Nottingham Advisors, a wholly-owned subsidiary of Community Bank N.A., has been in business as an SEC registered investment adviser since September 1982. Among other services, the Firm offers asset management and investment advisory services through the use of separately managed accounts to individuals, trusts, corporations, foundations, endowments, and pension funds. As of December 31, 2023, the Firm had $1,408,520,588 in assets under management, $1,351,054,869 of which was managed on a discretionary basis and $57,465,719 of which was managed on a non- discretionary basis. Prior to engaging Nottingham Advisors to provide any of the foregoing investment advisory services, the client is required to enter into a written agreement with Nottingham Advisors setting forth the relevant terms and conditions under which Nottingham Advisors renders its services (the “Agreement”). In addition, Nottingham Advisors claims compliance with the Global Investment Performance Standards (“GIPS®“). Nottingham Advisors is GIPS verified through 2020 and has engaged to be verified for 2021, 2022, and 2023. GIPS is a voluntary set of investment performance measurement standards that seek to provide assurances for investors who want reliable performance metrics based on the principles of fair representations and full disclosure. To claim compliance, an investment firm must demonstrate adherence to comprehensive and rigorous rules governing input date, calculation methodology, composite construction, disclosures, presentation, and reporting. This Disclosure Brochure describes the business of Nottingham Advisors. Certain sections also describe the activities of the Firm’s Supervised Persons, which refer to Nottingham Advisors’ officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, and all other persons who provide investment advice on the Firm’s behalf and are subject to the Firm’s supervision. Financial Planning and Investment Consulting Services Nottingham Advisors provides certain advisory clients with a range of financial planning and investment consulting services. The Firm’s financial planning services include, but are not limited to, retirement planning, insurance needs, tax planning, cash flow forecasts, and estate planning. In addition, Nottingham Advisors’ investment consulting services involve the Firm taking a largely consultative role advising on the management of its clients’ assets, which may include functions such as portfolio construction, risk management assessment and asset allocation optimization, amongst others. Generally, these services are provided pursuant to specialized engagements individually negotiated with Nottingham Advisors’ clients based upon their specific needs and objectives. Page 5 © MarketCounsel 2024 In performing its services, Nottingham Advisors is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. The Firm will recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Nottingham Advisors recommends its own services. Clients remain under no obligation to act upon any of the recommendations made by Nottingham Advisors under a consulting engagement or to engage the services of any such recommended professional, including Nottingham Advisors itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Nottingham Advisors’ recommendations. Clients are advised that it remains their responsibility to promptly notify Nottingham Advisors if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s previous recommendations and/or services. Investment Management Services Nottingham Advisors generally manages its clients’ investment portfolios on a discretionary basis. Nottingham Advisors primarily allocates clients’ investment management assets among various exchange-traded funds (“ETFs”), mutual funds, individual debt and equity securities, and options, in accordance with its clients’ individual investment objectives. In addition, the Firm recommends that certain clients who qualify as “accredited investors,” as defined under Rule 501 of the Securities Act of 1933, invest in private placement securities, which includes debt, equity,

and/or pooled investment vehicles, when consistent with the clients’ investment objectives. Nottingham Advisors also provides advice about any legacy positions or investments otherwise held in its clients’ accounts, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Nottingham Advisors also renders investment management services to clients relative to their individual employer-sponsored retirement plans, 529 plans, and other products that are not be held by the client’s primary custodian. In so doing, Nottingham Advisors either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product’s provider. Nottingham Advisors tailors its advisory services to the individual needs of clients. Nottingham Advisors consults with clients on an initial and ongoing basis to develop and maintain an Investment Policy Statement, which determines risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Nottingham Advisors ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Nottingham Advisors if there are changes in their financial situations or investment objectives, or if they wish to impose reasonable restrictions upon the Firm’s management Page 6 © MarketCounsel 2024 services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if Nottingham Advisors determines, in its sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Sub-Advisory Services A sub-advisory relationship occurs when Nottingham Advisors enters into an agreement with an unaffiliated registered investment adviser and/or other financial advisors (“the Delegating Advisor”) to provide discretionary portfolio management on a continuous basis to certain of the Delegating Firm’s clients (each a “Sub-Advisory Client”). For such relationships, Nottingham Advisors will place, per the written agreement between Nottingham Advisors and the Delegating Advisor, orders for the execution of all investment transactions for the Sub-Advisory Clients’ with the broker-dealer(s) or platform(s) specified by the Delegating Advisor, but subject to the disclosures in this Brochure. Nottingham Advisors provides such management consistent with each Sub-Advisory Client’s individual stated goals, objectives and risk tolerances, as provided to Nottingham Advisors by the Delegating Advisor. Sub-Advisory Clients incur fees related to both Nottingham Advisors’ sub-advisory services and the on-going services provided by the Delegating Advisor. Such fees may be higher than a Sub-Advisory client would otherwise pay in the event they engaged Nottingham directly. Investment Model Services Nottingham Advisors licenses investment models to third party investment advisers and turnkey asset management platform (“TAMP”) providers, which enables those third parties to trade their clients’ assets pursuant to the Firm’s investment models. Retirement Plan Consulting Services Nottingham Advisors provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: Plan Design and Strategy; Plan Review and Evaluation; Executive Planning & Benefits, Investment Selection, Plan Fee and Cost Analysis, Plan Committee Consultation, Fiduciary and Compliance, and Participant Education. As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Nottingham Advisors as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Nottingham Advisors’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Page 7 © MarketCounsel 2024