Advisory Firm Asset Planning Corporation (“APC” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). APC is corporation under the laws of the State of Tennessee and was founded by P. Kemp Fain, Jr. and has been providing independent investment advisory services since 1975. The Advisor is owned and operated by Joseph Ottaviano. The following pages describe APC’s services, fee arrangements, and business practices. Advisory Services APC provides wealth management and related advisory services to individuals, charitable organizations, trusts, estates, business entities, and non-profit organizations (each a “Client” and also “you”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. APC’s fiduciary commitment to each Client is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth management is a process designed to help you determine your financial goals and the strategies that will increase the likelihood of reaching those goals. APC’s wealth management service includes both personal financial planning and portfolio management. The steps in the financial planning process are: 1. Understanding the Client’s personal and financial circumstances. 2. Identifying and selecting goals. 3. Analyzing the Client’s current course of action and potential alternative course(s) of action. 4. Developing the financial planning recommendation(s). 5. Presenting the financial planning recommendation(s). 6. Implementing the financial planning recommendations (ex: portfolio management). 7. Monitoring progress and updating. Financial planning may focus on areas including investment strategy, financial independence, education funding, insurance, taxes, and estate planning. The objective of portfolio management is to maximize the rate of return consistent with your financial goals and risk tolerance. As a result of successful planning, many people accumulate portfolios of assets, which require time and expertise to manage. Many investors lack the time required to efficiently manage their assets. Portfolio management provides ongoing, professional supervision of your investment assets. Also, Clients find it convenient to have a third party keep records and manage their investments for them. You specify your risk tolerance level. APC reviews managed portfolios at least quarterly and we make any needed changes to rebalance to the target asset allocation and/or to ensure best execution on a discretionary basis.

Discretion means that we place trades without prior approval from you. APC will contact or attempt to contact you at least annually to review your financial plan and portfolio. It is your responsibility to notify APC at any time there are changes in your financial situation or life matters. You may contact APC as needed to discuss your account, financial situation, or investment needs. APC typically recommends that Clients select Charles Schwab & Co., Inc. (“Schwab”), a FINRA- registered broker-dealer and member SIPC, as its “qualified custodian” (hereinafter the “Custodian”) to serve as the primary asset record-keeper, custodian and broker-dealer for Client accounts. You will receive from the Custodian timely confirmations and monthly statements containing a description of all transactions and all account activity. You will retain rights of ownership of all securities and funds in the account[s] to the same extent as if you held the securities and funds outside APC’s portfolio management service. In addition to statements from the Custodian, APC sends quarterly performance reports to you. However, the Custodian statements are always the official records for your account[s]. Participant Account Management - As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. The Advisor is not affiliated with the platform in any way and does not receive 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. Once Client account(s) is connected to the platform, the Advisor will review the current account allocations. When deemed appropriate, the Advisor will rebalance the account considering client investment goals and risk tolerance, and changes in allocations will take into account current economic and market trends. The goal is to improve account performance over time and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Other Services APC occasionally holds Client seminars and workshops. These seminars may include presentations on various investment topics or on financial planning strategies. Generally, there is not a fee to attend. As of December 31, 2023, APC has $366,495,524 in assets under management on a discretionary basis and $5,059,375 of assets under management on a non-discretionary basis, with total assets under management of $371,554,899.