A. Description of Advisory Firm American Retirement Planning Group, Inc. (hereinafter referred to as “ARPG” or the “Firm”) was formed in 1991 and is an investment adviser registered with the Securities and Exchange Commission (hereinafter referred to as “SEC”). ARPG is incorporated in the State of Nevada. ARPG has one shareholder, Matthew Dahl who owns 100% of the stock. No one outside the company owns stock. Matthew Dahl is a Registered Principal of ARPG. Listed below are the firm’s principal shareholders (i.e. those individuals and/or entities controlling 25% or more of this company),
• Matthew D. Dahl, Chief Investment Officer & Chief Compliance Officer ARPG offers fee-based money management programs (listed below) in which we use our in-house Macro Fundamental Top-Down Allocation Management Program. Macro Fundamental Top Down Allocation Management Program helps us identify where to allocate your funds. We will work with mutual funds, annuities, stocks, bonds and insurance. As of December 31, 2023, ARPG is managing $180,594,285 on a discretionary basis and $54,548,491 on a non-discretionary basis. There are three advisory services offered. You can use more than one advisory service. Investment Management Services Account Program The Investment Management Services Account Program provides investment management of your assets through the application of our Macro Fundamental Top-Down Allocation, as well as the provision of execution, clearing and custodial services through Pershing, LLC. Investment Management Services Account Program can provides risk tolerance assessment on request, portfolio optimization, our discussions together regarding your investment objective, risk tolerance, investment time horizon, account restrictions, and overall financial situation, will help us construct a portfolio of investments for you. Our investments are not limited to any specific product or service and generally will include the following securities: mutual funds, exchange traded funds, equities, options, debt securities, variable life, and/or variable annuity sub-accounts (certain restrictions may apply), among other types of investments. Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you can place reasonable restrictions on the types of investments to be held in the portfolio. Investment Management Services Account Program is offered as a discretionary account, where ARPG is authorized to manage all trades in the account without seeking your consent for each transaction. For further Investment Management Services Account Program details, please see the Investment Management Services Account Program Agreement. Cerberus Strategy agreement is only available through and must accompany an Investment Management Services Agreement as an addendum. Cerberus is an aggressive unconstrained opportunity strategy which seeks to maximize long term capital appreciation through exploitation of market inefficiencies with added emphasis on the protection of capital during unfavorable market conditions. It pursues this objective by investing primarily in common stocks and ETF’s while using hedging strategies to vary the exposure of equities based on general market and macro-economic conditions. Financial Consultation Complex situations require an individual financial consultation. The maximum hourly fee is $450 per hour. Fee is negotiable. You will be kept apprised of the fee or given a maximum fee before consultation. Fee will be paid after work is completed. You will receive an invoice for these services before you pay your fee. ARPG also consults on Life Insurance and Fixed Annuity programs on an hourly basis. You will be informed of any charges ahead of these consultations. No refund will be made after work has been completed. The maximum fee is $450 an hour. Employee Retirement Income Security Act(ERISA) American Retirement Planning Group (ARPG) may authorize certain of its investment advisor representatives (IARs) to provide fiduciary or non-fiduciary services to ERISA plans. ERISA plan documents typically designate one or more persons, such as the plan trustee(s), to undertake fiduciary responsibility for the operation of and take actions on behalf of the plan. Such persons are known as Responsible Plan Fiduciaries (RPFs). Following are the types of services that ARPG IARs may provide to ERISA plans. ERISA Fiduciary Services Selection of Investments The RPF may request the IAR to provide advice on the selection of various investment options for the plan to make available to its participants. This assessment may also include an evaluation of alternatives for the plan's Qualified Default Investment Alternative(s) (QDIA). The final decision on which investment options the plan shall select, including the QDIA, remains with the RPF and/or their delegate. Assessment of Investments The RPF may request the IAR to conduct a periodic review of the plan investments and investment options. This periodic review may be conducted on an annual, semi-annual, or quarterly basis, as requested by the RPF. The review may include, but is not necessarily limited to (1) reviewing investment performance, fund expenses and style drift for the investments that are offered by the Plan to participants; and (2) when the IAR deems appropriate, providing suggestions to the RPF for alternative investment options for the Plan to make available to its participants. The final decision on which investment options the plan shall select, including the QDIA, remains with the RPF and/or their delegate. Participant Investment Advice The RPF may authorize the IAR to provide services to plan participants as a Fiduciary Adviser (as defined in ERISA and the Pension Protection Act of 2006) The IAR will meet with the participant at least annually to provide recommendations regarding the participant's contributions and allocations among investment options available within the Plan. These recommendations will be based upon the participant's stated financial circumstances, investment objectives and risk tolerances. While ARPG and the IAR acknowledge their status as ERISA fiduciaries and accept fiduciary responsibility concerning to the provision of individualized investment advice

to the participant, the final decision as to whether to implement the advice provided by the IAR remains with the participant. Investment Policy Statement Individually Designed After gathering information regarding the plan's specific investment policies and objectives, the IAR will assist in developing a written Investment Policy Statement (IPS) that is designed to meet the individualized needs of the plan, including plan participants and any other employee eligible to participate in the plan. While ARPG and the IAR acknowledge their status as ERISA fiduciaries and accept fiduciary responsibility concerning the development of the IPS for the plan, the final decision as to whether to implement the IPS remains with the RPF. Neither ARPG nor the IAR can guarantee that the plan will achieve its investment objectives. Non-ERISA Fiduciary Services Investment Policy Statement Review After gathering information regarding the plan's general investment policies and objectives, the IAR will assist the RPF in developing a written Investment Policy Statement (IPS). As an alternative, if the Plan has an existing IPS, the IAR will review the existing IPS and, using information provided by the RPF, assist the RPF in determining (1) whether the plan's performance is consistent with the IPS and/or (2) whether the IPS needs to be revised, based on an analysis of the plan's asset class and risk tolerance guidelines, liquidity requirements, and performance goals. When providing IPS Review Services, ARPG and the IAR do not provide specific, individualized recommendations in the IPS for the plan and will not be an ERISA fiduciary. The final decision on whether or not to implement the objectives of the IPS remains with the RPF. Neither ARPG nor the IAR can guarantee that the plan will achieve its investment objectives. Performance Monitoring The IAR will conduct a review of plan investments and/or investment options and deliver written reports to the RPF to assist the RPF in monitoring the relative performance of such investments in relation to the policies and investment objectives of the plan's IPS. The RPF may request that performance monitoring services be provided initially and/or on an annual, semi-annual or quarterly basis. Performance monitoring reports may include rate-of-return data, any updated fund information known by IAR and comparative return information against the appropriate peer group. When providing performance monitoring services, ARPG and the IAR will not provide individualized investment advice to the plan and will not be acting as an ERISA fiduciary. Third Party Service Provider Liaison As needed and directed, the IAR will act as liaison for the Plan and the RPF when dealing with the trustee, custodian, plan actuary and other third-party service providers. Employee Enrollment The IAR will conduct enrollment meetings with plan participants and provide employees with administrative and educational information about the Plan. The RPF may request that the IAR conduct employee enrollment meetings initially and/or on an annual, semi-annual or quarterly basis. When providing employee enrollment services, the ARPG and the IAR will not provide individualized investment advice to plan participants and will not be an ERISA fiduciary. Employee Education The IAR will conduct informational meetings with plan participants and provide general investment education. The RPF may request that employee education meetings be provided initially and/or on an annual, semi-annual or quarterly basis. The IAR may provide plan participants with information about the plan, general financial and investment information and information and materials relating to asset allocation models available through the plan. The IAR may also provide plan participants with interactive investment materials to assist them in assessing future retirement income needs and the impact of different asset allocations on retirement income. When conducting employee educational meetings, ARPG and the IAR will not provide individualized investment advice to plan participants and will not be an ERISA fiduciary. Vendor Review/Conversion The IAR will assist the RPF in assessing current vendors identified and selected by RPF. The IAR may also assist in preparing Request for Proposals (RFPs) from prospective new vendors and may assist the RPF in reviewing and comparing responses to RFPs. ARPG and the IAR may suggest vendors to provide fiduciary services under ERISA, including investment advice. When providing Vendor Review Services, ARPG and the IAR will not render individualized investment advice to the Plan and will not be an ERISA fiduciary. The final decision as to whether or not to replace existing vendors and/or select and contract with new vendors remains with the RPF. The services above are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the RFP with a written statement of the services we provide, the compensation we receive for providing those services, and our status (which is described below). The services we provide to you are described above, and in the service agreement that you have previously signed with our firm. Our compensation for these services is described below, at Item 5, and also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. In providing services to the Plan, our status is that of an investment adviser registered with the State of Nevada and such other state securities authorities as required by law, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we may act as a non- discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA or a fiduciary of the Plan as defined in Section 3(38) under ERISA.