Barron Financial Group, LLP (“BFG” or “Firm”) is owned by James A. Thibault and has been providing advisory services since 2006. As of December 31, 2023, Barron Financial Group, LLP had a total of $ 131,631,890.35 in assets under management. $127,689,092.98 of those assets were managed on a discretionary basis, and $3,942,797.37 were managed on a non-discretionary basis. PORTFOLIO MANAGEMENT SERVICES: BFG provides continuous advice to a client and investment management based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, BFG develops a client’s personal investment policy and creates and manages a portfolio based on that policy. The Portfolio Management Service, BFG will manage advisory accounts on a discretionary basis only. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). PORTFOLIO ADVISORY SERVICES: In some cases, BFG’s Portfolio Management Services are not suitable for a client. In these cases, BFG offers Portfolio Advisory Services to clients and manages their accounts on a non-discretionary basis. Recommendations will be based on a client’s individual circumstances and needs, BFG will help determine investments, or managers, which are appropriate for the client. Factors considered in this determination are account size, risk tolerance and the opinion of the client. Clients should refer to the specific investment prospectuses for a full description of the investments chosen. BFG will meet with the client on a regular basis, or as determined by the client, to review the account(s). Under the Portfolio Advisory Service, BFG will assist the client in selecting new investments, and then monitor the performance accordingly. However, all investment decisions are solely at the discretion of the client. RETIREMENT PLAN ADVISORY SERVICES: BFG offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. BFG acts as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor BFG has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using BFG can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Clients will make the final decision regarding the initial selection, retention, removal, and addition of investment options. BFG acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c)(5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment

alternatives available to them under the Plan. Client understands BFG’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, BFG is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. BFG will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. BFG can provide these services or, alternatively, can arrange for the Plan’s other providers to offer these services, as agreed upon between BFG and Client. 3. BFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in t h e calculation of Fees paid to BFG on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING SERVICES: BFG also provides advice in the form of a Financial Plan. Clients purchasing this service will receive a written report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. Generally, BFG only offers financial planning services to existing Portfolio Management clients, although exceptions to this can be made at BFG’s discretion. In general, the financial plan will address any or all of the following areas of concern:  PERSONAL: Family records, budgeting, personal liability, estate information and financial goals.  TAX & CASH FLOW: Income tax and spending analysis and planning for past, current, and future years. BFG will illustrate the impact of various investments on a client’s current income tax and future tax liability.  DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.  RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.  INVESTMENTS: Analysis of investment alternatives and their effect on a client’s portfolio. BFG gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals, and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client, and a written report is prepared. Should a client choose to implement the recommendations contained in the plan, BFG suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. If a conflict of interest exists between the interests of BFG and the interests of the Client, the Client is under no obligation to act upon BFG’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through BFG. Financial plans will be completed and delivered within ninety (90) days contingent upon timely delivery of all required documentation. BFG tailors all services to meet the individual needs of our clients. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients can impose restrictions on investing in certain securities or types of securities. These restrictions can, in some cases prohibit engagement with BFG.