Creative Financial Group was founded in 1988 as an independent registered investment advisor. In February of 2001, Creative Financial Group (“CFG”) became a subsidiary of Synovus Financial Corporation, a publicly traded company (NYSE: SNV). As of January 1, 2011, CFG was merged into the corporate structure of its affiliate, Synovus Securities, Inc. (“SSI”) a dually registered broker‐dealer and investment adviser. CFG operates as a separate division of SSI, maintains its own office space and personnel, and offers a different scope of advisory services than SSI’s other divisions. As of January 1, 2024, CFG’s assets under management were $1,953,068,172 on a discretionary basis, and $92,500,311 on a non‐discretionary basis. CFG offers a comprehensive package of wealth management services to its Clients, or provides individual service components, such as broad‐based financial planning, investment and asset management, tax related services, risk management services, or administrative services. A. Financial Planning: A broad‐based financial planning relationship with emphasis upon the six steps listed below as the Financial Planning Process. The primary objective of the Financial Planning services is to construct a comprehensive financial plan that provides sufficient cash flow to meet the Client’s standard of living throughout their lifetime. Other objectives include retirement planning, risk management, tax planning, estate planning, investments, education and special needs planning. The fee CFG charges for preparing a written financial plan and other financial planning services is based on the complexity involved and skill required to complete the plan. The Financial Planning Process includes: 1. Establishing and defining the client‐planner relationship; 2. Gathering extensive personal and financial client data, including the exploration of Client’s goals and objectives; 3. Analyzing and evaluate the Client’s financial status and formulate action recommendations and plans for Client to progress towards goals and objectives; 4. Developing and present recommendations to Client in a consultative and interactive manner towards formal financial plan; 5. Implementing the financial planning recommendations, including any action plans and investment plans; 6. Monitoring the financial planning recommendations, per agreement. The advice and monitoring arrangement is continuous if the Client elects to engage CFG for regular review of the plan. Typically, a broad‐based written financial plan would include advice on income tax planning, life and disability insurance planning, estate planning, retirement planning, children’s education planning, cash flow and investment planning. All these things might not necessarily involve securities. Broad‐based financial planning comprises the bulk of services provided by CFG. B. Investment and Asset Management: CFG provides individualized discretionary and non‐ discretionary investment advisory services, including but not limited to utilizing the following kinds of assets: mutual funds, stocks, bonds, exchange traded funds, index products, and on a more limited basis, options, private placements, hedge funds, as well as separate accounts, with services provided internally or through third‐parties. Clients can impose reasonable restrictions on the management of their account, such as limiting the amount of certain securities or types of securities in their portfolio. For discretionary accounts, CFG has full Page 5 discretion to supervise, manage and direct the assets in the Client account; however, CFG attempts to secure Client approval prior to execution of any transactions. CFG serves as an overall wealth manager for its Clients.

CFG’s Financial Planning services revolve around setting investment goals and objectives, formulating a comprehensive asset allocation strategy, selecting investment managers or funds, reporting and meeting periodically, and making change recommendations as necessary. Many of the actual processes and advisory services are integrated with the Financial Planning services: 1. Planning: Set investment scope, goals and objectives, and formalize an appropriate asset allocation strategy. 2. Implementation: Select investment products appropriate for each Client’s investment goals. Products and services recommended by CFG may be implemented through CFG or through any other broker, agent or representative chosen by the client. Clients are not required to implement the Financial Plan through CFG. 3. Monitoring: Portfolio reports are prepared for Clients, usually quarterly. Account reviews are scheduled, at least annually, to assess asset allocations and discuss any changes to the Client’s financial situation. Unsupervised Assets: Under certain circumstances, a Client may hold securities or other property in their brokerage account for which CFG does not provide investment advisory services (“Unsupervised Assets”). An unsupervised asset is not monitored or reviewed by CFG and is only traded upon instructions from the Client. CFG may request that Clients provide a list of Unsupervised Assets in writing and may also request any trade instructions are in writing. Client account statements normally include the Unsupervised Assets, but these assets are not included in the account fee calculations, do not count towards assets under management, and CFG will have no duty, responsibility or liability with respect to the Unsupervised Assets and will not take the Unsupervised Assets into consideration when managing the portion of the account for which it provides investment advice. Unsupervised assets are not included in current investment performance calculations, nor historical performance calculations, provided that the asset has been designated as unsupervised since the account’s inception. In cases where an asset is part of the managed portfolio and is later designated as unsupervised, the historical performance will include that asset’s returns up to the point at which it was designated as unsupervised. C. Tax‐Related Services: CFG provides individualized tax‐related services with emphasis upon: 1. Identifying tax‐saving opportunities, primarily through the financial planning relationship, including employee benefits, investment planning, gifts and charitable giving, and estate planning concerns. 2. Preparing periodic tax projections. 3. Preparing tax returns, as described in the Client agreement and/or engagement letter. 4. Considering changes in tax laws, investment products, business relationships, employee benefits plans, and family relationships. D. Risk Management Services: CFG provides individual risk management services with emphasis upon identifying financial and non‐financial risk‐related alternatives including: 1. Long‐term care; 2. Life insurance; 3. Employee/employer benefits; 4. Disability insurance; Page 6 5. Business succession planning; and/or 6. Estate planning. E. Administrative Services: CFG, under the broad umbrella of administrative/family office services, provides management and coordination of the following: 1. Cash flow management, including services with budgeting and financial statement preparation; 2. Document and Record Management; 3. Coordination of external advisors, including legal, financial, and risk management; 4. Family objectives development, including philanthropy and trust referrals.