This Disclosure document is being offered to you by Tillman Hartley LLC (“Tillman Hartley” or “Firm”). It discloses information about our services and how those services are made available to you, the client. We are an investment management Firm located in Denver, CO. Tillman Hartley provides personalized, confidential financial planning, and investment management to individuals, plans, trusts, estates, charitable organizations, and small businesses. Our Firm was founded in 1999 as a registered investment advisor and is owned by Michael D. Lambert, Gary W. Lutes, Jr., Kevin R. Schwall, and Benjamin R. Cannon. INVESTMENT AND WEALTH MANAGEMENT AND SUPE RVISION SERVICES Our Firm manages advisory accounts on a discretionary basis. Advice is provided through consultation with you, the client, and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Once we have determined your profile and investment plan, we will execute the day-to-day transactions without seeking your prior consent. We determine your investment objectives, time horizons, risk tolerance, and liquidity needs during our initial discussions. As appropriate, we also review your prior investment history, family composition, and background. Based on your needs, we develop a personal profile, determine the types of investments to be included in your portfolio, and create an Investment Policy Statement (“IPS”). We will use your customized IPS to provide ongoing investment management services. Account supervision is guided by the written IPS and reviewed on at least an annual basis. We primarily allocate client assets among individual stocks, bonds, exchange traded funds (“ETFs”), US Government Treasuries, municipal bonds, corporate bonds, futures and options, alternative investments, mutual funds, cash, and cash equivalents, all of which are considered asset allocation categories for the client’s investment strategy. We tailor our advisory services to meet our clients' needs and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing instructions to refrain from investing in limited amounts of securities. It is the client’s obligation to notify us immediately if circumstances have changed with respect to your goals and/or changes in your personal financial condition. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain capital market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Clients may engage us to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, 529 Plans, and assets held in employer-sponsored retirement plans. In these situations, Tillman Hartley directs or recommends allocating 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. FAMILY BOARD OF DIRECTORS SERVICES Tillman Hartley provides Family Board of Directors™ services, which it pioneered and trademarked. Family Board of Directors™ services are recommended when a family's assets and family-related entities (such as charitable trusts and foundations) reach a complexity level where a team of professionals is helpful. Tillman Hartley arranges a team of professionals who meet (in person or by teleconference) quarterly with the client and invited family members. APRIL 2024 | PAGE 5 For families with total assets over $40,000,000, Tillman Hartley collects extensive information about the clients family's personal and business interests and develops a comprehensive multi-generational plan to accomplish the client's goals and objectives within the family. A Family Board of Directors™ is created consisting of clients, family members, other professionals, and Tillman Hartley Partners. The purpose of the Family Board of Directors™ is to maintain and monitor the plans and strategies developed for the client’s family. As the governing instruments are formed, Tillman Hartley will monitor these instruments' terms and conditions, including oversight of tax and information return filing. Tillman Hartley provides for the development of an appropriate Investment Policy Statement. Tillman Hartley organizes, implements, and administers the family financial structure in accordance with the family's unique set of values, goals, and objectives. To administer the Family Board of Directors™, Tillman Hartley oversees the establishment of accounts and advisory relationships, monitors these for Investment Policy Statement compliance; establishes appropriate benchmarks for investment performance measurement and provides for adaptation to changing conditions and family objectives; and maintains documents, records, comprehensive financial information, and current information about investment strategies and tax matters. Through the Wealth Planning process, the Tillman Hartley team strives to engage our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With each family's unique goals and circumstances in mind, the Tillman Hartley team will offer wealth planning ideas and strategies to address the client's holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and family legacy objectives. Computer modeling is used to test financial and economic strategies. Our team partners with our client's other advisors (CPA, estate attorney, insurance broker, etc.) to ensure all parties' coordinated effort toward their stated goals. Such services include various reports on specific goals and objectives, general investment and/or planning recommendations, guidance to outside assets, and periodic updates. SUB-ADVISORY SERVICES Tillman Hartley may determine use of a Sub-advisor is appropriate for the strategy of managing a client’s account. Tillman Hartley has established relationships with an independent registered investment advisor (“Sub-advisor”) to carry out Sub-advisor services for certain clients deemed appropriate. Tillman Hartley maintains discretionary authority over the client’s assets and use of the Sub-advisor. In all cases, the Sub- advisor receives prior approval from Tillman Hartley of all trades made in the client accounts. Prior to utilizing a Sub-advisor for a portion of a client’s portfolio, our Firm will provide the initial due diligence and complete ongoing reviews of the management. In order to assist in the selection of a Sub- advisor, our Firm will gather client information

pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. LEGACY MANAGEMENT SERVICES Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit or restrict our trading in these positions. FINANCIAL PLANNING SERVICES Our Firm offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We provide full written financial plans, which may address one or several topics: APRIL 2024 | PAGE 6 Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios, and Allocation Review. Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to implement our financial planning recommendations. Our financial planning services do not involve implementing transactions on your behalf nor include active and ongoing monitoring or management of your investments or accounts. The Client must execute a separate written agreement if the Client elects to implement any of our investment recommendations through our Firm or retain our Firm to monitor and manage investments actively. CONSULTING SERVICES In consultation engagements, you will be required to select your own investment managers, custodian and/or insurance companies to implement consulting recommendations. If your needs include brokerage and/or other financial services, we will recommend using one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals. You must independently evaluate these Firms before opening an account or transacting business, and you have the right to effect business through any Firm you choose. On more than an occasional basis, Tillman Hartley gives clients advice on matters not involving securities, such as financial planning matters, taxation issues, and trust services that may include estate planning. RETIREMENT PLAN SERVICES When applicable, our Firm accepts its appointment as an “Investment Manager” within the meaning of Section 3(38) of ERISA (but only concerning those plan assets constituting the portfolio models). We will not have any authority or responsibility in the administration of the Plan (including the selection of portfolio models for the Plan) or interpretation of any Plan document. Our Firm agrees it will act in a manner consistent with the requirements of a fiduciary under ERISA and the Code. We further agree that all investment management powers, duties, and responsibilities relating to the portfolio shall be exercised exclusively by our Firm per the Plan. DISCLOSURE REGARDING INVESTMENT ADVICE & ROLLOVER RECOMMENDATIONS We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect 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). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan APRIL 2024 | PAGE 7 sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. CLIENT OBJECTIVES & RESTRICTIONS Our Firm tailors our investment management and advisory services continuously to meet the needs of our Clients. We seek to ensure Client portfolios are managed consistently with those needs and objectives in mind. We meet with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to managing their portfolios. Clients may impose reasonable restrictions on managing the accounts if the conditions do not impact the performance of a management strategy. WRAP FEE PROGRAM Typically, we do not offer or sponsor a wrap fee program. However, we provide services as part of a legacy Wrap Fee Program. Under the legacy Wrap Fee Program, they will receive investment advisory services, the execution of securities brokerage transactions, custody, and reporting services for a single specified fee. The terms and conditions of a wrap program engagement are more fully discussed in our Wrap Fee Program Brochure. The legacy “wrap” fee might be more or less than the fees and commissions charged by other advisory Firms, third-party managers, and brokerage firms if the services were acquired separately. The factors that bear upon the cost of services are the size of the account, type of transaction, and whether trades are placed through a brokerage firm other than the custodian resulting in per trade commission being charged. ASSETS Tillman Hartley classifies assets it manages as Assets Under Management and Assets Under Advisement. As of December 31, 2023, Tillman Hartley managed approximately $569,548,000 in Discretionary Assets under Management and approximately $62,092,000 in Assets Under Advisement.