A. Description of the Advisory Firm Keenan, LLC dba Keenan Financial (hereinafter “Keenan”) is a Limited Liability Company organized in the Commonwealth of Massachusetts. The firm was formed in October 2016, and the principal owner is Brian Keenan. B. Types of Advisory Services Portfolio Management Services Keenan offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Keenan creates a Risk profile questionnaire 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 Risk Profile
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Keenan evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Keenan will request 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 Risk profile questionnaire, which is given to each client. Keenan seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Keenan’s economic, investment or other financial interests. To meet its fiduciary obligations, Keenan attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Keenan’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 Keenan’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. 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. Tax Preparation Services Keenan offers tax preparation and tax planning services to individuals, families, and fiduciaries. Keenan evaluates the current tax situation, offers recommendations for future tax minimization, and provides tax preparation services for current and prior tax years. Services Limited to Specific Types of Investments Keenan generally limits its investment advice to insurance products

including annuities, equities, and fixed income, which will include both domestic and non-U.S. exposure and be accomplished primarily through ETFs and mutual funds. Investing in a mix of securities (foreign + domestic, equity + fixed income) helps to diversify holdings, though Keenan may use other securities as well to balance out 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. 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 Keenan 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 Keenan on behalf of the client. Keenan recommends model allocations based on each client’s individual needs, targets, and restrictions (if any). Specifically, Keenan has several different allocations between equity and fixed income exposure, primarily via ETFs and/or mutual funds. This variety of investment vehicle (ETFs vs. mutual funds) and security classes (equity vs. fixed income) allows Keenan to find the mix best suited for each investor. 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 Keenan from properly servicing the client account, or if the restrictions would require Keenan to deviate from its standard suite of services, Keenan reserves the right to end the relationship. D. Wrap Fee Programs Keenan Financial does not sponsor nor provide portfolio management services to a wrap fee program. E. Assets Under Management Keenan has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $102,705,869 $0 December 2023