A. Description of the Advisory Firm 724 Asset Management, LLC (hereinafter “724 Asset Management”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in September 2021, and the principal owner is 724 Holdings, LLC. B. Types of Advisory Services Portfolio Management Services 724 Asset Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 724 Asset Management creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring 724 Asset Management evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. 724 Asset Management 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. 724 Asset Management seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of 724 Asset Management’s economic, investment or other financial interests. To meet its fiduciary obligations, 724 Asset Management attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, 724 Asset Management’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is 724 Asset Management’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. 724 Asset Management has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, 724 Asset Management will always ensure those other advisers are properly licensed or registered as an investment adviser. 724 Asset Management conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. 724 Asset Management then makes investments with a third-party investment adviser by investing with the third-party adviser. 724 Asset Management will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Subadvisor Services 724 Asset Management may also act as a subadviser to advisers unaffiliated with 724 Asset Management. These third-party advisers would outsource portfolio management services to 724 Asset Management. This relationship

will be memorialized in each contact between 724 Asset Management and the third-party adviser. Pension Consulting Services 724 Asset Management offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives • monitoring performance of money managers and investment options and making recommendations for changes • recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments 724 Asset Management generally limits its investment advice to mutual funds, fixed income securities, real estate funds, equities, ETFs, treasury inflation protected/inflation linked bonds and private placements. 724 Asset Management may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions 724 Asset Management will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by 724 Asset Management on behalf of the client. 724 Asset Management may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent 724 Asset Management from properly servicing the client account, or if the restrictions would require 724 Asset Management to deviate from its standard suite of services, 724 Asset Management reserves the right to end the relationship. D. Wrap Fee Programs 724 Asset Management acts as portfolio manager for a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes 724 Asset Management’s non-wrap fee advisory services; clients utilizing 724 Asset Management’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure from the wrap fee program’s sponsor. 724 Asset Management manages the investments in the wrap fee program but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. 724 Asset Management receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management 724 Asset Management has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 176,116,860.00 $0 December 2023