Salomon and Ludwin, LLC (“Salomon and Ludwin”) is a limited liability company organized in the state of Virginia. The firm was founded in November 2009 by Dalal Salomon and Daniel Ludwin. The firm employs a consultative approach to financial planning. Salomon and Ludwin, LLC specializes in managing financial assets for individuals, families, estates, trusts, and group retirement plans. The firm is primarily focused on the selection and monitoring of specific non-proprietary investments, then using these investments inside actively managed accounts. Advisory services are typically performed in exchange for a fee which is calculated as a fractional percentage of assets. At Salomon and Ludwin, we recognize that each client has individual objectives and goals, which are determined during the initial consultation, and reaffirmed periodically. Clients determine the level of risk they are willing to take with their assets and their estimated time horizon. The term “time horizon” refers to the amount of time clients feel they have before they think they will start spending the assets in their account, whether it be for their own retirement or some other financial objective. Our advice requires an understanding of your financial condition, goals, and tolerance for risk. At Salomon & Ludwin, we believe that our clients engage with us for the advice and services we provide, along with our portfolio management strategies. Although, where applicable, transaction costs are covered by our wrap fee, they are not a significant component of our value proposition. Investment Advisory/Portfolio Management Services Salomon and Ludwin provides discretionary portfolio management, financial planning, and retirement plan consulting services. Salomon and Ludwin offers active money management services for individuals, high net worth individuals, families, employer- sponsored qualified plans, small businesses, trusts, and foundations. Salomon & Ludwin provides discretionary investment advisory services on a fee basis as discussed at Item 5 below. Before engaging Salomon & Ludwin to provide investment advisory services, clients are generally required to enter into an Investment Advisory Agreement with Salomon & Ludwin setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, Salomon & Ludwin will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Salomon & Ludwin provides ongoing supervision of the account(s). Salomon & Ludwin ’s annual investment advisory fee shall generally include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. Investment Philosophy The world, your life, and the markets are not stagnant. There is a lot to be said about the importance of adapting. Yet, some things at Salomon & Ludwin are constant: our belief that honesty, reputation, integrity, and innovation will drive our success. We devote our attention to knowing our clients well, to making a difference in their lives and in the lives of their 4 families. We are a close-knit group of professionals serving our clients in our own unique way. We prefer to use low-cost, tax-efficient, transparent, investments to implement our strategies. Our strategies are designed to mitigate risk in an attempt to limit portfolio losses. We believe that our industry focuses too much time on trying to predict the markets. We prefer to have a logical strategy in place that reacts to the markets. We strive to act decisively, logically, and unemotionally. Investment Strategy Salomon and Ludwin employs a flexible investment strategy with the freedom to invest in a wide variety of asset classes. Salomon and Ludwin generally limits its investment advice and/or money management to Exchange Traded Funds (“ETFs”), mutual funds, equities, bonds, fixed income, debt securities, REITs, insurance products including annuities, and government securities. Use of Mutual and Exchange Traded Funds Salomon & Ludwin utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Salomon & Ludwin ’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Salomon and Ludwin may use other securities as well to help diversify a portfolio when appropriate. Salomon and Ludwin combines fundamental and technical analysis in seeking to profit from market trends, biases and the future expectations of companies, industries, regions, and countries. We may use a variety of no- load/load-waived/non- transaction fee mutual funds or exchange traded funds, stocks, bonds, as well as separate account managers in the management of client assets. Our driving objectives in investment strategies are diversification, unemotional discipline, and consistent favorable and competitive returns, especially in negative markets. Item 8 further describes our Methods of Analysis, Investment Strategies and Risks of Loss. Financial Planning To the extent requested by the client, Salomon & Ludwin will generally provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, etc. Salomon & Ludwin provides such consulting services inclusive of its advisory fee set forth at Item 5 below. Please Note: Salomon & Ludwin believes that it is important for the client to address financial planning issues on an ongoing basis. Salomon & Ludwin ’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Salomon & Ludwin. Please Also Note: Salomon & Ludwin does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Salomon & Ludwin does not prepare legal documents or tax returns, nor does it offer or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including one of Salomon & Ludwin’s representatives in his separate individual capacity as a registered representative of Triad Financial Advisors (“Triad”), an SEC registered and FINRA member broker-dealer, and other representatives as licensed 5 insurance agents. The client is under no obligation to engage the services of any such recommended professional. Please Note-Conflict of Interest: The recommendation that a client purchase a securities or insurance commission product from Salomon & Ludwin ’s representative in his/her individual capacity as a representative of Triad and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions can provide an incentive to recommend investment and/or insurance products based on commissions to be received, rather than on a particular client’s need. The fees charged and compensation derived from the sale of such insurance and/or securities products is separate from, and in addition to, Salomon & Ludwin ’s investment advisory fee. No client is under any obligation to purchase any securities or insurance commission products from any of the Salomon & Ludwin ’s representatives. Clients are reminded that they can purchase securities and insurance products recommended by a Salomon & Ludwin ’s representatives through other, non-affiliated broker-dealers and/or insurance agents. The client is not under any obligation to engage any such professional(s). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Salomon & Ludwin and/or its representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the engaged professional shall remain exclusively responsible for resolving any such dispute with the client. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Salomon & Ludwin, shall be responsible for the quality and competency of the services provided. Retirement Rollovers - Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Salomon & Ludwin recommends that a client roll over their retirement plan assets into an account to be managed by Salomon & Ludwin , such a recommendation creates a conflict of interest if Salomon & Ludwin will earn new (or increase its current) compensation as a result of the rollover. If Salomon & Ludwin provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Salomon & Ludwin is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Salomon & Ludwin, whether it is from an employer’s plan or an existing IRA. Salomon & Ludwin ’s Chief Compliance Officer, Jacob Salomon, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. ESG Investing Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the 6 investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment

strategies recommended and/or undertaken by Salomon & Ludwin), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Salomon & Ludwin does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. 401(k) and 403 (b) Accounts S&L offers actively managed model portfolios to 401(k) and 403(b) plans, similar to the services offered for individual clients. Salomon and Ludwin can also provide investment advisory services to 401(k) and 403(b) participant accounts outside our firm who want additional assistance in selecting investments in their plan. We do not collect a fee for this assistance. Sub-Advisory Engagements Salomon & Ludwin also serves as a sub-adviser to unaffiliated registered investment advisers per the terms and conditions of a written Sub-Advisory Agreement. The unaffiliated investment advisers that engage Salomon & Ludwin ’s sub-advisory services shall maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for Salomon & Ludwin’s designated investment strategies. Cash Sweep Accounts Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Salomon & Ludwin shall generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Salomon & Ludwin reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within a Salomon & Ludwin actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. 7 Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Salomon & Ludwin unmanaged accounts. ANY QUESTIONS: Salomon & Ludwin’s Chief Compliance Officer, Jacob Salomon, remains available to address any questions that a client or prospective client may have regarding the above. Borrowing Against Assets/Risks A client who has a need to borrow money could determine to do so by using: Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money and uses the assets in the client’s brokerage account as collateral; and, Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e. custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Salomon & Ludwin does not recommend such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new residence). Salomon & Ludwin does not recommend such borrowing for investment purposes (i.e. to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Salomon & Ludwin: by taking the loan rather than liquidating assets in the client’s account, Salomon & Ludwin continues to earn a fee on such Account assets; and, if the client invests any portion of the loan proceeds in an account to be managed by Salomon & Ludwin, Salomon & Ludwin will receive an advisory fee on the invested amount; and, if Salomon & Ludwin ’s advisory fee is based upon the higher margined account value, Salomon & Ludwin will earn a correspondingly higher advisory fee. This could provide Salomon & Ludwin with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Cybersecurity Risk The information technology systems and networks that Salomon & Ludwin and its third-party service providers use to provide services to Salomon & Ludwin ’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Salomon & Ludwin ’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Salomon & Ludwin are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective 8 measures, and loss from damage or interruption to systems. Although Salomon & Ludwin has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Salomon & Ludwin does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Client Obligations In performing our services, Salomon & Ludwin shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Salomon & Ludwin if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Portfolio Activity Salomon & Ludwin has a fiduciary duty to provide services consistent with the client’s best interest. Salomon & Ludwin will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Salomon & Ludwin determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by the Salomon & Ludwin will be profitable or equal any specific performance level(s). Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Salomon & Ludwin) will be profitable or equal any specific performance level(s). Wrap Program-Conflict of Interest Salomon & Ludwin provides services on a wrap fee basis as a wrap program sponsor. Under Salomon & Ludwin ’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program can cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in Salomon & Ludwin ’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by Salomon & Ludwin to the account custodian/broker-dealer, Salomon & Ludwin could have an economic incentive to maximize its compensation by seeking to minimize the number of transaction fee trades in the client's account. See separate Wrap Fee Program Brochure. Salomon & Ludwin ’s Chief Compliance Officer, Jacob Salomon, remains available to address any questions that a client or prospective client may have regarding 9 a wrap fee arrangement and the corresponding conflict of interest. Please Note: Cash Positions. Salomon & Ludwin continues to treat cash as an asset class. As such, unless determined to the contrary by Salomon & Ludwin, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Salomon & Ludwin ’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Salomon & Ludwin may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Salomon & Ludwin ’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Salomon & Ludwin ’s Chief Compliance Officer, Jacob Salomon, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Disclosure Brochure A copy of Salomon & Ludwin ’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and Salomon & Ludwin Salomon and Ludwin had $1,709,639,369 in discretionary assets under management in accounts as of December 31, 2023.