A. Description of the Advisory Firm Cooper Financial Services, Inc. is a Corporation organized in the state of Connecticut. This firm has been in business since May 1985, and the principal owner is Michael James Butler. B. Types of Advisory Services Cooper Financial Services, Inc. (hereinafter “CFS”) offers the following services to advisory clients: Investment Supervisory Services CFS provides financial planning, consulting, and investment management services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities. CFS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CFS creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then if requested, construct a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CFS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. In some cases, CFS will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client upon request. Selection of Other Advisors CFS may direct clients to the various third-party money managers (“TPMM”) who they feel are suitable and appropriate for their clients. Factors that CFS shall consider in recommending TPMMs include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting,

pricing, and research. CFS will be compensated via a fee share from these advisors to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, CFS will always ensure those other advisors are properly licensed or registered as investment advisor. Services Limited to Specific Types of Investments CFS generally limits its investment advice and/or money management to managed accounts, mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, REITs, and government securities. CFS may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CFS offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement or other similar document which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CFS from properly servicing the client account, or if the restrictions would require CFS to deviate from its standard suite of services, CFS reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. CFS DOES NOT participate in any wrap fee programs. E. Amounts Under Management CFS has the following assets under management: Discretionary Amounts: Non- Discretionary Amounts: Total AUM: Date Calculated: $170,512,440 $0.00 $170,512,440 May 30, 2024