2 account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Depending on the client agreement, CFAM may be the only portfolio manager to an account, or CFAM may allocate a client’s assets to one or more Investment Solutions, Sub-Advisers, or portfolio strategies available to CFAM through one or more platform providers. Currently, CFAM utilizes various investment options provided by the AssetMark Advisory Platform (“AssetMark”). CFAM may enter into agreements with additional platform providers in the future. CFAM clients enter into agreements with such providers, as applicable, and are provided disclosures about the provider(s), which will include disclosures of any related fees and/or expenses specific to that provider. AssetMark Advisory Platform. – CFAM has entered into a sub-advisory relationship with AssetMark, an investment adviser registered with the U.S. Securities and Exchange Commission. Through CFAM, CFAM clients can utilize the AssetMark investment platform to access various Investment Solutions, including specialized tactical strategy portfolios that primarily utilize diversified baskets of exchange traded funds and indexed mutual funds (portfolios can also include individual equity securities at the discretion of the portfolio manager). The AssetMark platform, for which clients pay a quarterly fee, provides online access to their account information. In addition, CFAM may also recommend that clients authorize the active management of a portion of their assets with one or more sub-advisers whose management is available through Asset Mark. (“AssetMark”). Under the sub-advisory arrangements available through AssetMark, CFAM will remain responsible for determining the client’s investment objectives and whether one or more of AssetMark’s asset management programs are suitable to meet such investment objectives. AssetMark is responsible for the discretionary management of the assets for which CFAM, as the primary adviser, has instructed AssetMark to invest in one or more of AssetMark’s asset management programs. For more information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure Brochure which is available at https://adviserinfo.sec.gov/firm/summary/109018. The minimum investment required on the AssetMark Platform depends upon the Investment Solution chosen for a Client’s account and is generally $50,000 for Mutual Fund accounts and $100,000 for ETF Accounts, and from $50,000 to $500,000 for Privately Managed and Unified Managed Accounts, depending on the investment strategy selected. These minimums are described in more detail in the AssetMark Platform Disclosure Brochure. Accounts below the stated minimums may be accepted on an individual basis at the discretion of AssetMark. Most clients authorize CFAM the discretion to select Sub-Advisers and/or Investment Solutions on the AssetMark platform including the discretion to hire and fire Sub-Advisers. This means we can select and remove Sub-Advisers from your account without first consulting with you. Alternatively, some clients may prefer to have us select Sub-Advisers on a non- discretionary basis which means you will need to provide written authorization of a choice of, or change in, Sub-Adviser in advance. The decision to use a particular Sub-Adviser is always based on each client’s individual needs and is triggered when CFAM believes that a strategy offered or available by a Sub-Adviser is in the best interests of our clients. Selected Sub-Advisers will manage your assets by providing ongoing discretionary investment management services over your designated assets. Discretionary authority allows the Sub- Advisers to determine the securities to be purchased and sold in your accounts managed by the Sub-Adviser. A complete description of the Sub-Adviser’s services, fee schedules and account minimums will be disclosed in the Asset Mark Form ADV Disclosure Brochure which we will provide to you at the time a Sub-Adviser is added to your Account. Financial Planning and Consulting - CFAM offers financial planning services, which involve preparing a customized written financial plan covering specific or multiple topics. We provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolio Review, and Asset Allocation. When providing financial planning and consulting services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Written financial plans prepared by us do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. In addition to these services, we offer ongoing advisement consultations to participants in retirement plans (401(k) plans, profit sharing plans, etc.). When providing these services, we review your financial situation, goals, and objectives as well as the investment options available in the retirement plan. We will review your retirement plan account at quarterly intervals and will make such recommendations from the list of available investment options in your retirement plan account as are deemed appropriate and consistent with your stated investment objectives and risk tolerance. These services do not constitute asset management services for your retirement plan account; we do not have investment discretion or trading authority over

your retirement plan account. You determine whether or not to implement our advice. The implementation of any trades in your retirement plan account is your responsibility. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through CFAM or retain CFAM to actively monitor and manage your investments, you must execute a separate written agreement with CFAM for our asset management services. Seminars/Educational Workshops/Classes - CFAM may occasionally provide information presentations in areas such as financial planning, retirement planning and estate planning. Informational presentations are always offered on an impersonal basis and do not focus on the individual needs of participants. CFAM does not charge participants for these programs. However, we reserve the right to charge fees to cover the expenses incurred by us for the presentations. In this case, all fees and payment provisions will be fully disclosed to you prior to the presentation. Services Limited to Specific Types of Investments In general, CFAM limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, third party money managers, REITs, insurance products, including annuities, private placements, and government securities which are available through AssetMark. CFAM may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions CFAM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client’s 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 impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, client imposed restrictions may not be compatible with certain AssetMark Investment Solutions and may not be accepted by Sub Advisers that may be hired by CFAM. CFAM may individually manage a client’s portfolio without utilizing a platform Investment Solution or Sub-Adviser. Wrap Fee Programs CFAM does not sponsor or sub-advise any wrap fee programs. However, the Asset Mark Platform includes “wrap fee” arrangements, meaning that if your assets are invested in an AssetMark Investment Solution, or otherwise sub-advised by Asset Mark, you will pay a fixed fee to AssetMark that includes both transaction fees, or commissions and investment management fees. AssetMark fees vary depending on which AssetMark Investment Solution or Sub-Adviser is applied to your account. Clients do not pay separate transaction fees for individual portfolio trades in their Account when their Account is invested in an AssetMark Investment Solution or another sub-advised portfolio. The wrap fees may be higher or lower than if such services were obtained separately. Generally, wrap programs are relatively less expensive for actively traded accounts. However, they often result in higher overall costs to the client in accounts that experience little trading activity. Amounts Under Management As of December 31, 2022, CFAM had total assets under management of $174,444,246, of which $174,444,246 are managed on a discretionary basis. Asset Management Fees Fees charged for our asset management services are charged based on a percentage of assets under management, billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the prior billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of a billing period, the prorated fee will be charged at the end of the next calendar quarter. Fees for the initial billing period will be billed in arrears at the same time as the next full billing period’s fee is billed in advance. If your account is terminated on a date other than the last business day of a quarter, pro-rated fees will be refunded for the time remaining in the quarter for which you were already billed, using the number of days in the quarter prior to termination. The fees charged by CFAM for our asset management services range from .70% to 1.50% annually and are generally based on the amount of assets a client has under management with CFAM. CFAM clients are also charged a “platform fee” by AssetMark, which will range from .20% to 1.0%, depending on which of AssetMark’s Investment Solutions, and/or Sub-Advisers, are utilized to manage your accounts. AssetMark provides full disclosure of the applicable fees for the various investment options offered by AssetMark. See “Fees for Third-Party Management/Sub-Advisory Services” for details about the AssetMark fees. Fees charged for our asset management services are negotiable based on the type of client, the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the potential for additional assets, deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. The exact amount of fee that will be charged for our asset management services will be specified in your client agreement. CFAM believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our investment advisory fees may be higher than that charged by other investment advisers offering similar services/programs. Our investment advisory fees will be deducted from your account and the investment advisory fees will be paid directly to our firm by the qualified