Slavic Mutual Funds Management Corporation (“SMF”) is a United States Securities and Exchange Commission (“SEC”) registered investment advisor and has continuously been licensed as such since 1987. SMF is principally based in Boca Raton, Florida. John J. Slavic founded SMF and is the president and principal owner. Michael A. Sandler is also a principal owner of SMF. SMF is under common ownership with Slavic Integrated Administration (“SIA”), a 401K administrator and recordkeeper, that together with SMF are also known as Slavic401K. Please refer to Item 9 for more information on SIA. This Brochure describes the Slavic Managed IRA Program (the “IRA Program”), which is a wrap fee program offered by SMF to individual retirement account (“IRA”) participants (also referred to as our Pre-Allocated Portfolios and Bespoke). This Program is designed to assist you in your investment goals by providing you with access to one of our portfolio services (“Services”). Please see Item 4.B–Services, Fees and Compensation—Detailed Description of Services for more information on each of these services. As part of the IRA Program, all client assets are held at a qualified custodian. For more information, please refer to Item 4.B–Services, Fees and Compensation—Detailed Description of Services–Brokerage and Custody Services. In addition to the IRA Program, SMF offers other types of advisory services. For a complete description of these services please refer to our Form ADV Brochure Part 2 for additional information. A. Description of Services Before investing through the IRA Program, please read the detailed description of our Services and the other information in this Brochure. Please speak with one of our representatives if you have any questions relating to this Brochure. SMF’s Pre-Allocated Portfolios and Bespoke are offered through our wrap fee program.1 You can select from among three managed portfolios: aggressive, moderate, or conservative or any combination thereof. We utilize the information you furnish in the investor profile questionnaire designed by SMF to provide advisory services and investment options through our Wrap Fee Program. The questionnaire was developed with questions we believe assist in determining a reasonable investment allocation and risk tolerance, but it should not be construed as an indication of future performance or recognized as a universally accepted investment questionnaire. The investor profile questionnaire is a tool used to help you evaluate your risk tolerance and investment timeline. By selecting the responses that best describe you as an investor, a score is computed based solely upon the information you have provided to us as part of your investor profile questionnaire. Each of our investment strategies has a profile score range. Based on your score, you are categorized into an investment strategy: conservative, moderate, or aggressive. With this information provided via the profile questionnaire, we will recommend a portfolio that we believe is designed to meet your stated investment needs. You should be aware that we rely upon your answers to questions relating to your risk tolerance, investment objectives, and investment time horizon provided through the profile questionnaire, and that such answers serve as the basis for our investment allocation recommendations. However, we encourage you to consult with investment or tax professionals that you deem appropriate to help you understand these allocations or to help you make your own independent determination and self-select any one, or a combination, of our strategies. This is especially true if you are going to deviate from the results of the profile 1 Please see our Form ADV Part 2A Brochure for additional information on our Bespoke program. 5 | P a g e questionnaire. Once you have selected your Strategy, you grant us the authority to implement such Strategy for your account. You may change your Strategy by contacting us directly to redirect the allocation of your funds. For more information on each Strategy please refer to Item 4.B–Services, Fees and Compensation—Detailed Description of Services–Portfolio Risk Tolerance. For further details on how each Strategy is reviewed and selected, please see Item 6–Portfolio Manager Selection and Evaluation. Portfolio Risk Tolerance Your risk tolerance is a reflection of your ability and willingness to lose some or all the assets in your portfolio in exchange for greater potential returns. The Investor Profile Questionnaire seeks to assist you in evaluating your risk tolerance. Your Profile Score will be determined by your answers to the Investor Profile Questionnaire and will be categorized as one of three types: conservative, moderate or aggressive. Currently our Strategies recommend allocation ranges of 0% to 100% across three asset classes: cash, fixed income investments and equity securities. PROFILE SCORE CONSERVATIVE - GOALS AND OJECTIVES Asset Allocation Estimated Risk 1 - 27 This portfolio attempts to provide stable, low returns with about 70% in cash and/or fixed income investments funds. This portfolio is rebalanced or re- allocated at least annually by SMF and there is a 0.40% annual management fee for this service. Because 30% is invested in equities, this portfolio will fluctuate and bears a degree of market risk. There is no guarantee the targets will be met. Cash/Fixed Income 60% - 70% Estimated Risk Potential of Portfolio Decline: -15% Equities 30% - 40% PROFILE SCORE MODERATE - GOALS AND OJECTIVES Asset Allocation Estimated Risk 28 - 53 This portfolio is allocated to generate moderate returns with average risk. The portfolio is rebalanced or re-allocated at least annually. There is a 0.40% annual management fee for this service. Typically, the moderate portfolio is designed for participants with 10 to 20 years until retirement and who are willing to accept average risk. Investing in the stock market is inherently risky. There is no guarantee the targets will be met. Cash/Fixed Income 25% - 50% Equities 50% - 75% Estimated Risk Potential of Portfolio Decline: -25% PROFILE SCORE AGGRESSIVE - GOALS AND OJECTIVES Asset Allocation Estimated Risk 54 - 80 Primarily invested in the stock market, this Portfolio is allocated for participants with a long-term investment horizon (over 20 yrs.), a tolerance for volatility and higher risk, and targeting a market rate of return. This portfolio is rebalanced and re-allocated annually by SMF and there is a 0.40% annual management fee for this service. Investing in the stock market is inherently risky. There is no guarantee the targets will be met. Cash/Fixed Income 0% - 20% Equities 80% - 100% Estimated Risk Potential of Portfolio Decline: -40% The portfolios may consist of exchange-traded funds (“ETFs”) and/or mutual funds; however, we reserve the right to change the selection of funds in the future. We may adjust our asset allocation ranges and/or percentages based on market conditions, and other factors taking into consideration your investment profile, and may do so without prior notice to you. Our more conservative strategy typically recommends a greater percentage of your assets to be allocated to fixed income investments and cash, rather than to equity securities. Our more aggressive strategy typically recommends a greater percentage of your assets to be allocated to equity investments, rather than to fixed income investments and cash. 6 | P a g e There may be more than one Strategy that is suitable for your investment needs, and the same or similar types of investments may be available in multiple Strategies as well as available through other programs and services, offered by SMF and other firms. Please see 4.C– Services, Fees and Compensation—Fees–Ability to Obtain the IRA Program Services Separately for more details on the Services we provided outside of the IRA Program. Rebalancing SMF periodically may rebalance your investments to the Strategy’s allocations at any time in its sole discretion. Once you have selected an asset allocation strategy (conservative, moderate or aggressive), we may need to rebalance the allocation

of funds in your account to align with the original target (conservative, moderate or aggressive). The frequency and parameters SMF use to rebalance your account in a selected Strategy may change at any time and may be different from the parameters used in other types of investment strategies or investment advisory programs. For more information on how we select and review the funds please see Item 6.A–Portfolio Manager Selection and Evaluation–Review and Selection of Portfolio Managers. Brokerage and Custody Services In order to participate in the IRA Program, you are required to establish and maintain a brokerage account for custody of your assets and execution of transactions. The IRA Program Fee you pay to SMF covers the custody of your assets and the execution of securities transactions in your account (except as otherwise indicated). For a description of our fees, please refer below to Item 4.C– Services, Fees and Compensation—Fees. The custodian provides you with written confirmation of securities transactions and account statements at least quarterly. The custodian will also send the applicable prospectuses and other financial reports according to your brokerage account agreement. While you are enrolled in the IRA Program, certain brokerage, banking or other features may not be available for your account. Further details on brokerage services, account characteristics, and beneficiary designations are more fully described in your brokerage account agreement. Your custodian will also communicate important terms, conditions, and information about your account through the delivery of periodic statements after you enroll in the IRA Program. Such statements will reflect the IRA Program Fee and the Services you have requested for your account under the Investment Management Agreement and the brokerage agreement. All transactions made through the Service will be confirmed by the custodian. Further details can be found in your brokerage account agreement. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest; 7 | P a g e
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we administrate, manage, or provide investment advice, because the assets increase our assets under management and, in turn, our fees. Other Legal Matters We will not advise or act for you with respect to any legal matters for securities held in your account, including bankruptcies or class actions. In the event we receive any legal documents, we will attempt to send you any documents received with respect to such matters. B. Fees For the Services provided in the IRA Program, you will pay SMF an asset-based fee (“IRA Program Fee”), which covers our investment advisory services and custody of your securities with a qualified custodian. SMF will charge an annual IRA Program Fee ranging from 40 basis points (0.40%) to 75 basis points (.0.75%), depending on the custodian used, on the account balance. This is a wrap fee. Our IRA Program Fee is not negotiable and is subject to change from time to time, upon notice to you. Your IRA Program Fee is payable quarterly in arrears and will be calculated based on the value of the assets in your account as of the last business day of the last month of the quarter. You are responsible for paying the full amount of the IRA Program Fee, regardless of whether you use the results of the Investor Profile Questionnaire to help you select a strategy. The IRA Program Fee (and any other fee payable by you) will be deducted directly from your account in arrears, to the extent permitted by law. In addition to mutual funds, the portfolios may consist of shares of, or interests in, ETFs. As an ETF shareholder, you, along with other shareholders of the ETF, will bear a proportionate share of the ETF’s expenses, including, as permitted by applicable law, certain management, and other fees. An ETF’s prospectus contains a description of its fees and expenses. C. Comparing Cost The Fee for your account may be higher or lower than the fees that we would charge the account if you had purchased the services covered by the fees separately; may be higher or lower than the fees that we charge other clients, depending on, among other things, the extent of services provided to those clients and the cost of such services; and may be higher or lower than the cost of similar services offered through other financial firms. Ability to Obtain the IRA Program Services Separately You may be able to obtain some or all of the Services described herein without participating in our IRA Program. If you were to do so, your total cost may be lower or higher than the IRA Program Fee. Depending on the level of trading and types of securities purchased or sold in your account, if purchased separately, you may be able to obtain transaction execution at a higher or lower cost elsewhere. Clients who participate in the IRA Program pay a fee based on the market value of the account for a variety of services, and accordingly may pay more or less for such services than if they purchased such services separately (to the extent that such services would be available separately to the client). Please see Item 9.B–Additional Information–Other Financial Industry Activities and Affiliations for further details on our affiliates. 8 | P a g e You should consider these and other differences when deciding whether to invest in an investment advisory or a brokerage account and, if applicable, which advisory programs best suit your individual needs. D. Other Fees and Expenses SMF’s advisory fees described above do not include certain charges such as electronic fund and wire transfer fees, custodial fees, and any other, non-trading, charges imposed by the account custodian. In addition, clients will incur additional fees and expenses of their underlying investments made or recommended by us, which include fees incurred as shareholders of mutual funds and ETFs. Each mutual fund and ETF expense ratio (the total amount of fees and expenses charged by the fund) is stated in each mutual fund’s prospectus. Clients should note that many mutual funds have different share classes, with some share classes paying a distribution fee to broker-dealers (a “12b-1 fee”) and others that do not. Additionally, some mutual fund share classes include a sub-transfer agent fee (“Sub-TA” fee), to offset certain shareholder servicing costs. Consequently, share classes that do not pay a 12b-1 or Sub-TA fee are less expensive for clients. The mutual fund fees and expenses, including those assessed by different mutual fund share classes, are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. SMF will generally not recommend a share class that pays a 12b-1 or Sub-TA fee when there is another share class with similar characteristics that does not pay a 12b-1 fee. However, in situations where the only share class that is available is a share class that pays a 12b-1 or Sub-TA fee, SMF has worked with its custodian to return such fees back to the client. SMF does not receive performance‐based fees and does not engage in side‐by‐side management agreements.