Roehl & Yi Investment Advisors, LLC, principally owned by Thomas H. Roehl and Jayman F. Yi, is a wealth management firm that has been serving its clients since 1998. The Firm’s wealth management services include financial planning and investment management. Based on the fundamental values of teamwork, integrity, stability and professionalism, the Firm believes its clients are entitled to personal attention and the best possible counsel from investment professionals who take pride in the quality of their work. As of December 31, 2023, Roehl & Yi had the following assets under management and assets under advisement: Assets Under Management Discretionary $797,753,588 Non-Discretionary $12,036,315 Assets Under Advisement $660,492,675 TOTAL $1,407,282,578 Assets under advisement includes assets over which the Firm provides various consulting services. This includes ongoing services to qualified and non-qualified retirement plans and their fiduciaries, as well as initial and ongoing services related to client illiquid holdings, including privately placed securities. Prior to rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Roehl & Yi setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). While this brochure generally describes the business of Roehl & Yi, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Roehl & Yi’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Roehl & Yi offers clients a range of financial planning and consulting, which may include any or all of the following functions:
• Investment Consulting
• Retirement Planning
• Estate Planning
• Charitable Giving
• Education Planning
• Life Planning
• Asset Allocation
• Investment Banking
• Distribution Planning
• Insurance Needs Analysis
• Family Legacy Planning
• Elder Planning Page 5 © MarketCounsel 2024 While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a wealth management engagement (as described below). In performing these services, Roehl & Yi is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. Roehl & Yi may recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Roehl & Yi or its supervised persons to provide additional fee- based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Roehl & Yi under a financial planning engagement or to engage the services of any such recommended professionals, including Roehl & Yi itself or its supervised persons. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Roehl & Yi’s previous recommendations and/or services. Retirement Plan Consulting Services Roehl & Yi provides various consulting services to qualified retirement plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:
• Investment Management and Review
• Plan Fee and Cost Analysis
• Retirement Plan Committee Consultation
• Executive Planning and Benefits
• Benchmarking and Evaluation
• Participant Education
• Fiduciary and Compliance As disclosed in the Agreement, certain of the foregoing services are provided by Roehl & Yi as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Roehl & Yi’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Wealth Management Services

Roehl & Yi provides clients with wealth management services which generally include a broad range of financial planning and consulting as well as discretionary management of investment portfolios. Page 6 © MarketCounsel 2024 Roehl & Yi primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and independent investment managers (“Independent Managers”), as well as the securities components of variable annuities and variable life insurance contracts, in accordance with the investment objectives of its individual clients. Where appropriate, the Firm also provides advice about any type of legacy position or other investments held in client portfolios. In addition, Roehl & Yi may also recommend that certain eligible clients invest in privately placed securities, which may include debt, equity, and/or interests in pooled investment vehicles (e.g., REITs or hedge funds). Clients also engage Roehl & Yi to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Roehl & Yi directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Roehl & Yi tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Roehl & Yi consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify Roehl & Yi if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Roehl & Yi determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Sponsor / Manager of Wrap Program Roehl & Yi is the sponsor and manager of the Roehl & Yi Wrap Fee Program (the “Program”), an arrangement where most brokerage commissions and transaction costs are absorbed by the Firm. Accounts managed through the Program are done so in substantially the same manner as those managed under a non-wrap arrangement. Participants in the Program may pay a higher aggregate fee than if investment management and brokerage services are purchased separately. Additional information about the Program is available in Roehl & Yi’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV (“Wrap Brochure”). Use of Independent Managers As mentioned above, where appropriate, the Firm recommends certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either Roehl & Yi or the client. In addition to this brochure, clients also receive the written Page 7 © MarketCounsel 2024 disclosure documents of the designated Independent Managers engaged to manage their assets. Roehl & Yi does not receive compensation from any such Independent Managers. Roehl & Yi evaluates various information about the Independent Managers it recommends to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Roehl & Yi also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Roehl & Yi continues to provide services relative to recommendation of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Roehl & Yi seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.