CPS has been in the advisory business since 1989. CPS had assets under management of $2,353,432,854 as of 12/31/2023. The Principals of CPS are Peter C. Golotko, Michael A. Riskin, Nolen B. Bailey, Anthony M. Corrao, Erica M. Lupercio and Shawn J. McCabe. ERISA Accounts: ADVISOR is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, ADVISOR may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset ADVISOR's advisory fees. Direct At the initial review of a client's portfolio, CPS may give advice on all investments owned by the client. CPS has discretionary authority (with respect to the purchase and sale of securities) and provides ongoing supervisory services for each account. Investment Supervisory Services: CPS provides Investment Supervisory Services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. Through personal discussions, CPS determines the client's goals and objectives. CPS then develops a client's personal investment policy and creates and manages a portfolio based on that policy. CPS provides this service to individuals, trusts, estates, charitable organizations, pension and profit-sharing plans, and corporations. CPS will manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client. CPS Investment Advisors 401(k) Services: CPS offers Investment supervisory services through its 401(k) Daily Valuation program. This is a service CPS offers to companies. CPS hires a third-party administrator to perform accounting and document preparation functions. CPS handles all of the investment decisions. CPS does not provide reports to the Participants. 401(k) Pilot Services: CPS offers Investment supervisory services through its 401(k) Pilot program. This is a limited- service CPS Offers to participants in company 401(k) plans. CPS develops a client’s personal investment policy and manages the investments in the 401(k) account through the Plan Administration website. CPS does not provide reports to the Participants. Participants can view reports and activity on line through the Plan Administration website. 403(b) Services: CPS offers Investment supervisory services through its 403(b) program. This is a limited-service CPS Offers to participants in public 403(b) plans. CPS develops a client’s personal investment policy and manages the investments in the 403(b) account through the employees account on the ASPire Financial Services website. CPS does not provide reports to the Participants. Participants can view reports and activity online through the ASPire Financial Services website. Personal Financial Counseling: CPS also provides advice in the form of a Financial Plan. Clients purchasing this service will receive a written financial plan, providing the client with a detailed financial plan designed to assist in achieving their stated financial goals and objectives. In general, the financial plan will address the following areas of concern: PERSONAL: Family records, budgeting, personal liabilities, estate information and financial goals. TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. CPS will discuss the impact of various investments on a client's current income tax and future tax liability. DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. INVESTMENTS: Analysis of investment alternatives and their effect on a client's portfolio. CPS gathers required information through in-depth personal interviews. Information gathered includes a client's current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client, and a written report is prepared. Should the client choose to implement the recommendations contained in the plan, CPS suggests the client work closely with his/her attorney, accountant, insurance agent, and/or investment advisor. Implementation of financial planning recommendations is entirely at the client's discretion. Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. CPS also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, CPS provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. All recommendations are of a generic nature. CPS holds seminars to help educate people on how to achieve financial independence by teaching them the fundamentals of investing and presenting different scenarios to show the effects of saving and spending money more wisely. These seminars teach direct instruments and mutual fund investing. In both situations,

we discuss costs and fees associated with each as well as risk and turnover. There is no cost for the seminars. Investment advice is not tailored to the attendees. CPS offers advice on various real estate investments including syndicated partnerships. CPS’ advice relates to the evaluation of these securities. A direct client agreement may be canceled by the client at any time for any reason upon receipt of 30 days’ written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Cash Management Services CPS provides Cash Management Services. This is a limited-service CPS offers to individuals, corporations, and business owners. CPS handles all of the investment and reinvestment of assets in the Client’s account(s) in securities and cash or cash equivalents. The account(s) managed by the cash management services offering are listed within the addendum to the Client’s personal investment policy statement. Client agrees to notify Advisor promptly of any significant change in the information provided by the Client or any other significant change in Client’s financial circumstances or investment objectives that might affect the manner in which Client’s account(s) should be invested. Client also agrees to provide Advisor with such additional information as Advisor may request from time to time to assist in advising Client. Advisor’s authority under this agreement will remain in effect until changed or terminated by Client in writing. CPAlliance ™ CPS has discretionary authority (with respect to the purchase and sale of securities) and provides ongoing supervisory services for each account. The Certified Public Accounting/Registered Investment Advisory firm (member) participating with CPS is responsible for educating the client with respect to the types of investments available, assisting each client in determining the amount of risk versus return in various investment vehicles, and assisting each client in making an asset allocation between those various investments. It is the responsibility of the participating member to monitor the performance of the account, as it relates to meeting the objectives of the client and the asset allocation. The member will meet with the client to continually assess the client's risk tolerance and change the asset allocation as necessary. The participating member has the discretionary authority to terminate the client's contract with CPS without the client's consent. CPS and the participating member have separate contracts with the client. CPAlliance™ Investment Supervisory Services: CPS offers investment supervisory services, through its alliance program to members. This program is called CPAlliance™ (hereinafter referred to as “Program”). These members that participate in CPS' Program are not affiliated with CPS by common control or ownership. Please refer to CPAlliance™ member's Form ADV for the additional services that they provide. CPAlliance™ 401(k) Services: CPS offers investment supervisory services through its CPAlliance™ program to members for the 401(k) Daily Valuation service. These members that participate in CPS' program are not affiliated with CPS by common control or ownership. This is a service CPS offers to companies. CPS hires a third party administrator to perform accounting and document preparation functions. CPS handles all of the investment decisions. Please refer to CPAlliance™ member's Form ADV for the additional services that they provide. CPS does not provide reports to the Participants. CPAlliance™ 401(k) Pilot Services: CPS offers investment supervisory services through its CPAlliance™ program to members. These members that participate in CPS' program are not affiliated with CPS by common control or ownership. This is a limited-service CPS offers to participants in company 401(k) plans. CPS develops a client’s personal investment policy and manages the 401(k) account through the Plan Administration website. CPS does not provide reports to the Participants. Participants can view reports and activity on line through the Plan Administration website. Please refer to CPAlliance™ member's Form ADV for the additional services that they provide. A CPAlliance™ client agreement may be canceled by the client or the participating member at any time for any reason upon receipt of 30 days’ written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. CPAlliance™ Separately Managed Account Program (CPAlliance™ SMA) CPS offers discretionary and non-discretionary management services to members of the CPAlliance™ program. This program is called CPAlliance™ SMA. Accounts and sub-accounts in the CPAlliance™ SMA program managed by CPS on a discretionary basis will be managed as described under “CPAlliance Investment Supervisory Services”. CPS offers separate account billing and reporting services for non-managed accounts and sub-accounts in the CPAlliance™ SMA program. Accounts in the “billing and reporting services” option are not regulatory assets under management for CPS Investment Advisors. It is the responsibility of the participating member to monitor the performance of the account, as it relates to the objectives of the client and the asset allocation. The member will meet with the client to continually assess the client’s risk tolerance and change the asset allocation as necessary. The participating member has the discretionary authority to terminate the member’s contract with CPS without the client’s consent. The participating member has discretionary authority with respect to the purchase and sale of securities. The participating member has discretionary authority to engage other money managers. The participating member has discretionary authority to allocate funds to separately managed accounts and sub-accounts managed by CPS on a discretionary basis.