Firm Description InvesTrust Consulting, LLC (“We” or “Firm”) is an SEC-registered investment advisor that has its principal place of business located in Oklahoma City, OK. InvesTrust Consulting, LLC is a wholly owned subsidiary of InvesTrust Wealth Management, LLC, founded in 1985. InvesTrust Wealth Management, LLC is owned 100% by American Fidelity Corporation. American Fidelity Corporation is a subsidiary of Cameron Enterprises, LP, which is a subsidiary of Cameron Associates, Inc. Cameron Associates, Inc. is owned by the Trusts of William Cameron and Lynda Cameron. Types of Advisory Services InvesTrust Consulting is an independent consulting firm that offers customized investment advisory services. Firm clients are foundations, endowments, pension plans, trusts, high-net worth individuals, insurance companies, and corporations. We provide advisory services on a discretionary and non- discretionary basis as set forth in the client’s advisory agreement. As a fiduciary, the Firm offers objective advice, accepts no commissions, and has no proprietary products to sell. InvesTrust Consulting’s services include, but are not limited to, the following:
• Investment Consulting Services  Establishment of Investment Objectives, Goals, and Restrictions  Asset allocation Studies/Services  Independent Performance Measurement/Aggregation  Comprehensive Quarterly Reporting  Manager Communication, Selection and Monitoring
• Asset Management Services
• Retirement Plan and Pension Consulting Services  Preparation of an Investment Policy Statement (IPS)  Monitoring of Investment Performance  Educational Support to the Plan Sponsor or Committee
• Macro-Economic Analysis
• Customized/Special Projects
• Bookkeeping (limited basis) Not all clients receive each of the services described above. The services we provide to each client are based on mutually agreed upon engagements with the client and tailored to fit their goals and objectives. Our investment recommendations are not limited to any specific product or service. Clients may impose restrictions on investing in certain types of securities, and we will refine our recommendations accordingly. We are a fee only advisor. Investment Consulting Services We advise across a broad range of asset classes that include separately managed accounts (investment managers), limited partnerships, commingled vehicles, mutual funds, and ETFs. Asset classes include domestic and international equites, fixed income, and alternative investments (private equity, REITs, hedge funds). Our process begins with discussions with the client and gathering data to determine their investment objectives, time horizon and risk tolerance. This knowledge guides us to a strategy that best fits the client’s needs and long-term goals in accordance with their investment policy. The chart below illustrates this investment process. Consulting services are provided on a non-discretionary basis. In performing consulting services, the Firm relies on information received from the client or the client’s other professionals (attorney, accountant, custodian, etc.), which is deemed to be reliable. The client is under no obligation to accept or approve any of the recommendations made by InvesTrust Consulting under a consulting agreement or to engage in the services of any such recommended professional. The client retains ultimate discretion over all decisions and is free to accept or reject any of InvesTrust Consulting’s recommendations. The implementation of the Firm’s recommendations, including the purchase or sale of investments is solely at the discretion of the client’s custodian or third-party managers. Clients are advised that it remains their responsibility to promptly notify us if there is any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the previous recommendations and/or services made by InvesTrust Consulting. Asset Allocation Studies/Services Our Firm aids in setting objectives and allocating assets to clients who request these services. Through personal discussions with the client, the client’s goals and objectives can be established. We provide asset allocation services to clients on a discretionary and non-discretionary basis, providing the client with continuous and on-going supervision over their assets. When providing these services on a discretionary basis, InvesTrust Consulting will direct the client’s custodian to execute trades when allocating assets among various assets or assisting plan sponsors with monthly distributions without prior consultation with Discovery Identify Objectives Develop Strategy Selection & Implementation Monitor & Review Five Step Process the client. While these services are provided without prior client consultation, when requested, we notify the client or their designated contact informing them of any action implemented. We also provide these services on a non-discretionary basis by providing a recommendation to our client when a re-allocation of assets is needed, and it is up to the client to implement the changes. Account supervision is guided by the client’s stated investment policy. Recommendations to a client are designed to be appropriate for the needs of the client and consistent with the client’s investment objectives, time horizon, liquidity needs, and risk tolerance, among other considerations. Clients may impose restrictions on investing in certain securities, types of securities, or industry sectors. Clients may also request that we not implement all of our recommended changes to their portfolios. Performance Verification and Reporting We provide reports, at least quarterly, concerning the client’s portfolio allocation and performance. Reports are customized for each client’s portfolio. InvesTrust Consulting relies on information received from the client or the client’s other professionals (attorney, accountant, custodian, etc.) deemed to be reliable. After portfolio performance is calculated, the client is provided with an aggregate report of the investments under advisement which reports or verifies the performance reported by the investment managers and fund companies. Investment reports contain data that includes but is not limited to trailing and calendar performance, allocation, risk statistics, attribution, and underlying holdings, where appropriate. Manager Communication, Selection and Monitoring Selection and monitoring services consist of analyzing, monitoring, and recommending third-party investment managers who manage portfolios in what are commonly referred to as “separately managed accounts”. Our research/analysis process is completed as described in Item 8. The investment managers may manage funds or “funds of funds” which hold various investment types or alternative investments on the behalf of the client. We review reports provided by the managers and provide ongoing due diligence of the managers acting as an intermediary (including hiring and firing), between the client and third-party investment advisor, as needed. For a full description of the services offered by the investment managers/funds, clients should refer to the investment manager’s Firm brochure, advisory contract and/or other disclosure documents. We are available to

meet with clients at least quarterly, or as determined by the client, to review their portfolio and investment managers selected. Other Investment-Related Comments InvesTrust Consulting utilizes a team-based approach to client service. Each client will be assigned a primary consultant that is responsible for coordinating the relationship and understanding the client’s specific needs. The investment services/products received by one client vary from the products/services received by another client. Factors such as risk tolerance, time horizon, investment objectives, account size, other assets, etc. will affect the services received and the fees charged. Asset Management Services We offer asset management services on a discretionary basis, providing the client with continuous and on- going supervision over their assets. This means we continuously monitor the client’s account and direct the custodian or third-party manager to place trades when necessary. For clients where InvesTrust Consulting has discretionary authority, the Firm has the authority to direct the client’s custodian or investment manager to implement recommended changes without prior consultation with the client, in accordance with the client’s Investment Policy Statement. For clients where InvesTrust Consulting has limited discretion and acts an intermediary, the Firm has the authority to direct the client’s custodian and/or investment manager to implement recommendations, raise cash for distributions or complete transactions for the purpose of rebalancing, but only after such recommendations are accepted by the client. Clients may impose restrictions on investing in certain types of securities, and we will refine our recommendations accordingly. Retirement Plan and Pension Consulting Services The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For these services InvesTrust Consulting will be considered a fiduciary under ERISA. InvesTrust Consulting will provide 3(21) fiduciary services to 401(k), 403(b), and other qualified and non-qualified deferred compensation plans on a non-discretionary basis only. Services are tailored to client needs. As mutually agreed, upon with the client, our Firm will assist with the development of an investment policy statement, recommendation of investment vehicles or a plan “line-up”, monitoring of investment performance, recommendations for fund replacement, due diligence research, comprehensive reporting and plan sponsor education. For example, InvesTrust Consulting will act as a co-fiduciary when providing non-discretionary investment advice to Plan fiduciaries or Plan Sponsors by providing investment monitoring and recommendations on a regular basis with the understanding the advice will serve as the primary basis for investment decision related to the plan. InvesTrust Consulting will provide advisory services as a co-fiduciary to defined benefit plans. Services are tailored to client needs. As mutually agreed, upon with the client, our Firm will help with the development of an investment policy statement, recommendation of investment vehicles or a plan “line- up”, monitoring of investment performance, monitoring and recommendation of investment options, rebalancing per the Investment Policy guidelines, comprehensive reporting and other general pension plan consulting. On a limited basis, we provide discretionary asset allocation services (as described on page 4) to our pension plan clients to assist with allocating contributions and distributions, as requested. Preparation of an Investment Policy Statement (an ''IPS'') We will assist in the preparation of a written Investment Policy Statement (“IPS”) with the client detailing investment requirements and restrictions, as appropriate. We will also assist clients in the development of an appropriate investment strategy reflecting the client’s stated investment objectives. Monitoring of Investment Performance Investments are monitored on a regular basis for adherence to the Investment Policy Statement. Recommendations for changes to the investment selection or Investment Policy are provided to the plan fiduciaries, as needed. Where third-party investment managers are used, we will provide ongoing due diligence of the managers and act as an intermediary between the client and third-party investment advisor. General Retirement and Pension Plan Consulting We provide periodic educational support regarding general investment principles to plan fiduciaries, as needed or requested. Plan fiduciaries may engage our Firm to provide a review of their retirement or pension plans. Areas reviewed include but are not limited to items such as fiduciary liability, investment policy statement, plan investments and administrative fees. Macro-Economic Analysis Our Firm presents to clients, quarterly economic analysis that provides general information on various financial topics including, but not limited to, pension data, inflation, unemployment, housing growth, and other broad economic data. This service is provided to clients at their request and is not intended to meet the objectives or needs of any specific individual/institution. Bookkeeping and Other Services Bookkeeping services are available to clients, on a limited basis and is based on the information provided by the client. To meet the unique needs of each client, our Firm may offer other financial-related consulting services, research and recommendations not described in this Brochure. Publication of Periodicals or Newsletters Our Firm periodically publishes newsletters providing general information on various broad economic topics. The newsletter information is purchased from Forefield, a third-party newsletter provider. These newsletters and the information provided in them are not intended to meet the objectives or needs of any specific individual. Our newsletters are distributed at no charge. Tailored Relationships InvesTrust Consulting offers tailored services to the specific needs of each individual client. Agreements may not be assigned without client consent. Our agreements can be customized to the specific needs of the client, such as:  The amount and types of reporting to be provided, including frequency.  The frequency of face-to-face meetings.  Providing for discretionary services: allowing our Firm to direct the client’s custodian and/or investment managers to make and execute trades when allocating assets among various assets, per the client’s investment policy.  Other specific needs or services can be described. Either InvesTrust Consulting or the client may terminate the agreement with 30 days written notice. InvesTrust Consulting provides, at least quarterly, written reports evaluating our clients’ asset allocation, portfolio performance, and investment strategy. InvesTrust Consulting does not participate in any wrap fee programs. Assets under Advisement As of 12/31/2023, InvesTrust Consulting advises on $2,082,819,658 in total client assets of which, $34,133,303 is advised on a discretionary basis, and $2,048,686,355 is advised on a non-discretionary basis. Of the total, $ 562,737,101 is reported as “regulatory assets under management.”