A. Description of Firm Frugal Financial is a privately owned limited liability company founded in, and becoming registered an Investment Adviser 2014, by the principal shareholders of Employee Fiduciary, LLC (“Employee Fiduciary”). Founded in 2004 and currently serving over 4,000 corporate clients, Employee Fiduciary has pioneered a low-cost, full-service approach to retirement plan services to smaller businesses nationwide. Frugal Financial’s mission is to complement and extend those core principles and services of Employee Fiduciary, providing investment advice and fiduciary guidance to qualified retirement plans. Frugal Financial is wholly owned by Employee Fiduciary, LLC. Eric Droblyen is the principal owner of Employee Fiduciary, LLC. Additionally, Mr. Droblyen serves as Frugal Financial’s Managing Director, Chief Executive Officer and Chief Compliance Officer. B. Types of Advisory Services Frugal Financial provides fiduciary investment management services to retirement plans on a discretionary basis, with one legacy non-discretionary client. The Firm’s investment advisory services include the provision of a fund lineup composed of index mutual funds to the plan. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets standards of conduct for those who manage an employee benefit plan and its assets (“fiduciaries”). Fiduciaries have important responsibilities and are subject to standards of conduct because they act on behalf of participants in a retirement plan and their beneficiaries. These responsibilities include:
• Acting solely in the interest of plan participants and their beneficiaries and with the exclusive purpose of providing benefits to them;
• Carrying out their duties prudently;
• Following the plan documents (unless inconsistent with ERISA); Diversifying plan investments; and Paying only reasonable plan expenses. The corporate sponsor of a plan is generally the primary fiduciary and is ultimately responsible for making sure all the fiduciary jobs get done and for determining what fiduciary jobs will be assigned to other parties. Many plan sponsors feel overwhelmed in trying to manage their fiduciary obligations under ERISA. Frugal Financial services are designed to help our clients easily understand, manage, and satisfy their fiduciary obligations under ERISA. Discretionary Investment Management For qualified retirement plans, Frugal Financial serves as a discretionary investment manager, as defined in ERISA §3(38) (“3(38) Investment Manager”). In this capacity, the sponsoring employer is relieved

of the fiduciary responsibility for investment selection and monitoring. As a 3(38) Investment Manager, Frugal Financial will prepare and maintain an investment policy statement (“IPS”), and will select, monitor, and benchmark plan investments consistent with that IPS. Frugal Financial will also select the qualified default investment and set procedures for assigning investments to specific participants who do not prospectively select investments within the qualified retirement plan. In all cases, individual participants will have the ability to change investments at any time, subject to plan requirements. 1. Other Services In addition to investment advice, Frugal Financial provides the following services:
• Preparing and maintaining an IPS for the plan;
• Reviewing, evaluating, and providing recommendations regarding investment options using criteria specified in the IPS;
• Reviewing, evaluating, and providing recommendations regarding asset allocation tools and Qualified Default Investment Alternative (“QDIA”) options;
• Providing fiduciary operational checklists, and/or ERISA compliance calendars, to help guide clients in satisfying their fiduciary responsibilities in a timely manner;
• Conducting an annual investment and administration review that evaluates investment performance, plan expenses, and ERISA compliance (including 404(c)); Providing QDIA notices for distribution to participants;
• Providing participant enrollment support. The services described above illustrate the types of services provided by the Firm. A complete description of services provided is included in the Firm’s Services Agreement. C. Advisory Agreements Clients will enter into a Services Agreement (the “Agreement”) with the Firm describing the retirement plan advisory services to be provided, the responsibilities of the Firm and other terms of engagement including fees and termination. The advisory client has a right to terminate the contract without penalty within five business days after entering into the contract with such client or prospective client. More information regarding the Firm’s fees can be found in Item 5 below. D. Participation in Wrap Programs The Firm does not participate in any wrap programs at this time. E. Assets under Management As of December 31, 2023, the following represents the amount of client assets under management by Frugal on a discretionary and non-discretionary basis: Type of Account Assets Under Management ("AUM") Discretionary $129,448,223 Non-Discretionary $6,862,009 Total: $136,310,232