Firm Description Burnham Gibson Wealth Advisors, LLC ("BGWA" "Adviser" or “Firm”) is an independent registered investment adviser that was founded in 2015. The firm's founder, Darin Gibson, has worked in the financial services industry for approximately 20 years prior to establishing BGWA. The Adviser is part of The Baldwin Insurance Group, Inc. (The Baldwin Group, NASDAQ: BWIN ). The Baldwin Group is an independent insurance distribution firm delivering tailored insurance and risk management insights and solutions. BGWA is engaged in the business of providing investment advisory, consulting cash management and asset management services to a broad range of clients including individuals, pension and profit- sharing plans, defined benefit plans, trusts, estates, charitable organizations, and small to mid-size businesses. BGWA offers advice through consultation with the client which may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. As of December 31, 2023, BGWA discloses approximately $3,244,151,546 in total assets representing: (1) $609,427,097 of assets under discretionary management in its Asset Management Services; (2) $2,634,724,449 of assets under non-discretionary management in its Portfolio Management Services; (3) $2,654,077,807 plan assets under consultation. Assets under consultation are assets for which BGWA acts as a 3(21) or a 3(38) fiduciary and provides ongoing recommendations based upon the needs of the retirement plan client, as to which specific securities or other investments to make available to its plan participants, among other services. Types of Advisory Services BGWA uses a four-step consultative process to provide a personalized investment strategy based on the disciplines of asset allocation and diversification. Once BGWA determines the best allocation to help clients meet cash flow and accumulation goals, it will construct a portfolio based on a disciplined methodology of evaluating investments and investment managers. BGWA uses a combination of institutional management, separate accounts, mutual funds, exchange traded funds, and other types of securities to provide a customized investment strategy that the Adviser manages with the client in mind. Fee Based Investment Management Asset Management: BGWA provides investment supervisory services, also known as asset management services, for separately managed accounts of its clients. Based on the client's goals and investment objectives, BGWA will build a customized portfolio consisting of stocks, bonds, options, mutual funds, real estate investment trusts, exchange traded funds ("ETFs"), and/or other types of investments. Other types of investments may include variable annuity products through a third party insurance company. Investors should carefully consider a variable annuity’s risks, charges, limitations, and expenses, as well as the risks, charges, expenses, and investment goals of the underlying investment options. Information about variable annuities is provided in the product and underlying fund prospectuses. These prospectuses should be read carefully before investing. The Adviser may also suggest using certain third-party money managers, alternative investments and/or limited private offerings in the event an Investment Advisor Representative considers it appropriate for eligible accounts based on the client's needs and investment objectives. BGWA customizes clients' portfolios according to their individual risk tolerance, time horizon and specific goals. For example, a client is able to place certain restrictions on their accounts, such as restricting BGWA from purchasing or selling a specific security and/or restrictions on the types of securities, industries or sectors that may be included as part of the client's account. Note that this may not be possible in all situations, such as when the client invests in mutual funds and ETFs. Additionally, clients should understand that when they place restrictions on the management of their account, the account's performance will be altered as compared to when we have full discretion to select investments. Client assets managed by BGWA are held in accounts at a registered broker-dealer and qualified custodian selected by the client, who will provide clearing, custody and other brokerage services for client accounts. While BGWA may assist the client in completing the custodian's paperwork, the client is ultimately responsible for providing all of the necessary information to establish the account. Clients will retain all rights of ownership on the accounts, including the right to withdraw securities and cash, vote proxies, and receive transaction confirmations. Cash Sweep Account Asset Management: BGWA acts as an investment adviser with limited authority to only invest client investment account assets in a money market fund by the Adviser. The scope of our advice is necessarily limited and therefore the account should be considered only part of a client’s overall investment plan. For clients in the cash sweep program, we do not meet with clients to determine the objectives, and we will have no responsibility for the management or diversification of any of the client’s assets which are not part of the Cash Sweep Account. Portfolio Management Services: BGWA also provides advisory services through certain programs sponsored by third party investment advisory firms. These programs allow clients to access third party Portfolio Managers, who will provide individual management to a client's account on a discretionary basis. A broad range of Portfolio Managers and multiple investment styles are available, including equity, fixed income, balanced, international, ETF, REIT and socially responsible portfolios. BGWA will help the client determine his or her investment objectives and risk/return preferences, to identify any investment restrictions on the management of the account, and to select an investment strategy and Portfolio Manager. The IAR provides the client with ongoing advice and monitoring relating to the Portfolio Manager's services and functions as the point of contact between the client and the Portfolio Manager with regards to changes in the client's investment objective, financial situation and investment restrictions. For more information regarding these programs, including the advisory services and fees that apply, the types of investments available in the programs, and the potential conflicts of interest presented by the programs, please refer to the appropriate disclosure document for the specific program. IRA Rollover Recommendations: When we provide “investment advice” (as that term is defined under DOL regulations) to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Financial and Estate Planning BGWA offers financial and estate planning services that can be comprehensive in nature or focus on a specific

topic or concern such as: retirement planning, tax planning, insurance planning, estate planning, educational funding, cash flow planning, retirement plan allocations and investments. BGWA's financial and estate planning philosophy focuses on helping clients achieve their goals and objectives, with an emphasis on linking their current financial situation, aspirations and lifestyle. BGWA uses a five-step process to help clients develop a plan to work towards specific goals.
• DISCOVERY - Listen to the client's goals, outline the client's objectives, and gather quantitative data to obtain a clear picture of the client's financial situation
• ANALYSIS - Develop an analysis that compares the client's existing plan to future goals and objectives
• STRATEGY - Create a final plan with specific recommendations to meet the client's stated goals
• IMPLEMENTATION - Manage the execution of recommended strategy to confirm the client's financial future is on track
• MONITORING - React to changes proactively and adjust the implemented plan to stay on course BGWA will provide a final written financial plan to the client by the end of the engagement. This may include a retirement model, portfolio analysis, insurance projection or other recommendation as based on the financial planning contract. Should the client choose to implement the recommendations contained in the plan, BGWA suggests that the client work closely with his or her attorney, accountant, and/or other advisors as necessary. Implementation of the financial plan recommendations are entirely at the client's discretion. Financial planning recommendations are client specific and are not limited to any product or service offered by a broker-dealer or insurance company. Retirement Plan Consulting Services BGWA provides service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) group, pension and profit sharing, defined benefit, simple IRA's, SEPs, ESOPs, deferred compensation, split dollar, 457(b) and (f), SERP (Supplemental Executive Retirement Plan), golden parachute and golden handcuff plans. BGWA offers plan sponsors the following consulting services: fiduciary compliance, investment due diligence, platform/fee benchmarking, employee education and communication, and plan strategy/design. In this capacity, BGWA provides both 3(21)(a) fiduciary services as well as 3(38) investment management and non-fiduciary services as further described below. 1. Limited Scope 3(21)(a) Fiduciary. BGWA acts as a limited scope 3(21)(a) fiduciary that advises, helps and assists plan sponsors with their investment decisions, which often includes selection of investment options and asset allocation recommendations. 2. 3(38) Investment Manager. BGWA also serves as an investment manager to certain plans in which it is granted discretionary management by the plan sponsor to select, monitor and replacement plan investments. Additional services applicable to BGWA's Retirement Plan Consulting Services are described in the client agreement. BGWA is deemed a "Covered Service Provider" to pension plan clients under ERISA Section 408(b)(2) regulations and is a fiduciary under Sections 3(21) and/or 3(38) of ERISA with respect to services involving “investment advice” (as that term is defined under DOL regulations) concerning or the exercise of investment discretion over plan assets. ERISA Section 408(b)(2) requires Covered Service Providers to make required disclosures to the responsible plan fiduciary ("RPF") that are in writing and include information the RPF needs to (i) assess the reasonableness of total compensation, both direct and indirect, received by the Covered Service Provider, its affiliates, and/or subcontractors, (ii) identify potential conflicts of interest, and (iii) satisfy reporting and disclosure requirements under Title I of ERISA. BGWA provides its pension plan clients with such information prior to entering into a written agreement with such clients, and upon changes to the information in accordance with ERISA and DOL regulations. Other Corporate Services BGWA and/or its affiliate Burnham Benefits Insurance Services, LLC ("Burnham Benefits) and The Baldwin Insurance Group Holdings, LLC (by and through its direct and indirect subsidiaries) offer several corporate services designed to assist a business in developing a strategy to meet its goals. These services include business succession planning, risk management and insurance services, executive benefit plans, employee benefit plans, and property and casualty insurance. The ownership and compensation structure for BGWA, employees and owners of Burnham Benefits or other affiliated entities do present a conflict of interest in that using affiliated entities may not be the lowest cost solution(s) and compensation or enrichment may lead to the use of affiliated services. No client is obligated to use the services of any of our affiliates, and such services are available from other providers. Written Agreements Prior to engaging BGWA to provide any of the foregoing investment advisory services, clients are required to enter into one or more written agreements with BGWA setting forth the terms and conditions under which the Adviser renders its services (collectively the "Agreement"). Clients also enter into agreements with their custodian. Clients who enroll in one of LPL Financial’s advisory programs, including the MAS Program (collectively, the “Advisory Programs”), will enter into an agreement with LPL Financial that governs the terms of the Program (the “Program Agreement”). Termination of Agreement A client may terminate an Agreement at any time by providing BGWA written notice. Unless otherwise stated in the terms of the Agreement, clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, the Adviser will refund any unearned portion of the advance payment. Clients terminating (surrendering) third party variable annuity contracts recommended by BGWA and associates are billed in arrears for fees incurred. BGWA may terminate an Agreement at any time by providing the client with written notice. If the client made an advance payment, BGWA will refund any unearned portion of the advance payment. BGWA reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser's judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded. Assignment of Agreements Agreements may not be assigned without client consent. Wrap Fee Programs BGWA does not currently sponsor nor provide management services to any wrap fee program (an advisory program under which a specified fee is charged for investment advisory services and execution of transactions). However, BGWA may recommend that its clients participate in a wrap-fee program, based on the client's specific financial needs and investment objectives. Under the MAS Program, clients pay a single fee for BGWA’s investment advice and LPL Financial’s execution and other services. This single fee is divided by LPL Financial and BGWA, BGWA’s share of the combined fee will change over time and BGWA may receive up to 100% of the MAS Program fees.