A. The Financial Advisory Group, LLC is a limited liability company, originally formed as a corporation on May 6, 1997 in the state of Texas, then executed a conversion in December 2022 to become a limited liability company. The Financial Advisory Group became registered as an Investment Adviser Firm in June 1997. The Financial Advisory Group is solely owned by Financial Advisory Group Holdings Inc., of which Richard Alphonso is the principal owner. Mr. Alphonso is also The Financial Advisory Group’s Chief Executive Officer and Chairman of the Board. Ryan Scharar, JD, CPA, MBA serves as an outside director of the firm. Steve Estrin is the Chairman of The Financial Advisory Group’s Investment Committee. Darryl Nelson is The Financial Advisory Group’s President. Juan Martinez serves as The Financial Advisory Group’s Chief Compliance Officer. Steven Rife serves as The Financial Advisory Group’s Chief Investment Officer. Lynnette Okwuonu serves as The Financial Advisory Group’s Chief Operating Officer. Connie Alphonso serves as The Financial Advisory Group’s Chief Administrative Officer. Thomas Sartor serves as The Financial Advisory Group’s Chief Investment Strategist. Nathan Bowen serves as The Financial Advisory Group’s Chief Planning Officer. And Christopher G. Kolenda, JD, CPA, MBA serves as the firm’s Tax Counsel. While Mr. Alphonso principally owns Financial Advisory Group Holdings, and Financial Advisory Group Holdings is the sole owner of The Financial Advisory Group as stated above, almost half of Financial Advisory Group Holdings is owned by second generation professionals. If Mr. Alphonso either retires, becomes incapacitated or dies, the Shareholder Agreement provides for the firm through the second generation of professional shareholders to redeem out Mr. Alphonso or his estate. Therefore, the Shareholder Agreement safeguards the succession of the firm to the next generation of professionals. B. As discussed below, The Financial Advisory Group offers to its clients (individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, tax preparation services, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES (COMBINED) The Financial Advisory Group provides discretionary investment management services, together with planning and consulting services, and, to the extent desired, tax preparation, on a fee-only basis. The Financial Advisory Group’s annual investment advisory fee for such combined services shall vary (generally up to 2.50% of the total assets placed under The Financial Advisory Group’s management) and shall be based upon various objective and subjective factors. (See also Fee Differential discussion below) INVESTMENT MANAGEMENT SERVICES (STAND-ALONE) The Financial Advisory Group provides discretionary investment management services on a stand-alone fee-only basis. The Financial Advisory Group’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under The Financial Advisory Group’s management, between negotiable and 1.00% and shall be based upon various objective and subjective factors. (See also Fee Differential discussion below) FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) The Financial Advisory Group provides financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Prior to engaging The Financial Advisory Group to provide planning or consulting services, clients are generally required to enter into a Financial Planning Agreement with The Financial Advisory Group 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 The Financial Advisory Group commencing services. Neither The Financial Advisory Group nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. In addition, The Financial Advisory Group does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with The Financial Advisory Group, if desired. It shall remain the client’s responsibility to promptly notify The Financial Advisory Group if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising The Financial Advisory Group’s previous recommendations and/or services. If requested by the client, The Financial Advisory Group 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 Financial Advisory Group. If the client engages any such recommended unaffiliated professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not The Financial Advisory Group, shall be responsible for the quality and competency of the services provided. ERISA INVESTMENT MANAGEMENT SERVICES The Financial Advisory Group offers pension advisory services to qualified retirement plans, on a discretionary basis, as a 3(38) fiduciary. Client accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). The Financial Advisory Group may provide discretionary investment advisory services by the direct investing and reinvesting of plan assets. The Financial Advisory Group shall exercise its responsibilities as a 3(38) fiduciary as appropriate, considering each plan’s stated objective, liquidity needs, and stated policies and guidelines. RETIREMENT PLAN CONSULTING The Financial Advisory Group also provides retirement plan consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants may choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, The Financial Advisory Group shall also provide participant education designed to assist participants in identifying how to find an appropriate investment strategy for their retirement plan accounts. TAX PREPARATION SERVICES (STAND-ALONE) The Financial Advisory Group provides tax preparation services on a stand-alone separate fee basis. The Financial Advisory Group’s Investment Management Agreement and/or Financial Planning Agreement shall indicate if the client has determined to engage The Financial Advisory Group to provide tax preparation services. Although The Financial Advisory Group’s Chief Executive Officer, Richard J. Alphonso, in his separate individual capacity is licensed as a Certified Public Accountant and an attorney, Mr. Alphonso does not provide accounting or legal services to any of The Financial Advisory Group’s clients, and no corresponding CPA-client or attorney-client relationship is established when Mr. Alphonso is engaged by a client of our firm. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, The Financial Advisory Group may provide financial planning and related consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. The Financial Advisory Group does not serve as an attorney, accountant, or insurance agency, and no portion of its services should be construed as legal, accounting, or insurance brokerage services. Accordingly, The Financial Advisory Group does not prepare estate planning documents or sell insurance products. To the extent requested by a client, The Financial Advisory Group may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are 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 made by The Financial Advisory Group or its representatives. If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not The Financial Advisory Group, shall be responsible for the quality and competency of the services provided. 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 The Financial Advisory Group recommends that a client roll over their retirement plan assets into an account to be managed by The Financial Advisory Group, such a recommendation creates a conflict of interest if The Financial Advisory Group will earn new (or increase its current) compensation as a result of the rollover. If The Financial Advisory Group provides a recommendation as to whether a client should engage in a rollover or not, The Financial Advisory Group 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 The Financial Advisory Group. Third Party Financial Information Aggregators. The Financial Advisory Group, in conjunction with the services provided by eMoney or other third-party financial information aggregators, may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by The Financial Advisory Group (the “Excluded Assets”). Unless specifically indicated otherwise in writing by The Financial Advisory Group, the client and/or their other advisors that maintain trading authority, and not The Financial Advisory Group, shall be exclusively responsible for the investment performance of the Excluded Assets. The Financial Advisory Group’s service relative to the Excluded Assets is limited to reporting and non-discretionary consulting services only, which does not include investment implementation. The Financial Advisory Group does not have trading authority for the Excluded Assets. As such, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not The Financial Advisory Group, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The Financial Advisory Group shall not

be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that The Financial Advisory Group provide discretionary investment management services (whereby The Financial Advisory Group would have trading authority) with respect to the Excluded Assets, the client may engage The Financial Advisory Group to do so pursuant to the terms and conditions of the Investment Advisory Agreement between The Financial Advisory Group and the client. The eMoney platform provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by The Financial Advisory Group. Furthermore, The Financial Advisory Group 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 Financial Advisory Group’s assistance or oversight. Use of Mutual Funds and Exchange Traded Funds. While The Financial Advisory Group may allocate investment assets to mutual funds and exchange traded funds (“ETFs”) that are not available directly to the public, The Financial Advisory Group may also allocate investment assets to publicly available mutual funds and ETFs that the client could purchase without engaging The Financial Advisory Group as an investment adviser. However, if a client or prospective client determines to purchase publicly available mutual funds or ETFs without engaging The Financial Advisory Group as an investment adviser, the client or prospective client would not receive the benefit of The Financial Advisory Group’s initial and ongoing investment advisory services with respect to management of the asset. Cash Positions. The Financial Advisory Group continues to treat cash as an asset class. As such, unless determined to the contrary by The Financial Advisory Group, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating The Financial Advisory Group’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), The Financial Advisory Group 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, The Financial Advisory Group’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, 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. The above does not apply to the cash component maintained within a Registrant 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. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Registrant unmanaged accounts. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Registrant does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, the Registrant, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, the Registrant will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. The Registrant does not recommend or advocate the purchase of, or investment in, cryptocurrencies. The Registrant considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Portfolio Activity. The Financial Advisory Group has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, The Financial Advisory Group 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, 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 The Financial Advisory Group determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. The Practice Advisory Group, LLC. The Practice Advisory Group, LLC (“Practice Advisory Group”) is a physician practice management company that provides non- investment related administrative services to medical and dental practices. Mr. Alphonso, the principal owner of Financial Advisory Group Holdings and an investment advisory representative of The Financial Advisory Group, is a 50% owner of Practice Advisory Group. Certain clients of The Financial Advisory Group may also have an ownership interest in Practice Advisory Group and/or utilize the administrative services provided by Practice Advisory Group. No client is under any obligation to invest in or engage the services of Practice Advisory Group. Client Obligations. In performing its services, The Financial Advisory Group shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify The Financial Advisory Group if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising The Financial Advisory Group’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks The Financial Advisory Group and its third-party service providers use to provide services to The Financial Advisory Group’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in The Financial Advisory Group’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and The Financial Advisory Group 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 The Financial Advisory Group has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that The Financial Advisory Group 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. Disclosure Statement. A copy of The Financial Advisory Group’s written Brochure and Client Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Management Agreement and/or Financial Planning Agreement. C. The Financial Advisory Group 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 Financial Advisory Group 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 Financial Advisory Group’s services. D. The Financial Advisory Group does not participate in a wrap fee program. E. As of December 31, 2023, The Financial Advisory Group had about $1,238,112,419 in assets under management on a discretionary basis.