GENERAL INFORMATION American Investment Services, Inc. (“AIS”), a SEC-registered investment adviser incorporated in Delaware with its principal place of business located in Massachusetts, began conducting business in 1978. AIS is a wholly owned subsidiary of the American Institute for Economic Research (“AIER”), a not-for-profit organization, and is governed by a Board of Directors appointed by AIER's Trustees. AIER established AIS to manage certain trust assets contributed to AIER and to provide investment advice and information to public investors. AIS Board of Directors Neil D. Holden, DBA, Chair Roy Bouffard, CFP Nelson E. Furlano, CPA James C. Lordeman, MBA, MSE AIS Mission Statement AIS provides wealth management services and publications based on portfolio diversification, discipline, and cost effectiveness consistent with the scientific research findings of AIER. AIS serves the interests of individuals and organizations through these investment services and the sale of investment publications and seeks to maximize shareholder wealth by acting in the best interests of clients. AIS carries out this mission by providing individuals, charitable organizations, corporations and institutional investors with wealth management and advisory services and through the sale of a monthly newsletter, the Investment Guide (“IG”). AIS Staff John L. Barry, President and Chief Executive Officer Luke F. Delorme, Director of Financial Planning Yana Y. Deluca, Client Services Associate Seth L. Hoffman, Vice President Charles D. Murphy, Vice President and Chief Financial Officer Sandra Potter-Stevenson, Chief Compliance Officer Michelle Ryan, Bookkeeper David F. St. Peter, Vice President, Dir. of Institutional Services and Corp. Secretary Tricia R. Storti, Chief Operating Officer and Client Services Manager Matthew J. Svirida, Vice President Mackenzie W. Waggaman, Vice President Tyler J. Warner, Client Services Associate AIS offers services on a non-exclusive basis. As fiduciaries to all our clients, we seek to avoid situations where one client’s interests may conflict with the interests of other clients or the interests of AIS and to provide full and fair disclosure when such potential or actual conflict(s) exists. All clients and prospective clients should be aware of the following with respect to AIS and AIS' parent, AIER:
• AIER and its trust funds are collectively AIS' largest advisory client;
• AIS advisory services are available to AIS Directors, officers, and employees, and to AIER Trustees, officers, employees, and voting members;
• The AIS Board of Directors reviews the compensation of AIS employees; and
• The AIS Board of Directors declares any dividends paid to AIER, as sole shareholder of AIS. If any of the relationships described above give rise to a conflict of interest, AIS endeavors to put the interests of its non-affiliated clients (i.e., those clients not specified above) first. PORTFOLIO MANAGEMENT, SUPERVISION AND ADVICE AIS is a fee-only registered investment adviser. The investment approach underlying our investment services and publications can be characterized as structured, passive, asset allocation. This approach to wealth management is based on the major tenets of Modern Portfolio Theory (“MPT”) which holds that capital markets are highly efficient at pricing securities and investors are rewarded with returns for accepting risk. Investment allocations regarding AIS’ portfolio management services are based on our understanding of client objectives and needs formulated pursuant to an initial financial plan. Clients can impose reasonable restrictions on investing in specific company securities, industries, or types of financial products. Please refer to the “Investment Discretion” section (Item 16) of this document for more information. While investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company AIS primarily utilizes mutual funds and exchange-traded funds – typically but not exclusively – those offered by Vanguard, Dimensional Fund Advisors (DFA), State Street SPDR ETFs, and BlackRock iShares. Further, select high yielding Dow equities (see High Yield Dow strategy below for further information), Real Estate Investment Trusts (REITs), utilities and bonds are also utilized in managing certain client accounts when appropriate to the client’s strategy and risk tolerance. AIS advice can also encompass a broad range of other types of market securities in response to a client’s or prospective client’s current holdings or securities under consideration. Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. AIS offers wealth management and advisory services to clients, including:
• The Professional Asset Management program
• The High-Yield Dow program
• Sub-Advised Separately Managed Accounts (Dimensional SMAs) Professional Asset Management (“PAM”) PAM is a discretionary wealth management service for an entire portfolio. This service is designed for clients who want structured low-cost, personalized asset management. Under PAM the client authorizes AIS to make and implement investment decisions with respect to a specified portfolio that is designed in consultation with client. The PAM service can include management of self-directed retirement plan assets on a discretionary basis if the plan permits, or, if it does not, on a supervisory basis involving continuous portfolio review and trading recommendations that are implemented by the client. PAM can also encompass management of certain legacy holdings including, but not limited to, annuities on either a discretionary or supervisory basis. Generally, AIS implements a balanced portfolio that provides exposure to stocks, cash and bonds which offers advantages both to the client and the manager. For the client, such as an endowment, having a balanced manager can add value, because the pivotal asset allocation decision is continuously reviewed by a professional investment manager rather than part time by an investment committee. That committee together with their AIS investment manager will establish strategic asset allocation guidelines initially and on a going forward basis. The manager maintains portfolios through asset class selection and asset allocation, This provides flexibility to target consistent risk-adjusted returns appropriate to each client’s circumstances. AIS requires a minimum investment of $300,000. Under certain limited circumstances this minimum account size is negotiable. Please refer to the “Fees and Compensation” section (Item 5) of this document for further information regarding account requirements and advisory fees. Generally, PAM clients receive the following:
• Development and implementation of a client-specific investment policy based on the account manager’s understanding of the client’s specific circumstances and needs. Portfolios are continually monitored, and investment policies are updated as needed, e.g., in response to changes in client circumstances. Typically, this investment policy will include a recommendation for liquidation of existing securities (taking into consideration tax and other consequences), although AIS retains sole discretion to maintain certain legacy positions. In some instances, such legacy assets will be excluded from AIS’ fee calculation pursuant to a client’s request;
• Quarterly reports, which include portfolio holdings by asset class and total returns versus appropriate benchmarks (from inception and for various time periods);
• Portfolio reviews, no less frequently than once per calendar quarter, to include portfolio rebalancing if warranted; and
• Access to DFA mutual fund products which are generally only available through DFA-approved advisors.
• PAM incorporates financial planning and consulting. This includes a review of the client’s overall financial objectives and situations at the inception of service and an annual updating review. The account manager will discuss the client’s options, as appropriate, regarding taxation, retirement planning, insurance, endowment spending and business planning legacy concerns as well as other client-specific financial planning matters. A formal written financial plan can be prepared, depending on the client’s needs and desires.
• Certain portfolios also include a client’s defined contribution plan assets. As reflected in certain clients’ Investment Management Agreement AIS will not have discretionary investment or trading authority over such client’s assets, however we will incorporate these holdings into the client’s overall asset allocation and investment strategy. When appropriate, AIS shall provide recommended changes to the client, who, in turn, shall be responsible

for their implementation. Where appropriate and available, AIS services extend to providing discretionary asset management services to clients whose assets are custodied at The Vanguard Group (Vanguard), Transamerica Corporation (Transamerica), Lincoln Financial Group (Lincoln) and Teachers Insurance and Annuity Association of America-College Retirement Equities Fund (TIAA), such assets will be included in AIS’ fee calculations. High-Yield Dow (“HYD”). As an adjunct to PAM, and when suitable to the needs of the client, all or a portion of the client’s assets can be managed pursuant to AIS’ HYD portfolio management strategy. The HYD strategy is designed to replicate the returns of a domestic large cap value model portfolio – the High-Yield Dow (“HYD”) model -- based on internally conducted research. While the HYD model is generally fully invested in a subset of the Dow Jones Industrial Average (DJIA), individual accounts will also hold adequate cash to cover brokerage costs, AIS management fees (if the client authorizes AIS to deduct fees) and client distribution needs. The HYD model portfolio follows a rules-based “four for 18-month” strategy based on relative dividend yield. From time-to-time, the portfolio will include spin-offs of DJIA components or stocks that are no longer part of the DJIA and un-reinvested cash from dividends. Sub-Advised Separately Managed Accounts (Dimensional SMAs). When appropriate to the specific needs of the client, AIS will utilize Dimensional Fund Advisors LP’s (DFA) Separately Managed Accounts (Dimensional SMAs) to implement a customized portfolio employing an enhanced strategy tailored to the investor’s particular needs. While DFA has discretionary authority for day-to-day management of the assets within the SMA, AIS will monitor all such client accounts on an on-going basis and may balance and reallocate assets as necessary. As the discretionary asset manager to such account(s) AIS is responsible for selecting the strategy or strategies for the client, and any changes to such strategy(ies) may only be made by AIS. AIS will also monitor the performance of the SMAs. Participation in this SMA program requires clients to custody those assets at Charles Schwab and/or Fidelity. DFA SMA offerings include several types of equity strategies (i) US Large Cap Core Equity, (ii) US All Cap Core Equity 1 and 2; (iii) US All Cap Equity Market, (iv) Global ex US Large Cap Core, and (v) Global Large Cap Core. For these accounts, AIS will ensure that the following conditions are met and maintained: 1) AIS will manage each client's account on the basis of the client's financial situation and investment objectives and any reasonable investment restrictions the client may impose; 2) AIS will obtain sufficient client information to be able to provide individualized investment advice to the client. At least annually, AIS will contact the client to determine whether there have been any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. On a quarterly basis AIS will remind the client in writing to notify AIS if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. These quarterly notifications will include the means through which contact shall be made to AIS; 3) AIS will be reasonably available to consult with the client; 4) Each client is able to impose reasonable investment restrictions on the management of the account; 5) Each client will receive a quarterly statement from their custodian with a description of all account activity; and, 6) Each client will retain certain indicia of ownership of the securities and funds in the account, e.g., the ability to withdraw securities, among others. DFA has established a minimum account size of $500,000 per strategy, (such as US Large Cap Core Equity) for the SMA offering. AIS, however, reserves the right to establish higher minimum account requirements based on individual client circumstances. Currently, participation in this program is limited to U.S. residents only and supports taxable and non-taxable accounts at Charles Schwab and Fidelity. Plans and accounts subject to ERISA are not eligible for Dimensional SMAs. Individual Retirement Accounts (IRAs), not subject to ERISA, are permitted, such accounts may not hold any interests in registered investment companies managed by Dimensional (including, but not limited to, Exchange Traded Funds (ETFs) and Mutual Funds) (Dimensional Registered Funds). As noted above, clients may impose reasonable restrictions or mandates on the management of their account if, in AIS’ discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. DFA also reserves the right not to accept certain restrictions in its discretion. AIS will deliver copies of DFA’s disclosure documents (i.e., Form ADV Part 2A and Part 2B, Form CRS and Privacy Notice) to participating clients. Clients are urged to read these documents for a more comprehensive understanding of the program. Retirement Plan Consulting Services AIS provides this service solely to existing Retirement Plan Consulting clients. This service is no longer offered to new clients. AIS serves as consultant to sponsors of qualified retirement plans. Services provided to clients include any or all of the following services: Investment Policy Statement Preparation (hereinafter referred to as ''IPS''). Together with the plan sponsor, AIS determines an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan which is memorialized in a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles. AIS assists plan sponsors in constructing appropriate asset allocation models. AIS will then review various mutual funds to determine which investments are appropriate to implement the Plan's IPS. The number of investments to be recommended will be determined by the plan sponsor, based on the IPS. Monitoring of Investment Performance. AIS monitors investment options for participants. Although AIS is not involved in any way in the purchase or sale of these investments, AIS evaluates the plan investment options and will make recommendations to the plan sponsor. Employee Communications. Within these retirement plans, participants exercise control over assets in their own account (''self-directed plans''). We provide periodic educational support and investment workshops designed for the plan participants. The frequency and nature of the topics to be covered will be determined by AIS and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. Publications AIS publishes the Investment Guide (the “IG”), a monthly newsletter. The IG covers developments in modern portfolio theory, capital markets, financial planning and their potential implications for individual investors. Additional investment-related topics include taxation, and innovations in capital markets. Each monthly issue includes a selected list of no-load, low-cost index type investment vehicles appropriate for each asset class. These vehicles are periodically screened to meet AIS criteria with respect to expenses, turnover ratios, diversification, and consistency in their ability to deliver the returns of their respective asset class. AIS regularly monitors the market for new investment vehicles that adhere to our requisite criteria while seeking to provide optimal post-tax, risk adjusted returns for risk assumed. Investment alternatives covering broad asset classes are provided in this newsletter, however, the information provided does not purport to meet the objectives or needs of any individual or provide personalized investment advice, nor is account supervision provided for subscribers. Furthermore, the opinions expressed in the Investment Guide are subject to change. AMOUNT OF REGULATORY ASSETS UNDER MANAGEMENT As of December 31, 2023, AIS provided continuous and regular supervision or management services on a discretionary basis for client assets totaling $1,243,691,845. AIS has no non-discretionary regulatory assets under management.