Belleair Asset Management, LLC (hereinafter “Belleair”) is owned by James M. Clark and Tina E. Clark and has been providing advisory services since 2017. As of December 31, 2022, Belleair managed $165,000,268on a discretionary basis and $50,860,800 on a non-discretionary basis for a total Assets Under Management of $215,861,068. Investment Management Services: Belleair manages investment portfolios for individuals, qualified retirement plans, trusts, not-for-profit organizations, and small businesses. Belleair will work with a client to determine the client's investment objectives and investor risk profile and may design a written Investment Policy Statement (IPS). For certain portfolios, an investment policy statement will not be prepared. Belleair evaluates the client's existing investments with respect to the client's IPS, if applicable. Belleair uses investment and portfolio allocation software to evaluate alternative portfolio designs. Belleair works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by Belleair. Belleair will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. Belleair will typically create a portfolio of no-load mutual funds, and may use model portfolios if the models match the client's investment policy. Belleair will allocate the client's assets among various investments taking into consideration the overall risk and return profile of the client. Belleair primarily recommends portfolios consisting of passively managed asset class and index mutual funds. Belleair primarily recommends mutual funds offered by Dimensional Fund Advisors (DFA). DFA-sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. Belleair will note such situations within the client’s IPS when an IPS is maintained for the client. Belleair manages mutual fund and equity portfolios on a discretionary or non-discretionary basis. A client may impose any reasonable restrictions on Belleair’s discretionary authority, including restrictions on the types of securities in which Belleair may invest client’s assets and on specific securities, which the client may believe to be appropriate. Use of Third-Party Sub-Advisers: Belleair has retained Buckingham Strategic Partners, LLC (“BSP)” to act as a sub-advisor for certain client accounts. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by Belleair. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by BSP. Each Portfolio is designed to meet a particular investment goal which Belleair has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, Belleair, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact Belleair to determine if changes to an account and the allocation of the assets held in the account are necessary. Belleair may also recommend to advisory clients fixed income portfolios, which consist of managed accounts of laddered individual bond portfolios. Belleair will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to engage an independent third-party fixed income manager. Belleair has contracted with Buckingham Strategic Partners, LLC for sub-advisory services with respect to clients’ fixed income accounts. A client agreement, including this discretionary authority granted to Belleair by the client to hire a fixed income sub-advisor, may be canceled at any time for any reason upon receipt of 30-days’ written notice. Pursuant to its discretionary authority, Belleair will engage the third-party fixed income manager. The fixed income manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s IPS. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). On an ongoing basis, Belleair will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. Belleair will periodically, and at least annually, review

clients’ investment policy, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. Belleair will provide any updated client financial information or account restrictions to third-party investment managers necessary for investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, Belleair may consult with clients on various financial planning areas including income and estate tax planning, disability income analysis, business sale structures, college financial planning, retirement planning, insurance and risk management analysis, personal cash flow analysis, investment analysis, establishment and design of retirement plans and trust designs, among other things. Belleair does not participate in or sponsor any wrap fee programs. Employee Benefit Plan Services: Belleair also provides advisory services to participant-directed retirement plans through third party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. Belleair will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Belleair will recommend investment options to help achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Belleair will recommend changes in the plan's investment vehicles as may be appropriate from time to time. Belleair generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, Belleair also works in coordination and support with Buckingham Strategic Partners, LLC. Retirement plan clients will engage both Belleair and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. Belleair will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Belleair has entered into an agreement with Flourish Digital Assets LLC (“Flourish Digital Assets”) to offer certain eligible clients the opportunity to invest in cryptocurrency basis through Flourish Crypto accounts offered on the Flourish platform. A Flourish Crypto account is a cryptocurrency investment account custodied by Paxos Trust Company, LLC (“Paxos”) through which investors can trade cryptocurrencies and maintain custody of cryptocurrencies and U.S. dollars. Belleair will not manage these assets; therefore, clients that invest through a Flourish Crypto account will manage their own accounts and execute agreements with Flourish Digital Assets and Paxos. Financial Planning Services: Belleair also provides advice in the form of Financial Planning. Clients purchasing this service may receive various written financial reports, providing the client with detailed financial information designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependent’s continuing educational needs through development of an education plan.
• Risk: Review of existing insurance policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile.
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years.
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of current and alternative investment holdings and costs, examining the potential long-term effects on a client’s portfolio, recommending appropriate investment options, allocations, or adjustments. Belleair gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report may be prepared. Should a client choose to implement the recommendations in the plan, Belleair suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion. Clients are encouraged to review their plan on a regular basis, especially if there are any changes in their financial situation, goals, need, or investment objectives.