Firm Description The Harbor Group, Inc. (“THG,” “we,” “us” or “our”) was founded in 1981. THG provides personalized financial planning and investment management to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations, and business entities. We provide advice through consultation with the client and may include determination of financial objectives, identification of financial challenges, preparation of net worth exhibits, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning recommendations. Investment advice is an integral part of financial planning. In addition, THG advises clients about cash flow, college planning, retirement planning, tax planning, estate planning and any other areas that the client requests us to review, providing we feel ourselves competent to do the work. Investment advice is provided, with the client making the final decision on initial investment selection. THG does not act as a qualified custodian of client assets. The client always maintains joint asset control. THG places trades for clients under a limited power of attorney. In the case of accounts that do not allow for third party authorization, THG uses access information provided by the client to access the account via the internet to place trades, and to obtain values and transactional data. Typically, we provide a written evaluation of each client's initial financial situation. We may also conduct periodic reviews to provide reminders of the specific courses of action that need to be taken or to track progress toward a goal. For asset management clients, we review accounts on at least a quarterly basis. Other professionals (e.g., lawyers, accountants, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. The initial meeting, which may be by telephone, is free of charge and is considered an exploratory interview to determine the extent to which financial planning and investment management may be beneficial to the client. Principal Owners Timothy M. Riley, President and Chief Executive Officer, Ryan J. Callaghan, Chief Investment Officer, and Christopher MacBean, Chief Planning Officer, and Chief Compliance Officer, are THG’s principal owners. Types of Advisory Services THG provides investment supervisory services, also known as asset management services. We also provide financial planning services. Financial planning services can be included with asset management services or may be completed on a standalone basis and billed separately. Upon client request, THG may agree provide consulting services about non- investment related matters, such as estate planning, tax planning, or insurance matters. THG does not serve as a law firm or CPA firm. No portion of THG’s services should be construed as legal or insurance implementation services. However, clients can engage THG to provide tax preparation and planning services as described below. Unless specifically agreed in writing, neither THG nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with THG, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from THG and its representatives in that respect. THG’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. THG may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional who is responsible for the quality and competency of the services they provide. Tailored Relationships The goals and objectives for each client are documented in their initial financial plan or in meeting notes. Investment policy statements are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Types of Agreements The following services define the typical client relationships as outlined in our client agreement letters: Financial Planning A financial plan is designed to help the client with all aspects of financial planning without ongoing investment management after the financial plan is completed. The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Detailed investment advice and specific recommendations may be provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. THG generally charges a negotiable financial planning fee at the inception of the client engagement, which may be waived at its sole discretion. The fee is predicated upon the facts known at the start of the engagement and based on the hourly rate of the planner completing the financial plan or it may be on a flat fee basis. The fee will be agreed upon before beginning work on the financial plan. Because financial planning includes a discovery process, it is possible that THG may identify financial exposures or issues about which the client was not previously aware. Therefore, if the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is deemed necessary. After delivery of a financial plan, future face-to-face meetings may be scheduled, as necessary. THG generally provides ongoing financial planning services without additional charge, as part of its investment supervisory services. However, upon client agreement, follow-on implementation work may be billed separately at rates ranging from $125 per hour to $650 per hour depending on the financial planner completing the work. For clients who do not wish to complete a full financial plan a scope of work is agreed on which identifies the specific financial planning areas to be reviewed. THG reminds those clients that financial planning would benefit them, and that the decision not to engage THG for those financial planning services may limit THG’s financial advice. At that time, an engagement letter is prepared which specifies the maximum number of hours to be billed. The hourly rate ranges from $125 per hour to $650 per hour depending on the staff member or financial planner completing the work. Asset Allocation Portfolio Management Clients typically choose to have THG manage their assets in order to obtain ongoing in-depth advice and life planning. THG conducts a thorough review of the client’s financial affairs, which sometimes includes a review of the client’s children or family members. THG assists clients in setting goals and investment objectives. As those goals and investment objectives change over time, THG may suggest and implement changes on an ongoing basis. Clients review and sign an advisory service agreement identifying the scope of work and applicable fee before THG provides services on a fee basis. An advisory service agreement may include cash flow management; insurance review; investment management (including performance reporting); education planning; retirement planning; estate planning; and tax planning, as well as the implementation of recommendations within each area. Financial planning work is usually included as part of the investment advisory fee, however, in some instances it may be billed separately on an hourly or quoted basis. Under this engagement, THG may provide investment advisory services relative to the client’s 401(k) plan assets, for which THG will manage the client’s account comprised of investment options available through the applicable 401(k) platform. THG’s investment management options will be limited to allocation of the assets among the investment alternatives available through the plan. THG will not receive any communications from the plan sponsor or custodian, and it is the client’s exclusive obligation to notify THG of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. The annual investment advisory fee under this engagement is based on a percentage of the investable assets generally according to the following schedule: 1.00% on the first $2,000,000; 0.75% on the next $2,000,000; 0.50% on the next $2,000,000; 0.40% on the next $2,000,000, 0.30% on the next $2,000,000, and 0.20% on assets over $10,000,000. Except as expressly agreed in writing, account assets consisting of cash and cash equivalent positions are included in the value of an account’s assets for purposes of calculating the advisory fee. Clients can advise THG not to maintain (or to limit the amount of) cash or cash equivalent positions in their account. THG’s investment advisory fee under this engagement is negotiable in certain limited circumstances at THG’s sole discretion, depending upon objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future additional assets; the professionals rendering the services; prior relationships with THG and its representatives, and negotiations with the client. THG may also determine to aggregate account values for related clients (such as spouses and minor children sharing the same residence) for the purpose of reducing the overall fee. Certain legacy clients may have accepted different pre-existing service offerings from THG and may therefore receive services under different fee schedules than as set forth above. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by THG to any particular client could be available from other advisers at lower fees, and certain clients may have fees different than those specifically set forth above. Tax Preparation and Planning Services Clients may also engage THG to provide tax planning and tax preparation services through a representative who focuses specifically on financial planning and tax matters. THG’s fixed fee for tax preparation services generally ranges between $200 and $5,000 on a fixed fee basis, depending upon the scope and complexity of the services required. The recommendation that a client engage a THG representative provide tax planning or preparation services presents a conflict of interest, because the receipt of additional compensation for those services may provide an incentive to recommend that a THG representative perform the service based on compensation to be received, rather than on a particular client’s need. THG clients are under no obligation to engage THG representatives for tax planning services. Miscellaneous Disclosures Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If THG recommends that a client roll over their retirement plan assets into an account to be managed by THG, such a recommendation creates a conflict of interest if THG will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over plan assets to an IRA managed by THG or to engage THG to monitor and/or manage the

account while maintained at the client’s employer. ERISA / IRC Fiduciary Acknowledgment. When THG provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way THG makes money creates some conflicts with client interests, THG operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, THG must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that THG gives advice that is in the client’s best interest; charge no more than is reasonable for THG’s services; and give the client basic information about conflicts of interest. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, THG will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when THG determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, THG is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify THG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending THG’s services or previous recommendations. Dimensional Fund Advisors. THG may allocate client investment assets to funds issued by Dimensional Fund Advisors (“DFA”), some of which are only available through selected registered investment advisers. Therefore, upon the termination of THG’s services, a client may experience restrictions on the transfer, additional purchases, or reallocation among DFA funds. Asset Aggregation / Reporting Services. THG may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged THG to manage (the “Excluded Assets”). THG’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because THG does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not THG, will be exclusively responsible for implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by THG. Accordingly, THG will not agree to be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without THG’s participation or oversight. Independent Managers / Separately Managed Account Platforms. THG may allocate (or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers / separately managed account platforms (the “Independent Managers”) in accordance with the client’s designated investment objectives. Currently, THG allocates or recommends such allocations to certain Independent Managers to access municipal bond management. In such situations, the Independent Managers will have day-to-day responsibility for the active discretionary management of the allocated assets. THG will continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. THG generally considers the following factors when considering its recommendation to allocate investment assets to Independent Managers: the client’s designated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Managers is separate from, and in addition to, THG’s investment advisory fee as set forth above, which is disclosed to the client before the allocation of investment assets to the Independent Managers. Margin / Securities Based Loans. THG does not recommend the use of margin for investment purposes. However, if a client determines to take a margin loan that collateralizes a portion of the assets that THG is managing, THG’s investment advisory fee will be computed based upon the average daily account balance, which incorporates a reduction in value based on any outstanding margin loan. Without limiting the above, upon specific client request and generally in a financial planning context, THG may help clients evaluate and establish a margin or securities based loan (collectively, “SBL”) with the client’s broker-dealer/custodian or their affiliated banks (each, an “SBL Lender”) to access cash flow. Compared to real estate-backed loans, SBLs can provide access to funds in a shorter time, provide greater repayment flexibility, and may also result in the borrower receiving certain tax benefits. Clients interested in learning more about the potential tax benefits of SBLs should consult with an accountant or tax advisor. The terms and conditions of each SBL are contained in a separate agreement between the client and the SBL Lender selected by the client, which terms and conditions may vary from client to client. SBLs are not suitable for all clients and are subject to certain risks, including but not limited to: increased market risk, increased risk of loss, especially in the event of a significant downturn; liquidity risk; the potential obligation to post collateral or repay the SBL if the SBL Lender determines that the value of collateralized securities is no longer sufficient to support the value of the SBL; the risk that the SBL Lender may liquidate the client’s securities to satisfy its demand for additional collateral or repayment / the risk that the SBL Lender may terminate the SBL at any time. Before agreeing to participate in SBL programs, clients should carefully review the applicable SBL agreement and all risk disclosures provided by the SBL Lender including the initial margin and maintenance requirements for the specific program in which the client enrolls, and the procedures for issuing “margin calls” and liquidating securities and other assets in the client’s accounts. If THG recommends that a client apply for SBLs instead of selling securities that THG manages for a fee to meet liquidity needs, the recommendation presents an ongoing conflict of interest because selling those securities (instead of leveraging those securities to access SBLs) would reduce the amount of assets to which THG’s investment advisory fee percentage is applied, and thereby reduce the amount of investment advisory fees collected by THG. Likewise, the same ongoing conflict of interest is present if a client determines to apply for SBLs on their own initiative. These ongoing conflicts of interest would persist as long as THG has an economic disincentive to recommend that the client terminate the use of SBLs. If the client were to invest any portion of the SBL proceeds in an account that THG manages, THG could receive an advisory fee on the invested amount, which could compound this conflict of interest. If a client accesses a SBL through its relationship with THG and the client’s relationship with THG is terminated, clients may incur higher (retail) interest rates on the outstanding loan balance. Clients are not under any obligation to employ the use of SBLs, and are solely responsible for determining when to use, reduce, and terminate the use of SBLs. Although THG seeks to disclose all conflicts of interest related to its recommended use of SBLs and related business practices, there may be other conflicts of interest that are not identified above. Clients are therefore reminded to carefully review the applicable SBL agreement, and all risk disclosures provided by the SBL Lender as applicable and contact THG’s Chief Compliance Officer with any questions about the use of SBLs. Cybersecurity Risk. The information technology systems and networks that THG and its third-party service providers use to provide services to THG’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in THG’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and THG are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although THG has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that THG does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Asset Management Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually through discount brokers. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm may charge fees for stock and bond trades. THG does not receive any compensation from fund companies. Investments may also include equities (stocks), corporate debt securities, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), and U.S. government securities. In certain limited circumstances, THG may also recommend that clients allocate investment assets to Real Estate Investment Trusts (“REITs”). Please refer to Item 8 below for a description of the risks associated with these investments. Initial public offerings (IPOs) are not available through THG. Termination of Agreement A Client may terminate any of the agreements at any time by providing THG thirty days’ notice in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination or the end of the thirty day notice period for asset management services. THG does not accept advance payments so no refunds of unearned fees will be necessary. For investment advisory clients, fees will be billed on a pro rata basis for the portion of the quarter completed. THG may terminate any of the aforementioned agreements at any time by notifying the client in writing. Wrap Fee Programs THG does not participate in a wrap program. Regulatory Assets Under Management As of December 31, 2023, THG managed: $1,486,774,714 of client assets on a discretionary basis, and $45,696,250 on a non-discretionary basis, for a combined $1,532,470,964 in assets under management.