A. Description of the Advisory Firm John E. Sestina and Company is an SEC-registered investment adviser with its principal place of business located in Columbus, Franklin County, Ohio. John E. Sestina and Company began conducting business in 1970. MTBW, LLC, an Ohio limited liability company, is the sole shareholder of John E. Sestina and Company. MTBW, LLC also owns the Ohio Trade Name “John E. Sestina and Company” and does business under that name. MTBW, LLC has four owners:  Lukan Enterprises, LLC, an Ohio limited liability company, which is solely owned by Stephen A. Lukan.  Int2Own, LLC, an Ohio limited liability company, which is solely owned by Tyler V. Cook.  Hilde, LLC, an Ohio limited liability company, which is solely owned by Anthony W. Payne.  Constantinovich, LLC, an Ohio limited liability company, which is solely owned by Craig A. Constantinovich. Lukan Enterprises, LLC and Int2Own, LLC are all of the managing members of MTBW, and they are in charge of the day-to-day operations for John E. Sestina and Company. All of the individual owners of the four LLCs listed above are financial planners that work full time at John E. Sestina and Company. B. Types of Advisory Services Full Service Financial Planning We provide comprehensive financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to estimate future cash flows, estimated asset values, and withdrawal plans. “Individual Portfolio Management” services are included at no additional cost to those engaging in Full Service Financial Planning with John E. Sestina and Company and is included as part of the annual Full Service Financial Planning Fee. Through the financial planning process, questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive reports, which provide the client with a detailed financial plan designed to assist the client in achieving his or her financial goals and objectives. Our comprehensive financial plan will address all of the following areas:  PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.  INCOME PLANNING: We analyze the client’s income tax and spending and planning for past, current, and future years; then illustrate the impact of various investments on the client's current income tax, spending needs, and future tax liability.  NET WORTH: We estimate and review the client's net worth for billing purposes and analyze it from many aspects including liquidity, and future growth or loss potential.  INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.  BUSINESS INTERESTS: In many instances a client's business provides a substantial portion of their estimated net worth and income. We assist the client in succession planning and analysis of the ability of the business interests to satisfy the client's financial needs.  INSURANCE: We review the client’s existing policies and goals to advise on proper coverage for life, health, disability, long-term care, liability, home and automobile.  RETIREMENT: We analyze current strategies and investment plans to help the client have a plan to achieve his or her retirement goals.  DEPENDENTS: We review the client’s needs of education funding.  ESTATE PLANNING: We assist the client in assessing and developing long-term strategies with their attorney, including as appropriate, living trusts, wills, powers of attorney, asset protection plans, nursing homes, Medicaid, review estate tax, etc. We gather required client information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, investment return objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written financial plan. Should the client choose to implement the recommendations contained in the financial plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. This plan also includes data management. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within two months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. The financial plan is typically reviewed quarterly. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. While we provide specific recommendations, at no time is a client

required to use a specific product or service. Individual Portfolio Management Our firm provides continuous asset management of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's personal investment policy. We create and recommend a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary and non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the client's portfolio has been established, we typically review the portfolio quarterly, and if necessary, recommend a rebalance of the portfolio as needed, based on the client's individual needs. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the securities set forth previously. Because some types of investments involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. John E. Sestina and Company seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of John E. Sestina and Company’s economic, investment or other financial interests. To meet its fiduciary obligations, John E. Sestina and Company attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, John E. Sestina and Company’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is John E. Sestina and Company’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Workshops and Educational Seminars John E. Sestina and Company provides educational seminars and workshops on a quarterly basis at no cost to attendees. Services Limited to Specific Types of Investments John E. Sestina and Company generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements, although John E. Sestina and Company primarily recommends mutual funds to a majority of its clients. John E. Sestina and Company may use other securities as well to help diversify a portfolio when appropriate. C. Client Tailored Services and Client Imposed Restrictions John E. Sestina and Company will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by John E. Sestina and Company on behalf of the client. John E. Sestina and Company may use “model portfolios” together with a specific set of recommendations for each client based on their personal 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 John E. Sestina and Company from properly servicing the client account, or if the restrictions would require John E. Sestina and Company to deviate from its standard suite of services, John E. Sestina and Company 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 other administrative fees. John E. Sestina and Company does not participate in any wrap fee programs. E. Assets Under Management John E. Sestina and Company has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $546,979,528 $0.00 12/31/2023