Capital Insights Group of WNY, LLC. is an independently operated, privately-owned, financial planning and wealth management firm, founded by Christopher R. Cinelli, CFP® in 2016, and registered with the SEC. Mr. Cinelli is the sole owner and shareholder of the corporation and has been in the financial planning profession since 2004. Capital Insights Group of WNY, LLC. is a fiduciary – offering financial planning and investment management services to individuals, families, small businesses, trusts, estates, and charitable organizations based upon their best interest. If a client is: (1) a participant or beneficiary of a Retirement Plan subject to Title I of the Employee Retirement Income Security Act (“ERISA”) or described in section 4975(e)(1)(A) of the Internal Revenue Code (the “Code”), with authority to direct the investment of assets in his or her Plan account or to take a distribution; (2) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or, ( 3) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Code, then Capital Insights Group of WNY, LLC. represents that it and its investment adviser representatives are fiduciaries under ERISA or the Code, or both, with respect to any investment advice provided by Capital Insights Group of WNY, LLC. or its investment adviser representatives or with respect to any investment recommendations regarding a Retirement Plan subject to ERISA or participant or beneficiary account. Financial Planning Services We provide a variety of financial planning services, custom tailored to meet the unique needs of each client. Our analysis and recommendations may encompass financial planning topics such as: savings and investment programs; income and cash flow planning; debt and liability issues; income tax and estate planning; and assessment of insurance coverages including life insurance, disability insurance, long-term care insurance, and fixed-, variable-, or immediate- annuities. Clients are required to enter into a Financial Planning Agreement prior to initiating financial planning services with Capital Insights Group of WNY, LLC. The Financial Planning Agreement will set forth the terms and conditions of the engagement (including termination), describe the scope of the services to be provided, and detail the fee to be paid by the client. Please note: Capital Insights Group of WNY, LLC. is not responsible for verifying any information received from the client, or from other professionals working on behalf of the client, except as specifically outlined in the Financial Planning Agreement. It remains the client’s responsibility to promptly notify us if there is any change in their financial situation, life circumstances, or investment objectives, which may create a need to review, evaluate, or otherwise revise any recommendations made by Capital Insights Group of WNY, LLC. Clients seeking advice which is limited to only one or several of the financial planning topics listed above, may hire us on an a la carte basis, with prices dependent on the anticipated complexity of the work involved. Capital Insights Group of WNY, LLC. may provide these limited-scope financial planning services through an hourly-fee arrangement, or in exchange for a fixed fee (tied to the project). The completed analysis will include specific recommendations for the client to consider. The client retains sole-discretion and responsibility over the implementation process and is free to accept or reject any financial planning recommendations proposed by Capital Insights Group of WNY, LLC. Clients seeking more comprehensive financial planning may hire us for an engagement that encompasses a broad spectrum of their financial picture including – savings, investments, insurances, taxes, and estate documents. The client will be guided through an organizational process which identifies key pieces of information, and any relevant documents, then catalogues the data within a secure, searchable, archival system. The client’s pertinent information is analyzed using financial planning software to help identify strengths, weaknesses, opportunities, and threats within their current financial circumstances. The analysis will include specific recommendations for the client to consider; however, the decision to implement, or not implement, any of these recommendations is completely up to the client. Implementation of the action items selected is the sole responsibility of the client, except where specifically outlined in the Financial Planning Agreement. The comprehensive personal financial planning program is available for a fixed fee, and is typically equal to 1% of the client’s adjusted gross income (AGI), but may be negotiated or adjusted at our discretion, and is dependent on circumstances. During the course of providing financial planning services, Capital Insights Group of WNY, LLC. may recommend that our clients work with outside professionals, such as attorneys or accountants, if we feel it would be advisable for them to do so. We do not receive referral fees or any other compensation in connection with making these referrals, and our clients are welcome to use any accountant or attorney of their choosing. Please note: If the client engages any such outside professional, and a dispute arises relative to the services delivered by that professional, the client agrees to seek recourse exclusively from and against the engaged professional, not from Capital Insights Group of WNY, LLC. for making the referral. During the course of providing financial planning services, Capital Insights Group of WNY, LLC. may recommend that our clients consider utilizing certain financial products, if we feel it would be advisable for them to do so. These products may include, but are not limited to, life insurance, disability insurance, long-term care insurance,

liability insurance, and fixed-, variable-, or immediate-annuities. Please note: The purchase of insurance products, such as those listed above, may generate a commission paid to an insurance agent who is connected to such a transaction. Capital Insights Group of WNY, LLC. is a fee-only financial planning firm; therefore, we do not engage in any commission-based sales practices; however, we can assist clients in working with a licensed insurance agent who can directly facilitate those planning objectives. We do not receive referral fees or any other compensation in connection with making referrals to outside insurance professionals, and our clients are always welcome to choose any insurance agent or advisor to assist them with the implementation of any financial planning recommendations. Our financial planning clients, if circumstances allow, may be eligible to engage Capital Insights Group of WNY, LLC. for the implementation of the investment management services recommended in their financial plan. Our investment management services are available as a separate and distinct offering from our financial planning services. The process of hiring Capital Insights Group of WNY, LLC. for investment management services would involve completing an Investment Advisory Agreement, and would entail a separate and additional fee. The Investment Advisory Agreement would set forth the terms and conditions of the investment management services to be provided (including termination), describe the scope of the services, and detail the fee to be paid by the client. Please note: There may be a conflict of interest in circumstances when the financial planning engagement involves consulting on a decision such as: (1) choosing between leaving investment assets in an employer-sponsored retirement plan (through a current or former employer) or rolling the assets over into an IRA (Individual Retirement Account); or (2) choosing between a lump-sum distribution option and an income- stream distribution option (within an employer-sponsored retirement plan). In those circumstances, if the client were to roll over the assets into an IRA, or to elect a lump-sum distribution option, the resulting proceeds would generally be eligible for investment management services offered by Capital Insights Group of WNY, LLC. This could result in the potential for an additional revenue stream for the firm, thereby creating an economic incentive for us to otherwise encourage the client to choose the rollover option instead of an income stream. We address this conflict of interest by alerting clients to the presence of such circumstances when they arise, and by not requiring clients to utilize the investment management services offered by Capital Insights Group of WNY, LLC., regardless of which payout option they choose. Clients are always welcome to use any payout options available to them. Investment Management Services Our investment management services involve discussing a client’s investment goals, planning objectives, and risk tolerance, and utilizing that information to manage an investment portfolio which fits their individual circumstances. We offer our investment management services both on a discretionary or nondiscretionary basis. Discretionary authority grants us the ability to determine, without obtaining specific client consent, the securities to be bought or sold within the portfolio, and the amount of securities to be bought or sold. This allows Capital Insights Group of WNY, LLC. to utilize our professional judgement to make, and execute, real-time investment management decisions, with the client’s best interest in mind. The scope and parameters of our discretion are outlined in the Investment Advisory Agreement, and is signed by both the client and Capital Insights Group of WNY, LLC. As of February 29, 2024, we managed $37,570,637 in assets for 122 clients on a discretionary basis. Nondiscretionary investment management requires that we obtain individual and specific client approval before we make or execute, any recommended portfolio adjustments. This allows for greater client involvement, but results in a less timely and responsive form of portfolio management, as each and every transaction must be discussed with each and every nondiscretionary client, before changes can be made. As such, Capital Insights Group of WNY, LLC., in our sole-discretion, may limit or restrict the availability of our nondiscretionary investment management services with respect to enrolling new clients or accounts into the program. Client portfolios may consist of, but are not limited to: no-load or load-waived mutual funds (which do not charge a commission or sales charge), exchange-traded funds, closed-end funds, individual stocks, individual bonds, exchange-listed limited partnerships or master limited partnerships, and various exchange-traded trust arrangements, such as currency trusts and energy royalty trusts. Please note: Capital Insights Group of WNY, LLC. may utilize long and short mutual funds and/or exchange-traded funds that are designed to perform in either: an inverse relationship to certain market indices, financial assets, or market segments (at a rate of one or more times the corresponding movement of the underlying index, asset, or segment) as an investment strategy or hedge against downside risk; or an enhanced relationship to certain market indices, financial assets, or market segments (at a rate of one or more times the corresponding movement of the underlying index, asset, or segment) as an investment strategy or for purposes of increasing gains in an advancing market. These strategies contain enhanced risks and rewards, and there can be no assurance that any such strategy will prove successful or profitable. Clients not wanting to participate in any or all such strategies may direct Capital Insights Group of WNY, LLC. in writing not to utilize such funds in their account.