A. Description of the Advisory Firm ROI Financial Advisors, LLC is a Limited Liability Company organized in the State of Oregon. The firm was formed in August of 2012, the sole owner is Lance Jarl Johnson. B. Types of Advisory Services ROI Financial Advisors, LLC (hereinafter “ROI Financial”) offers the following services to advisory clients. Investment Supervisory Services ROI Financial offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ROI Financial creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, risk tolerance levels and other important elements of suitability) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific needs. Investment Supervisory Services include, but are not limited to, the following:
• Investment Strategy
• Personal Investment Policy
• Asset Allocation
• Asset Selection
• Risk Tolerance
• Regular Portfolio Monitoring ROI Financial evaluates the current investments of each client with respect to their investment objective, risk tolerance levels and time horizon. ROI Financial 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 are documented in the Investment Policy Statement, which is given to each client. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance, tax concerns, retirement planning, college planning, estate planning, and debt/credit planning. These services are based on fixed fees or hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement and as noted below. One Year Financial Planning Agreement Clients that choose this option will be billed at the listed fee as determined by the client and ROI Financial and will not be eligible for any discounts from the listed fee found in the Financial Planning Agreement. Services will be provided for one year and there will be no expectation from the client or ROI Financial for Financial Planning services to be provided or fees to be collected past the one year anniversary date of the Financial Planning Agreement. Annual Renewal Agreement Clients that choose this option will be offered a discount from the listed prices as stated in the Financial Planning Agreement. The client will be billed on an annual basis at the agreed upon rate. ROI Financial will provide an updated plan to the client each year when fees are paid in full. Business Module For clients that own small businesses, ROI Financial can complete Business Financial Planning in conjunction with Personal Financial Planning. The Business Module is offered as an add on to the personal comprehensive financial plan. During the financial planning process, the Business Module will focus on business related cash flows, ownership, owner compensation, retirement plan opportunities, and business related tax scenarios. Advanced Estate Module For clients that have large and/or complex estate scenarios, ROI Financial offers an Advanced Estate Module. This module will assist in the planning and implementation of complex trusts (ROI Financial does not offer legal advice, consult an Estate Attorney for the creation of legal documents). The client’s options and wishes for estate planning will be included through detailed illustrations. This module is required when the plan is more complex than a standard Living will and/or Living Trust. Services Limited to Specific Types of Investments ROI Financial generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETF’s, real estate, hedge funds, REITs, insurance products including annuities, and government securities. ROI Financial may use other securities as well to help diversify a portfolio when applicable. Pension Consulting Services ROI Financial offers pension consulting services that include: identifying investment objectives and restrictions; allocating plan assets to various objectives; selecting money managers to manage plan assets in ways designed to achieve objectives;

selecting mutual funds that plan participants can choose as their funding vehicles; monitoring performance of money managers and mutual funds and making recommendations for changes; and selecting other service providers, such as custodians, administrators, and broker-dealers. ROI Financial may recommend a retirement plan administrator to clients. ROI Financial may be compensated by the retirement plan services administrator for working with the client. ROI negotiates the compensation and service arrangement with the client, however the client contracts directly with the Plan Administrator for services and fee payment. Held Away Assets ROI utilizes Pontera, a third-party platform, to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows ROI to avoid being considered to have custody of client funds since the Firm does not have direct access to client log-in credentials to affect trades. ROI is not affiliated with the Pontera platform in any way and receives no compensation from them for using their platform. In order for ROI to manage held away assets (assets not held at Schwab) a link will be provided to the client allowing them to connect an account(s) to the platform. Once a client account is connected to the platform, ROI will review the current account allocations. When deemed necessary, ROI 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. C. Client Tailored Services and Client Imposed Restrictions ROI Financial offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (investment objectives, income, tax levels, and risk tolerance levels), the Financial Planning Checklist and the Risk Assessment Questionnaire which are used to help construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ROI Financial from properly servicing the client account, or if the restrictions would require ROI Financial to deviate from its standard suite of services, ROI Financial reserves the right to end the relationship. Investment Supervisory Services: Investment Advisory Contract Communications and Reporting Guidelines Adviser will evaluate client’s portfolio on a quarterly basis and contact the client for needed adjustments (non- discretionary model) or make adjustments as needed to the clients account(s)(discretionary model). Adviser will schedule “in person” meetings with client on an annual basis to discuss client’s accounts. Portfolio snapshot reports or numbers will be presented to the client on an annual basis. Client will receive statements from the custodian on a monthly basis. Clients will receive a monthly invoice from the Adviser detailing the Adviser’s fees. See Item 5 Fees and Compensation for a complete description of the invoice. The Adviser will send the invoice to the client concurrent with the request for payment of the Advisory fees to the custodian. (Clients are encouraged to compare this information with the fees listed on the custodian account statement and immediately notify the Adviser with any questions or concerns about the billing.) Client will promptly notify Adviser of any changes to client’s investment profile information (i.e. job and income changes, births or deaths, investment time frame changes, etc.). D. Wrap Fee Program A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transactions costs, fund expenses, and any other administrative fees. ROI Financial DOES NOT participate in any wrap fee programs. E. Amount Under Management ROI Financial has the following assets under management: Discretionary Non-discretionary As of Date $ 156,877,397 $ 4,694,345 12/31/23