A. Sterling Wealth Advisors Ⓡ, Inc. (the “Adviser”) is a Florida corporation formed on August 31, 2001 (before which it operated as a sole proprietorship), and which first became registered as an investment adviser in September 1998. Elizabeth A. Barrett, who is Adviser’s President, Chief Executive Officer, and Chief Compliance Officer is Adviser’s sole principal owner. B. Adviser offers combined investment advisory services with financial planning, stand-alone investment advisory services, and stand-alone financial planning and related consulting services to its clients that currently include individuals, high net worth individuals, trusts, and estates. Adviser does not sell insurance or investment products and does not accept commissions as a result of any product recommendations. Adviser does not pay referral or finder's fees, nor does it accept such fees from other firms. Investment Advisory Services Financial Planning and Investment Advisory Services This service provides ongoing, financial planning combined with discretionary investment advisory services on a fee-only basis. During the initial year, clients will receive a financial plan, which generally addresses the services listed below. Clients will have two to four scheduled meetings during the initial year, depending on their individual situation, and generally one to four scheduled meetings during renewal years. In addition to scheduled meetings, additional face-to-face, email and/or phone consultations are generally included at no additional charge. The financial planning services provided depend on each client’s unique situation and may include, but are not necessarily limited to cash flow analysis, investment planning, tax planning, insurance review, inventory of assets, analysis of financial goals, portfolio analysis, development of an asset allocation strategy, retirement planning and estate plan reviews. Under this service offering, clients will also receive the investment advisory services on an ongoing basis as described immediately below. Investment Advisory Services Only Alternatively, the client can choose to engage the Adviser to provide discretionary investment advisory services without financial planning services on a fee-only basis. The Adviser’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Adviser’s management. When providing investment advisory services, Adviser will coordinate with clients to develop investment objectives and then allocate or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Adviser provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may execute or recommend execution of account transactions based upon those reviews or upon other triggering events. Financial Planning and Consulting Services (Stand-Alone) In addition to the combined investment advisory and financial planning services set forth above, the Adviser offers the following financial planning and consulting services on a stand-alone basis (typically these plans are short term engagements for those clients who do not wish to engage in an open retainer and are completed within two to six months): Financial Overview This is an objective overview of a client’s financial situation. A financial overview provides the client with a net worth summary and recommendations on up to three financial planning topics selected, in advance, by the client. The written recommendations will be presented in one meeting that takes approximately one to two hours with Adviser’s Principal, Elizabeth A. Barrett. No follow-up services are provided with the financial overview. This level of service is tailored to client’s specific financial situation. The plan does not include help with implementation of any recommendations (i.e., investments, estate plans, tax preparation, etc.). This engagement is completed upon Adviser’s presentation of the financial plan and its associated recommendations. However, if the client later seeks additional consultations with Adviser in that respect, the client is welcome to initiate contact and Adviser will explore a subsequent engagement with the client for this service. Consulting Project/Retainer If an ongoing, comprehensive financial planning and investment advisory services relationship is not desired or practical, Adviser may choose to offer a project retainer service. The project retainer service is narrower in scope and usually focuses on one or more of the following areas: goal setting, asset/liability analysis, tax planning, cash flow management, investment review, retirement planning, risk management, estate planning, and record keeping. The service may include client consultations as necessary, in addition to oral recommendations resulting from such consultations. This engagement is completed upon Adviser’s delivery of its final findings or recommendations. Miscellaneous Limitations of Non-Investment Consulting/Implementation Services. Unless specifically agreed in writing, neither Adviser nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. Adviser’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon written delivery of a financial plan or confirming document, or upon termination of the applicable agreement for ongoing services. Adviser does not serve as a law firm, accounting firm, or insurance agency, and no portion of Adviser’s services should be construed

as legal, accounting, or insurance implementation services. Accordingly, Adviser does not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, Adviser may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional who is responsible for the quality and competency of the services they provide. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Adviser recommends that a client roll over their retirement plan assets into an account to be managed by Adviser, such a recommendation creates a conflict of interest if Adviser will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Adviser. ERISA / IRC Fiduciary Acknowledgment. When Adviser provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way Adviser makes money creates some conflicts with client interests, Adviser operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Adviser must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that Adviser gives advice that is in the client’s best interest; charge no more than is reasonable for Adviser’s services; and give the client basic information about conflicts of interest. Order Management System. As part of its investment advisory services, Adviser may manage clients’ retirement plan accounts (generally 401(k), 403(b) or profit- sharing plans) on a discretionary basis using an “Order Management System.” Adviser regularly reviews the available investment options in these accounts, monitors them, and rebalances or reallocates investments in the accounts in the same way we do other accounts, though using different tools, as necessary. The Order Management System allows Adviser to access and manage the client’s designated retirement plan account maintained on platforms where Adviser would otherwise need to collect the client’s personal login credentials to manage the account and therefore potentially trigger additional custody obligations. However, when clients engage Adviser in this capacity, they are responsible to keep the Order Management System link / Adviser’s login credentials active, so that Adviser will be able to access and manage the respective account without delay. If Adviser determines that an Order Management System link has become inactive, Adviser will use its best efforts to notify the client to resolve the issue. However, clients will remain subject to Adviser’s fees described in Item 5 even when Adviser is not capable of executing trades because of the inactive link. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, Adviser will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when Adviser determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, Adviser is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Adviser if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Adviser’s services or previous recommendations. C. The Adviser tailors investment advisory services specifically to the needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with each client to develop their investment objectives. The Adviser then executes its customized investment strategy by allocating investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on the Adviser’s services. D. The Adviser does not participate in a wrap fee program. E. As of December 31, 2023, the Adviser had $164,376,313 in assets under management on a discretionary basis.