Firm Description Richard W. Paul & Associates, LLC (“we” or “the Firm”) is a Michigan registered investment adviser formed in March 2011. It is owned by Richard W. Paul. Matthew M. Paul is the Chief Compliance Officer. The Firm is a fee based financial planning and investment management firm. The Firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The Firm’s managing member has an affiliated business, Midwest Financial Consultants which sells insurance products and recommends that clients purchase insurance products as a substitute for securities products within a clients portfolio. Please see Item 10 of this brochure for more information. The Firm does not act as a custodian of client assets. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement or risk analysis. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Types of Advisory Services Prior to the Adviser-Client relationship, the Firm may offer a complimentary general consultation to discuss services available, to give a prospective Client time to review services desired, and to determine the possibility of a potential relationship. Investment advisory services begin only after the Client and Firm formalize the relationship with a properly executed Client Agreement. In the client on-boarding process, each client has a custom retirement income projection built out. This is unique to the client based on their situation and helps determine income needs in retirement. We also perform a risk assessment and talk through what type of volatility they are comfortable seeing. We then create a recommended allocation of active managed solutions, passively managed solutions, and annuities, tailored to their income needs, growth goals, and risk profile. Actively managed solutions are monitored closely and are adjusted as needed, whereas passively managed solutions have a set allocation determined in January, and only rebalanced as needed if the allocation falls out of balance. Annuities are disclosed to clients as insurance vehicles and regulated by the MI Department of Insurance, and compensation and conflicts of interest are disclosed in writing. The weight of AUM to annuity is determined by the unique needs of the client (risk tolerance, income needs, etc). The following services are offered by the Firm: Portfolio Management Services The Firm offers discretionary direct asset management services to advisory clients. The Firm manages individualized portfolios for its Clients. The Firm works with each Client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. The Firm uses marketable securities that may include bonds, common stock (equities), and treasury bonds. The investment philosophy of the Firm is to use principals of value, safety and quality to seek investment options globally. The Firm places heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. When deemed appropriate for the Client, we may hire Sub-Advisors to manage all or a portion of the assets in the Client account. The firm has full discretion to hire and fire Sub- Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and the firm. Sub-Advisors execute trades on behalf of the firm in Client accounts. The firm will be responsible for the overall direct relationship with the Client. The firm retains the authority to terminate the Sub-Advisor relationship at the firm’s discretion. Financial Planning: The Firm offers financial planning consultations to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews the Firm will collect pertinent data, identify goals, objectives, financial problems,

potential solutions, prepare specific recommendations and implement recommendations. Some clients may only require advice on a single aspect of the management of their financial resources. For these clients, the Firm offers financial planning in a modular format and/or general consulting services that address only those specific areas of concern. The Firm’s services include any one or all of the following: 1. Spreadsheet Analysis, Reports & Consultations – This includes the formation of financial statements that may include a financial summary and cash flow statement as well as analysis of these items to evaluate the client’s current situation and to help build a financial roadmap for the future. The Firm also may consolidate account information such as account titling, account numbers, cost basis, inception dates, market values and interest/dividend earnings where such information is available. 2. Retirement Planning – This involves advice with respect to alternatives and techniques for accumulating wealth for retirement income or advice relative to appropriate distribution of assets following retirement. Additionally, self-directed retirement assets are evaluated and, where appropriate, recommendations and assistance are provided. Tax consequences and their implications are identified and evaluated in general terms. The Firm is not engaged in rendering legal or accounting advice, has no lawyers or accountants on staff and therefore refers all matters requiring legal or tax advice to the Client’s chosen and properly licensed professionals in these areas. 3. Investment Planning/Asset Allocation/ Fund Choice – This involves advice with respect to asset allocation and investment income accumulation techniques. Evaluations are made of existing and, when applicable, potential investments in terms of their economic and tax characteristics as well as their suitability for meeting client’s objectives. Tax consequences and their implications are identified and evaluated in general terms. 4. Estate Planning – This service generally involves a review of assets and liabilities, the titling of assets and the consideration of trusts. However, the Firm may provide advice with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques as well as a discussion of gifts, trusts, etc. and the disposition of business interests. Tax consequences and their implications are identified and evaluated in general terms. The client’s chosen licensed attorney must be used for evaluation and document creation. 5. Insurance Planning – This includes risk management associated with advisory recommendations based on the combination of insurance types that best meet a client’s specific needs, e.g. life, health disability, long-term care, and others as appropriate. 6. College Planning – This includes alternative and strategies with respect to the complete or partial funding of college or other post-secondary education experience. Tax consequences and their implications are identified and evaluated in general terms. 7. Tax Planning – Tax planning is referred to the client’s chosen personal tax advisor. The Firm may offer advice as to how tax laws may affect various financial decisions, e.g. acquisitions, pension strategy, investing in new opportunities or consolidation of existing investments, and individual taxations issues, among others. 8. Consolidation of Financial Situation – As a result of performing some or all of these services listed in bullets 1 through 7, the Firm may be able to recommend strategies or methods for consolidating the client’s financial situation in order for the client to manage their financial situation more easily and to obtain efficiency, cost savings, and diversification. Client Tailored Services and Client Imposed Restrictions Agreements may not be assigned without written client consent. Wrap Fee Programs The Firm does not participate in wrap fee programs. Client Assets under Management The Firm has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $263,833,052 $0 07/20/2023