A. Firm Description Virtus Financial Partners, LLC (“VFP” or the “Firm”) is an SEC registered investment advisor. VFP was founded in August of 2015. The Principal Owner and Chief Compliance Officer of VFP is Stanley P. Stewart. B. Types of Advisory Services The Firm offers a large variety of services, including portfolio management, investment analysis and financial planning for individuals, high net worth individuals, and small businesses. The Firm offers these services to clients or potential clients (“clients”). Investment Advisory Services VFP specializes in quantitative, fundamental, technical, and economic analysis to determine what investments are in favor of VFP’s investment models. VFP assesses clients’ current holdings and ensures alignment with both short- and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. Any and all trades are made in the best interest of the client as part of VFP’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, VFP does not guarantee any results or returns. Prior to engaging VFP to provide any investment advisory services, VFP requires a written financial service agreement (“FSA”) signed by the client prior to the engagement of any services. The FSA will outline services to which the client is entitled and fees the client will incur. In instances in which VFP utilizes model portfolios, VFP will select model portfolios of securities for client accounts made available by professional asset managers. The professional asset managers shall supervise and invest the assets in each client account in accordance with the investment strategy set forth by the client and VFP. VFP will have the discretion to hire and fire professional asset managers at their discretion. Professional asset manager fees are paid from the fees charged by VFP. VFP is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. VFP does not act as a custodian of client assets. The client always maintains asset control. VFP places trades for clients under a limited power of attorney through qualified custodian/broker. Pontera Our firm will also provide service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System (Pontera) to implement asset allocation and opportunistic rebalancing strategies on behalf of the client. Pontera is a clerical service that facilitates orders from VFP to client accounts not held in our custody, for example, employer sponsored retirement plans like 401(k)s. This service does not facilitate account billing and fees are paid through a separate billing process. The accounts that will utilize these services will be primarily 401(k) accounts, HSAs, and other assets that VFP does not have custody of. Our firm will regularly review, rebalance, and implement our strategies using different tools as necessary. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Clients who choose to participate in this program will be notified when our firm places a trade through Pontera implementing any and all changes to your account. The fees charged in these situations are the same as described in the table under “Fees and Compensation.” The Advisor and not the Client pays any fees charged by Pontera. Investment Discretion Where you engage us for portfolio management services, you will be required to grant VFP the discretionary authority to implement its investment recommendations directly within your investment accounts held at the custodian without obtaining your specific consent prior to each transaction. This authority will include the ability to engage and terminate third-party managers (“TPMs”) to manage all or a portion of your account, and to determine the allocation of assets between and among such TPMs within the pre-determined asset allocation ranges for your account(s). Qualified Retirement Plan Consulting Services Virtus offers the following services to qualified retirement plans: The Firm will perform the following Fiduciary Services: (i) Provide non-discretionary or discretionary 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. Client shall have the final decision-making authority regarding the initial selection, retention, removal and addition of investment options. (ii) Assist the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. (iii) 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 investment policy statement. (iv) 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 or remove and replace investment options. (v) Meet with Client on a periodic basis to discuss the reports and the investment recommendations. (vi) Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). In cases where Virtus provides discretionary ERISA Section 3(38) fiduciary investment services, Virtus is responsible for the implementation of recommendations for the Qualified Plans. Where Virtus provides non-discretionary ERISA Section 3(21) fiduciary investment recommendations, the trustee and the investment committee are responsible for implementation of recommendations and Virtus will not act on the plan participants’ behalf to implement these recommendations. The Firm will perform the following Non-Fiduciary services: (i) Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that Virtus’ assistance in participant investment education shall be consistent with and within the scope of section (d) (i.e., the definition of investment education) of Department of Labor Interpretive Bulletin 96-1. As such, the Firm is not providing fiduciary advice (as defined in ERISA) to the participants. Virtus 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. (ii) Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Virtus may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Virtus and Client. The Firm's roles and actions in fulfilling all responsibilities pertaining to the qualified plan consulting services shall not include those of the Plan's Trustee and will be performed solely at the direction of the Plan Sponsor, its authorized officers, employees and/or agents. At no time will the Firm accept, maintain possession of, or have custodial responsibility for the Plan's assets. The Firm will not conduct or effect the purchase or sale of any assets of the Plan on behalf of the Plan Sponsor or Plan Participants. The Firm will not advise, in any manner, any Participant, person or entity related to the Plan other than the Plan Sponsor, except where the Participant is an advisory client of Virtus under a separate advisory agreement. Communicational and educational activities in which the Firm engages related to Participants in the Plan shall be solely at the direction of the Plan Sponsor and shall not be represented by the Firm or Plan Sponsor as investment, tax or legal advice. Virtus is not licensed to provide, shall not provide, nor be construed to provide, the services of an attorney or accountant. Financial Planning Financial plans and financial planning may include but are not limited to advice with respect to some or all the following financial topics: retirement income, risk management, tax reduction strategies, and investment strategies. Our financial planning advice will be delivered to you in the form or a written financial plan, a shorter report or checklist, or via informal discussions with you (in-person, via telephone or tele-video conference, or via e-mail), as we may agree in a written financial planning agreement. VFP provides financial planning for recent college graduates. This service includes planning meetings and discussions around cash flow, student loans and goal setting. Some clients only wish to engage us in financial planning. In this scenario, the client retains the sole discretion to accept or reject any of our financial planning advice, in whole or in part, and is responsible for implementation and monitoring of all investments held away from the accounts designated for our investment advisory services. C. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. D. Wrap Fee Program versus Portfolio Management Program VFP does not offer a Wrap Fee Program. E. Assets Under Management As of March 23, 2023, Virtus had $39,051,000 in discretionary and $17,655,000 in non-discretionary client assets under management.