A. Description of the Advisory Firm Wisdom Index Advisors, LLC (hereinafter “Wisdom Index Advisors”, “Wisdom Index” or “WI”) is a privately-owned SEC registered investment advisor that offers personalized wealth management and investment consulting solutions for select individuals, corporations, trusts, pension and profit-sharing plans, estates, charitable organizations and small businesses. WI was founded on July 27, 2004 and is currently registered with the Securities Exchange Commission. Principal Owners Michael J. Davidson is the only firm principal and is a 100% stockholder. B. Types of Advisory Services WI offers wealth management solutions to customers (hereinafter “Clients” or “Client”) by combining investment management services and advanced planning services. Investment Management Services WI implements portfolio and investment management services based upon Nobel-prize winning academic research utilizing primarily market-based investment strategies and long-term holding periods. Differentiated from traditional investment management where the primary objective is to beat the market by stock picking or market timing, WI directs Client investments applying the following financial principles: Markets Work Efficiently Risk and Expected Return are Related Market Dimensions Have Different Risk Factors Asset Allocation Determines Risk & Expected Return Investing Requires Time Investing Requires Rebalancing Investment management services are facilitated through the creation and implementation of a Wisdom Index and Investment Policy Statement (IPS). The IPS includes information about the Client including values, accomplishments, key relationships, feelings about risk, balance sheet information, other advisors and financial goals. The IPS is a key component to the overall plan and helps to communicate and implement the investment strategy. WI analysis methods utilize resources from commercially available software packages, market rating services, general market data and financial publications. WI also benefits from the economic expertise and investment knowledge of economists affiliated with Dimensional Fund Advisors (DFA). We approach client account management with a holistic view, utilizing mutual funds, exchange traded funds and individual fixed income securities to provide diversification. Wisdom Index may also recommend small allocations to registered interval funds to improve client diversification. Advanced Planning Services – Wisdom Index® On more than an occasional basis, WI furnishes advice to Clients on matters not involving securities, such as financial planning matters, taxation concerns, life insurance, retirement planning, college planning, debt/credit planning and stewardship consulting. Typically, these areas are covered in the creation of the Client (IPS) but may also be addressed in the development of a client Wisdom Index®. The Wisdom Index® may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations.

The first Client meeting, called a Discovery Meeting, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the Client. The next step is the development of a draft Wisdom Index® and IPS. WI will work closely with the Client and their other advisors to implement the necessary next steps. Retirement Plan Services WI offers services to qualified retirement plans utilizing the same investment management approach for individual clients. Typically, this involves analyzing current plan investments, building investment policy statements and creating model portfolios for plan participants. WI generally serves in the capacity of a 3(38) “Investment Manager” to these plans and is a fiduciary under ERISA with respect to investment management services and advice provided to ERISA Clients, including plan participants. Prohibited transaction exemption (“PTE”) 2020-02 Improving Investment Advice for Workers and Retirees is a new prohibited transaction exemption that falls under ERISA, and the code for investment advice fiduciaries with respect to ERISA covered employee benefit plans, individual retirement accounts, and health saving accounts. It is intended to ensure that the investment advice fiduciaries can be granted exemption from the DOL 2020 investment advice rule so that they can offer and be compensated for recommendations that are in the best interest of the retirement investors. PTE applies to registered investment advisers, broker-dealers, banks, insurance companies, and their employees and agents, plan participants, individual retirement account owners, and health saving accounts owners. Without the exemption, these institutions, the employees, and agents cannot be compensated for their investment advice because to do so would be a conflict of interest. Wisdom Index seeks the following standards when providing IRA rollovers: Offer advice that is in the Retirement Investor’s best interest. Charge reasonable compensation for services. Seek to obtain the best execution of investment transactions; and Acknowledge fiduciary status under ERISA with respect to investment advice rendered to Retirement Investors. Provide a description of the services provided and disclosure of material conflicts of interest. With respect to rollovers only, provide an explanation of the rationale as to why the recommendation is in the best interest of the Retirement Investor. Include a consideration of alternatives. Address fees associated with both the plan and the IRA; C. Tailored Relationships and Client Imposed Restrictions Client goals and objectives are documented in a custom Client profile and stored in our Client relationship management system. Custom Investment Policy Statements contain stated goals, values, feelings about risk and objectives. Clients may impose restrictions on investing in certain securities or types of securities. D. Wrap Fee Programs WI does not participate in any wrap fee programs. E. Assets Under Management As of 12/31/2023, WI manages approximately $180,307,263 in assets on a discretionary basis, and $0 is managed on a non-discretionary basis. A discretionary basis includes the Client authorizing WI to manage Client accounts within the chosen investment strategy; therefore, WI is responsible for determining which trades to make.