A. Description of the Advisory Firm Bay Rivers Group Wealth Partners (hereinafter “BRGWP”) is a Corporation organized in the State of Virginia. The firm was formed in March 2017, and the principal owners are Alan Broderick, Bruce Lemley and Charles Lucy. B. Types of Advisory Services Portfolio Management Services BRGWP offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BRGWP creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring BRGWP evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. BRGWP will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. BRGWP seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of BRGWP’s economic, investment or other financial interests. To meet its fiduciary obligations, BRGWP attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, BRGWP’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is BRGWP’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. BRGWP may direct clients to third-party investment advisers to manage all or a portion of the client’s assets. Before selecting other advisers for clients, BRGWP will always ensure those other advisers are properly licensed or registered as an investment adviser. BRGWP then makes investments with a third-party investment adviser by referring the client to the third-party adviser. BRGWP will not review the ongoing performance of the third- party adviser as a portion of the client’s portfolio. 529 Plan Account Services 529 college savings plans are offered by 49 states and the District of Columbia. 529 plans may be offered in

two versions, direct-sold and advisor-sold. Direct-sold 529 plans are available directly from the state, while advisor-sold 529 plans are available through investment advisors. BRGWP will help facilitate the initial set-up of the account, and will offer recommendations and advice, on an ongoing basis, to direct-sold 529 plan accounts based on the individual goals, objectives, time horizon, and risk tolerance of each client. BRGWP does not exercise discretion, nor will it execute transactions on behalf of the client in direct-sold 529 accounts. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. If BRGWP recommends an estate plan as a component of the client’s overall financial plan, BRGWP will use the services of EncorEstate Plans (“Encor”). BRGWP will coordinate the creation of the client’s estate planning documents through Encor and their team of professionals. Encor and BRGWP are not affiliated. Services Limited to Specific Types of Investments BRGWP generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors) and treasury inflation protected/inflation linked bonds. BRGWP may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions BRGWP will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by BRGWP on behalf of the client. BRGWP may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BRGWP from properly servicing the client account, or if the restrictions would require BRGWP to deviate from its standard suite of services, BRGWP reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. BRGWP does not participate in any wrap fee programs. E. Assets Under Management BRGWP has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 185,613,471 $4,133,203 September 2023