SCM is an independent fee-only registered investment adviser providing investment advisory services to both individuals and company sponsored retirement plans. Having been in business to best serve clients since 1995, SCM is committed to minimizing potential conflicts of interest and providing transparent pricing. When we provide investment advice to clients regarding a retirement plan account or individual retirement account, we are fiduciaries with 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 client interests, so we operate under a special rule that requires us to act in our clients’ best interest and not put our interest ahead of our clients’ interests. Under this special rule’s provision, 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 our clients’ best interest;
• Charge no more than is reasonable for our services; and
• Give clients basic information about conflicts of interest. SCM is primarily owned and operated by principals that work on and in the business every day, including Michael Steele with a majority ownership, as well as Kathryn Moran as Chief Financial Officer and Chief Compliance Officer, Brett Wessels as Chief Investment Officer, Bradley Lewis as Senior Portfolio Manager, Nick Smith as Senior Portfolio Manager and Chris Boxleiter, Director of Company Sponsored Retirement Plans. For operational purposes, Michael Doyle serves as President but does not have ownership interest at this time. For estate planning purposes, the Ashley E. Steele 2024 Trust and Daniel L. Steele 2024 Trust own a minority interest in SCM but are not part of the day-to-day operations. As of December 31, 2023, SCM had $2,692,631,000 of assets under management, of which $2,665,599,000 was managed on a discretionary basis and $27,032,000 was managed on a non- discretionary basis. Individual Advisory Services Asset Management. SCM assists clients with long-term investment plans that are guided by documented client goals, constraints, and risk profiles. To this end, SCM makes initial investment recommendations only after thoroughly analyzing each new client’s risk tolerance, goals, and financial situation. Once SCM has established an appropriate investment portfolio for a new client based on these guiding factors, SCM then meets or interacts with each client at least annually to review any changes to their situation that may require adjustments to their investment portfolio. Although SCM does have certain investment strategies that it seeks to execute for all clients, SCM will tailor its advisory services to the individual needs and preferences of each client. Clients may engage SCM to manage all or a portion of their investment portfolios on a discretionary basis. SCM also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products. In so doing, SCM either directs or recommends the allocation of client assets among the various investment options that are available. Financial Planning.

SCM makes financial planning available to its investment management clients for no additional cost. This service provides guidance in the areas of retirement planning, estate planning, education funding, tax planning, cash flow analysis, and Social Security maximization. Retirement Plan Consulting Services Investment Advice. SCM also specializes in providing investment advisory services to company sponsored retirement plans. Advisory services provided are in the nature of research, analysis, and selection of investment alternatives. SCM may manage a plan's assets on a discretionary or nondiscretionary basis. On a non-discretionary basis, SCM contracts with the Plan Sponsor to evaluate and recommend no-load mutual funds for each investment objective and for use in asset allocation strategies. SCM provides Plan Sponsors with periodic research reports on funds held by the Plan, and on additional funds SCM believes should be under consideration. Since SCM investment advisory services are non-discretionary, the Plan Sponsor makes the final decision as to which investments are offered to participants in the Plan. Each participant then makes the final decision as to which of those investments, and how much of each, is held in his/her account. In a discretion arrangement with a Plan Sponsor, SCM is an ERISA fiduciary to the Plan. As a fiduciary, SCM supervises and directs the selection, removal and replacement of the investment options offered under the Plan. SCM is charged with providing investments that are consistent with the authorized investment objectives stated in the Plan Sponsor’s formal, written Investment Policy Statement (IPS). Services may include development of risk-based and/or target date asset allocation strategies and quarterly monitoring of the Plan investments. The services may be tailored to the Plan Sponsor’s desire for its level of involvement in the selection of investment options, either selecting from the entire universe of available funds or only from an SCM selected group of funds in categories such as: ETF’s, Index Funds, Low-Cost Funds, Sector Funds, Actively Managed Funds, etc. SCM does not place any trades for participant accounts and does not have authority to do so for Plan Sponsors, however, SCM may have the discretion to select the investments available to participants. Under both types of Retirement Plan investment advice, non-discretionary and discretionary, SCM meets with Plan Sponsors at least annually to review the quality of the service provided by SCM and to review investment objectives of the Plan. SCM’s services may also include participant education and enrollment. SCM typically does not make specific investment recommendations to plan participants. However, participants may contract directly with SCM for individual investment advisory services. Strategic Roadmap Portfolios. The Strategic Roadmap Portfolios (SRP) are five Collective Investment Funds (CIF) sponsored by Matrix Trust Company (MTC). A CIF is an institutional-only structured fund that is exclusively available to certain types of tax-exempt retirement plans. As trustee of the SRP, MTC has engaged SCM as the subadvisor to the funds. As such, each of the funds is invested according to the strategies developed and provided by SCM. The five SRP funds that SCM manage are the Conservative Fund, Moderate Fund, Balanced Fund, Growth Fund, and Aggressive Fund. SCM utilizes these funds in the company sponsored retirement plans that it advises. Retirement plan participants are encouraged to select the fund that best suits their investment goals and objectives.