Firm Description TRI-AD Capital Management I, LLC, hereinafter (“TCMI” or “Adviser”) was founded in 1993 as a registered investment adviser. The Chief Compliance Officer is Judy Simons. The Adviser is a fee-only investment management firm. The firm does not sell securities on a commission basis. However, there may be some associated persons who are in other fields who have the potential to receive commissions as compensation. The Adviser will offer 401(k) plan-level investment advisory services. This service includes assistance in developing an Investment Policy Statement for the plan, investment selection assistance, ongoing reporting and investment monitoring, participation in periodic investment meetings with the client, documentation of what was discussed in client investment meetings, and assistance in drafting participant communications concerning plan investments, participant investment education, and other plan changes. TCMI provides investment selection and monitoring services to TRI-AD Actuaries, LLC (TRI-AD) for TRI-AD's Health Savings Account (HSA) product. The Adviser does not act as a custodian of client assets and the client always maintains control over assets. The Adviser also offers the TRI-AD SnapIRA®. The TRI-AD SnapIRA® is an IRA product that consists of 6 risk-based model portfolios of mutual funds (currently DFA funds) and a money market fund. The product can be used for Traditional and Roth IRAs, including Rollover IRAs. Statherós Financial Solutions, Inc. manages the DFA model portfolios for SnapIRA®. The Advisor generally does not have discretion of SnapIRA® client accounts, the only exception is the periodic rebalancing of the SnapIRA® model portfolios. All such exceptions of discretionary authority will be appropriately disclosed and acknowledged by the Client within the client agreement. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged directly by the client on an as-needed basis. Any conflicts of interest arising out of the Adviser’s or its associated persons are disclosed in this brochure. Principal Owners: Navia Benefit Solutions owns 100% of TCMI Types of Advisory Services The Adviser provides investment supervisory services, also known as asset management services and manages investment advisory accounts. As of December 31, 2023, the Adviser manages approximately $ 380,399,710 of Non-Discretionary Assets Under Management and $ 28,150,685 of Discretionary Assets Under Management. Assignment of Investment Management Agreements Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client relationships. Retirement Plan Consulting Services TCMI provides service to qualified and non-qualified retirement plans including, but not limited to, 401(k) plans, 403(b) group, pension and profit sharing, defined benefit, ESOPs, deferred compensation, 457(b) and others. TCMI offers plan sponsors the following consulting services: fiduciary compliance, investment due diligence, platform/fee benchmarking, employee education and communication, and plan strategy/design. TCMI provides 3(21) services for all TCMI retirement plan clients and has partnered with LeafHouse Financial Advisor (“LeafHouse”) who will provide 3(38) advisor services to TCMI retirement clients. (1) Limited Scope 3(21)(a) Fiduciary. TCMI acts as a limited scope 3(21)(a) fiduciary that advises, helps and assists plan sponsors with their investment decisions, which often includes selection of investment options and asset allocation recommendations. (2) 3(38) Investment Manager. LeafHouse will serve as an investment manager to certain plans in which it is granted discretionary management by the plan sponsor to select, monitor and replace plan investments. By assuming the 3(38) role, LeafHouse:
• Takes on the full fiduciary responsibilities regarding the Plan’s investments. This relieves your Plan committee members and Trustees of this liability, including professional and personal liability.
• Will create customized investment lineups that align with your Plan’s financial objectives using innovative technology.
• Provides increased investment oversight and quarterly investment reports and actively manages plans to adapt to market changes, offering you peace of mind.
• Will offer managed account investments (at the Participant level), allowing for more personalized investment strategies tailored to individual participants’ investment objectives.
• brings both fiduciary protection and additional investment expertise at no increased cost to you or the Plan. TCMI has a contract with LeafHouse to pay all of LeafHouse’s expenses. Also, our organizations’ combined scale allows access to exclusive investment offerings normally reserved for only the largest corporations, which can reduce overall investment expenses. Additional services applicable to TCMI’s Retirement Plan Consulting Services are described in the client agreement. TCMI is deemed a “Covered Service Provider” to pension plan clients under ERISA Section 408(b)(2) regulations and is a fiduciary under Sections 3(21) and/or 3(38) of ERISA. ERISA Section 408(b)(2) requires Covered Service Providers to make required disclosures to the responsible plan sponsor (“RPS”) that are in writing, and include information the RPS needs to (i) assess the reasonableness of total compensation, both direct and indirect, received by the Covered Service Provider, its affiliates, and/or subcontractors, (ii) identify potential conflicts of interest, and (iii) satisfy reporting and disclosure requirements under Title I of ERISA. TCMI provides its pension plan clients with such information prior to entering into a written agreement with such clients, and upon changes to the information in accordance with ERISA regulations. Health Saving Accounts (HSA) TCMI provides investment selection and monitoring services to TRI-AD Actuaries, LLC (TRI-AD) for TRI-AD's Health Savings Account (HSA) product. This investment selection and monitoring service is at the

"product" level only. This means that if a single investment is replaced, it would be replaced for all clients using the TRI-AD HSA product. TCMI does not contract directly with individual companies (TRI- AD clients) for the TRI-AD HSA product. Additionally, TCMI does not provide any participant level services. TCMI limits HSA investments to mutual funds. SnapIRA® As part of the investment management service for SnapIRA®, the adviser directs Account Holders to complete an on-line application that includes educational tools, suitability questionnaire, custodial agreement, and fee disclosure. Account Holder is provided with online access to their account, as well as contact information for general questions and advisory inquiries. The adviser periodically rebalances the model portfolios. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment. Although TCMI does not give direct rollover recommendations, it does educate clients about their options. In the future, if TCMI does give direct rollover advice, provide investment advice to individuals or account holders regarding their retirement plan account, or individual retirement account, TCMI is a fiduciary 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 TCMI makes money creates some conflicts with individual or account holder interests, so TCMI operates under a special rule that requires it to act in the individual’s or account holder/s best interest and not put TCMI’s interest ahead of individuals or account holders. Under this special rule's provisions, TCMI must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of individuals’ or account holders’ when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the individuals’ or account holders’ best interest;
• Charge no more than is reasonable for our services; and
• Give basic information about conflicts of interest. Termination of Advisory Agreement A Client may terminate any of the agreements directly entered into with the Adviser at any time by notifying the Adviser in writing 30 days in advance. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, the Adviser will refund any unearned portion of the advance payment. The Adviser may terminate any of the agreement directly executed with the Client and the Adviser at any time by notifying the Client in writing 30 days in advance. If the client made an advance payment, the Adviser will refund any unearned portion of the advance payment.Item 5-Fees and Compensation Investment Management The Adviser bases its fees on a percentage of assets under management, and fixed fees (not including subscription fees). Although the Advisory Service Agreement is an ongoing agreement and periodic adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. The investment management fees are negotiable at the sole discretion of the Adviser. The Adviser’s fees are as follows: Fee Schedule for Retirement Plan 401(k) Advisory Clients – 1. Fiduciary RIA Model - a) 3(21)(a) Advisory Clients - The greater of $5,000 or 10 basis points on core plan assets. The minimum fee for new advisory clients increased to $5,000 beginning February 1, 2016. Existing clients subject to the existing $3,500 minimum fee will remain on that schedule until at least three years from the date of the initial agreement between TCMI and the client. There may be some instances where minimum fees and asset-based fees are negotiated with clients. - Not to exceed a maximum fee of $30,000 b) 3(38) Advisory Clients – The great of $7,500 or 15 basis points on core assets. The minimum fee for new advisory clients increased to $7,500 and 15 basis points beginning January 1, 2018. Existing clients subject to the existing $5,000 minimum fee or 10 basis points (the greater of) will remain on that schedule until at least three years from the date of the initial agreement between TCMI and the client. There may be some instances where minimum fees and asset- based fees are negotiated with clients. - Not to exceed a maximum fee of $50,000 c) Core assets are defined as plan assets not invested in brokerage accounts, employer stock, or other investments not included in TCMI’s investment advisory services agreement. d) In the first year of a new client engagement, TCMI, has the right to waive the fee for one or more quarters. 2. Non-Fiduciary RIA Model – flat fee of $1,500. Includes: IPS assistance, periodic investment reporting, and supporting materials as agreed to. Financial advice or recommendations are not provided. From time to time there may be individual projects where the fees are negotiated or based on time and expense. SnapIRA® .6% Annually for accounts under $500,000 .4% Annually for accounts $500,000 or more. There are additional costs associated with the SnapIRA® program including program/technology, custodial fees and mutual fund expenses. Please refer to SnapIRA® Fee Disclosure for more details.