A. Background. Spectrum Investment Advisors, Inc. (“SIA”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). SIA, formerly known as Christiansen Investments, Inc., began providing advisory services in November 1999. SIA specializes in assisting institutional clients in establishing 401(k) pension, profit sharing plans and other retirement plans and in monitoring investments in the plans. It also provides wealth management services to individuals and other clients. SIA is principally owned by Jonathan J. Marshall and other minority shareholders including James F. Marshall. SIA does not control any other firm, nor is it under common control with any other firm. B. Services Plan Consulting Services SIA’s Plan Consulting Services include: 1. Policy Formation and Financial Summaries. A defined investment policy is the foundation on which the administration and management of institutional plan assets are built. To properly review investment performance, it must be measured against specific goals and objectives set forth in a client’s written policy statement. SIA helps clients prepare their statement to the extent clients ask for such assistance. To develop policies and objectives for an institutional account, an SIA representative first meets with the client to obtain background information about the client, the client’s investment objectives, and the composition of the client’s portfolio, or expected portfolio, and investment restrictions. An analysis of that information is then made and, if requested by a client, SIA prepares an investment policy statement for the client’s review and approval. The statement is the framework for the management of plan assets and establishes objectives, risk tolerances, procedural guidelines, performance criteria and performance evaluation requirements. 2. Selection of Investment Categories. Once an investment policy is developed, SIA assists a client by recommending various investment categories for the client’s retirement plan. SIA recommends no- load mutual funds from Fidelity Investments, T. Rowe Price, Vanguard, J.P. Morgan, American Funds and other mutual fund companies. In addition, SIA may recommend no-load group annuities which provide a menu of various sub-account investment choices within the annuity to plan sponsors. 3. Selection of Investment Choices and Asset Allocations. SIA will make recommendations concerning the investment choices available in no-load mutual funds, collective investment trusts (“CIT”) and no-load annuity sub-accounts. This process is designed to assist a client in determining the most appropriate mix of assets based on plan objectives and historical rates of return for the various classes of assets, including equities, bonds and cash. Other important factors considered are the client’s risk tolerance, and the impact of different types of investments in relation to the client’s disbursement and income requirements. Before making such recommendations, SIA reviews historical investment performance data by comparing various asset allocation mixes and their rates of return and risk level. When SIA is providing services as defined under Section 3(38) (“3(38) services”) of the Employee Retirement Income Security Act (“ERISA”) SIA has discretionary authority to determine investment choices. 4. Periodic Reviews and Meetings. On a quarterly basis, SIA monitors the performance of the client’s investment choices and overall performance of the account and provides periodic advice regarding possible changes to the investment selections. Such reviews are made no less frequently than annually. Meetings, scheduled by mutual agreement between the client and SIA, will be held to discuss investment performance and, if necessary, alternative investments. For some clients, as plan investment reviews are made, SIA provides advice regarding whether investment selections should be added or deleted. Such changes may be required if a particular investment is not meeting plan objectives. The final selections are always made by the client. When SIA is providing 3(38) services, SIA has discretionary authority to make investment decisions on behalf of the client. 5. Fiduciary Support. SIA provides fiduciary support to our Plan Consulting clients. SIA provides training and guidance on best practices, regulatory updates, documentation of plan decision, expenses analysis and benchmarking. 6. Written Reports. SIA provides clients with quarterly plan performance reports and semi-annual reports which summarizes plan performance against one or more market benchmarks and also appropriate investment style categories. 7. Meeting with Participants. If agreed upon with the Plan Consulting client, SIA representatives will meet one on one with individual participants. These meetings discuss appropriate asset allocations and contribution rates for investor objectives, as well as address other retirement plan topics or questions. SIA representatives make specific recommendations to participants in attempt to achieve a particular objective. SIA representatives may hold group meetings with plan participants to communicate universal topics such as updates to plan provisions or investment education. 8. Financial Wellness. As an expansion upon the meetings with participants described above, SIA may provide plan participants more specific guidance related to their overall financial wellness. These services allow greater attention to be given to other areas of financial needs or goals beyond retirement planning. Topics include maintaining a budget, debt reduction, personal savings and investment strategies, college savings, among other things. 9. Custodian and Administrator Selection. Because plan custodian and administrator selections are such an integral part of

establishing a plan and having it work, SIA will, if needed, assist clients by recommending appropriate custodians and plan trustees/administrators. To the extent that a client already has a custodian or plan administrator, SIA can, if requested to do so, evaluate the level of services being provided. All Plan Consulting Services advice is based on information provided by the client. It is the client's responsibility to be certain that SIA has current and accurate information. Spectrum Investor® Fund Monitoring Scorecard Services Our services begin by SIA reviewing a client’s existing mix of investments made available. SIA then provides the client with a Spectrum Investor® Fund Monitoring Scorecard™ report periodically, which includes the performance (1 year, 3 year, 5 year, 10 year) of each investment selected by the client; the aggregate historical performance of comparative securities for the same periods; a numerical performance ranking developed by SIA; and the years the client’s investment portfolio managers have served as managers. SIA also meets with representatives of the client, at times mutually acceptable to the client and SIA, to discuss the Scorecard report and investment performance of the client’s plan investment selections. SIA also advises a client of appropriate investment categories for the client’s retirement plan and about group annuities and mutual funds which are consistent with the investment categories selected by a client. Wealth Management Services SIA provides investment management services which involve making investments for a client’s account, including retirement accounts, based on the individual needs of the client and then managing the investments made. Services may include providing advice on the client’s overall asset allocation, including assets managed by external managers and making recommendations regarding the selection, retention and investment/performance of the other managers. After personal discussions in which goals and objectives based on a client's particular circumstances, objectives and restrictions are established, SIA develops a client's personal investment policy and creates and manages a portfolio based on that policy. SIA manages advisory accounts on a discretionary basis. This means that after obtaining discretionary authority in writing from a client, SIA will make purchases and sales as it deems necessary. Account supervision is guided by the stated objectives of each client (e. g., capital appreciation, growth, income, or growth and income). SIA generally creates a portfolio consisting of various no-load mutual funds and exchange-traded funds (ETFs). In addition, for certain clients based on their specific needs, SIA may also utilize other securities, including stocks, bonds, interval funds, no-load annuity contracts, non-traded real estate investment trusts, business development companies, unregistered private funds, private placements and other alternative securities as well as external managers. SIA will allocate the client's assets among these various investments taking into consideration the client’s investment objective, risk profile, and overall management style selected by the client. The mutual funds and ETFs will be selected on the basis of any or all of the following criteria: the fund performance history; the industry sector in which the fund invests; the track record of the fund manager; the fund's investment objectives; the fund management style and philosophy; and the fund management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Certain types of securities (e.g., unregistered private funds and private placements) will be evaluated as investment selections based upon the individual goals of the client and financial qualifications as determined by the security’s offering documents. External account managers (investment advisers) recommended by SIA are monitored for performance, consistency with investment objectives and process and management changes. Clients have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. Clients may request financial planning services which is included in their investment management services. Financial planning services may include financial position planning, retirement planning, income tax estimates, business planning and preparation of a financial plan. All financial planning advice is provided on a non-discretionary basis and clients are responsible for deciding what advice to act upon. Financial Planning Services SIA offers financial planning services to clients as a standalone service. Financial planning services may include financial position planning, retirement planning, income tax estimates, business planning and preparation of a financial plan. All financial planning advice is provided on a non-discretionary basis and clients are responsible for deciding what advice to act upon. Investment Consulting Services SIA offers consulting services based on the scope agreed upon between SIA and the client. Services may include providing advice on the client’s overall asset allocation, including assets managed by external managers and offering guidance on the selection, retention and investment/performance of the other managers. External account managers (investment advisers) recommended by SIA are monitored for performance, consistency with investment objectives and process and management changes. C. Assets Under Management and Advisement As of December 31, 2023, SIA had discretionary assets under management of $719,388,251and $5,434,965 of non-discretionary assets under management. In addition, SIA had $3,026,116,917 of assets under advisement as of December 31, 2023.