Shepherd Financial Investment Advisory, LLC (“Shepherd,” “we,” “our,” or “us”) is an Indiana limited liability company owned by Shepherd Financial Holdings, LLC (“Holdings”). Holdings is primarily owned by Steven Wylam, Thomas Mayer, Andrew Denny, and David Shepherd. We have been providing investment advisory services since September 2017. We provide advisory services and consulting to ERISA-qualified and non-qualified retirement plan clients. Wealth Management Services—Advisory Clients Shepherd’s portfolio asset management services are predicated on the Advisory Client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. We will analyze each Advisory Client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. Our objective is to review the Advisory Client’s investment objectives and goals in connection with other personal and financial circumstances and make appropriate recommendations and implementation decisions. In addition, we may utilize third-party software to analyze individual security holdings and separate account managers utilized within an Advisory Client’s portfolio. Our investment advisory services take into account an Advisory Client's personal financial circumstances, and our engagement will include, as appropriate, the following: ▪ Providing assistance in reviewing the Advisory Client's current investment portfolio against the client's personal and financial circumstances disclosed to us in response to a questionnaire and/or in discussions with the client and reviewed in meetings. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Retaining independent investment managers, as appropriate. ▪ Reporting to the Advisory Client on a quarterly basis or at some other interval agreed upon with the client, information on contributions and withdrawals in the client's investment portfolio, and the performance of the portfolio measured against appropriate benchmarks (including benchmarks selected by the client). ▪ Proposing changes in the Advisory Client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments, and/or the performance of any investment manager retained on behalf of the client. In addition to providing us with information regarding their personal financial circumstances, investment objectives and tolerance for risk, Advisory Clients must provide us with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify us in writing of any changes in such restrictions or in the Advisory Client's personal financial circumstances, investment objectives, goals and tolerance for risk. We remind clients of their obligation to inform us of any such changes or any restrictions that should be imposed on the management of their account. We also contact Advisory Clients at least annually to determine whether there have been any changes in their personal financial circumstances, investment objectives and tolerance for risk. Wealth Planning Services Shepherd offers wealth planning as part of its investment management services or as a standalone service. Clients will receive a written or oral report (depending on the client’s preference) providing a basic financial plan designed to help achieve their stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Liability Management ▪ Understand debt utilization and opportunities for arbitrage. ▪ Assist family with banking relationships and employing “Family Bank” concept. ▪ Insurance Evaluation ▪ Evaluate whether advanced life insurance planning could enhance overall family wealth. ▪ Identify any gaps in insurance coverages, or opportunities to shift risk / enhance liability protection. ▪ Review whether long-term care or longevity income is appropriate. ▪ Tax Planning ▪ Coordinate efforts with the family CPA and team to monitor and enhance tax strategies. ▪ Plan for highly appreciated individual stock investments, assist with entity tax planning, evaluate distributions from IRA accounts, charitable giving / charitable entity planning, etc. ▪ Estate & Wealth Transfer ▪ Review and document estate planning and wealth transfer objectives. ▪ Develop estate planning summary / flowchart for communication purposes. ▪ Create, track, and develop thorough understanding of consolidated balance sheet. ▪ Identify and model multi-generational wealth transfer opportunities. ERISA-Qualified Plans Shepherd either serves as the plan’s investment adviser under Section 3(21) of the Employee Retirement Income P a g e | 5 Security Act of 1974 (“ERISA”) (in which case we will recommend investments for approval by the plan’s named fiduciaries), or as the plan’s investment manager under ERISA §3(38) (in which case we will manage the plan’s investments on a discretionary basis). For plans with participant-directed accounts, we may provide advice or management on the investment options available to the plan’s participants. When we provide these services, we work with the plan’s named fiduciaries to evaluate the demographics of the plan’s participants to select investment options that are appropriate for their retirement needs based upon ERISA §404(c)’s requirement that participant- directed retirement plans offer a “broad range” of investment options. The plan’s named fiduciaries may impose restrictions on the types of investments that may be held by, or offered through, the plan, and those guidelines are typically referenced in the plan’s investment policy statement. We also offer additional services to our retirement plan clients, including assisting the plan’s named fiduciaries with drafting the plan’s investment policy statement, selecting an appropriate qualified designated investment alternative, investment manager search, selection, due diligence and monitoring, fiduciary training, fee benchmarking analysis, and investment education / engagement, financial wellness and enrollment services for the plan’s participants. The asset allocation and mutual fund recommendations we give to plan clients may differ from those we give to our high- net-worth and affluent individuals and institutions because, among other reasons, a participant’s asset allocation target typically consists of a smaller number of asset categories to reflect the relatively smaller size of the participant’s investment assets; or the sponsor has constrained the investment alternatives from which we may make recommendations. In such cases, we may be required to observe quantitative criteria established by the sponsor in preparing participant-oriented lists of mutual funds, or to confine the advice given to choices among a relatively narrow set of investment alternatives established by the sponsor. Participants are informed when the plan sponsor imposes constraints on our ability to recommend mutual funds or other securities. Discretionary Asset Management When we provide discretionary asset management services, we receive a limited power of attorney to effect securities transactions for our clients that include securities and strategies described under “Methods of Analysis, Investment Strategies & Risk of Loss” below. Our discretionary asset management services are predicated on the plan’s investment mandate or investment policy statement. Client-Tailored Services & Client-Imposed Restrictions Each Advisory Client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. Wrap Fee Programs Shepherd offers its individual wealth management services exclusively in its proprietary wrap fee program, where certain brokerage commissions and transaction costs are included in the asset-based fee charged to the client. Assets Under Management As of December 31, 2023, Shepherd has $3,304,141,937 in non-discretionary assets under management, and $712,801,107 in discretionary assets under management. Fees & Compensation Individual Wealth Management Fees All individual wealth management services are provided exclusively through our wrap fee program. Wealth management fees are paid monthly, at the end of each month pursuant to the terms of the wealth management agreement. Wealth management fees are based on the average daily closing market value of assets under management during the month. Wealth management fees range from 0.50% to 1.20% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and/or the overall relationship with the advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The wealth management fee may be offered as a fixed annual rate or a tiered, incremental fee schedule, not to exceed to the range above. The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the advisor. The client’s fees will take into consideration the aggregate assets under management with us. All securities held in accounts managed by Shepherd will be independently valued by the custodian. Shepherd will not have the authority or responsibility to value portfolio securities. A client investment advisory agreement may be canceled at any time by the client, or by us with 30 days’ prior written notice to the client. Upon termination, any earned, unpaid fees will be due and payable/unearned, prepaid fees will be refunded. ERISA-Qualified Plan Fees We charge either on a percentage of assets in the retirement plan or as a flat amount. These fees are negotiable and vary greatly based upon the size of the plan and the services we provide. Retirement plan clients

may decide whether the fees will be paid directly by the plan sponsor or deducted from plan assets. Because our fees are often paid by the plan’s custodian, the custodian usually determines whether our fee will be paid in advance or in arrears. However, if the plan sponsor pays our fee directly, the parties may negotiate when those payments will be due. Under ERISA §408(b)(2), we and other vendors providing services to the plan must disclose all direct and indirect compensation they will receive in exchange for the services P a g e | 6 they provide to a retirement plan. We disclose the services we will provide and the fee we charge for those services in the written agreement with the retirement plan’s sponsor. Our advisory fee does not include any applicable taxes; confirmation fees for trades; custodial fees; brokerage commissions; transaction fees; charges imposed directly by a mutual fund, index fund, or ETF (as disclosed on the fund’s prospectus); fees imposed by variable annuity providers (as disclosed in the annuity contract); certain deferred sales charges; odd-lot differentials; transfer taxes; wire transfer and electronic fund fees, as well as other fees imposed upon brokerage accounts and securities transactions. The plan’s administrator is required to provide participants with a disclosure of the costs associated with the investment options offered under the plan, such as mutual fund internal expenses, under ERISA §404(a)(5). Wealth Planning Fees For clients with at least $500,000 in assets under management with Shepherd, wealth planning is offered at no additional charge. For standalone financial planning or clients with less than $500,000 in assets under management, Shepherd will charge an hourly fee from $300 to $600 per hour, depending on the advisor handling the client’s account. The wealth planning fee typically incorporates a minimum of six hours and may increase, depending on the scope of work required. We require 50 percent of the fee to be paid in advance prior to the start of the project, with the remainder to be paid upon completion and delivery of the plan. We do not require prepayment of fees of $1,200 or more, six months or more in advance. Clients seeking to terminate this service must do so in writing. Payment of Fees Our advisory fees are either paid directly by the client or disbursed to us by the qualified custodian, subject to the client’s prior written consent. The custodian will deliver directly to the client an account statement, at least quarterly, showing all investment and transaction activity for the period, including fee disbursements from the account. A client’s investment advisory agreement may be canceled by either party upon 30 days’ prior written notice. Upon termination, any unearned, prepaid fees will be promptly refunded and any earned, unpaid fees will be immediately due and payable. We generally require clients to authorize the direct debit of fees from their accounts. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. Additional Charges Our fees for investment advisory services are separate and distinct from the fees and expenses charged by ETF, mutual funds, pooled investment vehicles, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each ETF and mutual fund’s prospectus, each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, each pooled investment vehicle’s offering memoranda, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. A client may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. External Compensation for the Sale of Securities to Clients Shepherd’s advisory professionals are compensated primarily through a salary and bonus structure. Shepherd’s advisory professionals may be paid sales, service or administrative fees for the sale of mutual funds or other investment products. Shepherd’s advisory professionals may receive commission-based compensation for the sale of securities and insurance products. Investment adviser representatives, in their capacity as a Lincoln Investment registered representative, are prohibited from earning an advisory fee on the securities value transferred from an advisory client’s Lincoln Investment brokerage account unless commissions earned on such securities transactions occurred at least a 12–18 months prior to the transfer. With respect to Plan clients, Shepherd Financial advisors receive fee-based compensation. Please see “Other Financial Industry Activities & Affiliations” below for detailed information and conflicts of interest regarding other sources of compensation. Important Disclosure – Custodian Investment Programs Please be advised that certain of the firm’s investment adviser representatives are registered with a broker-dealer and/or the firm is a broker-dealer or affiliated with a broker- dealer. Under these arrangements, we can access certain investment programs offered through the broker-dealer that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. As such, the investment adviser representative and/or the firm may have an economic incentive to recommend the purchase of 12b-1 or revenue share class mutual funds offered through the broker-dealer platform rather than from the investment adviser platform. Please be advised that the firm utilizes certain custodians/broker-dealers. Under these arrangements we can access certain investment programs offered through such custodian(s) that offer certain compensation and fee structures that create conflicts of interest of which clients need to be aware. Please note the following: Limitation on Mutual Fund Universe for Custodian Investment Programs: Please note that as a matter of policy we prohibit the receipt of revenue share fees from any mutual funds utilized for our advisory clients’ portfolios. There are certain programs in which we participate where a client’s investment options may be limited in certain of these programs to those mutual funds P a g e | 7 and/or mutual fund share classes that pay 12b-1 fees and other revenue sharing fee payments, and the client should be aware that the firm is not selecting from among all mutual funds available in the marketplace when recommending mutual funds to the client. Conflict Between Revenue Share Class (12b-1) and Non- Revenue Share Class Mutual Funds: Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and generally, all things being equal, cause the fund to earn lower rates of return than those mutual funds that do not pay revenue sharing fees. The client is under no obligation to utilize such programs or mutual funds. Although many factors will influence the type of fund to be used, the client should discuss with their investment adviser representative whether a share class from a comparable mutual fund with a more favorable return to investors is available that does not include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs and priorities and anticipated transaction costs. In addition, the receipt of such fees can create conflicts of interest in instances [If registered reps of a broker dealer: (i) where our adviser representative is also licensed as a registered representative of a broker-dealer and receives a portion of 12b-1 and or revenue sharing fees as compensation – such compensation creates an incentive for the investment adviser representative to use programs which utilize funds that pay such additional compensation; and (ii)] where the custodian receives the entirety of the 12b-1 and/or revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it may elect to provide to the firm, even though such benefits may or may not benefit some or all of the firm clients. Additional Disclosure Concerning Wrap Programs: To the extent that we either sponsor or recommend wrap fee programs, please be advised that certain wrap fee programs may (i) allow our investment adviser representatives to select mutual fund classes that either have no transaction fee costs associated with them but include embedded 12b-1 fees that lower the investor’s return (“sometimes referred to as “A-Shares,” depending on the mutual fund issuer), or (ii) allow the use of mutual fund classes that have transaction fees associated with them but do not carry embedded 12b-1 fees (sometimes referred to as “I-Shares,” depending on the mutual fund sponsor). Wrap fee programs offer investment services and related transaction services for one all-inclusive fee (except as may be described in the applicable wrap fee program brochure). The trading costs are typically absorbed by the firm and/or the investment representative. If a client’s account holds A- Shares within a wrap fee program, the firm and/or its investment adviser representative avoids paying the transaction fees charged by other mutual fund classes, which in effect decreases the firm’s costs and increases its revenues from the account. Effectively, the cost is transferred to the client from the firm in the form of a lower rate of return on the specific mutual fund. This creates an incentive for the firm or investment adviser representative to utilize such funds as opposed to those funds that may be equally appropriate for a client but do not carry the additional cost of 12b-1 fees. As a policy matter, the firm does not allow funds that impose 12b-1 or revenue sharing fees on the client’s investment within its wrap fee programs. Clients should understand and discuss with their investment adviser representative the types of mutual fund share classes available in the wrap fee program and the basis for using one share class over another in accordance with their individual circumstances and priorities. Performance-Based Fees & Side-by- Side Management We do not charge performance-based fees and therefore we have no economic incentive to manage clients’ portfolios in any way other than what is in their best interests.