A. Description of the Advisory Firm Starr-Mathews Financial, LLC is a Limited Liability Company organized in the state of Georgia. The firm was formed July of 2005 and became a Registered Investment Adviser in January of 2013. The principal owners are SMA Financial, LLC and Holland Capital Advisors, Inc. Jason Edward Holland is the sole owner of Holland Capital Advisors, Inc., James Starr Mathews (40%), Robert Mathews (25%), Barton Mathews (25%) and Craig Mashburn (10%) are the owners of SMA Financial, LLC. B. Types of Advisory Services Starr-Mathews Financial, LLC (hereinafter “SM”) offers the following services to advisory clients: Investment Supervisory Services SM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SM 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. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SM 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. 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. These services are based on fixed fees or hourly fees and the final fee structure and services to be performed are documented in the Financial Planning Agreement. Qualified Retirement Plan ERISA 3(38) or ERISA 3(21) Services ERISA provides that a plan sponsor can delegate key responsibilities to an independent fiduciary or hire service providers to assist in the key roles necessary to provide a qualified retirement plan. Those responsibilities can include both fiduciary and non- fiduciary services. Services we provide are clearly defined and delineated between fiduciary and non-fiduciary services in the retirement plan agreement “RPA”. A list of services provided is included below. ERISA 3(38) Fiduciary Services defined: A plan sponsor can delegate responsibilities that relate to fund management such as fund selection, monitoring, and replacement. An ERISA 3(38) fiduciary has the authority as a decision maker to take discretion and make investment decisions on behalf of the plan sponsor. Those decisions would include creating a plan menu of investment options, review of that menu, and adding to, subtracting from or replacement of investment options. An ERISA 3(38) fiduciary does not make investment decisions for the plan participant. The plan participant is solely responsible for his own asset allocation decisions. The plan sponsor freely delegates these responsibilities given to the ERISA 3(38) by virtue of the RPA. The plan sponsor can withdraw those rights given to the

investment fiduciary and once again take back the responsibility to select, monitor and replace plan investments. The plan sponsor cannot delegate responsibility without retaining the obligation to review the work of the ERISA 3(38) fiduciary to validate that the delegated duties are in fact being performed. ERISA 3(21) Fiduciary Services defined: A plan sponsor can choose to share fiduciary responsibility with another named fiduciary. An ERISA 3(21) fiduciary does not have the authority as a decision maker to take discretion and make investment decisions on behalf of the plan sponsor. An ERISA 3(21) fiduciary may provide the due diligence necessary to select, monitor and replace investment options. An ERISA 3(21) fiduciary does not make investment decisions for the plan participant. The plan participant is solely responsible for his own asset allocation decisions. The plan sponsor freely delegates this responsibilities given to the ERISA 3(21) by virtue of the RPA. At the discretion of the plan sponsor, the ERISA can withdraw those rights given to the investment fiduciary and once again take back sole responsibility to select, monitor and replace plan investments. The plan sponsor cannot delegate responsibility without retaining the obligation to review the work of the ERISA 3(21) fiduciary to validate that the delegated duties are in fact being performed. Additionally, the plan sponsor will be required to provide approval to accept recommendations for plan menu options and ongoing changes. Services to Qualified Retirement Plans can include and will be clearly delineated in the RPA as fiduciary or non-fiduciary services:
• Investment selection • Ongoing monitoring • Assist in IPS design • Ongoing reporting on investments • Selection of QDIA • Client meetings and education
• Participant education • Participant enrollment
• Regulatory Assistance • Plan Design & Admin Assist Services Limited to Specific Types of Investments SM generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, ETFs, real estate, REITs, insurance products including annuities, and government securities. SM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs SM sponsors a wrap fee program; which is an investment program where the investor pays one stated fee that includes the transaction costs. SM does manage the investments in the wrap fee program. SM does not manage those wrap fee accounts any differently than non-wrap fee accounts. A portion of the fees paid to the wrap account program will be given to SM as a management fee. E. Amounts Under Management SM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $121,489,727.00 $5,234,244.00 December 2023