American Financial Advisors, Inc. (hereinafter referred to as “American Financial”) is an investment advisory firm offering a variety of advisory services customized to your individual needs. A. American Financial was incorporated in 1989. As of January 2020, Matthew Boyce and William Mertes own 50% each of American Financial. Karen S. Torres is the Chief Compliance Officer of American Financial Advisors, Inc. B. American Financial’s primary service is asset management. Additionally, American Financial offers financial planning and consulting services. The services are more fully described below. C. American Financial tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. American Financial will gather various information from you through the use of an Investor Questionnaire and Risk Tolerance Questionnaire. Additionally, an Investment Policy Statement (“IPS”) will be created specific to your managed account. The information gathered by American Financial will assist American Financial to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, American Financial will gather various financial information and history from you including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by American Financial in order to provide the investment advisory services requested. D. American Financial does not participate in wrap fee programs. E. As of December 31, 2023, we have $0 in discretionary assets under management and $887,197,372 in non-discretionary assets under management. Asset Management Services Investment strategies are consistent for all clients and are determined by the Investment Committee which is comprised of Matthew Boyce, CFP®, William Mertes, CFA, and Mark Bras, CFP®, CDFA®. Data regarding each client is maintained in a Client Relationship Management system that is accessible by all team members. This CRM is password protected and on-line. Individual Advisory Representatives are not permitted to trade client accounts. All trading is done by Matt Boyce and Bill Mertes who have access to the TRX trading system, which does all the trading through Charles Schwab. American Financial does not recommend individual stocks or bonds. Implementation of client Investment Policy Statements is done through no-load asset class and index funds. American Financial Advisors provides you with a formal, written Investment Policy Statement (IPS) that is based on your answers to an Investment Policy Statement questionnaire you will be asked to complete. This formal written Investment Policy Statement (IPS) will outline your objectives, time frame, risk tolerance, and asset allocation. This document will control the investment of your funds and can be reviewed if your personal situation changes. The Investment Policy Statement will outline to you the allocation that will be implemented for you and how the account will be managed. To initiate the management services, you must enter into the AFAdvantage Account Agreement. American Financial’s Investment Sub-Committee comprised of William Mertes, CFA and Matthew Boyce, CFP, have designed a group of model portfolios with a goal to address various risk profiles, investment objectives and investment goals. Therefore, your portfolio may be invested identically to or similarly to other clients. Generally, after analysis of the your situation, American Financial will assist you to determine one or more model portfolios in which to allocate your investable assets for management. After evaluating your information gathered by American Financial, American Financial will determine which of its model portfolios would be most suitable for you. From there, American Financial customizes your portfolio allocation taking into consideration your limitations or restrictions, and your financial situation, goals and objectives. You are advised that transactions in the account, account reallocations, and rebalancing may trigger taxable events, with the exception of IRA accounts, 403(b) accounts, and other qualified retirement accounts. American Financial provides continuous and ongoing management of your account. American Financial manages your accounts on a nondiscretionary basis. Therefore, American Financial will not make changes to the allocation of your account without prior consultation with you and your expressed agreement. The allocation of your account will not be changed unless you agree and sign a revised written asset allocation change form. However, American Financial will periodically rebalance your account to bring the account back into alignment with the original allocation. This is not considered discretionary authority and is done to maintain your agreed upon allocation. Financial Planning and Consulting

Services American Financial offers a wide array of financial services from individual consultation on specific topics such as debt reduction to the preparation and implementation of a comprehensive financial plan including insurance planning, education planning, retirement strategies, and estate considerations. Additionally, American Financial can assist corporate clients by conducting educational programs for the participants in qualified retirement plans (401k) regarding the plan’s provisions and options. Plans are based on your financial situation at the time and are based on financial information disclosed by you to American Financial. You are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance. American Financial cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, you must continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify American Financial promptly of the changes. You are advised that the advice offered by American Financial may be limited and is not meant to be comprehensive. Therefore, you may need to seek the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through American Financial or Advisory Representatives. American Financial Advisors, Inc. does not sell insurance products nor does it provide legal or tax advice. Services to 401(k) Plan Sponsors American Financial Advisors, Inc. as an investment advisor to 401(k) Plan Sponsors (“The Client”) performs the following Fiduciary Services: (i) Provides non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client shall have the final decision –making authority regarding the initial selection, retention, removal and addition of investment options. (ii) Assists the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. (iii) Assists the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. (iv) Assists in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. (v) Meets with the Client on a periodic basis to discuss the reports and the investment recommendations. (vi) Provides non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who re automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 401(c)(5). Non-Fiduciary Services: American Financial Advisors, Inc. will perform the following non-fiduciary services: (i) Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that Adviser’s assistance in participant investment education shall be consistent with and within the scope of (d) (i.e. the definition of investment education) of Department of Labor Interpretive Bulletin 96-1. As such, the Adviser is not providing fiduciary advice (as defined in ERISA) to the participants. Adviser shall not provide investment advice concerning the prudence of any investment option of combination of investment options for a particular participant or beneficiary under the Plan. (ii) Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Adviser may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between the Adviser and the Client. General Information You are advised the investment recommendations and advice offered by American Financial are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform American Financial promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify American Financial of any such changes could result in investment recommendations not meeting your needs.