DESCRIPTION OF THE FIRM Vestia Advisors, LLC is an Indiana domiciled limited liability company formed in 2017. We frequently operate under the trade names Vestia Personal Wealth Advisors and Vestia Retirement Plan Consultants. For the purpose of this brochure, we utilize Vestia Retirement Plan Consultants. Our advisory firm is a subsidiary of Vestia Holdings, LLC; shares of which are owned by 6174 Holdings, Inc., Abnormal Consulting, LLC., CDH Financial, LLC., Kabrana, LLC., MD Advisory Services, LLC., Peridot Rever Holdings, LLC., Sahwa Advisory Services, LLC., and Collaborative Consulting, LLC., as well as other minority shareholders. Vestia Advisors, LLC is under common control with Vestia Insurance, LLC, Vestia Ventures, LLC (“Vestia Ventures”), Vestia Contract Negotiation, LLC, Vestia Brokerage, LLC, Mammoth Advisors, LLC (“Mammoth Advisors”), and Mammoth Scientific, LLC (“Mammoth Scientific”) as noted in Item 10 of this brochure. Vestia Retirement Plan Consultants is an affiliated registered investment advisor with the United States Securities and Exchange Commission (SEC) and commenced business operations in January 2018. Our firm and its associates may notice-file (register) and/or become licensed or meet certain exemptions to registration and/or licensing within other jurisdictions where investment advisory business may be conducted. As of December 31, 2023, the Firm manages approximately $668,440,249 in discretionary assets under management for approximately 567 clients. Vestia Retirement Plan Consultants manages approximately $16,702,999 for approximately 17 clients of that total. DESCRIPTION OF SERVICES OFFERED Vestia Retirement Plan Consultants provides a broad range of customized retirement plan solutions to its corporate clients including but not limited to fiduciary process oversight, core portfolio management, fiduciary guidance, and participant education services. In addition to our retirement plan services, we are available to serve individual investors and businesses interested in financial planning and portfolio management, as well as conduct educational workshops involving a range of planning and investing topics. Such details are found in a separate brochure that is made available to interested parties on request. It should be noted that we do not sponsor or serve as portfolio managers involving investment programs using wrapped (bundled) fees. Prior to engaging us for services, each client will be provided with this Form ADV Part 2A firm brochure that includes a statement involving our privacy policy (Item 11), in addition to a brochure supplement about the representative(s) who will be assisting them. Our services are noted in the following paragraphs of this section (“item”), and their associated fees are stated in Item 5. Our firm will ensure that any material conflicts of interest have been disclosed that could be reasonably expected to impair the rendering of unbiased and objective advice, such as information found in Items 10 through 12 of this Brochure. If the client wishes to engage our firm for its services, they must first execute a written engagement agreement with our firm. Thereafter further discussion and analysis will be conducted to determine financial need, goals, holdings, etc. Depending on the scope of the engagement, clients may be asked to provide the following information or documentation early in the process:
• Expectations of what you hope to achieve through our work together
• Information on current retirement plans and benefits provided
• Employee census information relevant to retirement plans
• Employment contracts or other business agreements
• Corporate financial statements or strategic planning items
• Completed risk profile questionnaires or other forms provided by our firm
• Other items that may have an impact on your financial situation It is important that clients provide us with an adequate level of information and supporting documentation throughout the term of the engagement, including but not limited to the source of funds, income levels, and an account holder or their legal agent’s authority to act on behalf of the account, among other information that may be necessary. This helps us determine the appropriateness of our planning strategies and/or investment recommendations. The information and/or financial statements provided by the client need to be accurate. Our firm may, but we are not obligated to, verify the information provided by a client which will then be used in the advisory process. Vestia Service Offerings VESTIA CORE PORTFOLIO MANAGEMENT The Vestia Core Portfolio Management platform can be either a non-discretionary or a discretionary investment management platform where we oversee the design of the portfolios within your core retirement plan (for participant-directed plans) or the full portfolio (for plans combining the balances of all participants for the process of portfolio design services). Our process focuses on optimizing participant choices to those that matter most in the long-term design of a portfolio. VESTIA FIDUCIARY GUIDANCE Our retirement plan consulting services assist plan sponsors1 in understanding the scope of their fiduciary duties and responsibilities, develop prudent practices and procedures to enable them to effectively discharge those duties and responsibilities, and document their actions and decisions. Our firm assists plan fiduciaries in the development of committee charters, fiduciary eligibility documentation, committee meeting documentation, investment policy, and other activities that generally relate to prudent plan governance. Also included is assistance in preparing an annual report to the board of 1 Throughout this brochure, the term “plan sponsor” includes any person with the authority to review and implement plan investment decisions, such as executive management, investment committees, retirement plan committees, general counsel, plan advisor, etc. director or trustees as our client deems prudent and appropriate. Our firm is available to provide process assessments on the practices currently in place to manage fiduciary duties and responsibilities, as well as offer recommendation to improve current plan practices. We can assist in benchmarking service providers by evaluating existing providers and their expenses incurred for their services, and we can prepare a vendor request for information and complete an analysis of the vendor responses. We may be engaged pursuant to §3(21) and/or §3(38) of the Employee Retirement Income Security Act of 1974 (“ERISA”). Our level of account authority is defined in further detail in Item 16 of this brochure. We do not serve as an ERISA §3(16) plan third-party administrator (“TPA”), but we will assist the plan sponsor in identifying a TPA if appropriate. ERISA AND NON-ERISA PLANS We are able to assist both ERISA and non-ERISA plans. VESTIA TRUE CHOICE™ RETIREMENT PLAN OPTIONAL ENHANCEMENT The Vestia True Choice™ Retirement Plan option (“True Choice™”) was designed with medical, dental, and other professional firms with multiple partners in mind. Through True Choice™ the core retirement plan platform is augmented with the additional option for plan participants to work with the advisor of his or her choice (even if they are outside of Vestia) through a limited self-directed brokerage account (“SDBA”) option. In order to reduce plan audit deficiency risk, the participant’s advisor must be able to interface with the plan’s chosen custodian. This platform provides participants with the strong flexibility of advisor choice (they do not have to work with us if they have their own preferred advisor) with reduced plan audit risk compared to full open architecture platforms that do not limit participants to a chosen custodian. VESTIA DISCIPLINED WEALTH MANAGEMENT AND PERSONAL FINANCIAL PLANNING OPTIONAL ENHANCEMENTS Participants with the option to utilize the Vestia True Choice™ SDBA option within a retirement plan may also elect to engage us individually to manage their plan assets and/or to assist them with personal financial planning. Additionally, some executive compensation plans may provide access to our individual wealth management and financial planning services as a benefit for

executives. Our personal advisory services are addressed under separate cover in our Vestia Personal Wealth Advisors brochure. A PROCESS DESIGNED FOR BUSY PROFESSIONAL FIRMS
• First, an initial interview is conducted with the plan sponsor to discuss their current situation, goals, and the scope of services that may be provided by our firm.
• Prior to or during this first meeting, the plan sponsor will be provided with this Form ADV Part 2 retirement plan services brochure that includes a statement involving our privacy policy (see Item 11), as well as a brochure supplement about the representatives who will be assisting them. The firm will disclose any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice, such as information found in Items 10 through 12 and 14 of this brochure.
• If the plan sponsor wishes to engage our firm, parties must enter into a written agreement; thereafter, discussion and analysis will be conducted to determine plan requirements. We will then provide written recommendations and deliverables as specified within our engagement scope. With respect to advisory services provided to a plan sponsor, we offer both fiduciary and non-fiduciary services: Fiduciary Services:
• Serve as §3(21) investment co-fiduciary or §3(38) fiduciary to the plan
• Assist in the development and/or implementation of the plan’s Investment Policy Statement (“IPS”)
• Construct model portfolios for participant-directed accounts
• Recommend and/or monitor investment options
• Review qualified default alternative (“QDIA”)
• Assist in the selection of an investment adviser to manage plan assets
• Assist in the selection of participant-level investment advice provider(s)
• Recommend retirement plan asset-class menu options for participant-directed plans
• Review and/or implement an Investment Policy Statement (“IPS”) for the plan Non-Fiduciary Services:
• Implement Vestia True Choice™ or other SDBA of your choice
• Attend and/or facilitate plan committee meetings
• Assist in the selection of your TPA
• Consult regarding your questions and communication with your plan’s other service providers
• Review your testing and other compliance reports with you
• Educate plan committee members regarding their fiduciary role and requirements
• Deliver or create customized or generic participant education services
• Analyze the plan design to help drive employee participation
• Analyze the plan design to enhance tax efficiency
• Review plan objectives with you to make them more intentional
• Develop and maintain the plan’s fiduciary file
• Report on and monitor investment performance
• Offer other customized services as agreed upon Our advisory firm does not provide direct legal or accounting services. With your consent, we will work with a professional of your choice to assist with the coordination and implementation of various strategies. You should be aware that these other professionals will charge you separately for their services and these fees will be in addition to our own advisory fee. If your plan does not call exclusively for self-directed investing by participants, you may choose to engage our firm to assist with implementing investment strategies. For those plans where we serve as portfolio managers, we employ strategies and a range of investment vehicles as described in Item 8 of this brochure. When serving as a §3(21) co- fiduciary of the plan, we manage plan portfolios on a non-discretionary basis as defined in Item 16. When serving as a §3(38) fiduciary of the plan, we manage portfolios on a discretionary basis as defined in Item 16. In either case, we will utilize your plan’s IPS, observing reasonable investment constraints as stated in the IPS. For example, the plan may choose to exclude certain securities (e.g., options, stocks, illiquid securities, etc.). Investment guidelines should be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. It will remain the plan sponsor’s responsibility to promptly notify us if there is any change in the sponsor’s financial situation and/or investment objectives for the purpose of our reviewing, evaluating, or revising previous account restrictions or firm investment recommendations. We do not serve as either §3(21) co-fiduciary or §3(38) fiduciary for plans that are unwilling to implement an IPS. Following our review and/or plan development, we may recommend the engagement of an institutional investment manager to serve as the portfolio or fund manager. We evaluate a variety of information about sub-advisors which may include the independent managers’ public disclosure documents, materials supplied by the independent managers themselves as well as other third-party analyses we believe to be reputable. Plans may be required to maintain a minimum asset size to be eligible for these services, and certain sub-advisors may require a higher asset level to invest in their program in comparison to our own. We will inform the plan sponsor in advance of each sub-advisor’s minimum criteria. If engaging a sub-advisor to assist with the management of the entire portfolio, we will provide the sub-advisor with the plan’s IPS so that they may develop the portfolio in accordance with plan policy. Sub-advisors invest in accordance with the strategies set forth in their own disclosure documents which will be provided to the plan sponsor prior to your employing these strategies. The selected sub-advisor often assumes discretionary authority over an account, and some of these programs may not be available for those clients who prefer an account to be managed under a nondiscretionary engagement or who may have other unique account restrictions. At least annually thereafter a review will be performed from both a compliance and performance perspective to determine whether the selected sub-advisor remains an appropriate fit for plan portfolios. VESTIA PARTICIPANT EDUCATION Through the Vestia Participant Education services, we offer periodic educational sessions and/or ongoing tools for attendees desiring information on personal finance and investing. Alternatively, we can work with you to establish educational initiatives that align with your HR employee development strategy. This may lead to customized or generic videos or other electronic methods that you can house on your corporate intranet to provide real-time access for employees. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, implications involving changes in marital status, and various other current economic or investment topics. Unless our firm is hired by a participant independent of our arrangement with your company, these participant educational services are offered on a non-fiduciary basis consistent with and within the scope of the definition of general investment education in Department of Labor Interpretive Bulletin 96-1. OTHER THIRD-PARTY SERVICES The Firm has entered into a service agreement with Pontera to provide asset management services for accounts held away from our primary custodial affiliations. Through this, we are able to create a portfolio, consisting of the securities/investment opportunities available depending on the type of held away account being managed by our firm. The Pontera platform allows us to avoid being considered to have custody of Client funds for these purposes since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the securities made available. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced.