A. OFG Financial Services, Inc., a Registered Investment Adviser (hereinafter “OFG”), became licensed as a Registered Investment Adviser in November 2002. OFG is a SEC-registered Investment Adviser in Kansas, Oklahoma, Texas, Arizona and Missouri and has no subsidiaries. J. Kenneth Ogdon is the sole owner of OFG, and Todd Payne is the Chief Compliance Officer. B. OFG offers the following advisory services, where appropriate, to advisory clients. PORTFOLIO MANAGEMENT: OFG provides continuous and regular supervisory and management services to clients, provided through the following investment platforms:
• Orion, formerly FTJ FundChoice
• Pentegra Retirement Services
• RBC Capital Markets, LLC – Management Platform
• Charles Schwab Advisor Services
• Security Benefit – Workplace Retirement Management Platform
• Assetmark, Inc.
• SEI
• Empower Retirement Advisory Services
• American Funds F-2 Direct
• ADP
• Voya Investment Management Services are defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. OFG and the client develop a client’s personal investment policy through discussions on investment goals and objectives. The development of a client’s investment policy can also be aided by using a strategist option through one of the above platforms. OFG and the client then create and manage a portfolio based on the client’s policy. Most portfolios under OFG management contain mainly no-load mutual funds, but a portfolio could also include one or more of the following: exchange-listed securities, securities traded over-the-counter, foreign issuers, corporate debt securities, commercial paper, certificates of deposit, municipal securities, variable annuities, no-load mutual funds, load-waived mutual funds, front-load mutual funds, and United States government securities, among others. FINANCIAL PLANNING AND CONSULTING: OFG is able to provide advice in the form of a financial plan. Clients purchasing this service will receive a written financial plan. OFG provides the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the financial plan may address any or all of the following areas of concern: PERSONAL: Family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. OFG will illustrate the impact of various investments on a client’s current income

tax and future tax liability. DEATH AND DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. RETIREMENT: Analysis of current strategies and investment plans to help the client achieve their retirement goals. INVESTMENTS: Analysis of investment alternatives and their effect on a client’s portfolio. OFG gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client, and a written report is prepared. Should a client choose to implement the recommendations contained in the plan, OFG suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area of concern such as estate planning, retirement planning or other specific topics. OFG also provides specific consultation regarding general investment and financial concerns of the client. Financial plan recommendations are not limited to any specific product or service. TIMING AND MANAGEMENT SERVICES: Clients can receive timing and management services from third-party investment advisers with which OFG is contracted. These third-party investment advisers are: Brinker, formerly Clarke Lanzen Skalla (“CLS”) Investment Firm, LLC C. OFG and clients allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. The investments will be selected based on any or all of the following criteria: the investment performance history, the industry sector, the record of management, the client’s investment objectives and time horizon, and the fee structure, among other criteria. Portfolio weighting between investments and market sectors will be determined by each client’s individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client’s behalf. Clients will retain individual ownership of all securities. D. OFG does not participate in wrap fee programs. E. OFG manages advisory accounts on a non-discretionary basis only. The amount of OFG’s non- discretionary Assets Under Management (“AUM”) was $100,000,000 as of December 31, 2022.