A. Description of Firm Lawley Retirement Advisors, LLC (“LRA”) is a Buffalo, New York-based retirement plan consulting firm, founded in 2010. LRA provides customized retirement plan consulting services to plan sponsors, trustees, and other retirement plan fiduciaries. As discussed more fully below, while LRA does not provide portfolio management services to any plan sponsor or its participants, the Firm assists its clients in plan management, consultation and selection of other investment advisers. LRA advises clientele on investment instruments including, among other things, mutual funds, separate accounts, collective investment trusts (“CITs”) and exchange traded funds (“ETFs”) that invest in asset classes such as domestic and foreign equities, fixed income instruments, commodities, and real estate. LRA is registered with the SEC as an investment adviser and is a State of New York limited liability company. The Firm conducts business primarily in New York. LRA is 100% owned by Lawley, LLC. James J. Rehak, Jr. and Todd M. Tevens serve as the Managing Directors of LRA. James J. Rehak, Jr. is designated as the Firm’s Chief Compliance Officer. Lawley, LLC was formed on January 1, 2000 and provides employee benefit consulting from its Buffalo headquarters and various other offices across the state of New York. Lawley, LLC specializes in consulting employers on health and group benefits, executive compensation and other facets of human resources operations. Lawley, LLC is managed by seven consulting partners with extensive experience in all areas of employee benefits. While each consulting partner owns a minority share of Lawley, LLC, Lawley Service, Inc., holds the majority interest. Please see www.lawleyinsurance.com for more information about Lawley, LLC, and the employee benefits division. In December 2015, Lawley-Courier Advisors, LLC (“LCA”) underwent a corporate reorganization (the “Reorganization”) though which Courier Capital Corporation (“Courier”) redeemed its fifty- percent (50%) membership interest in LCA. In connection with the Reorganization, the new registered entity is named Lawley Retirement Advisors, LLC (“LRA” or the “Firm”). After the Reorganization, neither Courier, nor its principals, Bruce Kaz, Randy Ordines, William Gurney and Thomas Hanlon, retains any management, ownership or economic rights with respect to LRA. LRA’s remaining member is Lawley, LLC. Post-Reorganization, LRA will be managed by James Rehak, Jr. and Todd Tevens, and James Rehak, Jr. will serve as LRA’s Chief Compliance Officer. As part of the Reorganization, LRA has filed a succession by application registration with the SEC and is considered a “new” investment adviser in accordance with the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Those LCA client agreements that

have been consented to for assignment have been assumed by LRA in accordance with the terms of the relevant terms of such agreements. If you have any questions relating to the Reorganization, please contact LRA at (716) 849- 8219. B. Retirement Plan Services Through their decades of experience, resources, and technology, LRA’s professionals assist companies in starting-up and/or managing existing retirement plans tailored to the specific needs of the sponsor firm and its employees. During the first stage of LRA’s retirement plan consulting process, LRA professionals will meet with the plan sponsor to understand the investments currently offered and thereafter will provide a strategic assessment of the investment options to help meet the client’s goals and objectives. LRA will then conduct a comprehensive review of the plan’s recordkeeping, administration, and other needs, providing guidance and comparison of available options for recordkeeping platforms, administrators, and new investment options designed to help meet the needs of the participants and plan sponsor. Throughout the process, LRA will provide the client with legislative and compliance information and may meet with the client’s retirement committee to review aspects of the plan and formally document the discussions. Finally, LRA will formulate a communications campaign and monitor employee education to help ensure employee satisfaction. LRA is unique in that it does not manage proprietary mutual funds nor receive compensation from fund companies. Consequently, the Firm’s advice is truly independent of such conflicts of interest. LRA strives to provide diversified investment selections strictly driven by its analytics of the marketplace and what is best for the client’s firm and its employees. LRA designs its retirement plan services to meet the needs of a wide range of investor profiles without causing an overload of investment choices. Through the Firm’s use of preferred partners, LRA is able to deliver fully bundled or unbundled retirement plan solutions, or alternatively, can work with the client’s firm’s existing plan service provider to deliver customized solutions. Lawley Retirement Advisors may provide 3(38) fiduciary services, in which case compensation may be based on either assets under management or a fixed fee. C. Health Savings Account Services LRA partners with HSA Bank and Aspire to provide investment advice on individual Health Savings Accounts. LRA has built investment asset allocation models based on risk tolerance. D. Assets Under Management As of December 2022, the following represents the amount of client assets under management by LRA on a discretionary and non-discretionary basis: Type of Account Assets Under Management (“AUM”) Discretionary $0 Non-Discretionary $ 1,301,091,580 Total: $1,301,091,580