A. Firm Description MLR was formed in January of 2017. MLR is an independent advisory firm that provides one line of advisory services: (a) fee only comprehensive consulting services to 401(k) plans, 403(b) plans, 401(a) Profit Sharing Plans, Defined Benefit plans as well as Non- Qualified Deferred Compensation programs. B. Types of Retirement Plan Services MLR offers Retirement Plan Consulting Services to employer sponsored retirement plans and their participants. Depending on the type of the plan and the specific arrangement with the Sponsor, we may provide one or more of these services. Upon being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2; an Investment Fiduciary & Retirement Plan Consulting Agreement (“Agreement”) for review, along with a copy of our Privacy Policy. We provide the following Retirement Plan Services, as identified below: Discretionary Investment Management Services These services are designed to allow the plan fiduciary to delegate responsibility for managing, acquiring and disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”). We will perform these investment management services through our investment advisor representatives (“IARs”), and may charge a fee for the investment management services, as described in this Form ADV and the Agreement. We will perform these services to the Plan as a fiduciary defined under ERISA Section 3(38) and will act with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Specifically, the Sponsor may determine that we perform the following services: - Selection, Monitoring & Replacement of Designated Investment Alternatives: Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an Investment Policy Statement (“IPS”) that contains criteria from which Advisor will select, monitor and replace the Plan’s Designated Investment Alternatives (“DIAs”). Once approved by Sponsor, Advisor will review the investment options available to the Plan and will select the Plan’s DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, Advisor will monitor and evaluate the DIAs and replace any DIA(s) that no longer meet the IPS criteria. - Selection, Monitoring & Replacement of Qualified Default Investment Alternative(s): Based upon the options available to the Plan, Advisor will select, monitor and replace the Plan’s Qualified Default Investment Alternative(s) (“QDIA(s)”) in accordance with the IPS. - Investment Management: Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS that contains criteria from which Advisor will select, monitor and replace the Plan’s investments. Once approved by Sponsor, Advisor will review the investment options available to the Plan and will select the Plan’s investments in accordance with the criteria set forth in the IPS. On a periodic basis, Advisor will monitor and evaluate the investments and replace any investment(s) that no longer meet the IPS criteria. - Management of Third Party Managers: Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor an IPS or other documentation that contains criteria from which Advisor will select, monitor and replace the Plan’s third-party investment managers. Once the IPS is approved, Advisor will select appropriate managers to manage all or a portion of the Plan’s investments. Advisor will monitor the manager(s) in accordance with the IPS and will replace any manager(s) that is no longer meeting the IPS criteria. Advisor must have a limited power of attorney in order to hire any managers on behalf of the Plan. Nondiscretionary Fiduciary Services These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these nondiscretionary investment advisory services through our IARs, and may charge a fee for these fiduciary services, as described in this Form ADV and the Agreement. We will perform these investment advisory services to the Plan as a fiduciary defined under ERISA Section 3(21) and will act with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. The Sponsor may engage us to perform one or more of the following nondiscretionary investment advisory services: - Investment Policy Statement: Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an Investment Policy Statement (“IPS”), Advisor will provide recommendations to Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, Advisor will review it for consistency with the Plan’s objectives. If the IPS does not represent the objectives of the Plan, Advisor will recommend to Sponsor revisions to align the IPS with the Plan’s objectives. - Advice Regarding Designated Investment Alternatives: Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the investment options available to the Plan and will make

recommendations to assist Sponsor with selecting Designated Investment Alternatives (“DIAs”) to be offered to Plan participants. Once Sponsor selects the DIAs, Advisor will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, Advisor will provide recommendations to assist Sponsor with replacing the DIA. - Advice Regarding Qualified Default Investment Alternative: Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting or replacing the Plan’s Qualified Default Investment Alternative (“QDIA(s)”). - Participant Investment Advice: Advisor will meet with Plan participants, periodically and upon reasonable request, to collect information necessary to identify the participant’s investment objectives, risk tolerance, time horizon, etc. Advisor will provide written recommendations to assist the participant with creating a portfolio using the Plan’s DIAs or Models, if available. The participant retains sole discretion over the investment of their account. - Investment Advice Based on the Plan’s IPS: Advisor will review the investment options available to the Plan and will make recommendations to assist Sponsor with selecting investments that meet the IPS criteria. Once Sponsor selects the investment(s), Advisor will, on a periodic basis and/or upon reasonable request, provide reports and information to assist Sponsor with monitoring the investment(s). If the IPS criteria require any investment(s) to be replaced, Advisor will provide recommendations to assist Sponsor with replacing the investment(s). - Advice Regarding Third Party Managers Based on the Plan’s IPS or other investment guidelines established by the Plan: Advisor will review the third-party investment managers available to the Plan and will make recommendations to assist Sponsor with selecting a manager to manage some or all of the Plan’s investments. Once Sponsor approves the manager(s), Advisor will provide reports, information and recommendations, on a periodic basis, designed to assist Sponsor with monitoring the managers. If the IPS criteria require any manager to be removed, Advisor will provide recommendations to assist Sponsor with evaluating replacement managers. Retirement Plan Consulting Services Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her fiduciary duties to administer the plan in the best interests of plan participants and their beneficiaries. Retirement Plan Consulting Services may only be performed so that they would not be considered fiduciary services under ERISA. The Sponsor may elect for our IARs to assist with any of the following services: Administrative Support - Assist plan sponsor in reviewing objectives and options available through the plan. - Review plan committee structure and administrative policies/procedures. - Recommend participant education and communication policies under ERISA 404(c). - Assist with development/maintenance of fiduciary audit file and document retention policies. - Deliver fiduciary training/education, including providing legislative & regulatory updates, periodically or upon reasonable request. - Assist with coordinating participant disclosures under ERISA 404(a). - Recommend procedures for responding to participant requests. - Facilitate the recording of minutes for Investment Committee meetings. - Assist with annual nondiscrimination testing upon reasonable request. - Assist with the preparation of annual participant notices. - Interface with retirement plan auditors to provide assistance, where feasible (e.g. ASC 820 asset classification, SSAE16 review, etc.). Service Provider Support - Assist fiduciaries with a process to select, monitor and replace service providers. - Assist fiduciaries with review of Covered Service Providers (“CSPs”) and fee benchmarking. - Provide reports and/or information designed to assist fiduciaries with monitoring CSPs. - Assist with use of ERISA Spending Accounts or Plan Expense Recapture Accounts to pay CSPs. - Assist with preparation and review of Requests for Proposals and/or Information. Investment Monitoring Support - Periodic review of investment policy in the context of plan objectives. - Assist the plan committee with monitoring investment performance. - Provide analysis of investment managers and model portfolios (if applicable). - Assist with monitoring Designated Investment Managers and/or third-party advice providers. - Educate plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s). Participant Services - Facilitate group enrollment meetings and coordinate investment education. - Assist plan participants with financial wellness education, retirement planning, and gap analysis. C. Regulatory Assets Under Management Regulatory assets under management are calculated the same for Form ADV Part 1 and Part 2A. These figures include all fee paying and non-fee paying (employees, family members, and friends) accounts to whom we provide our portfolio management services as of the date indicated. Under Pension Consultant status and with no custody, technically there are no assets deemed to be Under Management.