Established in 2002, KLR Investment Advisors, LLC ("KLRIA") provides investment advisory services to clients on a discretionary and non-discretionary basis. KLRIA has been registered as an investment advisor in the state of Rhode Island since April 3, 2003 and the Commonwealth of Massachusetts since July 14, 2007. KLRIA transitioned from state to federal registration, and became federally registered on May 13, 2020. KLR Wealth Management, LLC is owned by KLR Holdings, Inc and KLRIA is a subsidiary of KLR Wealth Management, LLC. KLRIA provides investment management services to individuals, pension and profit-sharing plans, trusts and corporations. The firm's investment management strategy is implemented in conjunction with the client’s investment objectives, risk tolerance level, liquidity needs, tax and/or legal implications and other concerns where applicable. KLRIA Managed Account Program At the start of the client relationship, KLRIA (or “Advisor”) will review the client’s individual financial circumstances, current investments, goals, objectives, risk tolerance, and time horizon. The client will complete a Risk Tolerance Questionnaire(“RTQ”) to document their investment risk level. The information provided by the client will assist KLRIA in making an investment recommendation that best meets the needs of the client. Investments are offered through Envestnet Financial Technologies, Inc. via LibertyFi, LLC (“Program Sponsor”), an unaffiliated registered investment advisor and financial technology platform. The KLRIA Managed Account Program is organized into four offerings, listed below. KLRIA Unified Managed Account (UMA) KLRIA Custom UMA Clients may consult with KLRIA to create a customized, single account strategy investing in a combination of third-party mutual funds, exchange traded funds (ETFs), fund strategist portfolios (FSPs) and separately managed accounts (SMAs) with consolidated performance and tax reporting. Investment minimum is $50,000. KLRIA Model Strategies KLRIA manages a suite of risk-based diversified model portfolios called the KLRIA Model Strategies, for taxable and tax-deferred accounts, created using third party mutual funds, exchange traded funds (ETFs) and separately managed accounts (SMA), with consolidated performance and tax reporting. Model minimums range from $178,000 to $500,000. Fund Strategist Portfolios (FSP) KLRIA offers model portfolios comprised of mutual funds and exchange traded funds (ETFs) managed by third party fund strategist portfolio (FSP) firms. Manager minimums range from $10,000 to $25,000. Separate Accounts (SMA) KLRIA offers separately managed accounts (SMAs) providing access to an asset class specific portfolio of individual securities managed by third party firms Manager minimums range from $100,000 to $400,000. Advisor as Portfolio Manager (APM) KLRIA maintains the capacity to offer this option only as an accommodation to its clients. Account holdings, etc. will be determined upon consultation with the client. Investment minimum determined by client and advisor. The Advisor will assist the client with the account opening documents of the custodian, Pershing Advisor Solutions, LLC (“Pershing”), to establish the client’s account, which may be managed on a discretionary basis, all or in part by KLRIA or the selected third-party investment manager. KLRIA will have oversight of the client’s account and conduct ongoing monitoring of the selected third-party investment manager. KLRIA, or the selected third party investment manager, will manage the investments and perform account rebalancing, on at least an annual basis, to maintain the asset allocation targets described in the Statement of Investment Selection (“SIS”). In consideration for such services, the Program Sponsor will add KLRIA’s management fee and the third-party investment manager’s fee to the Program

Sponsor’s fee and charge the client account. For more information on our fee and the independent manager’s fee, see Item 5. The client, at the time of entering into an agreement with KLRIA, will be provided with KLRIA’s Brochure and the selected third party manager’s Brochure (as applicable). Consulting Services KLRIA offers consulting services which include but are not limited to serving as a client’s Chief Financial Officer to become fully integrated in all aspects of our client’s financial life. Our consulting services will include, but not be limited to:
• Comprehensive consultative planning services that help you articulate your goals, develop budgets and create a financial plan.
• Provide guidance on business planning, asset protection, insurance, retirement, education, philanthropic, income tax and estate planning.
• 24/7 Concierge access to your advisor.
• Attendance at meetings with outside advisors.
• Year-end tax planning and business planning coordinated with your CPA, or tax preparation by KLRIA.
• Investment performance reports and on-line access to your accounts.
• On-demand meetings with your advisor.
• Determination of the proper asset allocation that reflects your risk tolerance and helps you to achieve your stated goals.
• Investment selection of the specific investments within the determined asset allocation.
• Investment implementation includes the work necessary to transition existing assets and deploy those assets to the selected investments.
• Ongoing performance monitoring and rebalancing of investments. At the beginning of the engagement with the client it will be determined what services will be provided and included in the KLRIA wealth management fee. For clients who only wish to retain KLRIA for planning services we will work out a mutually agreeable fee. Clients will be provided with an invoice from KLRIA, and payment is due and payable within 30 days of receipt. Client Imposed Restrictions As stated above, KLRIA manages or may utilize third party investment managers to manage its client portfolios. Clients invested in either the KLRIA Model Strategies or Fund Strategist Portfolio (“FSP”) program may not impose any restrictions to the model portfolio holdings. Clients invested in either the Custom UMA, Separate Accounts “SMA”), or Advisor as Portfolio Manager (“APM”) may discuss the imposition of certain security or industry level restrictions with either KLRIA or the selected third party investment manager. KLRIA invites clients to discuss any concerns they may have with any of the holdings in their account. Assets Under Management As of December 31, 2022, KLRIA manages $252,740,278 in Client assets, all of which are managed on a discretionary basis. KLRIA also has $25,790,210 in assets under advisement. KLRIA oversees total assets of $278,530,488. Clients may request more current information at any time by contacting the Advisor. Wrap Fee Programs KLRIA does not provide portfolio management services to wrap fee programs. Retirement Plan Advisory Services KLRIA provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Ongoing Investment Recommendation and Assistance These services are provided by KLRIA serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of KLRIA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.