Description of the Advisory Firm BRWM is a limited liability company organized in the state of Alaska. The firm was formed in June of 2012, and the principal owner is Brian Kent Pinkston. Types of Advisory Services BRWM offers the following services to advisory clients: Investment Supervisory Services BRWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, risk tolerance, income, tax situation, and other factors of each client. BRWM uses TIFIN profiles for each client to determine the appropriate asset allocation given the desired level of risk and return. The aforementioned additional information is captured via the Bright Road Wealth Management Client Profile Document (“BRWM Client Profile Document”), which, along with any other relevant supporting documentation, is used to construct an investment plan. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring BRWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon, among other things. BRWM 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, desired asset allocation and other information is documented in the TIFIN risk profile document, which is given to each client. Financial Planning Services BRWM also offers financial planning engagements for clients who do not participate in BRWM’s Investment Supervisory Services. This financial planning may include, but is not limited to: investment planning, life insurance, tax concerns, retirement planning, college planning, and debt/credit planning. Participant-Directed Retirement Plan Services BRWM provides advisory services to participant-directed retirement plans. As part of these services, BRWM will analyze the plan’s current investment platform, and assist the plan in creating a Client Name Investment

Policy Statement defining the types of investments to be offered and the restrictions that may be imposed within the plan, among other things. Further, BRWM will recommend investment options to achieve the plan’s objectives, provide participant education meetings, and monitor the performance of the plan’s investment vehicles. From time to time BRWM will recommend changes in the plan’s investment line-up. BRWM will meet with plan fiduciaries periodically to review plan investment performance, as well as the investment policy statement. In instances when it is in the best interest of the client, BRWM may refer Plan Sponsors to utilize Guideline as the fiduciary advisor for the plan. In these instances, Guideline will be the principal advisor, with BRWM acting in a non-fiduciary capacity as educator. Services Limited to Specific Types of Investments BRWM generally limits its investment advice and money management to mutual funds, equities, bonds, fixed income, debt securities, exchange-traded funds (“ETFs”), real estate investment trusts (“REITs”), and government securities. BRWM may use other securities as well to help diversify a portfolio when appropriate. Client Tailored Services and Client Imposed Restrictions BRWM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Totum Risk profile and BRWM Client Profile Document 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, if the restrictions prevent BRWM from properly servicing the client account, or if the restrictions would require BRWM to deviate from its standard suite of services, BRWM reserves the right to end the relationship. Assets Under Management As of December 31, 2023, BRWM manages approximately $272,427,874 on a discretionary basis, and $11,674,685 on a non-discretionary basis.