A. Description of the Advisory Firm Quest 10 Wealth Builders, Inc. (hereinafter “Q10WB”) is an SEC-registered investment adviser. This firm has been in business since July of 2010, and the principal owners are Kenneth D. Stephenson (50%) and Sandra V. Stephenson (50%). B. Types of Advisory Services Q10WB offers the following services to advisory clients: Investment Supervisory Services Q10WB offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Following an initial interview, Q10WB 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 (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring Q10WB evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Q10WB will typically 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. Selection of Other Advisors Q10WB may direct clients to various third-party money managers, co-advisers or sub-advisers who are chosen based on how well their services match the needs and goals of the individual client. Q10WB typically requests discretionary authority from clients to select other advisers or sub- advisers to manage client accounts. Before selecting other advisors for clients, Q10WB will always ensure those other advisors are properly registered as investment advisers. Recommendation of Co-Advisers In some situations, Q10WB will recommend that clients enter into agreements by which Q10WB and another registered investment adviser will serve as co-advisers to the client. Usually, a tri-party agreement will be signed describing the services to be provided by Q10WB and the co-adviser. Educational Seminars Q10WB provides educational seminars/workshops at local community colleges and universities. These classes are not sponsored or endorsed by the college. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; costs and risk analysis; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are based on fixed fees or hourly fees and the final fee structure is documented in Exhibit II of the Investment Advisory Contract. At Q10WB’s sole discretion, various financial planning services may be provided at no cost to the client. This is typically dependent on the services provided to the client by Q10WB or one of its affiliated firms. Services Limited to Specific Types of Investments Q10WB limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, ETFs, hedge funds, third-party money managers, REITs, insurance products including annuities, and private placements. Q10WB may use other securities as well to help diversify a portfolio when applicable. Retirement Plan Rollovers When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our client’s interests, so we operate under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our clients. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement plan assets into an account to be managed by Q10WB, such a recommendation creates a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Retirement Plan Consulting Services We offer non-discretionary retirement plan consulting services to employer-sponsored retirement plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Our retirement plan consulting services include, but are not limited to, the following services: Fiduciary Consulting Services
• Investment Policy Statement Preparation. Q10WB assists clients in the development or review of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the plan. Clients have the ultimate responsibility and

authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. Q10WB provides clients with general, non- discretionary investment advice regarding asset classes and investment alternatives available for the plan that are consistent with the plan’s IPS. Q10WB assists clients with the selection of a broad range of investment options consistent with the investment option selection provisions of ERISA Section 404(c) and the regulations thereunder. Clients have the final decision-making authority regarding the selection, retention, removal and addition of any investment options.
• Investment Monitoring and Reports. Q10WB assists clients 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 or remove and replace investment options. The Firm will meet with clients on a periodic basis to discuss the reports and the investment recommendations.
• Qualified Default Investment Alternative Advice. Q10WB provides clients with non- discretionary investment advice to assist in developing qualified default investment alternative(s) (“QDIA”), consistent with ERISA Section 404(c) and the regulations thereunder, for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. Clients retain the ultimate responsibility to comply with the requirements of Section 404(c), to monitor Section 404(c) compliance, and to follow the terms of the plan document. The specific services to be provided will be listed in Q10WB’s agreement with each retirement plan. Q10WB acknowledges that in performing the retirement plan consulting services listed above it is acting as a “fiduciary” as such term is defined under ERISA Section 3(21)(A)(ii) for purposes of providing non-discretionary investment advice only. Q10WB acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Q10WB to be a fiduciary as a matter of law. All recommendations are submitted to the client for ultimate approval or rejection. The retirement plan which elects to implement any recommendations made by Q10WB is solely responsible for implementing all transactions. Non-Fiduciary Services
• Education Services to Plan Committee. Q10WB assists in the education of the participants in the plan about general investment principles and the investment alternatives available under the plan. Such education services may include preparation of education materials and/or conducting investment education seminars and meetings for participants. Education services do not take into account the individual circumstances of each participant and do not refer to the appropriateness of any specific investment alternatives or options for the participants.
• Participant Enrollment. Q10WB assists clients with group enrollment meetings designed to increase plan participation among employees and investment and financial understanding by the employees. These meetings do not include recommendations with respect to any specific investment alternatives or options available to participants.
• Service Provider/Vendor Services. Q10WB assists clients by arranging for the plan’s other third-party service providers to offer these services, as agreed upon between Firm and client. In such cases, Q10WB acts only in accordance with instructions from the client and shall not exercise any independent judgment or discretion. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 (the “Advisers Act”) and is required to meet the fiduciary duties required of an investment adviser, the services listed above as “Non-Fiduciary” are not considered fiduciary services for the purposes of ERISA since Q10WB is not acting as a fiduciary to the plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to clients are listed and detailed in the Retirement Plan Consulting Agreement. C. Client Tailored Services and Client Imposed Restrictions Q10WB offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) 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 not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee is a fee charged to a client that covers both advisory fees and the costs of execution of transactions. Q10WB clients may participate in one or more wrap fee programs sponsored by other advisers. Currently, certain Q10WB clients participate in the wrap fee program offered by AE Wealth Management, LLC (“AE Wealth”). All clients will be provided AE Wealth’s Wrap Fee Brochure at the beginning of the relationship and are encouraged to review that brochure for material information regarding the program. E. Amounts Under Management Q10WB has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 156,956,122 $0 12/31/2023