A. The Welch Group is a limited liability company formed on September 4, 1998 in State of Alabama. The Welch Group became registered as an Investment Adviser in February 1999. The Welch Group is principally owned by Stewart H. Welch, III, who is The Welch Group's Founder. On January l, 2018, pursuant to an internal merger between two affiliated entities, both under common control ownership by Stewart H. Welch (the Founder), Welch Investments, LLC (SEC File Number: 801-56718) merged into The Welch Group, LLC. As a result of the merger, all future services are provided by The Welch Group. As discussed below, depending upon the terms of the engagement, The Welch Group can provide its clients (i.e. individuals, pension and profit sharing plans, trusts, and business entities) with investment management services, financial analysis services, and, to the extent engaged to do so and specifically requested by a client, financial planning and related consulting services. PORTFOLIO DESIGN/MANAGEMENT In the event the client desires, the client can engage The Welch Group to design an investment portfolio and provide ongoing corresponding investment management services on a fee-only basis. To the extent provided in the written agreement between the Welch Group and the client, The Welch Group's annual investment advisory fee shall include, to the extent specifically requested by the client, financial planning and consulting services (generally subject to a $3 million assets under management minimum-see Item 5 below). The Welch Group's annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under The Welch Group's management, generally between 0.30% and 1.20%. To commence the investment advisory process, The Welch Group will ascertain each client's investment objective(s) and then allocate the client's assets consistent with the client's designated investment objective(s). Once allocated, The Welch Group provides ongoing supervision of the account(s). Before engaging The Welch Group to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Please Note: The Welch Group believes that it is important for the client to address financial planning issues on an ongoing basis. Registrant's advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Registrant. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent it is specifically requested to do so, The Welch Group may provide its clients with a broad range of financial analysis and consulting services (including non-investment-related matters) on a stand-alone separate fee basis. The Welch Group's planning and consulting fees are negotiable, but generally range up to $3,500 on a fixed fee basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s).Prior to engaging The Welch Group to provide financial analysis and/or consulting services, the client will generally be required to enter into a Financial/ Advisory Agreement with The Welch Group setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to The Welch Group commencing services. Please Note: The Welch Group does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, The Welch Group does not prepare estate planning or any other legal documents, tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). No client is under any obligation to utilize the services of any such recommended professional. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. If, and when The Welch Group is involved in a specific matter (i.e. estate planning, insurance, accounting-related engagement, etc.), it is the engaged licensed professionals (i.e. attorney, accountant, insurance agent, etc.), and not The Welch Group, that is responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify The Welch Group if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising The Welch Group’s previous recommendations and/or services. REPORTING SERVICES AND AGGREGATE DATA STORAGE The Welch Group offers investment data storage and 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 Welch Group (the "Excluded Assets "). Should the client desire reporting services, the client acknowledges and understands that with respect to the Excluded Assets, The Welch Group's service is limited to reporting and data storage services only and does not include investment management, review, or monitoring services, nor investment recommendations or advice. As such, the client, and not The Welch Group, shall be exclusively responsible for the investment performance of the Excluded Assets. In the event the client desires that The Welch Group provide investment management services with respect to the Excluded Assets, the client may engage The Welch Group to do so for a separate and additional fee in accordance with the fee schedule set forth above. MISCELLANEOUS Variable Annuity Sub-divisions. The Welch Group may also render discretionary investment management services to clients relative to variable annuity products that they may own. In so doing, The Welch Group directs the allocation of client assets among the various mutual fund sub-divisions which comprise the variable annuity product based upon the investment objectives of the client. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: As indicated above, to the extent requested by a client, we may provide financial planning and related consulting services regarding non-investment- related matters, such as estate planning, tax planning, insurance, etc. Please Note: The Welch Group does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as legal, accounting, or insurance services. Accordingly, The Welch Group does not prepare estate planning or any other legal documents, tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). No client is under any obligation to utilize the services of any such recommended professional. Please Also Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. If, and when The Welch Group is involved in a specific matter (i.e. estate planning, insurance, accounting-related engagement, etc.), it is the engaged licensed professionals (i.e. attorney, accountant, insurance agent, etc.), and not The Welch Group, that is responsible for the quality and competency of the services provided. Neither The Welch 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 Welch Group does not monitor a client's financial plan, and it is the client's responsibility to revisit the financial plan with us, if desired. Retirement Plan 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) rollover 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 Welch Group recommends that a client roll over their retirement plan assets into an account to be managed by Welch Group, such a recommendation creates a conflict of interest if The Welch Group will earn new (or increase its current) compensation as a result of the rollover. If The Welch Group provides a recommendation as to whether a client should engage

in a rollover or not (whether it is from an employer’s plan or an existing IRA), The Welch 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 Welch Group, whether it is from an employer’s plan or an existing IRA. ANY QUESTIONS: The Welch Group's Compliance Officer, Brent Gillis, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Margin Accounts: Risks/Conflict of Interest. The Welch Group does not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will magnify both account gains and losses. Should a client determine to use margin, The Welch Group will include the entire market value of the margined assets when computing its advisory fee. Accordingly, The Welch Group’s fee shall be based upon a higher margined account value, resulting in The Welch Group earning a correspondingly higher advisory fee. As a result, the potential of conflict of interest arises since The Welch Group may have an economic disincentive to recommend that the client terminate the use of margin. Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. ANY QUESTIONS: Our Chief Compliance Officer, Brent Gillis, remains available to address any questions that a client or prospective client may have regarding the use of margin. . Use of Mutual Funds and Exchange Traded Funds. While The Welch Group may recommend allocating investment assets to mutual funds and exchange traded funds that are not available directly to the public, The Welch Group may also recommend that clients allocate investment assets to publicly-available mutual funds or exchange traded funds that the client could obtain without engaging The Welch Group as an investment advisor. However, if a client or prospective client determines to allocate investment assets to publicly available mutual funds or exchange traded funds without engaging The Welch Group as an investment advisor, the client or prospective client would not receive the benefit of The Welch Group's initial and ongoing investment advisory services. Please Note: In addition to The Welch Group's investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, The Welch Group shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless The Welch Group 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, 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. Cybersecurity Risk. The information technology systems and networks that The Welch Group and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and The Welch 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 Welch Group has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that The Welch 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. Custodian Charges-Additional Fees: As discussed at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, The Welch Group generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker- dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions, others do). Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future). These fees/charges are in addition to The Welch Group’s investment advisory fee at Item 5 below. The Welch Group does not receive any portion of these fees/charges. ANY QUESTIONS: The Welch Group's Chief Compliance Officer, Brent Gillis, remains available to address any questions that a client or prospective client may have regarding the above. ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. The Welch Group may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, The Welch Group will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 ("ERISA"). The Welch Group will generally provide services on an "assets under management" fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm.
• Client Retirement Plan Assets. If requested to do so, The Welch Group shall provide investment advisory services relative to the client's 401(k) plan assets. In such event, The Welch Group shall recommend that the client allocate the retirement account assets among the investment options available on the 401(k) platform. The Welch Group shall be limited to making recommendations regarding the allocation of the assets among the investment alternatives available through the plan. The Welch Group will not receive any communications from the plan sponsor or custodian, and it shall remain the client's exclusive obligation to notify The Welch Group of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Portfolio Activity. The Welch Group has a fiduciary duty to provide services consistent with the client's best interest. As part of its investment advisory services, The Welch 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, market conditions, 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 Welch Group determines that changes to a client's portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by The Welch Group will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in