Neuenschwander Asset Management, LLC (“NAM”) provides wealth management services to its clients, including but not limited to, investment management, personal financial planning, and retirement plan services. NAM is owned by Timothy James Neuenschwander and James Vincent Murphy and has been providing advisory services since in 2003. As of December 31, 2023, NAM managed $130,349,864 of clients' assets on a discretionary basis. PORTFOLIO MANAGEMENT NAM manages investment portfolios for individuals, qualified retirement plans, trusts, not-for-profit organizations, and small businesses. NAM will work with a client to determine the client's investment objectives and investor risk profile and will design a written Investment Policy Statement (IPS) that aligns with the clients’ stated goals and objectives. NAM evaluates the client's existing investments with respect to the client's IPS. NAM uses investment and portfolio allocation software to evaluate alternative portfolio designs. NAM works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by NAM. NAM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. NAM will typically create a portfolio of passively managed asset classes, comprised of no-load index based mutual funds and/or exchange traded funds (ETFs). Model portfolios may be used if the models match the client's investment policy. NAM will allocate the client's assets among these various asset classes and investments taking into consideration the overall risk and return profile of the client. Client portfolios may also include some individual equity securities, mutual funds, ETFs and bonds in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. NAM will note such situations within the client’s IPS when an IPS is maintained for the client. NAM manages mutual fund and equity portfolios on a discretionary basis. A client may impose any reasonable restrictions on NAM’s discretionary authority, including restrictions on the types of securities in which NAM may invest client’s assets and on specific securities, which the client may believe to be appropriate. NAM may also recommend to advisory clients fixed income portfolios, which consist of managed accounts of laddered individual bond portfolios. NAM will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to engage an independent third-party fixed income manager. NAM has contracted with Buckingham Strategic Partners, LLC (“BSP”) for sub-advisory services with respect to clients’ fixed income accounts. A client agreement, including this discretionary authority granted to NAM by the client to hire a fixed income sub-advisor, may be canceled at any time for any reason upon receipt of 30- days’ written notice.

Pursuant to its discretionary authority, NAM will engage the third-party fixed income manager. The fixed income manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s IPS. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). On an ongoing basis, NAM will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. NAM will periodically request, at least annually, to meet with each client to review the clients’ investment policy, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. NAM will provide any updated client financial information or account restrictions to third-party investment managers necessary for the investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, NAM may consult with clients on various financial planning areas including income and estate tax planning, college financial planning, retirement planning, insurance and risk management analysis, personal cash flow analysis, investment analysis, establishment and design of retirement plans and trust designs, among other things. NAM does not participate in or sponsor any wrap fee programs. RETIREMENT PLAN SERVICES NAM also provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. NAM will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. NAM will recommend investment options to help achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. NAM will recommend changes in the plan's investment vehicles as may be appropriate from time to time. NAM generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, NAM also works in coordination and support with BSP. Retirement plan clients will engage both NAM and BSP. BSP will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. NAM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.