Form ADV Part 2A, Item 4 Valley National Advisers Inc.’s registration was granted by the U.S. Securities and Exchange Commission on August 30, 1985. Matthew E. Petrozelli (CRD Number 4720275) is Chief Executive Officer and Chief Compliance Officer of the firm. Thomas M. Riddle, Chairman and Founder, owns one hundred (100%) percent of the equity of the firm. The firm is not publicly owned or traded. There are no indirect owners of the firm or intermediaries who have any ownership interest in the firm. The firm manages each client’s portfolio on an individualized basis. Clients may impose restrictions on their accounts. The firm does not participate in wrap programs. As of December 31, 2023, the firm managed assets on a discretionary basis in the amount of $1,297,643,633 representing 5278 accounts and managed assets on a nondiscretionary basis in the amount of $4,307,212 representing 2 accounts. The Firm will provide investment advisory and supervisory services to the clients on an asset allocation basis utilizing comprehensive software such as Morningstar and Tamarac. The client shall pay the Firm a fee (Advisory Fee) for its services on a monthly or quarterly basis depending on the program selected and will be disclosed at the initial proposal. The standard Advisory Fee will be calculated using the Fee Schedules below based upon the client’s average account asset value or month or quarter end balance depending on the custodian and accounts managed in previous calendar month or quarter and will become due on the following business day. The first fee payable will be prorated for the first month or quarter from the date of the Agreement or the date the account is funded. An initial set-up fee may be charged depending upon the complexity of the engagement and will not exceed ½ of 1%. Financial planning services will consist of gathering facts regarding the client’s assets and liabilities, tax situation, cash flow, financial goals, retirement objectives, estate, risk exposure and business interests. Financial planning recommendations will be made based upon the information developed in the fact-finding phase. The fees will range from $500 - $10,000 dependent upon the complexity of the client’s financial situation. Clients may choose any organization to implement financial planning recommendations. Engagements for a specific goal may be on an hourly or fixed fee rate. Estate analysis will consist of applying the facts of a client’s particular situation, gathered in the fact-finding phase, and utilizing computer application software designed to project liquidity, federal and state death taxes, and other considerations which flow from the client’s existing or proposed estate plan. Recommendations to clients will generally be based upon the complexity of the engagement and the perceived liquidity, tax savings and asset distribution goals. Furthermore, to the extent requested by a client, VNA shall provide, for a separate fee, consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc., per the terms and conditions of a written agreement with the client. VNA does not serve as an attorney (VNA does not prepare estate planning or any other legal documents) or accountant (VNA does not provide tax preparation services, but its affiliated firm can be engaged to do so), and no portion of VNA’s services should be construed as legal or accounting services. To the extent requested by a client, VNA may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, tax preparers, insurance, etc.), including representatives of VNA in their separate individual capacities as: (1) representatives of Valley National Investments, Inc. ("BD"), an affiliated SEC registered and FINRA member broker-dealer; (2) as licensed insurance agents of Valley National Indemnity Corp, an affiliated licensed insurance agency (“Insurance”); or, (3) as tax preparers of Valley National Services, Inc. (“Services”), an affiliated tax return preparation firm, per the terms and conditions of a separate written agreement and fee between Services and the client. 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 VNA and/or its representatives. Portfolio Activity. VNA has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, VNA will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when VNA determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by VNA will be profitable or equal any specific performance level(s). Please Note: If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note-Conflicts of Interest: The recommendation by VNA that a client purchase a securities or insurance commission product from firm representatives in their individual capacities as representatives of BD and/or as agents of Insurance, or engage Services for tax preparation services, presents a conflict of interest, as the broker dealer or the insurance agency may receive commissions on investment products recommended. No client is under any obligation to purchase any securities or insurance commission products from VNI or VNIC representatives or engage Tax for consulting or tax preparation services. Clients are reminded that they may purchase securities and insurance products recommended by VNA through other, non- affiliated broker-dealers and/or insurance agencies, and obtain tax consulting and preparation services from unaffiliated providers. Valley National Advisers Inc. Chief Compliance Officer, Matthew E. Petrozelli, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. Please Note: Retirement Rollovers-Potential for 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 Valley National Advisers recommends that a client roll over their retirement plan assets into an account to be managed by Valley National Advisers, such a recommendation creates a conflict of interest if Valley National Advisers will earn new (or increase its current) compensation as a result of the rollover. If Valley National Advisers provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Valley National Advisers is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Valley National Advisers, whether it is from an employer’s plan or an existing IRA. Valley National’s Chief Compliance Officer, Matthew Petrozelli, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note-Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by VNA independent of engaging VNA as an investment adviser. However, if a prospective client determines to do so, he/she will not receive VNA’s initial and ongoing investment advisory services. Participant Directed Retirement Plans. VNA may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Consulting Agreement between VNA and the plan. For such engagements, VNA shall assist the Plan sponsor to select an investment platform from which Plan participants shall make their respective investment choices, and, to the extent engaged to do so, shall provide corresponding education to assist the participants with their decision- making process. ByAllAccounts. VNA, in conjunction with the services provided by ByAllAccounts, Inc, may also provide periodic comprehensive reporting services which can incorporate all the client’s investment assets, including those investment assets that are not part of the assets managed by VNA (the “Excluded Assets”). The client and/or his/her/its other advisers that maintain trading authority, and not VNA, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, VNA’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if VNA is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), VNA does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If VNA is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and VNA shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that VNA provide investment management services for the Excluded Assets, the client may engage VNA to do so pursuant to the terms and conditions of the Asset Management Agreement between VNA and the client. Client Obligations. In performing its services, Valley National Advisers Inc. shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Valley National Advisers Inc. if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Valley National Advisers Inc.’s previous recommendations and/or services. Unaffiliated Private Investment Funds. VNA also provides investment advice regarding private investment funds. VNA, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, fees, including incentive compensation) is set forth in the fund’s offering documents. VNA ’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of VNA calculating its investment advisory fee. VNA ’s fee shall be in addition to the fund’s fees. VNA ’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that VNA references private investment funds owned by the client on any supplemental account reports prepared by VNA, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, the VNA shall calculate its fee based upon the latest value provided by the fund sponsor.