A. Description of the Advisory Firm CovingtonAlsina, LLC (hereinafter “CovingtonAlsina”) is a Limited Liability Company organized in the State of Maryland. The firm was formed in February 2016, and the principal owner is Ann M. Covington. B. Types of Advisory Services Portfolio Management Services CovingtonAlsina offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CovingtonAlsina creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CovingtonAlsina evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CovingtonAlsina will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CovingtonAlsina seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CovingtonAlsina’s economic, investment or other financial interests. To meet its fiduciary obligations, CovingtonAlsina attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CovingtonAlsina’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CovingtonAlsina’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Other Advisers /Use of Independent Managers CovingtonAlsina may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) available through SEI Private Trust Company (“SEI”), CRD# 105146, for all or apportion of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client may be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which SEI and/or the Independent Manager will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will offer discretionary services and may assist in the selection of investment managers or investment platforms without the clients permission. The Client, prior to entering into an agreement with an Investment Manager or investment platform, will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes

the appropriate disclosures). Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Ongoing Financial Coaching CovingtonAlsina may provide Ongoing Financial Coaching. Ongoing Financial Coaching includes an upfront financial plan and monthly scheduled calls. Educational Seminars/Workshops CovingtonAlsina provides periodic educational seminars and workshops to clients and the general public. Services Limited to Specific Types of Investments CovingtonAlsina generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds, digit assets, and private placements. CovingtonAlsina may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours 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 your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions CovingtonAlsina will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CovingtonAlsina on behalf of the client. CovingtonAlsina may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CovingtonAlsina from properly servicing the client account, or if the restrictions would require CovingtonAlsina to deviate from its standard suite of services, CovingtonAlsina reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. CovingtonAlsina does not participate in wrap fee programs. E. Assets Under Management CovingtonAlsina has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 148,883,390.00 $ 0.00 December 2023