Schlindwein Associates, LLC (the “Firm”) provides discretionary and non-discretionary investment supervisory services to individuals and institutions, investment guidance programs for corporate and not-for-profit groups and consulting services on investment management issues. The Firm was founded in 1995. Timothy A. Schlindwein indirectly owns 99% of the Firm and his wife owns the remaining 1%. As of December 31, 2023, the Firm manages $199,903,557 million in assets on a discretionary basis. The Firm’s investment supervisory services consist primarily of a portfolio management service that allocates and periodically reallocates the client’s assets among various investment vehicles and securities. The Firm invests client assets primarily in open-end investment companies (“mutual funds”) and exchange-traded funds (“ETFs”), but may also invest client assets in variable annuity and variable life insurance contracts, closed-end investment companies and other types of pooled investment products, structured notes, and, to a lesser extent, individual securities. Based upon a review of the client’s investment objectives, risk tolerance and financial and tax circumstances, the Firm creates a model client portfolio. Clients may restrict or prohibit purchases of certain types of securities in their accounts. For clients with similar characteristics, the Firm provides substantially identical portfolio recommendations, depending upon each client’s individual circumstances. The Firm’s investment consulting services include ongoing asset allocation advice, ongoing mutual fund reviews and recommendations and mutual fund advisory programs. In certain circumstances, the Firm will also provide clients recommendations based on third-party research. The Firm has developed a questionnaire that is designed to assess investor risk tolerance, which it uses to recommend overall asset allocation and specific investment options consistent with this allocation. The Firm may recommend that clients rollover their retirement or other account into an individual retirement account (“IRA”) maintained at Charles Schwab. The Firm charges a flat fee plus an asset-based fee on all investment advisory accounts, including IRA accounts. As a result, the Firm has an incentive to encourage clients to rollover their assets to an IRA account to which the Firm charges fees based on the amount of assets in the account. In addition, as discussed further below in this section and in “Brokerage Practices” below, maintaining client accounts at Charles Schwab creates some conflicts of interest for the Firm based on the way Charles Schwab charges fees to the Firm and the benefits the Firm receives from Charles Schwab. In connection with its investment advisory services, the Firm assists eligible clients with IRAs and/or employer-sponsored retirement accounts in meeting their required minimum distributions (“RMDs”). In doing so, the Firm is not providing tax advice and assumes no responsibility for miscalculations of RMDs The Firm also offers its services to certain clients of CIBC Wealth Management (“CIBC”), a division of CIBC Bank USA. The Firm renders continuous investment advice to CIBC regarding the investment and reinvestment of assets in the accounts of certain clients of CIBC (“CIBC Clients”) in mutual funds and other securities based upon the investment objectives, policies and restrictions applicable to each CIBC Client account. CIBC Clients deal directly with CIBC and not with the Firm. The Firm manages the assets of CIBC Clients using a style similar to the style the Firm uses in managing its own clients’ assets. The Firm offers an automated investment program (the “Program”) through which a client is invested in a range of investment strategies the Firm has constructed and manage, each consisting of a portfolio of ETFs and mutual funds and a cash allocation. A client may instruct

the Firm to exclude up to three funds from their portfolio. A client’s portfolio is held in a brokerage account opened by the client at Charles Schwab. The Firm uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Charles Schwab, to operate the Program. The Firm is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, Charles Schwab, or their affiliates (together, “Schwab”). The Firm, and not Schwab, is the client’s investment advisor and primary point of contact with respect to the Program. The Firm is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for a client, choosing a suitable investment strategy and portfolio for a client’s investment needs and goals, and managing that portfolio on an ongoing basis. The Firm has contracted with SPT to provide the Firm with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables the Firm to make the Program available to a client online and includes a system that automates certain key parts of the Firm’s investment process (the “System”). (Option 1) The System includes an online questionnaire that can help the Firm determine a client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. A client should note that, if the Firm uses the online questionnaire, the Firm will recommend a portfolio via the System in response to a client’s answers to the online questionnaire. (Option 2) Based on information a client provides to the Firm, the Firm will recommend a portfolio via the System. A client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but the Firm then makes the final decision and selects a portfolio based on all the information the Firm has about the client. The System also includes an automated investment engine through which the Firm manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). The Firm charges clients a fee for the Firm’s services as described below under Fees and Compensation. The Firm’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Charles Schwab as part of the Program. Schwab receives other revenues, including (1) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (2) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™, Schwab Funds® and Laudus Funds® that the Firm selects to buy and hold in the client’s brokerage account; (3) fees received by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (4) remuneration Schwab receives from the market centers where it routes ETF trade orders for execution. The Firm does not pay SPT fees for the Platform so long as the Firm maintains $100 million in client assets in accounts at Charles Schwab that are not enrolled in the Program. If the Firm does not meet this condition, then the Firm pays SPT an annual licensing fee of 0.10% (10 basis points) on the value of the Firm’s clients’ assets in the Program. This fee arrangement gives the Firm an incentive to recommend or require that the Firm’s clients with accounts not enrolled in the Program be maintained with Charles Schwab