EM 4 Who We Are Fund Advisors of America, Inc. (hereinafter referred to as “the Company”, “we”, “us” and “our”) is a full-service registered investment advisor1 incorporated in January of 1993 as a Florida corporation. We offer a wide range of financial management services2 designed to assist you, our client3, in achieving your financial goals. Owners The following person controls the Company: Name Title CRD# Gregory B. Galloway President, Director & Chief Compliance Officer 1834265 Assets Under Management As of December 31, 2023, our assets under management totaled: Client Discretionary Managed Accounts ......................... $106,146,828 We do not offer non-discretionary investment management services. You will find more information about our fees and management under “Portfolio Management” in Item 5, “Fees & Compensation” below and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” Mission and Objective Our mission is to preserve wealth and promote financial independence and security in an economic environment that is increasingly becoming borderless, complex and volatile as our U.S. financial markets evolve to address the demands of a growing global economy. What We Do We manage wealth. We offer investment management services, which stress fiscal responsibility and disciplined economic decision-making, ultimately designed to protect your monetary needs for today, tomorrow, and in the future. We provide this service through: v Advice on how to best navigate the current economic and investment environment. v The design of an asset allocation guideline unique to your predefined goals and objectives. 1 The term “registered investment advisor” is not intended to imply that Fund Advisors of America, Inc has attained a certain level of skill or training. It is used strictly to reference the fact that we are “Registered” as a licensed “Investment Advisor” with the United States Securities & Exchange Commission – and “Notice Filed” with such other State Regulatory Agencies that may have limited regulatory jurisdiction over our business practices. 2 Fund Advisors of America, Inc. is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any financial management services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). 3 A client could be an individual, a corporation and/or small business, another fiduciary, a trust, an estate, a charitable organization and/or any other type of entity structure to which we choose to give investment advice. v Implementation of the investment and risk management strategies necessary to attain your financial goals. v Monitoring the investment performance of such management strategies. Earning your trust and confidence is a great compliment. We understand that when this is accomplished, you are at peace knowing your financial affairs are being managed with your best interest always in mind. How We Get to Know You We get to know you through one-on-one consultations to discuss issues such as your current personal goals, investment return expectations and prior investment experience. In addition, we have you complete a Confidential Financial Profile questionnaire4 to provide us a picture of your financial needs. With the complexity of today’s marketplace, it is critical for us to understand who you are and what you want to accomplish financially. We must have a clear picture of your unique financial composition and risk tolerance so that we can develop a successful investment plan and tailored asset allocation guideline. Our meetings with you to discuss your finances will help to eliminate much of the guesswork in achieving the security and independence you desire and simplify your financial alternatives. In return, we will have: v Defined and narrowed objectives and investment options; v Identified areas of greatest distress; v Developed a strategy for addressing concerns about the future; and, v Created a unique picture of your overall economic personality. Once your financial parameters have been identified, we will prepare an allocation that is most suitable for your unique investment expectations and risk tolerance. This allocation plan will guide us in the management of your account(s), and as a standard against which to measure future results and to make modifications where necessary. FEES & COMPENSATION IT EM 5 Portfolio Management Portfolio management is provided on an asset-based fee arrangement. Our management fee is calculated based on the aggregate market value of your account on the last business day of the previous calendar quarter multiplied by one-fourth of the corresponding annual percentage rate (i.e., 2.25% ÷ 4 = 0.5625%). We retain discretion to negotiate the management fee under 2.25% on a client-to-client basis. Generally, fee breaks will occur as assets in your portfolio increase past the following tiers: 4 The Confidential Financial Profile questionnaire we use is an important tool in

gathering information about your investment methodology, risk tolerance, income/tax bracket, liquidity, time horizons, etc. If you elect not to answer the questionnaire or choose to respond with limited input, it is possible that we could operate in a handicapped capacity contrary to your investment needs. Therefore, if you desire the most effective and accurate recommendations regarding your managed account(s), you should make every effort to provide us with your detailed personal needs and objectives, along with detailed financial and tax information. Account Value Annual Fee Rate Not to Exceed Up to $100,000 .................................................. 2.25% From $100,001 to $250,000 ................................... 2.00% From $250,001 to $500,000 ................................... 1.75% From $500,001 to $1,000,000 ................................ 1.50% $1,000,001 and up .............................................. Negotiable We generally require a minimum initial investment of $100,000 to open a managed account; however, we retain the right to waived or reduced this minimum if we feel circumstances are warranted. Protocols for Portfolio Management The following protocols establish how we handle our portfolio management accounts and what you should expect when it comes to: (i) managing your account; (ii) deposits and withdrawals in/from your account(s); (iii) your bill for investment services; (iv) other fees charged to your account(s); and, (iv) termination. Discretion We will establish discretionary trading authority on your management accounts to execute securities transactions at any time without your prior consent or advice. However, you may impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of leverage, etc.) Billing Your account will be billed quarterly in advance based on the above fee arrangements. For new managed accounts opened mid-quarter, our fee will be based upon a pro-rata calculation of the fair market value of your assets to be managed for the period. Advisory fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. Such liquidation may affect the relative balances of the account. Deposits and Withdrawals Assets deposited by you into your management account between billing cycles will not result in additional management fees being billed to you. For assets you may withdrawal during the quarter, we do not make partial refunds of your quarterly portfolio management fee. Any withdrawal of assets from your portfolio may require modifications and adjustments to be made in the account to correct your allocation of assets. Fee Exclusions The above fees for all of our management services are exclusive of any charges imposed by the custodial firm including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, including, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. In addition, all fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses generally include management fees and various fund expense, such as: redemption fees, account fees, and purchase fees may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. Termination of Portfolio Management Services To terminate our investment advisory services, either party (you or us) by written notification to the other party, may terminate the Investment Advisory Agreement at any time. Termination will be effective on the business day we received such notification. At that time, neither party has any obligation to the other – we no longer earn management fees or give investment advice and you become responsible for making your own investment decisions. In the event termination does not fall on the last/first day of a calendar quarter, you shall be entitled to a pro-rated refund of the prepaid quarterly management fee calculated beginning 30 days from the date of termination through the end of the billing quarter (i.e.; Advisory services terminate on July 15th, the refund will be pro-rated from August 15th to September 30th.). PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT IT EM 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts.