A. Description of the Advisory Firm Yanni & Associates Investment Advisors, LLC is a Limited Liability Company organized in the state of Pennsylvania. This Firm has been in business since January of 2007, and the principal owner is Matthew Adam Yanni. B. Types of Advisory Services Yanni & Associates Investment Advisors, LLC (hereinafter “YANNI”) offers the following services to advisory clients: Investment Supervisory Services YANNI offers ongoing discretionary and non-discretionary portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. In an initial meeting, a complimentary interview is provided by Matthew A. Yanni to determine the scope of services to be provided. Prior to entering into a written contract (Investment Advisory Agreement), YANNI’s ADV Part II, ADV Part III and Privacy Policy will be given to the client. Should the client wish to engage YANNI for its services, both parties must sign YANNI’s Investment Advisory Agreement. Afterwards, it will be Matthew A. Yanni’s responsibility to meet with each client to create a written Investment Policy Statement (“IPS”), which outlines the client’s current situation (return expectations, risk tolerance levels, income needs, tax levels, time horizon, and other unique needs). Matthew A. Yanni then constructs a plan (written into the IPS) to aid in the construction of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment Strategy • Personal Investment Policy
• Asset Allocation • Asset Selection
• Risk Tolerance • Security Selection All clients are strongly encouraged to indicate in writing their agreement with the financial goals and YANNI’s strategy to meet them as outlined in the IPS. YANNI also provides a one-time, portfolio analysis for a fixed fee. This allows YANNI to review asset allocation of existing assets, make general comments on existing assets, recommendations on “other financial assets”, and “next steps” should a professional partnership develop. YANNI requires its clients to notify it of any material change to the client’s overall investment objectives. YANNI, in turn, will notify the client if there is any material change in how it believes a client’s portfolio should be managed. YANNI will assume the responsibility of managing the client’s assets according to the IPS. Typically, the IPS is signed within the first 90 days of the relationship as dollar-cost averaging, market circumstances, ongoing discussion with regards to client’s goals & objectives, and other reasons may cause some time to lapse before the IPS is written and signed off by the client & YANNI. As part of the Investment Advisory Agreement, YANNI does request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, client’s still have the ability to direct or restrict trading of specified securities. Trades can be directed (new trades, retention or exclusion of assets) through written communication from a client to YANNI (email or letter). All client accounts are reviewed on an ongoing basis to ensure the account's structure and underlying securities are consistent with YANNI's policies and the individual client's needs. Each relationship will be reviewed quarterly through the examination of our quarterly reports. The overall strategic investment decisions are determined by YANNI’s Investment Committee which is currently comprised of Matthew A. Yanni and Komal G. Motwani (while Komal G. Motwani may conduct transactions in client accounts). Additional professionals may be retained or utilized to advise or become a member of this Committee from time-to-time. Tactical implementation of the Committee’s strategy will be applied to each client’s individual portfolio, if it meets the client’s individual circumstances. YANNI’s focus is directed toward portfolios ranging from $250,000 to $25 million. YANNI typically invests clients’ assets in various no-load mutual funds, exchange-traded funds or index type vehicles through its discretionary

authority. Individual stocks and/or bonds as well as certificate of deposits (CDs) may be used depending on each client’s unique circumstances. Each client’s account will be managed in accordance with its unique situation. YANNI may have access to some IPOs (not all of them) through Schwab Institutional. Investing in IPOs is not a part of YANNI’s investment process and clients who choose to invest in IPOs must provide a written letter of direction (email or signed letter). Further, while YANNI may have access to some IPOs, clients must either ask to be notified of upcoming eligible IPO(s) or inquire regarding specific ones. Unless specifically asked to do so, YANNI will not be broadcasting to clients which IPOs the Firm will have access. It is also not guaranteed clients will be able to invest as much as they desire in these IPOs. If multiple clients desire to invest in the same IPO, proportional allocation will be allotted. Essentially, YANNI is just registering with Schwab to have access to its allocated IPOs, should our clients desire to direct these types of trades. Newsletter Subscription YANNI provides their clients with a free newsletter, YAIA Quarterly or Periodic Newsletter. Services Limited to Specific Types of Investments YANNI typically utilizes a proprietary combination of “core” and “niche” strategies. A large majority of YANNI’s recommended investments (core positions) will include exchange-listed securities, securities traded over-the-counter, corporate debt securities, commercial paper, certificates of deposit, municipal securities, mutual fund shares, and United States government securities. Other considerably smaller (niche positions) investments may include currencies, commodities, real estate investment trusts (REITs), or derivatives (including options and futures contracts) all usually invested in the form of an exchange-traded fund or mutual fund. The niche positions will generally be under 10% of the consolidated portfolio value at the time of purchase and are invested in based on current or anticipated economic developments. YANNI’s investment advice is limited to these types of investments. Matthew A. Yanni is licensed to sell life insurance, long-term care insurance, short-term disability insurance and annuities. These are commission-based products that Matthew A. Yanni will receive as an Individual, not through his corporate entity. Part 2b, Item 4 has additional detail. Clients need to be aware that YANNI does not provide legal or accounting services. With the client’s consent, YANNI may work with the client’s other advisors (lawyers, accountants, etc.) to coordinate efforts for the client’s financial situation. Client’s still need to be aware that YANNI may only focus on certain areas of client’s financial situation and may not fully address client’s entire financial situation to limitations. All material conflicts are disclosed in YANNI’s government documents. C. Client Tailored Services and Client Imposed Restrictions YANNI offers the same suite of services to all of its clients. However, their implementation is dependent upon the client IPS which outlines each client’s current situation and is used to construct a client specific plan to aid in the selection of a portfolio that matches 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 YANNI from properly servicing the client account, or if the restrictions would require YANNI to deviate from its standard suite of services, YANNI reserves the right to end the relationship. It shall be noted that client restrictions on portfolios may also impact performance. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. YANNI DOES NOT participate in any wrap fee programs. E. Amounts Under Management YANNI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 141,000,000 $0.00 December 2023