A. TFA is a Maryland Limited Liability Company established in 1996. Victoria M. Trumbower is the sole owner and managing member. B. The Firm offers comprehensive financial planning and tax compliance services. As such, we frequently deliver advice that is only marginally related to investments including estate planning, retirement planning, cash flow management, budgeting and tax planning. C. TFA uses a five-step investment advisory process. We begin by identifying the client’s objectives, risk parameters, liquidity needs and other relevant factors. This typically involves the development and presentation of a long-range personal financial plan. Second, we evaluate the client’s existing asset allocation in view of the criteria established in step one. The Third Step is the selection of a theoretically efficient target portfolio allocation within the context and constraints identified in Steps One and Two. In Step Four, the Adviser helps clients determine the most effective methods of implementing their investment policies. Finally, the Adviser and client agree on a suitable schedule and procedures for reviewing portfolio performance and rebalancing. Background information, the target portfolio mix, strategies to be employed and security selection guidelines including client-imposed restrictions on investing in certain securities or types of securities are articulated in a written Investment Policy Statement (“IPS”). The IPS is a dynamic document which provides specific, personalized information that any adviser would need to implement the client’s plan. The IPS does not presume

that the client will engage TFA to manage investments. Supervision of assets held in brokerage accounts over which TFA has discretionary or non- discretionary managerial authority is one alternative clients may choose. If TFA is engaged to execute investment policies, we will implement the target portfolio in accordance with a pre-approved detailed plan. TFA may also refer clients to brokers or other registered investment advisers for implementation when they may be more suitable. Specific recommendations made by those advisers may be reviewed by the Adviser to assure that they are appropriate and cost effective. Upon request, TFA may prepare in-depth analysis and evaluations of investment opportunities that are offered to clients by unrelated third parties. Adviser will express an opinion as to the suitability of these prospects by testing them against criteria articulated in the client’s IPS and in the context of other facts and circumstances that may subsequently arise. Adviser will also comment on income and estate planning implications as appropriate. D. TFA does not participate in wrap fee programs. E. Total assets under management (“AUM”) are $1,657,808,618 as of 12/31/2023. This includes $145,348,914 in discretionary and $1,512,459,704 in non-discretionary assets. TFA’s client portfolios often include a Conservative Fixed Income component comprised of individual debt securities that meet strict quality and maturity criteria. TFA must have discretionary authority to purchase securities within pre-approved parameters to effectively manage this portfolio segment.