Holland Advisory Services, Inc. (“Holland Advisory, we, our, ours”) is a corporation organized under the laws of Florida. David Holland founded the Ormond Beach-based investment advisory firm in 1997. Holland Advisory is a wholly owned subsidiary of Holland Financial, Inc., of which David Holland is the sole owner. Holland Advisory is a registered investment adviser. As of December 31, 2022, we managed approximately $185.1 million in client assets where we made the investment decisions for our clients. We use asset allocation and Modern Portfolio Theory (MPT) as the cornerstone of portfolio construction in our indexed strategic and active strategic strategies. MPT is the analysis of a portfolio of securities as opposed to selecting them based on their unique investment opportunity. The objectives of MPT are to determine a client’s preferred level of risk, then construct a portfolio that maximizes their expected return for that given level of risk. We offer, or assign, you to one of our investment strategies or, based on certain circumstances, may customize a portfolio for you. This is determined through a series of meetings with you to determine the most appropriate solution for your financial situation. In managing your investment portfolio, we consider your financial situation, risk tolerance, investment horizon, liquidity needs, tax considerations, investment objectives, and any other issues important to your state of affairs. Information concerning specific investment strategies can be found under the section entitled “Methods of Analysis, Investment Strategies and Risk of Loss” later in this disclosure document. You should notify us promptly if there are any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon the management of your account. Indexed Strategic Strategies Approximately 8-10 mutual funds and/or Exchange Traded Funds (ETFs) are used to implement the asset allocation of these strategies. Rebalancing will be performed when the target allocation for a strategy drifts to an out- of- tolerance condition. Additionally, a reallocation of the strategy (i.e., shifting the allocation from one asset class to another and/or replacing investment(s) within the strategy) occurs when we believe it is prudent to do so based on economic, market, or geopolitical events. We seek to minimize trading costs and fund expenses for clients who are invested in these strategies. These strategies are for the client who desires an indexed approach to investing. We may, however, chose to allocate a portion of the strategy to non-index (active) mutual funds or ETFs. Shown below are the target asset compositions for the strategies. 5| P a g e Indexed Strategic Asset Allocation Model Target Percentage Equity Bonds Cash Aggressive 90-100% 0-5% 0-5% Moderately Aggressive 70-80% 20-30% 0-5% Moderate 45-55% 45-55% 0-8% Moderately Conservative 25-35% 65-75% 0-10% Active Strategic Strategies Mutual funds and ETFs are primarily used to implement the asset allocation of these strategies. These strategies are constructed using indexed and actively managed mutual funds and/or ETFs. Index funds are used to provide diversification which may not be present with some mutual funds that maintain concentrated security positions. Additionally, index funds allow for precise exposure to certain sector, global region, or market-cap equities that we believe may provide a better opportunity. The actively managed mutual funds are selected and allocated according to current market climate and chosen in an attempt to outperform their respective benchmark and peers. In the selection of mutual funds, we concentrate on funds with long-term consistent management, performance, and reasonable expense ratios. Adjustment of these strategies is performed approximately three to five times per year. Each strategy consists of a different asset mix. Shown below are the asset allocation ranges for the Active Strategic Strategies. 6| P a g e Active Strategic Asset Allocation Model % Equity Target % Bonds Target %Cash Target Growth – Tax Sensitive 80-100% 0-20% 0-4% Growth 80-100% 0-20% 0-4% Balanced Growth – Tax Sensitive 60-80% 15-35% 0-5% Balanced Growth 60-80% 15-35% 0-5% Balanced – Tax Sensitive 40-60% 36-54% 0-8% Balanced 40-60% 36-54% 0-8% Conservative Income 20-35% 52-78% 0-10% Conservative 0-10% 75-100% 0-15% Financial Planning Financial planning is an evaluation of the investment and financial options available to you based upon your defined economic criteria. This kind of planning includes: ❖ attempting to make optimal decisions; ❖ projecting the consequences of these decisions for the client in the form of a specific, targeted financial plan – a working blueprint; ❖ implementing the financial plan in an attempt to achieve your objectives; ❖ comparing future performance against the working blueprint; and, ❖ making modifications as needed to the blueprint as your situation and economic conditions change. In general, our financial planning encompasses one or more of the following areas of financial need as presented by the client: 7| P a g e ❖ Financial Analysis: Analyzing investment accounts to compare overall appropriateness of existing portfolio to risk tolerance and investment objectives. ❖ Investment Reallocation: Examining investment choices available and advising how to reallocate existing investment accounts based upon financial goals and investment objectives. ❖ Retirement Income: Providing an income projection based on available assets and unique needs. ❖ Survivorship Income: Determining how long current and future

assets will last, based on income needs, retirement date, and assumptions about interest, growth, inflation, and longevity. ❖ Estate Planning Strategies: Reviewing and exploring existing legal documents in relation to overall financial situation, goals, and needs to determine strategies for providing for ongoing care, support for a surviving spouse or child, and management of funds for beneficiaries. ❖ Estate Planning Implementation: Reviewing estate planning documents, including wills and trusts for consistency with stated financial goals and to determine if you should seek the assistance of an estate planning attorney. ❖ Long-term Care Strategies: Analyzing specific situations and developing strategies to mitigate the financial risks of the need for long-term care. Financial Advice Financial advice involves recommendations tailored to your goals and objectives. Recommendations may be for you to take or refrain from taking a specific action, such as selling assets and/or purchasing other assets, including insurance products and investment advisory services. Such an engagement is not financial planning, which takes into consideration a broad range of subjects or your complete financial picture. Financial Advice is more limited in scope and provides recommendations in one or more of the following areas as presented by the client: ❖ Life Insurance: Analyzing your situation and providing life insurance recommendations. ❖ Disability Insurance: Analyzing your situation and providing disability insurance recommendations. ❖ Long-term Care Insurance: Analyzing your situation and providing long-term care recommendations. ❖ Annuity: Evaluating risk tolerance, income needs, and time frame to determine whether an annuity should be purchased. ❖ Investment: Providing written investment recommendations based upon risk tolerance, investment objectives, and time frame, which are tailored to need for income. ❖ Reallocation: Providing written allocation recommendations for retirement plans or other accounts based on risk tolerance and investment objectives. 8| P a g e For both financial planning and financial advice, we gather the necessary information to complete the particular area of analysis through a financial profile questionnaire and personal interviews. Information gathered could include but is not limited to your current financial status, a list of assets and liabilities, insurances, wills and/or trusts documents, current monthly income and expenses, and future goals. Related documents that you supply are carefully reviewed and discussed with you. Pension Consulting Services Holland Advisory provides pension consulting services to retirement plans and the plan sponsors based upon the needs of the plan and the desired services of the trustees and named fiduciaries. Our services include but are not limited to; plan design and needs assessment, investment policy statement generation or review, recommendation of investment options, recommendation of investment models, monitoring of investments in the plan, review of plan fees, investment committee services, recommendation of service providers, and employee education regarding topics such as investment risk, return, time horizon, and asset allocation. All services agreed to by plan trustees and fiduciaries will be detailed in a Retirement Plan Advisory Service Agreement. The fees charged for the services provided by Holland Advisory shall be negotiated with the plan sponsors and named fiduciaries on an individual basis. Trustee Services Although a grantor may name himself as trustee of a living trust during his lifetime, a grantor often names a successor trustee to act when the grantor is incompetent or deceased. At the grantor's death, the successor trustee must administer the assets of the trust in accordance with the directions in the trust document. David D. Holland, CPA, or Steve Tacinelli, CPA, in their respective individual capacities, serve as trustee or successor trustee for certain client estates. Mr. Holland and Mr. Tacinelli also serve in other roles as personal representative and/or attorney-in- fact for certain clients. Neither Holland Advisory nor its affiliated companies, is a trust company or bank. Accordingly, estate and trust services are separate and distinct from the financial services available from Holland Financial, Inc.'s affiliated companies. Neither David Holland nor Steve Tacinelli is an attorney and they do not offer legal advice or prepare legal documents. Clients are encouraged to seek legal advice from an attorney of their choosing regarding their estate planning, as well as the documents they may need to accomplish their objectives. Acknowledgement of Fiduciary Status Holland Advisory is deemed to be a fiduciary to employee benefit plans (plan sponsors) or advisory clients who hold individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with client interests, so we operate under a special rule that requires us to act in the client’s best interest and not put our interest ahead of client. Under this special rule’s provisions, we must, 1) Meet a professional standard of care when making investment recommendations (give prudent advice), 2) Never put our financial interests ahead of client when 9| P a g e making recommendations (give loyal advice), 3) Avoid misleading statements about conflicts of interest, fees, and investments, 4) Follow policies and procedures designed to ensure that we give advice that is in our client’s best interests, 5) Charge no more than is reasonable for our services, and 6) Give client’s basic information about conflicts of interest.