Prowell Financial Management LLC (“PFM”) has been in business since February 2016. Mark Prowell, Courtney Kauffman, and Sarah Lynch are the firm’s owners. PFM provides advice to a select group of clients, who are most typically closely held companies seeking to ensure the succession of the company by ensuring that each of its owners has a financial plan that is consistent with that goal. Each company owner or other key person that receives services from PFM has services specifically tailored to that individual and the company for whom he or she is an owner. These services include financial planning and asset management, but not necessarily the way those concepts are most typically defined within the securities industry. Privately owned companies have specific business issues, including the continuity of ownership, and the risks associated with being controlled by a small group of individuals and families. The company’s best interests are served by maintaining a consistent approach to these issues, where each owner’s individual circumstances are planned and organized, thus in turn limiting the risks to the company as a whole. The coordination of business issues, tax concerns, and investments is actually key to the continuity of the company, and therefore its value. Companies can engage PFM to work with each individual owner, be it a family or an individual, to assist in the coordination and organization of that owner’s financial concerns. Because PFM’s clients are companies and their owners, PFM’s services are more aptly described as management of financial circumstances than financial planning, though planning does play a role. PFM’s goal is to create an organized approach to the complex financial circumstances that surround the individual, acting as the main contact point and advocate for each owner. The process begins with a review of the individual’s financial circumstances, which include current estate plans, trusts, other assets, and investments. At times, the organizational structure of these circumstances can be very complex, with various trusts and family partnerships created to hold and manage the family’s wealth. PFM may also evaluate an individual’s or family’s current insurance needs to ensure that they are protected and the coverage they have is appropriate given the circumstances. If PFM believes that insurance coverage is inadequate, PFM may recommend certain insurance products to clients. Each individual’s circumstances are different, and PFM endeavors to gather as much information as possible in order to make the best recommendations to clients. In the event an insurance product is recommended by an individual associated with PFM, in the event the recommendation is accepted, the product may be purchased on a commission basis through an individual associated with PFM. This presents a conflict of interest, in that the individual will have a financial incentive to recommend an insurance product. To mitigate this conflict, PFM informs clients that they are always free to purchase insurance products through other agents that are not affiliated with

PFM, or to determine not to purchase the insurance product at all. For asset management, PFM does not encourage the placement of assets directly with PFM’s recommended custodian, unless specific circumstances merit a change in custodian. Individuals come to PFM with an array of existing managers, and in many cases, these managers are in PFM’s opinion appropriate choices for the individual’s assets. Where PFM attempts to add value is through the management of these managers: pressing each for specific concessions for the PFM client’s benefit. These concessions can be in the form of fee discounts or adding specific investment restrictions to prevent the overall portfolio from being overly concentrated. Through these reviews, PFM strives to synchronize and consolidate a client’s entire financial life, providing a primary point of contact for the client and their existing managers. Our clients find all of the information they need in one place, organized in a manner that can be easily understood. While not a separate service, PFM may on occasion recommend that a client places assets with a third-party investment adviser. The rationale and investment process associated with such recommendations are more fully described in Item 8. In some limited circumstances, PFM will manage client assets, on a discretionary basis or a non- discretionary basis. Discretionary management means that while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made but we will not seek specific approval of changes to client accounts. Clients can always make deposits or withdrawals in their accounts at any time, or place restrictions on the types of investments in an account or portfolio. Because we take discretion when directly managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and PFM. When a client engages us to provide services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have your approval (either verbally or in writing), prior to each and every transaction, that our proposed change is acceptable to you. If you request, PFM may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from PFM. If you engage any professional recommended by PFM, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Assets Under Management As of December 31, 2023, PFM managed approximately $8,343,637,084 in assets under management of which $1,001,162,103 are managed on a discretionary basis.