Charter Advisory Corporation (hereinafter “Charter”), offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Charter’s services and fee arrangements are described in the following pages. Charter is a corporation formed under the laws of the State of Indiana. Charter has been conducting advisory services since 1979. Michael J. Kelley is the principal owner and President of Charter Advisory Corporation. This narrative provides clients with information regarding Charter and the qualifications, business practices, and nature of advisory services that should be considered before becoming an advisory client of Charter. Individuals associated with Charter will provide its investment advisory services. These individuals are authorized to provide advisory services on behalf of Charter. Such individuals are known as Investment Adviser Representatives (IARs). IARs with Charter are registered representatives of LPL Financial, a licensed full service securities broker/dealer and investment adviser under federal and state securities laws, located in Boston, Massachusetts. LPL Financial is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). Securities transactions for LPL's brokerage clients are executed through LPL. Charter is not an affiliate of LPL Financial. Financial Planning Services Financial planning services will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of their individual needs. Charter works with a variety of clients to assist them with their long and short term financial planning. Charter focuses on the preparation of financial plans, which plans provide a framework and structure for combining client goals with current and future savings and retirement programs. It also works on a contract basis to assist clients in decisions concerning their investments, insurance and other related accounts. Charter relies on responses provided by clients to questionnaires and interviews, as well as copies of supporting documentation and/or data provided by the client or its lawyer, accountant or other advisers. Implementation of the prepared plan or recommendations is solely at the discretion of the client, with the client also determining how he/she will implement the plan or recommendations. The client is encouraged to utilize any desired professional or group of professionals to assist in implementation. Charter’s Investment Advisory Services Charter provides investment advisory services to its clients on a discretionary and non- discretionary basis. The advisory services include, among other things, providing advice regarding asset allocation and the selection of investments. Account management is guided by the stated objectives of the client. In addition, the Adviser considers the client’s risk profile and financial status prior to making any recommendations. LPL Financial Sponsored Advisory Programs Charter may provide advisory services to clients through certain programs sponsored by LPL Financial (LPL), a registered investment adviser and broker/dealer. Below is a brief description of each LPL advisory program available to Charter. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. LPL Advisory Services Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $50,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $1,000; note that accounts below $10,000 are required to have annual or recurring contributions in place for OMP. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion for selecting third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. Advisor will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize

LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $10,000. In certain instances, a lower minimum for a portfolio is permitted. Small Market Solution (SMS) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus (“Fiduciary Selection Services”). The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that term is defined in section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None of the services offered under SMS other than the Fiduciary Selection Services will constitute “investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or Charter to be deemed a fiduciary. In addition to the Fiduciary Selection Services, Plan Sponsor may also select from a number of non-fiduciary consulting services available under SMS that are provided by Charter. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets, and LPL and Charter do not act as fiduciaries under ERISA in providing such consulting services. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell open-end mutual funds and exchange-traded funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although Advisor will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and Charter by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or Charter, do not enter into an advisory agreement with LPL, FutureAdvisor or Charter, do not receive ongoing investment advice or supervision of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Solicitation/ Referral Services to Sponsored Programs Directly Managed Programs In directly managed programs, Charter will refer clients to independent, third-party investment advisers (TPIA). The TPIA manages the client's account in accordance with the disclosures set forth in the third-party investment adviser's documents. Charter is engaged by the TPIA to provide referral services on behalf of the TPIA pursuant to an agreement between Charter and the TPIA. Charter is compensated by the TPIA for referring the clients. The TPIA may assume discretionary authority over the assets in the accounts participating in these programs. Charter provides the following services on behalf of the TPIA. Charter typically gathers information from the client about the client's financial situation, investment objectives, and reasonable restrictions the client wants to impose on the management of the account. Charter then periodically reviews reports provided to the client; contacts the client at least annually to review the client's financial situation and objectives; communicates information to the third-party investment adviser as warranted; and assists the client in understanding and evaluating the services provided by the third party adviser that is directly managing the account. ERISA Plan Services Charter is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (ERISA) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. Charter is also a fiduciary under the Internal Revenue Code (IRC) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, IRAs and IRA owners (collectively, “Retirement Account Clients”). As such, Charter is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (PTE). Charter manages assets on a discretionary or nondiscretionary basis. As of December 31, 2023, Charter managed $319,216,086 of client assets of which, $267,933,135 in 935 accounts are managed on a discretionary basis and $51,282,951 in 19 accounts are managed on a non- discretionary basis.