Item 5 - Additional Compensation .......................................................................................................................... 22 Item 6 - Supervision ..................................................................................................................................................... 22 Firm Description Arnold Castellano & Associates, LLC (“ACA”) was founded as a certified public accounting (CPA) firm in 1987 and began offering advisory services in 2002. Arnold Castellano Jr, CPA is 100% owner. The CPA firm established the Investment Advisor firm to include a financial planning service integrated with quality tax planning and preparation. Types of Advisory Services ASSET MANAGEMENT ACA offers discretionary asset management services to advisory Clients. ACA will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize ACA discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. When deemed appropriate for the Client, ACA may hire Sub-Advisors to manage all or a portion of the assets in the Client account. ACA has full discretion to hire and fire Sub- Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and ACA. Sub-Advisors execute trades on behalf of ACA in Client accounts. ACA will be responsible for the overall direct relationship with the Client. ACA retains the authority to terminate the Sub-Advisor relationship at ACA’s discretion. Orion Portfolio Solutions ACA offers discretionary management services through a program sponsored by Orion Portfolio Solutions (“OPS”). The terms and conditions under which the Client shall engage Orion Portfolio Solutions shall be set forth in separate written agreements between (1) the Client and ACA and (2) the Client and Orion Portfolio Solutions. ACA shall continue to render advisory services to the Client relative to the ongoing monitoring and review of account performance, for which ACA shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by Orion Portfolio Solutions. Factors that ACA shall consider in recommending Orion Portfolio Solutions include the Client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. In addition to ACA’s written disclosure statement, the Client shall also receive the written disclosure statement of Orion Portfolio Solutions. Clients should review Orion Portfolio Solutions’ ADV Part 2 or Terms of Use for additional details regarding services. Betterment Platform ACA offers discretionary direct asset management services to advisory clients utilizing The Betterment for Advisors platform for digital services. On this platform, ACA has the discretion to delegate the management of all or part of the Assets to one or more independent investment managers or independent investment management programs (“Independent Managers”). To the extent utilized, Independent Managers will have limited power-of-attorney and trading authority over those assets ACA directs to them for management. ACA will supervise the Independent Managers and monitor and review asset allocation and asset performance. ACA may terminate or change Independent Managers when, in ACA’s sole discretion, ACA believes such termination or changes is in your best interest. ERISA PLAN SERVICES ACA provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. ACA may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. ACA may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor ACA has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using ACA can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. ACA acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands ACA’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, ACA is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. ACA will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. ACA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between ACA and Client. 3. ACA has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to ACA on the ERISA Agreement.

Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. ACA can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. ACA would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• ACA has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the ACA’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the ACA is not providing fiduciary advice as defined by ERISA to the Plan participants. ACA will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. ACA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between ACA and Client. 3. ACA has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING Financial planning services include a comprehensive evaluation of an investor's current and future financial state and will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. ACA will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Typical topics reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy. Financial goals should be quantified and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide the necessary coverage to protect the family and its assets against financial loss. The risk management plan includes a full review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage.
• Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and a risk profile. This investment plan sets guidelines for selecting, buying and selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax- favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. If a conflict of interest exists between the interests of ACA and the interests of the Client, the Client is under no obligation to act upon ACA’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through ACA. Financial plans will be completed and delivered inside of 120 days contingent upon timely delivery of all required documentation. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs ACA does not sponsor any wrap fee programs. ACA places clients into wrap fee programs offered by Betterment. When participating in a wrap fee program provided by Betterment, Client will receive additional information from Betterment in the form of a Client Agreement. Betterment LLC will provide the wrap program with Betterment Securities as the custodian for the wrap program. ACA will ensure that client has received the program brochure prior to engaging in this service. Betterment Securities will make available on the Website to Client any and all notices and other communications relating to the Account, including privacy notices, transaction confirmations, prospectuses, and, where required by applicable laws and regulations, any proxy materials, annual reports, notices of meetings and any other material furnished to Betterment Securities by issuers whose securities Client owns. Betterment Securities will also deliver to Client account statements, and other notices regarding the Account or Services Such notices and other communications will be sent or forwarded to Client via electronic mail address Client has specified or by making them available on the Website. Client Assets under Management ACA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $113,742,554 $0 April 17, 2024