Oath Planning is owned by Rod Yancy, who is also the President and Chief Compliance Officer (‘CCO’) and was established in 2018. As of December 31, 2023, Oath Planning managed $123,496,945 on a discretionary basis and $0 on a non-discretionary basis. Investment Management Services Oath Planning manages investment portfolios for individuals, qualified retirement plans, trusts, not-for-profits and small businesses. Oath Planning will work with the client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. Oath Planning uses investment and portfolio allocation software to evaluate alternative portfolio designs. Oath Planning evaluates the client's existing investments with respect to the client's investment policy statement and works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by Oath Planning. Oath Planning will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary, and upon request by the client. Oath Planning will typically create a portfolio of no-load mutual funds and may use model portfolios if the models match the client's investment policy. Oath Planning will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. Oath Planning primarily recommends portfolios consisting of passively managed asset class and index mutual funds, such as Dimensional Fund Advisors (DFA) mutual funds. DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Consequently, the DFA fund fees are generally lower than fees and expenses charged by other types of funds. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. Some such assets may be held but not considered as part of the relationship for billing or in the IPS, due to client preferences. Oath Planning manages mutual fund and equity portfolios on a discretionary or nondiscretionary basis. Clients may impose any reasonable restrictions on Oath Planning’s discretionary authority, including restrictions on the types of securities in which Oath Planning may invest the client’s assets and on specific securities that the client may believe to be appropriate. Oath Planning may also recommend fixed income portfolios to advisory clients, which consist of managed accounts of individual bonds. Oath Planning will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. These sub-advisory services will be provided by Buckingham Strategic Partners, LLC (“BSP”). Oath Planning will prepare a separate Fixed Income Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, Oath Planning may retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client's Fixed Income Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain Oath Planning's consent prior to the sale of any client securities. On an ongoing basis, Oath Planning will answer clients' inquiries regarding their accounts and review with clients the performance of their accounts. Utilizing Drift Reports available daily, Oath Planning will review client's investment policy, risk profile, and discuss the re-balancing of each client's accounts to the extent appropriate. Oath Planning will provide to the investment manager any updated client financial information or account restrictions necessary for the investment manager to provide sub-advisory services. Oath Planning’s Investment Management Services are offered at different service levels based on the total assets under management (“AUM”) a client has with Oath Planning (see Item 5 for AUM tiers). The three service levels are Silver, Gold and Platinum. Clients in all services level will receive the service outlined above. In addition, each service level will receive the following:
• Silver: o Annual Review
• Gold: o Required minimum distribution management. o Semi-Annual Reviews
• Platinum o Required minimum distribution management o Tax minimization o Quarterly Reviews Buckingham Strategic Partners, LLC Sub-Advisory Services Oath Planning has retained Buckingham Strategic Partners, LLC to act as a sub-advisor for certain client accounts. Buckingham Strategic Partners, LLC shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by Oath Planning. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to Buckingham Strategic

Partners, LLC, which may include, but is not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by Buckingham Strategic Partners, LLC. Each Portfolio is designed to meet a particular investment goal which Oath Planning has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and Buckingham Strategic Partners, LLC will have the discretionary authority to manage the Portfolio(s), including rebalancing. However, Advisor, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact Advisor to determine if changes to an account and the allocation of the assets held in the account are necessary. Employee Benefit Retirement Plan Services: Oath Planning also provides advisory services to participant-directed employee retirement benefit plans as a 3(21) fiduciary under ERISA. Oath Planning will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Oath Planning will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Oath Planning will recommend changes in the plan's investment vehicles as may be appropriate from time to time. Oath Planning generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, Oath Planning also works in coordination and support with Buckingham Strategic Partners, LLC. Retirement plan clients will engage both Oath Planning and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will act as the 3(38) fiduciary, while Oath Planning will be the 3(21) fiduciary providing to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. Oath Planning will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: Clients may hold or retain other types of assets as well, and Oath Planning may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. Oath Planning also provides advice in the form of Financial Planning. Clients purchasing this service may receive various written financial reports, providing the client with detailed financial information designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern: - Personal: Family records, budgeting, personal liability, estate information and financial goals. - Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependent’s continuing educational needs through development of an education plan. - Risk: Review of existing insurance policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. - Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. - Death & 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 his or her retirement goals. - Investments: Analysis of current and alternative investment holdings and costs, examining the potential long-term effects on a client’s portfolio, recommending appropriate investment options, allocations, or adjustments. Oath Planning 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 and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, Oath Planning suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion. Clients are encouraged to review their plan on a regular basis, especially if there are any changes in their financial situation, goals, need, or investment objectives. Estate Planning Services Oath Planning offers estate planning through its affiliated law firm, Oath Law. The services include amendments and restatements of legal documents such as wills, trusts, powers of attorney, and advance directives.