-term government bonds. They are generally considered low-risk compared to other asset classes. While they offer safety, liquidity, and stability, they come with certain risks, such as inflation, interest rate fluctuations, and opportunity costs. • Short-term purchases : Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with • Trading risk inflation. : Investing involves risk, including possible loss of principal. There is no • Structured Notes Risk: assurance that the investment objective of any fund or investment will be achieved. The risks involved with using structured notes are credit risk of the issuing investment bank, illiquidity, and there is a risk to the pricing accuracy as most structured notes do not trade after issuance. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings Schulmerich & Associates and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings Without admitting or denying the allegations, in August of 2025, Stephen Schulmerich entered into a Stipulation and Consent Order with the State of Florida. The State of Florida stated Schulmerich & Associates violated section 517.12(4), Florida Statute (2020) by rendering investment advice from a location within Florida without being registered in Florida. Schulmerich agreed to an administrative fine of $22,000. In 1992 Stephen C. dba Schulmerich & Associates Asset Management (801-21041) was ordered to Cease and Desist (Administrative Proceedings File No. 3-7861) related to recordkeeping and reporting violations. - 9 -  Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration Schulmerich & Associates is not registered as a broker-dealer and no affiliated representatives of Schulmerich & Associates are registered representatives of a broker- dealer. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither Schulmerich & Associates nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Stephen Schulmerich has a financial affiliated business as an insurance agent. He will offer Clients services from those activities. As an insurance agent, he will receive separate yet typical compensation. These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the Recommendations or Selections of Other Investment Advisors and Conflicts of Interest option to purchase these products through another insurance agent of their choosing. Schulmerich & Associates does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of Schulmerich & Associates have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Schulmerich & Associates affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of Schulmerich & Associates. The Code reflects Schulmerich & Associates 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. Schulmerich & Associates’ 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 Schulmerich & Associates 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. - 10 -  Schulmerich & Associates’ Code is based on the guiding principle that the interests of the Client are our top priority. Schulmerich & Associates’ 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. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Schulmerich & Associates 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 Schulmerich & Associates 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 Schulmerich & Associates and its affiliated persons may buy or sell securities that are also held by Clients. In order 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 Schulmerich & Associates with copies of their brokerage statements. The Chief Compliance Officer of Schulmerich & Associates is Stephen Schulmerich. 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 Schulmerich & Associates 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. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Schulmerich & Associates with copies of their brokerage statements. The Chief Compliance Officer of Schulmerich & Associates is Stephen Schulmerich. 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 Schulmerich & Associates 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 - 11 -  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 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 effect 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. Schulmerich & Associates will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees, reporting ability, execution capability (speed and accuracy), financial stability and reputation, access to markets, technology and reporting platforms, quality of client service and availability of investment research and other brokerage services. Schulmerich & Associates 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 Schulmerich & Associates. Schulmerich & Associates does not receive any portion of the trading fees. • Research and Other Soft Dollar Benefits Schulmerich & Associates will recommends the use of Charles Schwab & Co., Inc. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by Schulmerich & Associates from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although Schulmerich & Associates has no formal soft dollar arrangements, Schulmerich & Associates 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, Schulmerich & Associates receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of Schulmerich & Associates. Schulmerich & Associates cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. Schulmerich & Associates does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. • Brokerage for Client Referrals A conflict of interest exists when Schulmerich & Associates receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that Schulmerich & Associates has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Directed Brokerage Schulmerich & Associates does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Not all advisors - 12 -  Aggregating Securities Transactions for Client Accounts require their clients to direct brokerage. Not all advisors require their clients to direct brokerage. Schulmerich & Associates does not generally aggregate (or bunch or block) trades when executing transactions. Bunching is generally done in order to realize more effective trade execution and the cost efficiencies that come from executing larger order sizes. Therefore, fees associated with services may be higher or lower than may be available through other financial service providers. However, Schulmerich & Associates acknowledges our fiduciary responsibility to provide best execution as can reasonably be expected under circumstances available. You are encouraged to discuss any questions that may arise regarding investment policies throughout the course of engagement with us. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Review of Client Accounts on Non-Periodic Basis Accounts are reviewed by the Chief Compliance Officer of Schulmerich & Associates, Stephen Schulmerich or qualified staff members. For investment management and wealth management clients, the frequency of reviews is determined based on the client’s investment objectives, but not less than annually. 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. Content of Client Provided Reports and Frequency 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. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by Schulmerich & Associates’ custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals Schulmerich & Associates receives additional economic benefits from external sources as described above in Item 12. Schulmerich & Associates does not compensate for Client referrals. - 13 -  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 Schulmerich & Associates. Schulmerich & Associates is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Schulmerich & Associates. Item 16: Investment Discretion Discretionary Authority for Trading Schulmerich & Associates requires discretionary authority to manage securities accounts on behalf of Clients. Schulmerich & Associates 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. The client will authorize Schulmerich & Associates discretionary authority as stated within the Investment Advisory Agreement. Schulmerich & Associates allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to Schulmerich & Associates in writing. The Client approves the custodian to be used. Schulmerich & Associates 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 Schulmerich & Associates 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, Schulmerich & Associates will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires 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 Schulmerich & Associates does not serve as a custodian for Client funds or securities and Schulmerich & Associates does not require prepayment of fees of more than $1200 per Client and six months or more in advance. - 14 -  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years Schulmerich & Associates has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Schulmerich & Associates has not had any bankruptcy petitions in the last ten years. Item 19: Requirements for State Registered Advisors Principal Executive Officers and Management Persons Outside Business Activities The education and business background for all executive officers and management persons can be found in the Part 2B of this Brochure. The outside business activities for all executive officers and management persons can be Performance Based Fee Description found in the Part 2B of this Brochure. Neither Schulmerich & Associates nor its management receive performance based fees. Please see Item 6 of the ADV 2A for more information. Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving Management Persons The disclosure of material facts related to arbitration or disciplinary actions for all Material Relationship Maintained by this Advisory Business or Management persons executive officers and management persons can be found in the Part 2B of this Brochure. with Issuers of Securities There are no material relationships with issuers of securities to disclose. - 15 -  S U P E R V I S E D P E R S O N B R O C H U R E Item 1 Cover Page F O R M A D V P A R T 2 B Stephen Schulmerich Office Address: 3030 Grand Bay Blvd. Unit 332 Longboat Key, FL 34228-4171 Tel: 503-672-7750 Email: Website: schulmerich@comscast.net www.schulmerichandassoc.com January 22, 2026 information about Stephen Schulmerich and This brochure supplement provides supplements the Schulmerich & Associates Asset Management, LLC, LLC brochure. You should have received a copy of that brochure. Please contact Stephen Schulmerich if you did not receive the brochure or if you have any questions about the contents of this ADDITIONAL INFORMATION ABOUT STEPHEN SCHULMERICH (CRD #415613) IS supplement. AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV. - 16 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Stephen Schulmerich • Item 2 - Educational Background and Business Experience Year of birth: 1949 • Educational Background: University of Central Arkansas; Engineering; 1991-1992 • Business Experience: • Schulmerich & Associates Asset Management, LLC.; Investment Advisor Representative; 04/2025-Present • Schulmerich & Associates Asset Management, LLC.; Managing Member; 04/2025- Present • Pacific West Securities, Inc.; Re Registered Representative; 06/2000-02/2005 • Pacific Harbor Securities, Inc.; Registered Representative; 02/1994-07/2000 • Royal Alliance Associates, Inc.; Registered Representative; 11/1989-02/1994 Item 3 - Disciplinary Information Integrated Resources Equity Corporation; 03/1987-11/1989 1. Mr. Schulmerich 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 d. 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. 2. Without admitting or denying the allegations, in August of 2025, Stephen Schulmerich entered into a Stipulation and Consent Order with the State of Florida. The State of Florida stated Schulmerich & Associates violated section 517.12(4), Florida Statute (2020) by rendering investment advice from a location within Florida without being registered in Florida. Schulmerich agreed to an administrative fine of $22,000. - 17 -  3. In 1992 Stephen C. dba Schulmerich & Associates Asset Management (801-21041) was ordered to Cease and Desist (Administrative Proceedings File No. 3-7861) related to recordkeeping and reporting violations. 4. Item 4 - Other Business Activities Mr. Schulmerich 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. Stephen Schulmerich has a financial affiliated business as an insurance agent. He will offer Clients services from those activities. As an insurance agent, he will receive separate yet typical compensation. Item 5 - Additional Compensation These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6 - Supervision Mr. Schulmerich receives commissions on the insurance products he sells. He 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. Since Mr. Schulmerich is the sole owner and investment adviser representative of Schulmerich & Associates and 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 schulmerich@comcast.net or 503-672-7750. - 18 -