FCA provides portfolio management, financial planning and consulting services to individuals, managed entities, and open-ended mutual funds. FCA was incorporated in Texas in 1983 and through its predecessor company, has been in business since 1975. FCA is wholly owned by First Commonwealth Holdings Corp. (hereinafter, “FCHC”), which in turn is owned by Robert W. Scharar, President of FCA, and others. Below is a summary of the services FCA provides: A. Portfolio Management Services FCA provides portfolio management services to clients. Portfolio management is defined as providing continuous advice to a client or making investment decisions for a client, as appropriate, regarding investment of client funds based on the individual needs of the client. FCA provides portfolio management services to clients’ accounts on a discretionary and non-discretionary basis. Account supervision is guided by the stated objectives of the client such as: balanced, balanced income or balanced growth. 1. Separately Managed Accounts For separately managed accounts, a client’s goals and objectives are established through personal discussions. Separately managed accounts are typically created as a result of a financial planning client deciding to implement the investment recommendations made by FCA through its portfolio management services. In general, portfolios are customized and managed to meet the individual investment needs of each client. 2. Adviser to Commonwealth International Series Trust FCA is the investment adviser to the Commonwealth International Series Trust (hereinafter the “Commonwealth Funds”), an open-end investment company registered under the Investment Company Act of 1940. 3. Adviser to Managed Entities FCA provides investment management, real estate advisory and administrative services to various entities on a non-discretionary basis. The offering and organizational documents of these entities along with FCA’s management or advisory agreements govern these relationships. 4. Types of Investments FCA identifies and investigates appropriate public and private investments which meet the client’s varied needs, such as risk tolerance, liquidity, time horizon, tax implications and investment objectives, as well as FCA’s views on investment options. FCA, when appropriate, will allocate the client’s assets among various investment products and create a portfolio consisting of one or more of the following: a) Equity securities – stock, options, warrants, b) Debt securities – government, agency, corporate, municipal, c) Convertible and non-convertible preferred stock, d) Fixed income securities, e) Investment company securities (1) Mutual funds (open and/or closed funds), (2) Exchange-traded funds, and (3) Variable life insurance and annuities f) Cash equivalents and other investment products, g) Interests in real estate investment trust or real estate corporations, partnerships, or limited liability companies, and h) Alternative investments. 5. Advice on Pre-Existing Investments When the client directs FCA to retain assets in the account held by the client prior to the hiring of FCA, FCA will not be held accountable for the performance of those assets even when those fees are “charged” on the value of those assets. 6. Assets under Management As of the September 30, 2023, FCA’s assets under management consisted of the following Discretionary: $393,409,346 Non-Discretionary: 72,003,033 Total: $465,412,379 7. Disclosure Regarding Financial Planning and Non-Investment Services To the extent requested by the client, FCA provides consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Neither FCA, nor any

of its representatives, serves as an attorney, CPA, or insurance agent to any FCA client, and no portion of FCA’s services should be construed as such. To the extent requested by a client, FCA may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, CPAs, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from FCA. Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. 8. Client Obligations In performing its services, FCA is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. It remains the client’s responsibility to promptly notify FCA if there is ever any change in his/her/its financial situation or investment objectives for reviewing/evaluating/revising FCA’s previous recommendations and/or services. B. Financial Planning Services FCA provides comprehensive financial planning services which represent a core service provided to clients. Clients utilizing this service will typically receive a written Financial Plan designed to achieve the client’s stated financial goals and objectives (“Financial Plan” or “Plan”). The primary objective is typically to obtain a level of financial independence in case of disability, retirement or death while meeting current lifestyle financial needs. In general, the Financial Plan addresses one or more of the following areas of concern: 1. Personal: Family records, budgeting, personal financial inventory, estate information and financial goals. 2. Tax and Cash Flow: Income tax and spending analysis of past, current, and future years. 3. Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. 4. Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. 5. Investments: Analysis of investment alternatives and their impact on a client’s portfolio. The Financial Plan is based on information FCA obtains through in-depth client interviews. These interviews typically address the client’s current financial status and future goals and attitude towards risk. FCA generally reviews relevant documents provided by the client including a client questionnaire. Should a client choose to implement the recommendations contained in the Financial Plan, FCA suggests the client work closely with his/her attorney, accountant, insurance agent or other advisor. Implementation of the Financial Plan’s recommendations is at the client’s discretion. FCA may prepare tax returns for clients and for some clients this is the only service provided. C. Consulting Services FCA also provides other types of advice on a more limited basis which falls within FCA’s consulting services. This includes advice regarding specific area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, advice on matters such as insurance or annuity purchases, general business matters and other topics. FCA also provides specific consultation and administrative services regarding investment and financial concerns of the client. D. Recommendations of Specific Products and Services Financial planning and consulting services are not limited to any specific product or service offered by a broker-dealer or insurance company.