4.A. ADVISORY FIRM DESCRIPTION Integrity is a Registered Investment Advisor and consulting practice founded in 2004. Kristofer R. Gray is the Principal and 100% owner. Integrity provides financial planning, asset management, retirement plan consulting, and investment advice to individuals, high net worth individuals, business owners and corporate pension and profit-sharing plans. Our service lines include wealth management, business financial planning, and legacy planning. Integrity’s primary investment focus is asset allocation, with the unique needs of each client being met through custom-tailored investment advice and financial planning solutions. 4.B. TYPES OF ADVISORY SERVICES Wealth Management Wealth management services are provided in the context of several different offerings: the first is the standard wealth management, which is a boutique, high-service level package. At the core, the company’s wealth management services include a portfolio of index and/or actively managed instruments (funds and exchange-traded funds) across a range of asset classes to create a low-cost, tax-efficient macro-diversified portfolio managed in line with client goals and risk tolerance. Portfolios are rebalanced to maintain the target asset allocation and impose discipline with regard to buying and selling of securities. In addition to an investment portfolio, alternative investment strategies may be implemented to complement core holdings to create a holistic approach to asset management and assist in meeting longer-term financial planning goals. In addition to the core strategies provided, Integrity assists clients with the implementation of alternative investment strategies when Accredited Investor, Qualified Client and Qualified Purchaser definitions are met. These strategies include but are not limited to investments in fund of funds and direct private equity, private credit, and private real estate investment trusts. These strategies are applied to a portion of the portfolio managed toward longer-term trends and economic views where all factors of the client’s suitability and liquidity have been met. In some instances, Integrity recommends investment in a private investment fund. Family Office / Investment Consulting Integrity provides investment consulting services to family office clients. Our approach to investment consulting emphasizes risk management and assisting our clients in identifying their investment objectives and designing risk-managed strategies that seek to achieve these objectives. The steps in our investment consulting process include:
• Identification of client goals and cash needs
• Identification of risks to goal-attainment
• Adoption of a written Investment Policy Statement
• Design of asset allocation and other investment strategies, guidelines and policies
• Selection of risk and performance benchmarks for ongoing monitoring
• Recommendation of investment managers or funds
• Ongoing monitoring of risk management and performance Our investment consulting clients often have multiple investment pools, each of which has its own goals and needs. Examples are capital reserves, endowment funds, and pension assets. Distinct policies, strategies, and monitoring processes are usually required for each situation. Our investment consulting services differ from investment management services in that our consulting services do not include the day-to-day selection of securities or trading. Financial Planning Integrity offers Financial Planning services in conjunction with ongoing investment management. Using data provided by the client, along with information we maintain, our team will prepare a plan for clients that covers preservation and transfer of wealth, tax mitigation, financial objectives, and philanthropic goals. Betterment for Advisors Integrity utilizes Betterment for Advisors, a digital wealth management platform generally serving independent investment advisory firms. Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-advisor. MTG LLC, dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of FINRA and the SIPC, serves as broker-dealer and custodian. The services provided by Betterment include:
• Goal-Based Investment Management: Betterment’s goal-based investment platform allows advisors and Clients to identify multiple investment goals for each Client, each with specific portfolio allocations;
• Portfolio Construction Tools: Advisors and Clients have access to a set of portfolio strategies, each of which is comprised of low-cost, index-tracking exchange-traded funds or mutual funds (the latter only for advisors who are approved to construct portfolios with Dimensional Fund Advisors mutual funds), and are able to customize the risk-level for each investment goal;
• Automated Investment Management Services: Betterment’s algorithms automate back- office tasks such as trading, portfolio management, tax loss harvesting, and account rebalancing;

• Website and Mobile Application: Betterment’s website and mobile application provide a platform for account access and monitoring and delivery of account documentation and notices; and
• Advisor Dashboard: Advisors have access to a dashboard for purposes of monitoring and managing Client accounts. 401(k) Plan Management As a boutique consulting firm, we distinguish ourselves by simplifying the complex financial needs of business owners into intentional and well-articulated goals. Integrity also works with business owners to design a qualified retirement plan to meet the unique needs of their employees. Services include plan design, recommended lineup of investment offerings, ongoing investment monitoring, and onsite employee education. The firm may act in either a 3(21) or a 3(38)-fiduciary role pursuant to The Employee Retirement Income Security Act of 1974 (“ERISA”). Implementing a 401(k) plan is an important decision that should incorporate a thoughtful process. Designing a plan that meets the unique needs of owners is equally as important as providing a plan that incentivizes employee retention and participation. As a fee-based, independent Registered Investment Advisor, Integrity specializes in providing business owners and plan sponsors with holistic strategies and a dedicated support team to simplify the complex process of qualified retirement plans. Amidst a heightened and more scrutinized legal environment, Integrity can act as a co-fiduciary guiding the design, implementation, and ongoing management of the plan in order to reduce the burden on plan sponsors. Our personalized employee education program includes group enrollment meetings and one-on-one financial planning ensuring each participant understands the benefit being offered and receives custom-tailored investment advice. It has become more important than ever to consider various types of investments and account types to diversify future taxable income in light of the political uncertainty and increasing national debt. Our team may assist clients in diversifying their tax strategies. Legacy Planning Additionally, we believe that leaving a financial legacy to one’s family and charitable causes requires a thoughtful approach. It is never too early to begin planning for the eventual transition of wealth. Our advisors are available to work with the client’s attorney, CPAs, and/or other representatives regarding matters related to the client’s assets managed by Integrity. Holistic financial planning includes tax planning, insurance planning, retirement planning and estate planning. Financial planning services may include consultations and/or written plans, which analyze a client’s financial situation and include appropriate recommendations for strategies and methods of implementation. Sub-Advisory Services to a Private Fund Integrity serves as discretionary investment subadvisor to the Integrity Diversified Private Equity Insurance Dedicated Fund (IDF), a Series of the SALI Multi-Series Fund, L.P. (the “Integrity Series”). SALI and SALI Fund Partners, LLC are the investment manager and general partner, respectively, of the SALI Multi-Series Fund, L.P. Interests in the Integrity Series are only offered to insurance company investors on behalf of certain of their segregated separate accounts that fund certain variable life insurance contracts. 4.C. CLIENT INVESTMENT OBJECTIVES/RESTRICTIONS Advisors at Integrity Financial work to create a customized plan for clients that weaves together the areas of income planning, asset management, tax diversification, risk management, legacy planning, and charitable giving. Our team of advisors strives to provide clients with a holistic solution to the client’s financial planning. Our advisors work with clients to create an accurate personal balance sheet by consolidating scattered investment accounts and thereby streamlining the management of those funds. Clients may impose restrictions on investing in certain securities or types of securities by providing such restrictions in writing to Integrity. In addition to an investment portfolio, alternative investment strategies may be implemented to complement core holdings to create a holistic approach to asset management and assist in meeting longer-term financial planning goals. 4.D. WRAP FEE PROGRAMS Integrity does not participate in, nor is it a sponsor of any wrap fee programs. 4.E. ASSETS UNDER MANAGEMENT Integrity manages client assets on both a discretionary and non-discretionary basis. As of December 31, 2023, Integrity managed $450,960,245 on a discretionary basis and $98,166,198 on a non- discretionary basis. Integrity also provides investment advice through consulting services to family office clients as well as retirement plans as described above. Integrity has no discretion to affect trades and no supervisory responsibility over the assets advised in this service and categorizes these assets as assets under advisement. As of December 31, 2023, Integrity’s AUA were $357,319,904.