Overview of Spectrum Financial Resources Spectrum Financial Resource LLC (“SFR” or “firm”) offers personalized investment advisory services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. The firm's services and fee arrangements are described in the following pages. SFR has been in the investment advisory business since 1987. SFR is owned by Daniel T. Hoban and Jean Ann Schneider, who are both principals and Managing Members of SFR. SFR provide its investment advisory services through Investment Adviser Representatives (IARs). SFR’s IARs are individuals associated with SFR who are appropriately licensed, qualified and authorized to provide advisory services on SFR's behalf. SFR’s IARs are also registered representatives of United Planners' Financial Services of America (United Planners), a full service securities broker/dealer registered under federal and state securities laws, whose main office is located in Scottsdale, Arizona. United Planners is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation (“SIPC”). Securities transactions for United Planners brokerage clients are executed through Pershing, LLC, (based in Jersey City, New Jersey), an unaffiliated securities broker/dealer or, in some cases, directly with the product sponsor. SFR, through its IAR’s provides the following services to the firm's advisory clients: Financial Planning Services Financial planning advice will typically involve providing a variety of services, principally advisory in nature, to the client regarding the management of their financial resources based upon an analysis of their individual needs. An IAR of the firm will first conduct a complimentary initial consultation lasting approximately one hour. After the initial consultation, if the client decides to engage SFR for financial planning services, the IAR will conduct a follow-up meeting during which pertinent information about the client's financial circumstances and objectives is collected. After this information is reviewed and analyzed, a written financial plan designed to achieve the clients' stated financial goals and objectives will be produced and presented to the client. The primary objective of this process is to allow SFR to assist the client in developing a strategy for the successful management of income, assets and liabilities in meeting the client's financial goals and objectives. Financial plans are based on the client's financial situation at the time the plan is presented and is based on financial information disclosed by the client to SFR. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Clients should keep in mind that past performance is in no way an indication of future performance and that SFR cannot offer any guarantees or promises that the client's financial goals and objectives will be met. As the client's financial situation, goals, objectives, or needs change, the client must notify SFR promptly. Advisory Consulting Services SFR offers consulting services, where an IAR of SFR provides a professional opinion on specific financial related areas. These areas may include, but are not limited to, retirement planning, risk assessment/ management, education funding, investment planning, and/or financial decision-making. The client acknowledges, in advance, that they only desire consultation in regard to the specific financial area agreed upon to be reviewed and/or analyzed. Under this arrangement, a written financial plan will not be provided to the client. General Information Regarding the Use of Independent Investment Advisors SFR has two alternatives by which client accounts may be managed by one or more independent third- party investment advisors. The first alternative, which is referred to below as the Third-party Investment Advisors Program, is whereby SFR acts as a solicitor for the third-party investment advisor. The second, which is provided for under the Portfolio Management Services section below, is through the Unified Managed Account Program provided by TD Ameritrade (TDA) Inc., member FINRA/SIPC/NFA and Placemark Investments, Inc., a registered investment advisor, whereby the client establishes a brokerage account with TD Ameritrade and, with SFR’s assistance, selects one or more independent investment managers/strategists or model portfolios for the management of the client’s account. In this case, SFR acts as an investment advisor and not as a solicitor and there is no solicitor fee. Third-Party Investment Advisors Program SFR also acts as a solicitor and refers clients to unaffiliated

third-party investment advisors (TPIAs) that offer asset management services to clients. When clients undertake a TPIA for the management of their accounts, SFR is paid a portion of the fee charged and collected by the third-party investment advisor in the form of solicitor or consulting fees. Each of SFR’s solicitation arrangements with TPIAs is performed pursuant to a written solicitation agreement between SFR and the TPIA and will be in compliance with all applicable regulations governing solicitor relationships. After gathering information about a client’s financial situation and investment objectives, SFR may recommend specific services or programs of one or more TPIAs to clients that are suitable and appropriate for the client based on the clients’ individual needs and circumstances, including investment objectives and risk tolerance levels, as they have made them known to SFR. Factors that SFR takes into consideration when making such recommendations include, but are not limited to, the TPIA’s performance, methods of analysis and fees. SFR regularly reviews the TPIA and its performance for continued consistency with the client’s investment objectives and risk tolerances. At the time of the referral, clients who are referred to TPIAs will receive the relevant TPIA’s Form ADV Part 2 and other relevant disclosure documents. These documents are designed to provide complete disclosure of the TPIA, including services rendered, fee schedules and the compensation to be paid to SFR as a result of the referral. Portfolio Management Services SFR provides discretionary and non-discretionary portfolio management services, as selected by the client. The investment advice provided is custom tailored to meet the needs and investment objectives of the client. While Portfolios constructed by SFR generally consist of shares of mutual funds and exchange traded funds, SFR additionally utilizes equity securities, corporate debt securities, municipal securities, and/or U.S. government securities, among others, if SFR determines such investments to be in the best interest of its clients. Alternatively, through the TD Ameritrade Unified Managed Account Program, SFR may recommend and assist the Client in selecting one or more independent investment managers/strategists/model portfolios for the management of the Client’s account. After the establishment of the Client’s account, SFR and/or the independent investment manager provides either continuous or periodic supervision or re-optimization of the portfolio as changes in market conditions and client circumstances may require. As of February 29, 2024, SFR had $93.198 million is discretionary assets under management and $104.195 million in non-discretionary assets under management. SFR also provides portfolio management and/or investment advisory services to clients relating to: (1) variable life/annuity products that they may own, and/or (2) their individual employer–sponsored retirement plans. When providing these services, SFR either directs or recommends the allocation of client assets among the various mutual funds or sub-accounts that are available in the variable life/annuity product or the retirement plan. The client assets are held at either the insurance company that issued the client’s variable life/annuity product, or at the custodian designated by the sponsor of the client’s retirement plan. Investments and service providers relative to Plan offerings are limited to only those available through the respective Plans and are determined by the Plan Sponsor(s). With respect to a Client’s Individual Employer Sponsored Retirement Plan, if the account is subject to the provisions of the Employee Retirement Income Security Act of 1974 (ERISA), Adviser acknowledges its fiduciary status under ERISA. Additional Important Information Fiduciary Status When we provide investment advice to you regarding your 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. Conflict of Interest The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. For example, if you roll over an IRA or 401k account to our firm or otherwise transfer any other account to our firm, we will charge your account and make money. If you decide to not roll over the IRA or other account to our program, we will not make money. While we therefore have a financial incentive to recommend that you to move your account to our program, SFR has established policies and procedures that are designed to address this conflict between our interests and yours and ensure that all recommendations made to you are in your best interest.