Firm Description Valley Forge Investment Consultants, Inc. (VFIC, the firm, we, or us) is a corporation formed under the laws of the Commonwealth of Pennsylvania. We are an Investment Adviser registered with the SEC since 3/30/16 and previously registered with the Commonwealth of Pennsylvania since 05/23/94. VFIC provides discretionary and non-discretionary investment advice to individuals, high net worth individuals and institutional investors including trusts, estates, charitable organizations, corporations, or other business entities. VFIC provides non-discretionary investment consulting advice to plan sponsors of 401(k) retirement plans while also offering discretionary investment management services to both pooled ERISA plans and participant directed ERISA plans. Firm Ownership VFIC is a privately held corporation. Michael J. Maher, Jr. (Chairman and Chief Executive Officer) and Sean Maher (Vice Chairman) each own 50% of the voting shares of VFIC. Our principal place of business is located in Audubon, Pennsylvania. Firm Management Michael J. Maher, Jr. is the Chairman and Chief Executive Officer of VFIC. Sean Maher is Vice Chairman, Stephen Mumford is President, Trina Menta Hanna is Treasurer, Michael Mallick is Secretary, and Patrick Lannon is Chief Compliance Officer. Types of Advisory Services VFIC primarily provides investment management and consulting services to assist clients with structuring a portfolio of investments based on the particular needs, investment objectives, financial goals, and risk tolerance of each client. We primarily allocate assets among open-end mutual funds, collective investment trusts (CITs) and exchange traded funds (ETFs). For certain clients we recommend investments in privately offered pooled investment vehicles such as hedge funds, private equity funds and, to a lesser extent, private real estate funds sponsored by affiliates of VFIC (Valley Forge Funds) or sponsored by unaffiliated third parties (Non-affiliated Private Funds). In addition, on occasion, for certain clients, we recommend the engagement and/or termination of unaffiliated Third-Party Advisers (Third-Party Advisers) to manage separately managed accounts (SMAs) for specific clients, as appropriate, based on the client’s needs, tax considerations and account size. Retirement Plan Management and Consulting Services VFIC provides retirement plan investment management and consulting services to employee benefit plans and their fiduciaries. VFIC provides non-discretionary investment advice to plan sponsors about asset classes and investment options available for the plan in accordance with the plan’s investment policies and objectives. VFIC provides advice regarding mutual funds and CITs as investment options for employee-benefit plans. Under investment consulting arrangements, the client retains final decision-making authority regarding the initial selection, retention, removal, and addition of investment options. VFIC assists with investment options, development of an investment policy statement (IPS), monitoring investment options and preparing periodic investment reports that document investment performance and conformance to IPS guidelines, assistance with qualified default investment alternatives (QDIA) for participants automatically enrolled that fail to make an investment selection, educating participants in the plan about general investment principles and alternatives under the plan and providing group enrollment meetings. VFIC provides retirement plan investment management and consulting services to qualified employee benefit plans consistent with Section 404(c) of the Employee Retirement Income Securities Act of 1974, as amended (ERISA). VFIC also provides retirement plan investment management and consulting services to non-qualified plan clients that are not subject to ERISA. In each case, the plan fiduciary retains final decision-making authority to accept or reject VFIC’s recommendations and is free to seek independent advice regarding the appropriateness of any recommended services for the plan. Retirement Plan Discretionary Investment Management VFIC provides discretionary investment management services to retirement plans subject to ERISA. Each ERISA plan client is required to enter into an investment management agreement with VFIC describing the services that are to be performed for the ERISA plan. VFIC provides both ERISA fiduciary services and non-fiduciary services to ERISA plan clients. Participant Directed Plans VFIC 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, VFIC’s investment decisions are made in our sole discretion without the ERISA plan client’s prior approval. The plan sponsor and/or trustee is removed from the selection, monitoring, and replacement process and the plan sponsor’s sole responsibility is to monitor VFIC, acting as the 3(38)-investment manager. 3(38) investment management services include the following:
• VFIC will develop an investment policy statement (IPS) for the client. The IPS establishes the investment policies and objectives for the ERISA plan.
• VFIC 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 authority, VFIC has the authority to remove and replace the investment alternatives available under the ERISA plan in its discretion.
• If the plan client decides to have a qualified default investment alternative (QDIA) for participants who fail to make an investment election under the ERISA plan, VFIC will select the investment to serve as the QDIA. The plan client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5).
• When serving as a 3(38)-investment manager, VFIC is only responsible for the investments it selects and will not have any responsibility or liability in regard to other investments offered by the plan. Certain plan sponsors may offer an option for plan participants to utilize self-directed brokerage accounts. VFIC will not manage assets held in such brokerage accounts and will not advise plan participants on any aspect of a self-directed brokerage account. Pooled Plans VFIC provides investment management services to ERISA plan clients that are not participant-directed (i.e., pooled plans) on a discretionary basis. Investment management services include the following:
• VFIC will develop an investment policy statement (IPS) for the client. The IPS establishes the investment policies and objectives for the ERISA plan.
• VFIC will develop asset allocations and portfolio modeling consistent with the plan objectives expressed in the IPS.
• In accordance with the IPS, VFIC 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, VFIC will provide periodic re-balancing as deemed appropriate in accordance with the IPS.
• VFIC will adjust the asset allocations as deemed appropriate in accordance with the IPS.
• VFIC will monitor and measure investment performance and adherence to the IPS. VFIC will make changes in the selected investments, if appropriate, and will provide the client with periodic reporting of investment performance and results. Discretionary Investment Management Services – Individuals, High Net Worth, and Institutions VFIC provides investment management

services to high-net-worth individuals, other individuals, and institutions by assisting clients with structuring a portfolio of investments. VFIC will assist the client in defining investment objectives and overall investment strategies by collecting relevant information such as client objectives, assets, risk tolerance, income needs, investment time horizon and investment experience. Our investment advice and recommendation to individual and institutional clients primarily relate to mutual funds and ETFs. In addition, for certain clients, VFIC recommends investment in Valley Forge Funds and, to a lesser extent, Non-affiliated Funds. On occasion, for certain clients, we recommend the engagement and/or termination of Third-Party Advisers to manage SMAs for specific clients, as appropriate, based on the client’s needs and where the account size meets the Third-Party Adviser’s minimum account size criteria. In cases where a Third-Party Adviser is engaged to manage an SMA for the client, we will monitor the performance of the Third-Party Adviser. The Third-Party Adviser will manage the client’s SMA assets on a fully discretionary basis. Third-Party Advisers do not pay VFIC for the opportunity to manage VFIC client assets. In addition, unless otherwise requested, generally we will provide clients with periodic (but no less than annual) performance reports that encompass all client assets under management, including SMAs managed by Third- Party Advisers, Valley Forge Funds and Non-affiliated Private Funds. Retirement Asset Rollovers For purposes of complying with the Department of Labor’s Prohibited Transaction Exemption 2020-02 (“PTE 2020- 02”) where applicable, we are providing the following acknowledgment to you. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and can engage in a combination of these options): (1) leave the money in the former Employer Plan, if permitted; (2) roll over the assets to a new employer’s plan (if available and rollovers are permitted); (3) rollover Employer Plan assets to an IRA; or (4) cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. We encourage you to discuss your options and review the above-listed considerations with an accountant, third-party administrator, investment adviser to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. If VFIC provides a recommendation as to whether you should engage in an Employer Plan asset rollover, we are acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No investor is under any obligation to roll over retirement plan assets to an account managed by VFIC. By recommending that you roll over your Employer Plan assets to an IRA advised by VFIC, we will earn fees as a result. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by your new employer likely results in little or no compensation to VFIC. We have an economic incentive to encourage investors to roll over Employer Plan assets into an IRA managed by us. Investors can face increased fees when they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by VFIC, the underlying investments (mutual funds, ETFs, or other investments) can also include fees. Custodial and trading fees may also apply. Investing in an IRA with VFIC will typically be more expensive than an Employer Plan. If VFIC recommends that you roll retirement assets from a separate account into an account managed by VFIC, we are likewise acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code. No investor is under any obligation to roll over retirement assets to an account managed by VFIC. By recommending that you roll over retirement assets to an IRA advised by VFIC, we will earn fees as a result. The fees you will pay in a retirement account managed by VFIC may differ from fees you pay in your existing retirement account, depending upon whether you are rolling out of a self-managed retirement account or an account managed by another financial services provider. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by VFIC, the underlying investments (mutual funds, ETFs, or other investments) can also include fees. Services Limited to Specific Types of Investments VFIC’s investment advice primarily relates to open-end mutual funds and ETFs. VFIC also provides advice to employee benefit plan clients on CITs. For individual and institutional accounts, VFIC is authorized to provide advice on certificates of deposit, municipal securities (e.g., 529 plans), variable annuities, Valley Forge Funds, Non-affiliated Private Funds, the engagement and termination of Third-Party Advisers, and other alternative investments. Each client retains the right to impose reasonable restrictions on VFIC’s discretionary authority, such as to direct VFIC to purchase other securities and not to purchase certain securities or types of securities. Additionally, VFIC advises clients on any other type of investment that it deems appropriate based on the client’s stated financial goals and objectives. When appropriate, VFIC will also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment on which the client requests advice. VFIC regularly and continuously monitors the investment performance of the accounts that we manage and the investment options we recommend. If we determine that a given investment option is not meeting our performance expectation or other criteria, or if we believe that a different investment option is more appropriate for our clients’ accounts, then we will generally recommend that the client assets be moved from one investment option to another and/or act with discretion to make the change. Many factors are considered, including tax considerations, in deciding whether a particular client should move assets from one investment option to another. Our investment option search and selection process is the result of extensive internal research and due diligence. The process involves a comprehensive review of macro factors, historical performance data and underlying quantitative analytics. Qualitative measures include such things as investment manager experience and ownership, investment philosophy, staffing, compliance, code of ethics, risk management, policy and procedures and trading efficiencies. VFIC at times utilizes the research and due diligence of other independent consultants for the purpose of obtaining their proprietary review of prospective investment options and investment managers. Discretionary and Non‐Discretionary Assets Under Management As of 12/31/2023, we actively managed $636,586,368 of client assets on a discretionary basis and $1,907,221,855 on a non-discretionary basis, for a total of $2,543,808,223 regulatory assets under management.