Item 5 - Additional Compensation .......................................................................................................................... 20 Item 6 - Supervision ..................................................................................................................................................... 20 Firm Description Financial Integrity Advisors, LLC (“FIA”) was founded in 2003 and began offering advisory services in 2009. Philip M. Harris is 100% owner. Types of Advisory Services ASSET MANAGEMENT FIA offers discretionary and non-discretionary asset management services to advisory Clients. FIA will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the Client provides FIA discretionary authority the Client will sign a limited trading authorization or equivalent. FIA will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use FIA on a non-discretionary basis, FIA will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, FIA will obtain prior Client approval on each and every transaction before executing any transaction. ERISA PLAN SERVICES FIA provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. FIA may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor FIA has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using FIA can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment options available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. FIA acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• 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 IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• 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, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands FIA’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, FIA is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. FIA 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.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. FIA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between FIA and Client. 3. FIA has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to FIA on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. FIA can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. FIA would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• FIA has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment options available to them under the Plan. Client understands the FIA’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the FIA is not providing fiduciary advice as defined by ERISA to the Plan participants. FIA 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.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. FIA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between FIA and Client. 3. FIA has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. Institutional Asset Management & Pension Consulting Services FIA will provide comprehensive consulting and investment advisory services to institutional clients, including tax-exempt plan sponsors such as corporate, public, and employee benefit and retirement plans endowments, foundations, trusts, estates, charitable organizations and corporations or other business entities such as banks, credit cooperatives, and insurance reserves. The services offered include the following: (a) Creation and Review of Investment Policy and Objectives: Provide the client an initial analytical and financial and actuarial data gathering process to review institutional strategic objectives. Assisting the client in defining appropriate investment objectives, policies, and standards for performance review to achieve those objectives based upon each client’s unique situation. The first phase concludes with a tailor-made asset and liability ratio analysis conducted to determine the client’s funding gap and drafting an asset allocation

model based on the performance requirements of client’s investment portfolio to assist in meeting such a gap. (b) Asset Allocation and Review: Assisting the client in allocating its assets in a strategic manner among different investment vehicles using various investment styles to achieve the clients’ stated investment objectives. The proposed allocation is adjusted by risk tolerance and investment style options. Asset Allocation is optimized in accordance with each client’s specific tax attributes. (c) Investment Manager Firm(s) Selection: Assisting the client in the evaluation and selection of an appropriately suited investment manager firm(s) to provide day- to- day portfolio management of client accounts based on each client’s circumstances and to meet the objectives selected by the client. The manager selection process relies on the diversification objectives approved by the client and on due diligence research conducted by FIA on investment managers selected from a universe of potential managers. Upon approval by the client, investment managers are formally engaged and entrusted with the approved level of institutional asset. (d) Preparation and presentation to the client of quarterly performance measurement and attribution analysis. (e) Ongoing Evaluation and Review of Investment Manager Firm(s): Comparison and evaluation of the investment manager’s firm(s) selected by the client, including a comparison of the manager’s reported performance with the performance of a cross- section of actual accounts as computed by FIA which may also interview the manager and its key personnel and examine its operations. This process is comprised of capital markets research, investment manager due diligence tasks such as performance measurement and attribution analysis, and investment policy compliance is prepared by FIA analysts and presented to the Client. FIA also provides the client with a customized quarterly written performance report including personnel analysis and interpretation. All reports are part of a fee-based, rather than subscription-based service. If the client selects, FIA also refers clients for service facilities of Clearing, Trading and Custody. FINANCIAL PLANNING AND CONSULTING FIA offers the following financial planning and consulting services. Full Financial Plan Financial planning services include a comprehensive evaluation of an investor's current and future financial state and will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. FIA will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Typical topics reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage.
• Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines for selecting, buying and selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax- favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. Consultation Services This service is appropriate for clients who need assistance with individual topics. This is not a detailed financial review and will not provide/result in a comprehensive financial plan. Client may select individual topics above, or other topics as may be deemed appropriate. The individual topics that will be included in this service will be outlined and agreed upon on the financial planning and consulting agreement. If a conflict of interest exists between the interests of FIA and the interests of the Client, the Client is under no obligation to act upon FIA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through FIA. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Ongoing Services Ongoing financial planning incorporates a six-step planning process: 1. Identifying and prioritizing financial and life goals, 2. Gathering and organizing financial data, 3. Analyzing financial information, 4. Proposing written recommendations, 5. Taking action, and 6. Tracking progress. Ongoing services may include:
• Financial position planning, consisting of allocating a Client’s resources to optimize net worth, cash reserve, and cash flow;
• Income tax planning, addressing the general tax considerations for transactions and ownership structures;
• Investment planning, allocating a Client’s investment portfolio in a way that is consistent with their goals, current financial situation, and risk tolerance;
• Retirement planning, applying strategies to help fund retirement, transition to retirement or ensure adequate retirement income;
• Employee benefits planning, developing strategies to take advantage of employer- sponsored benefit plans;
• Business planning, addressing financial planning needs as a business owner, which may include an analysis of business cash flow, business valuation, business tax planning, business benefits planning and business transition;
• Education funding, developing strategies to help fund the education of children, grandchildren or others. This may also include financial aid analysis.
• Accumulation goals, quantifying future goals and developing strategies to achieve them;
• Protection needs, analyzing needs in the event of death, disability, long-term care, and lawsuit, as applicable;
• Estate planning, developing strategies to pass wealth to beneficiaries in an efficient manner Clients that participate in on-going financial planning can expect the following:
• At least one meeting to determine financial goals and values, what the Client’s current financial picture looks like (including assets, debts, income and spending), and what current limitations or hurdles the Client may be facing.
• At least one meeting to deliver financial planning recommendations and action items.
• Quarterly meetings to discuss goals, monitor progress and update any changes.
• Ongoing check-ins via phone or email for accountability, encouragement and to address changes along the way.
• Initial recommendations are completed and delivered within ninety (90) days, contingent upon timely delivery of all required documentation. If a conflict of interest exists between the interests of FIA and the interests of the Client, the Client is under no obligation to act upon FIA’ recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through FIA. Initial recommendations will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Ongoing services will continue from year to year unless cancelled by either party. SEMINARS AND WORKSHOPS FIA holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs FIA does not sponsor any wrap fee programs. Client Assets under Management As of December 31, 2022, FIA has $5,396,899 in discretionary Client assets under management and $12,431,858,755 non-discretionary assets under management.