Page 4 A. Carter Financial Group, Inc. Carter Financial Group, Inc. (“Carter Financial” and/or “the firm”) is an Illinois corporation primarily owned by Kevin Carter. Carter Financial has been providing investment advisory services since October 2019. B. Advisory Services Offered Investment Management Services We offer Investment Management Services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Management Services may include, but are not limited to, the following: ▪ Discretionary and non-discretionary investment management ▪ Asset allocation strategy ▪ Regular and/or continuous portfolio monitoring ▪ Portfolio allocation with third-party managers ▪ Self-directed trading accounts/selection of third-party managers through Eaglebrook platform ▪ Coordination with other third parties (accountants, attorneys, insurance agents, etc.) on an as-needed basis For discretionary investment management services, Carter Financial receives a limited power of attorney to effect securities transactions on behalf of clients that include securities and strategies described in Item 8 of this brochure. Discretionary authority allows us to act on behalf of the client in most matters necessary or incidental to the handling of the account, including monitoring certain assets, without the client’s prior approval. Risk tolerance levels establishing the client’s objectives and suitability will be documented and made available to each client. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Carter Financial will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Carter Financial will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Plan Participant Account Management (Discretionary) We use a third-party platform (Pontera Order Management System) to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of client funds since we do Page 5 not have direct access to client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no 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, we will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, 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. We may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between our firm and the client. Financial Planning Services Carter Financial offers financial planning as part of its investment management services or as a standalone service. Several primary areas are evaluated in order to develop a written financial plan, tailored to fit the client’s needs. Consultation may involve discussion of the client’s assets and liabilities, current income and expenses, goals and objectives, current investments, insurance coverage, retirement planning, estate planning, business holdings, education planning, special needs planning, and the attitudes and investment philosophy of the client. These topics may be discussed, along with other relevant factors to help assess the client’s immediate and long-term financial needs. Financial planning services may include any of the following topics: ▪ Individual savings goals and asset allocation ▪ Assistance with major purchase buy/sell decisions ▪ Retirement accumulation planning ▪ Retirement income planning ▪ Education planning and funding choices ▪ Qualified plan and IRA distribution analysis ▪ Retirement social security benefit analysis ▪ Investment planning ▪ Financial organization through a personal financial website ▪ Insurance planning ▪ Estate planning and gifting strategies ▪ Executive planning with stock options and deferred comp evaluations ▪ Business planning services ▪ Divorce planning ▪ Estate distribution services ▪ Special needs planning Page 6 Carter Financial provides online access to client’s financial assessment, and includes recommendations and investment strategies on how to achieve the client’s goals and objectives. Written financial reviews are available upon client request. Implementation of the prepared plan or recommendations is mutually developed with the client and is solely at client’s discretion. Carter Financial encourages clients to utilize any desired professional or group of professionals to assist in the implementation. Flourish Cash Carter Financial provides clients the opportunity to establish checking accounts through Flourish Cash, a cash management platform. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be sold in the portfolio. D. Wrap Fee Programs Carter Financial does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) Carter Financial may recommend wrap fee programs offered through third-party managers. Carter Financial’s fee is separate and distinct from the fees charged by such third-party managers. E. Client Assets Under Management As of December 31, 2023, Carter Financial had $246,435,548 of discretionary assets under management and $44,557,374 of non-discretionary assets under management. Item 5: Fees and Compensation