A. TGS Financial Advisors (the “Registrant”) is a corporation formed on September 16, 1990, in the state of Delaware. The Registrant became registered as an investment adviser in June 1991. The Registrant is owned by James Hemphill. Mr. Hemphill is the Registrant’s President. B. As discussed below, the Registrant offers discretionary investment advisory services, and financial planning and related consulting services to clients. INITIAL PROPOSAL Generally, upon commencement of a relationship, and prior to providing investment advisory services, the Registrant will meet with the client to determine the client’s investment objectives, financial planning issues, and other pertinent information. Thereafter, the results of the meeting and corresponding recommendations are set forth in an “Initial Proposal.” See Item 5 below. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary or non- discretionary investment advisory services as part of the TGS Financial Advisors Wrap Program or the TriageMD Wrap Foundations Program (the “Programs”). Clients in the Program pay a single fee for investment advisory services, brokerage, custody and reporting (excluding the separate investment management fee charged by sub- advisers such as Marshfield-see below). The specific services a client receives in the Program will depend upon each client’s particular need. The Program’s specific services and conditions are discussed in the Program Brochure, a copy of which is presented to all prospective Program participants. The Program Brochure is incorporated into this Brochure by reference. All prospective Program participants should read both the Registrant’s Brochure and the Wrap Fee Program Brochure and ask any corresponding questions that they may have prior to participation in the Program. Raymond James Financial Services, Inc. (“RJFS”) is the custodian for Program accounts. As indicated in the Program Brochure, participation in the Program may cost more or less than purchasing such services separately. However, the Registrant does not generally offer its services on an unbundled basis. As also indicated in the Wrap Fee Program Brochure, the Program fee charged by Registrant for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. The Registrant receives the balance of the Program fee after all other costs incorporated into the wrap fee program have been deducted or paid for by the Registrant (i.e., transaction costs). Because Registrant pays transaction fees to RJFS, Registrant has an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. Generally, the Registrant provides its advice without regard to whether it will be required to pay transaction fees. TGS MEDICAL PROFESSIONAL PROGRAM (TRIAGEMD) Subsequent to completion of stand-alone financial planning services (see below), Registrant may, in its sole discretion, allow certain qualified clients who are: (1) finalizing their medical studies; (2) have been in a medical practice for approximately three years or less; and/or (3) any other medical professionals who Registrant deems in its sole discretion to be otherwise qualified, to participate in the TGS Medical Professional Program (referred to as the “MPP” and/or TriageMD program). Before rendering services under the MPP, qualified clients are required to enter into a separate written agreement with the Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of, and fee for, the services to be provided. The consulting services provided under the MPP will generally be limited to financial planning issues relevant to new medical professionals. See additional disclosure at Item 5 below. FINANCIAL PLANNING AND CONSULTING SERVICES TGS provides financial planning and consulting services primarily on a stand-alone separate fee basis. To the extent desired, the client can engage the Registrant to provide financial planning or consulting services (including investment and non-investment related matters) on a stand-alone separate fee basis (subject to exception at the exclusive discretion of the Registrant)). Prior to engaging the Registrant to provide planning or consulting services on a stand-alone basis, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. Registrant does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Registrant does not prepare estate planning documents or tax returns. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes. 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 the Registrant. If the client engages any recommended professional, and a dispute arises, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and competency of the services provided. Clients are responsible for promptly notifying the Registrant if there is ever any change in their financial situation or investment objectives so that the Registrant can review, and if necessary, revise its previous recommendations or services. MISCELLANEOUS Inclusive Planning Services. The Registrant believes that it is important for the client to address financial planning issues on an ongoing basis. To the extent that planning services are included in Registrant’s advisory fee, as set forth at Item 5 below, Registrant’s fee will remain the same regardless of whether or not the client determines to address financial planning issues with Registrant. Sub-Advisory Arrangements. The Registrant may engage sub-advisors, including Marshfield Associates, Inc., for the purpose of assisting the Registrant with the management of its client accounts. The sub-advisors shall have discretionary authority for the day-to-day management of the assets that are allocated to it by the Registrant. The Registrant will continue to monitor and review the client’s account performance, investment objectives, and asset allocation. The Registrant generally considers the following factors when recommending a sub-advisor: the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the sub- advisors, including the fee charged by Marshfield Associates, Inc., is in addition to the Registrant’s wrap program investment advisory fee discussed at Item 5 below. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Peter Mai, remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to a sub-adviser, including the specific additional fee to be charged by such sub-adviser. Client Obligations. The Registrant will not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information in its possession. Clients are responsible for promptly notifying the Registrant if there is ever any change in their financial situation or investment objectives so that the Registrant can review, and if necessary, revise its previous recommendations or services. 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant 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), Registrant 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 Registrant, whether it is from an employer’s plan or an existing IRA. eMoney. The Registrant may provide its clients with access to an online platform hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that the Registrant does not manage (the “Excluded Assets”). The Registrant does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, the Registrant shall not be responsible for the investment performance of the Excluded Assets. The client or their other advisors that maintain trading authority, and not the Registrant, shall be exclusively responsible for the investment performance of the Excluded Assets. In addition, eMoney also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by t h e Registrant. If the Registrant is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and the

Registrant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may engage the Registrant to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between the Registrant and the client. Finally, the Registrant shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without the Registrant’s assistance or oversight. Aggressive Growth Strategy. The Registrant offers an actively managed growth strategy comprised of individual exchange enlisted equity securities of smaller, less- followed, less actively traded public companies (the “Strategy”). The Strategy is more aggressive than other portfolios offered by the Registrant and is suitable for those clients who have a long- term objective, are not adverse to portfolio volatility, and have no need for income from the amount invested. The Strategy could buy put options (an option contract that profits if the underlying stock decreases in value during a specific time period, there being no assurance that any such contracts will be profitable, in which event the amount paid to purchase the contract will result in a loss). In addition, depending upon investment opportunities, there could be extended periods of time when the Strategy maintains high cash balances. Once the client has agreed to allocate a portion of their investment assets to the Strategy, the Registrant will thereafter manage the Strategy on a discretionary basis. The current annual Program fee ranges from negotiable to 1.50% (per the fee schedule annexed to the Investment Advisory Agreement), depending upon the amount of the Program assets. Please Note-Use of Mutual Funds and Exchange-Traded Funds (ETFs): Registrant utilizes mutual funds and exchange-traded funds for its client portfolios. In addition to Registrant’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange- traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Please Note: Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by the Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Raymond James Financial Services, Inc. (“RJFS”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as RJFS charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including RJFS, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that RJFS will not change their transaction fee pricing in the future. Please Also Note: RJFS may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Trade-aways: When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom Registrant and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC-registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by RJFS. The above fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below. Registrant does not receive any portion of these fees/charges. Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. Registrant 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, market conditions, 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 Registrant determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by the Registrant will be profitable or equal any specific performance level(s). Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, Registrant shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Registrant reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within the Registrant’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of the Registrant’s unmanaged accounts. Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non- public personal information. Clients and Registrant 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 Registrant has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Registrant 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. Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non-discretionary investment advisory basis must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, the Registrant will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Disclosure Brochure. A copy of the Registrant’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior to the execution of any advisory agreement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. The Registrant only provides services through wrap fee programs. The Registrant receives a portion of the wrap fee after the payment of trading and administrative expenses. E. As of December 31, 2023, the Registrant had $336,421,869 in assets under management on a discretionary basis and $3,493,225 on a non-discretionary basis.