Firm Description: Legend is an investment adviser registered with the U.S. Securities Exchange Commission located in Pittsburgh, Pennsylvania. Legend was founded on July 23, 1993, and began accepting clients on January 10, 1994. As of February 2022, James J. Holtzman and Christopher J. Kail are each 50% shareholders. James Holtzman is the Firm’s Chief Compliance Officer. Types of Advisory Services: The Firm offers a large variety of services, including portfolio management, investment analysis, financial planning, retirement plan consulting, and general financial consulting to individuals, high net worth individuals, qualified and non-qualified retirement plans, non-profit organizations, and corporate entities. The Firm may also provide sub-advisory services for pension and profit-sharing plans and other investment advisors. The Firm offers these services to clients or potential clients (“clients”). The following section describes Firm services in detail. Refer to the description of each investment advisory services listed below for information on how Legend personalizes and tailors advisory services to advisory clients’ individual needs. Upon retention and depending upon the Client’s situation and needs, advice will be provided but is not limited to one or more of the following services: 1. Financial objective determination; 2. Financial problem identification; 3. Cash flow consulting; 4. Income tax planning; 5. Insurance coverages review; 6. Investment management/consulting; 7. Education planning; 8. Retirement planning; 9. Estate planning; 10. Other potential services. Portfolios and the underlying investments are generally reviewed at Legend’s discretion depending upon, but not limited to, client circumstances, cash inflows and outflows, if material, and political and economic conditions as well as investment and financial market conditions and movements. Financial Planning Services: Legend offers financial planning services to individuals and families on an hourly basis at Legend’s stated billing rates or on a fixed rate basis. Financial planning services are generally not offered without the retention of the firm for investment management or investment consulting services. An analysis of the client’s current family, financial, long-term objectives and the preparation of recommendations will be made. Financial planning includes one or more of the following topics: 1. Analysis of overall financial well-being 2. Current cash flow analysis 3. Income tax planning, projections and tax reduction strategies 4. Education projections, funding and counseling for other educational issues 5. Retirement projections, withdrawals from retirement accounts and counseling for other retirement issues 6. Estate document review, estate and inheritance tax reduction strategies, beneficiary coordination and asset retitling 7. Insurance policy type reviews including survivor needs analysis and liability assessments 8. Review of all employee benefits 9. Advise clients where possible as to how to manage their debts 10. General recommendations with regard to investments Recommendations will be provided in all the above areas mentioned when retained by the client to do so. Our financial planning recommendations are reviewed and updated periodically based on the client’s needs and reasonable requests for such reviews. Implementation of the recommendations is at the discretion of the client. Investment Advisory Services/ Portfolio Management: Legend offers investment advisory services to individuals, families, qualified and non-qualified retirement plans, non-profit organizations and corporate entities on a discretionary basis. An analysis of the client’s current family, financial, long-term objectives and the preparation of recommendations will be made by Legend. Legend will attempt, on a best-efforts basis, to minimize income tax events on a yearly or multi-year basis to the best of its ability if appropriate. Margin transactions, although not used for investment purposes, can be used when requested by clients to access cash from their account. Our recommendations to investment advisory clients are reviewed and updated periodically based on the client’s needs and reasonable requests for such reviews Discretionary Investment Management Services: One of the investment advisory services offered by Legend is managing securities portfolios (each has its own strategy) on an ongoing discretionary basis. After an initial discussion about the client’s comfort with risk, their goals and objectives as well as the client’s income tax situation to a degree, Legend will develop an initial investment strategy to address the client’s needs. The recommended investment strategy will incorporate a portfolio of investments appropriate for the clients’ circumstances. Upon mutual agreement with the client regarding the recommended investment strategy, a portfolio will be implemented. Thereafter, Legend will provide ongoing management of the investment assets at its sole discretion without first consulting the client. Should the client’s circumstances and/or wishes change after the initial recommendations are developed, the client will need to notify Legend. Legend will then consult with the client to develop a new investment strategy or modify the existing investment strategy. Most portfolios can include open-end and closed-end mutual funds and Exchange-Traded products, but some portfolios in certain cases could include individual securities such as bonds, stocks and other types of investments unless the client has otherwise restricted their usage in writing. Investment securities will be selected on the basis of any or all of the following criteria: the investment's performance history; the industry/sector; country and/or region it is located in; statistical measures; valuation of the investment or asset class as are applicable; the mutual fund/investment manager; the mutual fund/investment manager’s style and philosophy; and the mutual fund/investment manager’s fee structure among other criteria as well as their income tax-efficiency, if applicable. Investment position weightings within a portfolio managed with discretion by Legend will be based upon the criteria mentioned above in addition to the client’s income tax circumstances, if possible, if applicable, as well as the type of portfolio they select. Legend assesses clients’ current holdings and ensures alignment with both short- and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. Any and all trades are made in the best interest of the client as part of Legend’s fiduciary duty. However, risk is inherent to any investing strategy and model. Therefore, Legend does not guarantee any results or returns. Legend offers ongoing portfolio management offerings tailored to the goals, objectives, time horizon and risk tolerance for each client. The investment offerings include active allocation, and management of assets through a series of equity income, equity growth, tax-efficient portfolios and environment/social/governance (ESG) portfolios. Prior to engaging Legend to provide any investment advisory services, Legend requires a written investment advisory agreement signed by the client prior to the engagement of any services. The agreement will outline services to which the client is entitled and fees the client will incur. Legend is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned products for clients. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. Legend does not act as a custodian of client assets. The client always maintains asset control. Legend places trades for clients under a limited power of attorney through a qualified custodian/broker. Investment Management Consulting / General Consulting Services: This service may or may not involve more complex assets and/or accounts to manage. This service could include accounts and/or investments that are difficult to value except for once per year, such as retirement plan balances of the individual client(s) and/or variable annuities, or could possibly be aggregated with accounts not held at one of the Firm’s recommended custodians and/or with family member accounts. Furthermore, Legend will not have trading authority over held-away assets. Legend will advise the client as to how these assets are to be positioned. Legend manages securities portfolios for this investment service similar to the Firm’s discretionary investment management services mentioned above. If the assets are held at custodians not recommended by the Firm, Legend will advise the client as to how to position those assets. Upon direction by Legend, trade executions of such securities will need to be traded directly by the client or in conjunction with the client and Legend. It is solely the responsibility of the Client to reposition these assets in this type of

situation although; the client can request Legend’s assistance. If the client opts to do so, the Firm may offer advice on held away assets that are reported by client to the Firm. To enable the Firm to provide advice accurately, the client must utilize additional software allowing held away asset valuation to be disclosed to the Firm in order for the Firm to provide the most informed advice to client. Under this arrangement, the advice given to the client is based on a point in time for which the information is provided to the Firm. The Client is responsible for placing trades in held away accounts for which we provide investment advice, but do not maintain trading authority. Legend will not provide portfolio management or execution services on these accounts. Pontera Legend uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows Legend to avoid being considered to have custody of Client funds since Legend does not have direct access to Client log-in credentials to affect trades. Legend is not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Legend will review the current account allocations. When deemed necessary, Legend will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Discretionary Sub-Advisory Investment Management Services: Legend may act as a Sub-Advisor to other Advisors offering its discretionary investment management services. In other words, a client, who is not Legend’s client, may engage an independent investment advisor (the "Advisor", which is not Legend) which, in turn, then engages Legend and perhaps other investment advisors to provide discretionary sub-advisory investment management services to a portion or all their client’s portfolio(s). Legend will only sub-advise the Advisor’s client accounts that are held at one or more of Legend’s recommended custodians. The Advisor will have the responsibility of discussing the client’s goals, portfolio objectives, ongoing needs and risk tolerance with the Client as well as, communicating any special requirements of a client with Legend (Sub-Advisor). The Advisor will be responsible for establishing and terminating accounts at the applicable custodians as well as requesting withdrawals and facilitating deposits into accounts. Investment Services For Retirement Plans: Discretionary Investment Management Services For 401(k), 401(a), 403(b) And 457 Multi-Participant Qualified Retirement Plans where the Client is the Plan Sponsor. One of the following options can be chosen by the Plan Sponsor: 1. Participants Select Managed Individual Portfolios From A Menu 2. The Retirement Plan Is Managed As A Pooled Account 3. Participants Select Individual Investments From A Menu Legend manages qualified retirement plan investment assets under the Employment, Retirement and Income Security Act of 1974 (commonly known as ERISA). Legend will also review the Plan’s Investment Policy Statement. The Plan Sponsors and/or Trustees may hire an ERISA 3(38) investment manager to accept the fiduciary responsibility for the discretionary management of the investment options offered to plan participants. However, the Plan Sponsors and/or Trustees can never delegate away its fiduciary responsibility for appointing the manager to carry out these duties. Legend is willing to act as a Section 3(38) Investment Manager or a 3(21) Investment Advisor if so designated by the Plan Sponsors and/or Trustees. 1. A 3(38) Investment Manager would select the investment options for the plan. [Please note a 3(21) Investment Advisor does this in conjunction with the Plan Sponsor’s Investment Committee]. 2. A 3(38) Investment Manager would designate Qualified Default Investment Alternatives (“QDIA”) in accordance with U.S. Department of Labor (“DOL”) guidelines which will be used as a default investment selection for participants who fail to make an affirmative investment election. [Please note a 3(21) Investment Advisor does this in conjunction with the Plan Sponsor’s Investment Committee]. 3. A 3(38) Investment Manager would monitor the investment options and portfolios on an ongoing discretionary basis and make changes when appropriate. [Please note a 3(21) Investment Advisor does this in conjunction with the Plan Sponsor’s Investment Committee]. 4. A 3(38) Investment Manager would, at least annually, provide the Plan Sponsors and/or Trustees with an overview regarding the selection of the investment options offered to plan participants. Legend if requested by the Plan Sponsors and/or Trustees to manage portfolios will provide information regarding the portfolios. This should enable the Plan Sponsor and/ or Trustee to fulfill its fiduciary responsibility regarding the sponsor’s retention of the manager. [Please note a 3(21) Investment Advisor does this in conjunction with the Plan Sponsor’s Investment Committee]. Expert Testimony: Certain principal executive officers and/or other employees of Legend may, in their capacity as officer or employee, provide expert legal testimony to assist attorneys regarding advisory or securities- industry related litigation, arbitration proceedings or otherwise. Legend’s expert testimony service will typically involve a recounting or verification of the standards for regulatory compliance and/or industry best-practices with respect to fiduciary responsibilities, fraud, suitability, compliance policies, procedures, codes of ethics and more. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. Services include management of bond, balanced and equity portfolios. Depending on the client’s financial situation and goals, we may offer active, passive and tailor hybrid portfolio combinations. We may recommend portfolios that include common stocks, corporate, government and municipal bonds, preferred stocks, government agency obligations, money market instruments, mutual funds, exchange-traded funds and such other securities that we may select, unless expressly limited by the client’s written direction or guidelines. The advice is tailored to the individual needs of the client based on the investment objective chosen by the client in order to help assist them to meet their financial goals. Accounts are reviewed on a regular basis and rebalanced as necessary according to each client’s investment profile. If the client engages us for portfolio management services, we will generally accept discretionary authority to make determinations regarding the securities that are to be bought and sold, as well as the quantities of such securities. This means the client will not be asked in advance to review or approve each transaction. Such authority is subject to mutual agreement and must be granted by the client, in writing. In other instances, such as when clients engages us for consulting services, we may accept non-discretionary authority. In these instances, clients would need to sign off on any account activity prior to execution. Clients may impose restrictions on investing in certain securities or types of securities. Clients should notify Legend in writing, in advance, of any restrictions about their investment portfolios. Within client’s guidelines, our portfolio managers will make decisions as to the nature and quantity of securities to be bought or sold. Legend reserves the right to not accept and/or terminate a client’s account if it feels that the client-imposed restrictions would limit or prevent the Firm and/or the client from meeting and/or maintaining its objectives. Legend will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that we may have relied upon in rendering our services. Wrap Fee Programs: Legend does not participate in any wrap fee programs. Assets Under Management: As of December 31, 2023, Legend manages approximately $308,473,044 in discretionary assets and approximately $0 in non-discretionary assets. As of December 31, 2023, the Firm had approximately $2,233,032 assets under advisement.