Koss Olinger Consulting, LLC (referred to as “Adviser” or “Koss Olinger”) is a registered* investment advisory firm under the Investment Advisers Act of 1940. * Registration with the SEC does not in any way constitute an endorsement by the SEC of an investment adviser’s skill or expertise. Further, registration does not imply or guarantee that a registered adviser has achieved a certain level of skill, competency, sophistication, expertise or training in providing advisory services to its clients. Koss Olinger Financial Group was established in 1969 as a privately owned, independent financial planning company to provide personal and professional wealth management services to individuals, families and businesses. In 2009, Koss Olinger Financial Group became two separate entities - Koss Olinger and Company, LLC and Koss Olinger Consulting, LLC. In September 2009, Koss Olinger Consulting, LLC was organized as a Limited Liability Company under the laws of the State of Florida. In September 2016, William D. Olinger III, Kirk E. Klein, William J. Rossi III and Brian E. Watson purchased 36% in member units (9% each) from founding members, William D. Olinger II (18%) and William F. Koss (18%). The resulting ownership percentages of both entities are William D. Olinger III (29%), Kirk E. Klein (29%), William J. Rossi III (21%) and Brian E. Watson (21%). William D. Olinger II remains involved as a consultant. Together these five individuals have over 150 years of financial advisory experience. Koss Olinger offers a variety of advisory services, among which are management of investment portfolios, investment supervisory services, investment advice through consultations, financial planning and, often, the furnishing of advice to clients on matters not involving securities. Koss Olinger’s investment advisory services are offered as a percentage of assets under management and fixed fees (not including subscription fees). Koss Olinger’s client base includes individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations or other business entities. Koss Olinger offers a range of investment advice on various types of investments including equity securities (exchange-listed securities and securities traded over-the- counter), certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual fund shares), exchange-traded funds (ETFs), United States government issued securities, and options contracts on securities. Koss Olinger also offers investment advice on interests in partnerships or private investments offered through the 1940 Act fund structure as closed-end investment management companies. In June 2019, as a part of a broader rulemaking package known as “Reg BI,” the SEC issued an interpretation clarifying its views of the fiduciary duty that investment advisers owe to their clients under the Advisers Act. The interpretation expounded on the duty of care and duty of loyalty components of that fiduciary duty, concluding that the obligation to act in the best interest of the client is the “overarching principle” encompassing both components of the investment adviser’s fiduciary duty. See, Commission Interpretation Regarding Standard of Conduct for Investment Advisers, Exchange Act Release No. IA-5248 (June 5, 2019) (“the Fiduciary Release”). As reaffirmed through the June 2019 Fiduciary Release, Koss Olinger recognizes that the scope of our fiduciary duty to a client, including the attendant obligation to not subordinate a client’s interest to our own or act contrary to a client’s best interest, encompasses the entirety of the client relationship. The investment strategies used to implement investment advice given to clients include long term purchases (securities held at least a year), short term purchases, trading (securities sold within 30 days), and options on publicly-traded securities, primarily covered calls. Koss Olinger provides a client-centered planning process that allows the Adviser to tailor the advisory services to the individual needs of the clients. The process takes clients through The Wealth Navigator System™. The Wealth Navigator System™ Engagement and Discovery™ The first step of the planning process is Engagement and Discovery™. The Adviser gathers as much pertinent information as possible through client meetings, questionnaires, etc., building a foundation on which the Adviser can begin to create a financial game plan unique to the client. The Adviser discusses the client’s current financial situation, their goals, objectives and available resources. The Critical Factors Analysis™ The second step of the planning process is The Critical Factors Analysis™. Using the information from the discovery process, the Adviser analyzes the client’s current financial strengths and weaknesses, as well as the financial opportunities available to the client. This step involves combining the client’s personal information and the Adviser’s wisdom, experience, and creativity to allow the Adviser to further shape and develop the client’s unique financial game plan. The Breakthrough Game Plan™ The Breakthrough Game Plan™ is the next step in the planning process. The Breakthrough Game Plan is a comprehensive strategy customized for

the client that may include retirement planning, estate planning, tax planning, business planning, risk management and asset management. The Adviser educates the client on the various options available in the marketplace that may be needed to implement the client’s game plan. The Adviser explains the client’s options in an objective, unbiased manner and the Adviser provides their recommendations. Utilizing The Legacy Optimizer™ (“LO™”), The Secure Retirement Maximizer™ (“SRM™”), The Optimized Portfolio Solution™ (“TOPS™”) and the Business Sale Evaluator™ (BSE™) as tools, the Adviser can identify, evaluate, analyze and develop a customized financial plan. The Implementation Solution™ Once the client is presented The Breakthrough Game Plan™, the Adviser will guide the client through the strategies they want to implement based on the client’s unique financial situation, goals and available resources. The Adviser will execute the client’s game plan at the request of the client. The Wealth Manager™ Koss Olinger will provide ongoing advice and management of the client’s Breakthrough Game Plan™. The Adviser will provide proactive, objective advice to help ensure the client’s goals are successfully accomplished should the client’s situation, goals or objectives change. Koss Olinger provides continuous and regular supervisory and management services to securities portfolios. The assets we have under management and number of accounts associated with those, as of December 31, 2023, are as follows: Account Description U S Dollar Amount No. Accounts Discretionary $1,730,344,963 2,554 Non-Discretionary $138,785,582 462 Total Assets Under Management $1,869,130,545 3,016 Acknowledgment of Fiduciary Status Under ERISA When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. When providing recommendations to retirement plan accounts involving rollover considerations, there are generally four options regarding an existing retirement plan account. An employee may use a combination of those options, such as: (i) leave the funds in the former employer’s plan, if permitted; (ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted; (iii) roll over to an Individual Retirement Account (“IRA”); or (iv) cash out the account value (which could, depending upon the individual’s age, result in adverse tax consequences). If we recommend that you rollover your retirement plan assets into an account to be managed by us, such recommendation creates a conflict of interest insofar as we will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement plan assets to an account managed by us. Third Party Money Managers We may on occasion determine that opening an account with a professional, independent investment manager (“Third Party Money Manager”) is in your best interest. We currently use Valmark Advisers, Inc. (“Valmark Advisers”) when recommending a Third Party Money Manager for client accounts. Some of our investment adviser representatives (“IARs”) are also registered representatives of Valmark Securities, Inc. (“Valmark Securities”), a FINRA registered broker-dealer and an affiliate of Valmark Advisers, as detailed in Item 10 of this Brochure. Most of our clients do not use a Third Party Money Manager. The Third Party Money Manager selected has discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions you impose. Each of the independent money managers is obligated to provide you with a separate advisory contract and disclosure document. You should carefully review these documents for important and specific program details, including pricing. When utilizing a Third Party Money Manager, we may assist in the identification of investment objectives; recommend specific investment style and asset allocation strategies; assist in the selection of appropriate money managers; review performance and progress; recommend reallocation among managers or styles; and recommend the hiring and firing of money managers. You should read the ADV Part 2 disclosure document of the Third Party Money Manager you select for complete details on the charges and fees you will incur. Please reference Item 12 below for details on fees and compensation issues with respect to our recommendation of Valmark Advisers.