Boulay Financial Advisors, LLC (BFA) was established in 2001 by the partners of the accounting firm Boulay PLLP (Boulay) to provide investment advisory services to clients through BFA’s Investment Advisor Representatives. BFA is co-owned by BFA Holdings, LLC (38% ownership) and Boulay (62% ownership). BFA Holdings, LLC is held by current Wealth Management Partners that work in and on our advisory practice every day, and include Joseph Bloodgood, Tim Beversdorf, Jay Brown, Nathan Faith, Ellen Horan, and Jon Melander. BFA’s advisory business specifically offers services that include an Investment Advisory Program, a Third-Party Managed Program and a Financial Planning Program, each of which are described in greater detail below. INVESTMENT ADVISORY PROGRAM Clients, with assistance of their Investment Advisor Representative, will complete an Investment Profile and provide information regarding their financial history, goals, objectives, and financial concerns. Upon receipt and analysis of a client’s information, the Investment Advisor Representative and client will determine an appropriate Investment Strategy. BFA also assists clients in allocating their assets among different investment types that are deemed appropriate for reaching their objectives. BFA has developed and maintains several Target Portfolio Allocation models that BFA has defined as ranging from conservative to aggressive. BFA’s Investment Selection and Strategy Committees meet regularly to evaluate and recommend changes to the model portfolios. Portfolios may be implemented among various asset classes which contain securities consisting of, but not limited to, money market funds, mutual funds, exchange traded funds, unit investment trusts, third party money managers, individual securities, certificates of deposit and other investment vehicles that are deemed appropriate. BFA provides regular Portfolio Reviews, which include a comparison of actual client allocations to Target Portfolio Allocations. Changes of Investment Strategy require prior approval from the client in either written or electronic format which is acknowledged by the Investment Advisory Representative. When BFA provides investment advice to clients regarding an employee benefit plan account or individual retirement account, BFA and its investment representatives are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way BFA makes money creates some conflicts with client interests, so BFA operates under a special rule that requires BFA to act in the clients' best interest and not put BFA’s interest ahead of the clients' interests. Under this special rule’s provisions, BFA must:  Meet a professional standard of care when making investment recommendations (give prudent advice).  Never put our financial interests ahead of those of the client 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 our clients' best interest.

 Charge no more than is reasonable for our services; and  Give clients basic information about conflicts of interest. THIRD PARTY MANAGED PROGRAMS In certain situations, BFA uses the services of third-party managers or asset allocators to offer asset management services to clients. Such programs can assist a client in determining their risk profile and investment objectives and provide a relevant asset allocation policy and management of the account. Such programs will generally provide continuous management of the client’s account and provide reporting on the performance of the account. Fees for such programs are disclosed in the third-party managers’ Form ADV Part 2A. Generally, third party management programs will have account minimums that must be met before a client may obtain the manager’s services. Various managers have different management philosophies and objectives. BFA will assist clients in evaluating their financial situation in order to help determine the suitability of a third-party manager’s service. BFA will be available to answer questions that the client may have regarding their account and act as the communication conduit between the client and the manager. Investment decisions are made by the third-party manager in accordance with the agreement between client and manager. BFA will not directly conduct any securities transactions on behalf of the client or participate directly in the selection of the securities to be purchased or sold for the client. FINANCIAL PLANNING PROGRAM BFA offers planning and review services that cover a client’s financial, estate, tax, retirement, college-funding, and asset allocation for a fee. BFA will gather financial information and history from the client which may include retirement and financial goals, investment objectives, investment horizon, financial needs, cash flow details, education goals, savings tendencies, and other applicable financial information. Based upon a client’s needs and desires, a financial plan will be prepared addressing those needs as appropriate. Financial plans are based on the client’s financial situation at the time as well as financial information disclosed by the client to BFA. Clients are advised that certain assumptions will be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. However, past performance is in no way an indication of future performance, and BFA cannot offer any guarantees or promises that a client’s financial goals and objectives will be met. Implementation of BFA’s financial planning recommendations is entirely at the client’s discretion. Further, it is the clients’ responsibility to monitor the plan and request revisions as desired. Clients are advised that BFA does not offer any advice or guidance on property, casualty, or liability insurance needs. ASSETS UNDER MANAGEMENT, AS OF MAY 31, 2023 US Dollar Amount Discretionary: $1,703,341,242.84 Non-Discretionary: $165,410,107.84 Total: $1,868,751,350.68 Please reference Items 10, 12 and 14 for disclosure of all identified conflicts of interest related to our advisory business.