Our Advisory Business 994 Group is a registered investment adviser which offers investment advice regarding securities and other financial services to clients. We provide management services to individuals, high net worth individuals, and trusts. We provide our investment advice through Investment Adviser Representatives (“IAR”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. 994 Group was founded in 2017 by Pete Markovich who serves as Chief Compliance Officer and Managing Member. The Adviser’s principal owners and managing members are Pete Markovich, CCO and Kristen LeClair, CEO. We are committed to the precept that by placing the clients’ interests first, we will add value to the asset management process and earn the clients’ trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business. Services 994 Group offers investment advice regarding securities, and other financial services to clients. We provide various asset management and financial planning services, with an emphasis on building portfolios designed to meet the needs of our clients. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We are available during normal business hours either by telephone, email, or in person by appointment to answer your questions. At this time, we do not participate in a wrap fee program. Asset Management Asset management is the professional management of securities (stocks, bonds, and other securities) and assets (e.g., real estate) in order to meet your specified investment goals. With an Asset Management Account, you engage us to assist you in developing a portfolio designed to meet your unique investment objectives. The investments in the portfolio account may include mutual funds, stocks, bonds, ETFs, alternative investments, etc. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management are based upon your investment goals and objectives, risk tolerance, and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in at least annual account reviews. These reviews will be conducted in person, by telephone conference, and/or via a written inquiry/questionnaire. We will work with you on 994 Group ADV Part 2A July 23 Page 5 of 29 an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. We will:  Review your present financial situation  Monitor and track assets under management  Assist you in setting and monitoring goals and objectives initially and as your situation changes  Provide portfolio statements, periodic rate of return reports, asset allocation statements, and rebalance statements as needed  Advise on asset selection  Provide research and information on performance and fund management changes, and macro economic trends.  Build and monitor your risk profile on an ongoing basis.  Provide personal consultations as necessary upon your request or as needed. You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. If we do not receive prompt updates when your financial situation, goals, objectives, or needs change, we are not able to take those changes into account when providing investment advice. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will be held in a separate account, in your name, at an independent custodian, and not with us. We require our clients to use TD Ameritrade or Charles Schwab & Co, Inc. as the qualified custodian for client account(s). TD Ameritrade Institutional is a division of TD Ameritrade Inc., member SIPC (“TD Ameritrade”), and unaffiliated SEC-registered broker-dealer and FINRA member. Charles Schwab & Co is a member SIPC (“Charles Schwab”), and unaffiliated SEC registered broker-dealer and FINRA member. We are independently owned and operated and not affiliated with TD Ameritrade or Charles Schwab. 994 Group ADV Part 2A July 23 Page 6 of 29 You will enter into a separate custodial agreement with the custodian which authorizes the custodian to take instructions from us regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian, either TD Ameritrade or Charles Schwab. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We manage accounts on a discretionary and non-discretionary basis. If we manage your account on a discretionary basis, then you have given us the authority to determine the following without your pre- approval:  Securities to be bought or sold for the account  Amount of securities to be bought or sold for the account  Broker-dealer to be used for a purchase or sale of securities for your account  Commission rates to be paid to a broker or dealer for your securities transaction. If we manage your accounts on a non-discretionary basis, we need your express consent prior to engaging in any of the activities described above. Consent may not be provided via email, voicemail or any other form of communication in which identity may not be verified. No non-discretionary trades will be made without verifying identity. Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. We are available during normal business hours either by telephone, email, or in person by appointment to answer your questions. Third Party Money Managers We may determine that opening an account with a professional third party money manager is in your best interest. We have access to several approved third party money managers, which will be employed to manage your account with a separate contract. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money 994 Group ADV Part 2A July 23 Page 7 of 29 managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may:  Assist in the identification of investment objectives  Recommend specific investment style and asset allocation strategies  Assist in the selection of appropriate money managers and review performance and progress  Recommend reallocation among managers or styles within the program  Recommend the hiring and firing of money managers utilized by you. You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur. Sub-Adviser 994 Group partnered with Dimensional Fund Advisors for subadvisor services, a third-party manager option. This option will be presented to High Net Worth clients where circumstances require Dimensional Fund Advisors separate account management. Financial Planning We provide services such as investment planning, general financial planning, income tax planning, education planning, business succession and general business planning, retirement planning, risk management, legacy planning, and life event planning on a flat fee basis for clients whose circumstances require. Financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan structured to best meet your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.), as necessary. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings, and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant, or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms, and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. 994 Group ADV Part 2A July 23 Page 8 of 29 We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. If you decide to implement our investment recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We require our individual advisory clients to use TD Ameritrade or Charles Schwab as the custodian for client account(s). Where 994 Group provides 321 Nondiscretionary Fiduciary Services to retirement plan sponsors, we may mutually agree with the plan sponsor to open participant accounts at a mutually agreed upon custodian and recordkeeper. Business Consulting Services We provide services such as marketing, leadership, and financial consulting to small businesses. These services may be or performed for a negotiated flat fee. If you engage us to perform these services, it is essential that you provide the information and documentation we request regarding the relevant aspects of the business. Based upon the services mutually agreed upon, you will be provided a detailed statement of work which will outline duties performed, information needed, and approximate timelines for completion. All recommendations developed as consultants are developed by our own professional judgment, and we cannot guarantee any of the results of our recommendations. Choosing to implement our advice is your decision. Retirement Plan Services For our firm’s Retirement Plan accounts, our service begins with an analysis of the current retirement plan structure, custodian, third-party administrator, daily record keeper, investments, managed investment models, and fees. The analysis is designed to determine if we are able to add value to the plan and what areas, if any, may be deficient from both a regulatory perspective and from a financial advisory perspective. We will offer you one or more of the following services:  Plan design and asset selection consultation  Develop and annually review Investment Policy Statement (“IPS”)  Develop investment menu according to the IPS and provide replacement guidance as needed  Review plan sponsor’s stated financial criteria for each investment option  Monitor each investment option according to the IPS  Provide investment research and performance information on investment options  Personal consultations with the plan sponsor as necessary  Fiduciary due diligence assistance  Attendance at Plan Committee and other meetings  Annual Fiduciary Plan Review 994 Group ADV Part 2A July 23 Page 9 of 29  Fiduciary education services to Plan Committee  Participant education, guidance, and enrollment  Benchmarking services Plan Structure We will assist our client in evaluating the current plan’s structure to determine if a change in the design of the plan better suits the needs of plan participants. We will facilitate any changes with the appropriate parties including the third-party administrator, record keeper, and custodian as well as facilitating the execution of the required plan document amendments or new plan documents. However, we will not draft any amendments as an attorney or a TPA will need to perform this service.

Investment Committee We will assist you in the establishment of the Investment Committee (if a Committee is deemed appropriate) and the establishment of a formal investment committee charter, delineating committee responsibilities and fiduciary roles. We will also serve on the Committee in a non-fiduciary capacity if needed. The Investment Committee may be charged with the fiduciary responsibility of the prudent management of the investment portfolio, selecting and retaining professional advisors to the portfolio including investment managers, investment consultants, custodians, attorneys, and clerical staff, and the establishment, execution, and interpretation of an Investment Policy Statement for the portfolio. We will assist the Investment Committee in meeting the committee’s responsibilities according to the investment committee charter, and fulfilling its fiduciary duty to the plan, including their review of service providers, third-party administration firms, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to other alternatives that are available to the client. Investment Policy Service Our Investment Policy Service is designed to assist you in creating a written investment policy statement (“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals. The service is generally designed for corporate retirement plans that are managed on a non-discretionary basis. We will assist the Investment Committee with the establishment, execution, and interpretation of the Investment Policy Statement. The Investment Policy Statement serves as a guide to assist the Investment Committee in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile various factors for the account such as investment objectives, risk tolerances, projected cash flow, and demographics of your retirement plan participants. It is the client’s responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. We recommend that your professional advisors, such as an attorney, actuary, and/or accountant, also review the IPS. The review and acceptance of the IPS is the responsibility of the plan fiduciary and your retirement program’s governing entity. 994 Group ADV Part 2A July 23 Page 10 of 29 Upon client’s final approval, the IPS is ready to be sent to client’s Investment Committee. It is client’s responsibility to confirm the Investment Committee’s acceptance of the IPS, and it is the Investment Committee’s responsibility to adhere to the IPS in managing the retirement program. We encourage you to review accounts periodically to verify investment committee’s compliance with the IPS. The Investment Policy Statement will be reviewed at least annually to determine whether stated investment objectives are still relevant and the continued feasibility of achieving those objectives. However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will not be updated to account for short term changes in market conditions or the economic environment. Investment Selection, Monitoring, and Replacement We will conduct research to determine allocations and to project potential ranges of returns and market values over various time periods and using various cash flows. As the financial advisor to the Plan, we will assist the Investment Committee in selecting the non-managed investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create forward looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. We have the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The plan sponsor has the responsibility and authority to make the final decision regarding what investments to include in the model portfolio and when to add or exclude a specific security. It is client’s responsibility to select the final mix and to determine whether to implement any strategy. We also encourage you to consult with your other professional advisors since 994 Group does not provide tax or legal advice that may affect asset classes or allocations used in the modeling. We will apply guidelines you supply, as directed; however, compliance with these restrictions or guidelines is client’s responsibility. We will also monitor the current non-managed investment line up including the investment’s performance, performance compared to an applicable benchmark index, fees, management changes, style and fundamental investment strategy changes, and fund composition to determine if an investment no longer meets the criterion defined in the Investment Policy Statement. If the Investment Committee determines that a fund no longer meets the IPS criterion, we will advise the Investment Committee on possible alternatives and assist in the selection of a replacement investment. 994 Group ADV Part 2A July 23 Page 11 of 29 If you decide to implement any of the firm’s recommendations, we will help you open a custodial account(s) for the plan. The funds in this account will generally be held in a separate account, in the plan’s name, at an independent custodian, not with us. The identity of your custodian will be communicated to you before the account is opened. The custodian will effect transactions, deliver securities, make payments, etc. You will at all times maintain full and complete ownership rights to all assets held in the account for the benefit of the plan participants. We are available during normal business hours either by telephone, email, or in person by appointment to answer your questions. Participant Meetings We will conduct plan participant meetings when a change is made either to the structure of the plan or if the investment lineup changes as a result of the decisions of the Investment Committee. We will detail the changes being made, how it affects the current participants, review the current investment opportunities, how participants may make changes to their investment selections, and will answer any and all questions a participant may have. We will review with the participants how to select the investments. Sub-advisory Services There may be instances in which we will enter into an agreement with a sub-advisor who will provide 3(21) fiduciary services to the Plan. In those instances, in which we have entered into an agreement with a subadvisor to provide 3(21) fiduciary services, we will monitor the performance of the subadvisor and the products made available to the Plan. We will also make recommendations to change the subadvisor or products made available to the plan, if necessary. Your Retirement Plan Consulting Agreement will further describe the 3(21) fiduciary services that will be provided by 994 Group and/or a sub-advisor. Other Services ERISA Fiduciary Both parties acknowledge that if the Account is subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA), the following provisions will apply:  The Adviser acknowledges that it is a “fiduciary” with respect to the Client as that term is defined under Section 3(21)(A) of ERISA.  The person signing this Agreement on behalf of the Client acknowledges its status as a “named fiduciary” with respect to the control and management of the assets held in the Account, and agrees to notify the Adviser promptly of any change in the identity of the named fiduciary with respect to the Account;  The Adviser agrees to obtain and maintain an ERISA bond satisfying the requirements of Section 412 of ERISA and include The Adviser and its members, agents and employees among those insured under that bond. When delivering ERISA fiduciary services, we will perform those services for the retirement plan as a fiduciary under ERISA Section 3(21)(A)(ii) will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. In our capacity as a 3(21)-plan fiduciary, we will conduct research to determine appropriate investment 994 Group ADV Part 2A July 23 Page 12 of 29 selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the plan sponsor in determining the appropriate model(s)investment(s) for the retirement plan. Non-Discretionary 3(21) Fiduciary Services When the Adviser performs “3(21) Fiduciary Services,” the Adviser will act as a co-fiduciary “investment adviser” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Adviser will not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. The Adviser will/will not communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. The Adviser will provide the Plan Sponsor with a sample investment policy statement. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the Adviser’s investment advisory services. The Adviser offers the following 3(21) services:  Investment screening  The selection of replacement funds to which existing Plan balances may be transferred  Assisting clients to finalize a Plan’s investment lineup of funds available for investment by Plan participants and used for other administrative purposes under the Plan  Assisting clients with electing a “qualified default investment alternative” as defined in section 404(c)(5) of ERISA In the Adviser’s capacity as a 3(21) plan fiduciary, they will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. 994 Group ADV Part 2A July 23 Page 13 of 29 The Client confirms that any instructions that have been given to the Adviser with regard to the Account are consistent with the governing plan documents and investment policy statements of the plan. Except as otherwise provided under ERISA the Adviser shall not be liable for any error of judgment or mistake of law or for any loss suffered by the Client in connection with the matters to which this Agreement relates except a loss resulting from the Adviser’s breach of its fiduciary duty, negligence, misconduct, or bad faith. The Adviser is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended (the “Code”); The Adviser is neither a law firm nor a public accounting firm and Adviser will not provide legal or accounting advice; The Client acknowledges that the services covered by this Agreement are consultative, and give no investment authority (“discretion”) or responsibility to the Adviser over any assets of the Plan or Participant regardless of how and where the assets are held. Throughout the term of this Agreement, the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held with any affiliated or unaffiliated third-party. We also encourage plan sponsors to consult with other professional advisors since we do not provide tax or legal advice that may affect asset classes or allocations. We will apply any guidelines our client supplies, as directed, however, compliance with these restrictions or guidelines, is our client’s responsibility. 994 Group does not act as a discretionary investment manager of any Sponsored Plans as defined in Section 3(38) of the Employee Retirement Income Security Act of 1974. Assets Under Management As of May 1, 2023, we provide asset management services for 433 discretionary accounts and 3 non- discretionary account, managing total discretionary assets of $106,196,362.86 and $982,547.17 in non- discretionary assets under management.