Ashford Advisors, LLC is a SEC-registered investment adviser located in Pittsford, New York. Ashford Advisors, LLC began conducting business in 2001. Ashford Advisors, LLC is owned by Patrick D. Martin (Principal and Manager) and Jeremiah A. Thisse (Chief Executive Officer). ASHFORD ADVISORY PROGRAM (“AAP”) Ashford offers advisory services to high net worth individuals (including trusts created by them or for their benefit, individual retirement accounts and profit-sharing plans), charitable organizations, corporations and other entities in which clients have a controlling interest. The Ashford Advisory Program (hereinafter “AAP”) is a comprehensive investment advisory service which bundles together Ashford’s services for one fee. In situations where an independent investment advisor or sub-adviser is used for particular services, the sub-adviser will charge a separate and distinct advisory fee from Ashford’s. Please refer to the sub-adviser’s Form ADV Disclosure Document (or other brochure in lieu of the Form ADV Disclosure Document) for information on the fees and services provided by the sub-adviser (if applicable). All AAP clients have the full range of services available to them. The foundation of the AAP is its broad based, independent, and comprehensive approach to financial management. 1. Financial Planning We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state using currently known variables to project future cash flow needs, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and personal situation of the client. In general, the financial plan can address any or all the following areas:  PERSONAL: We review family records, budgets, personal liability, estate plans, risk tolerance and financial goals.  TAX & CASH FLOW: We review a client’s income tax situation, spending and planning for past, current and future years and then illustrate the impact of various investments on the client’s current and future income tax liabilities as well as their cash flows.  INVESTMENTS: We analyze investment alternatives and their effect on a client’s portfolio.  INSURANCE: We assist in the review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability and property.  RETIREMENT: We analyze current strategies and investment plans to help a client achieve his or her retirement goals.  DEATH & DISABILITY: We review a client’s overall estate plan, estate cash needs at death, the income needs of surviving dependents and disability income needs.  ESTATE: We assist the client in assessing and developing long-term strategies including, as appropriate, living trusts, wills, estate tax planning, powers of attorney, asset protection plans, nursing homes, Medicare and elder law. 2. Portfolio Management Ashford provides continuous advice to clients regarding the investment of funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment plan and create and manage a portfolio based on that plan. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment experience, as well as family composition and background. Ashford will accept advisory accounts on either a discretionary or non-discretionary basis. These are often referred to as separately managed accounts and are held in the client’s name with a qualified custodian. For discretionary accounts, portfolio allocations are guided by the client’s stated strategy (i.e. equity-oriented, balanced, fixed income or cash management). For discretionary accounts, Ashford will create a portfolio consisting of one or more of the following:  Exchange-listed securities (including options)  Mutual funds (including money market funds)  Securities traded over-the-counter (including options)  Foreign securities  Corporate debt securities  Commercial paper  Certificates of deposit  Municipal securities  Securities issued by the United States Government Ashford will allocate the client’s assets among these various investments taking into consideration the overall investment objective and strategy selected by the client. As of year-end 2023, Ashford was not managing any options or other derivative securities on a discretionary basis. Mutual funds and ETFs (exchange traded funds) are selected

on the basis of a number of factors such as investment objective, performance history, management style, investment minimum, assets under management, trading volume (for ETFs only) and fee structure. Portfolio weightings between various investments are determined by each client’s individual needs and circumstances. Clients have the opportunity to place reasonable restrictions on the types of investments that are made on their behalf. Clients retain individual ownership of all securities which are, to the extent possible, maintained with independent qualified custodians. For non-discretionary accounts, we will assist the client in placing trades only at their direction to do so. 3. Money Manager Search and Monitoring To better achieve a client's investment objectives, Ashford may perform searches for various independent investment advisors (i.e. third-party managers) on behalf of the client. Based on a client’s individual circumstances and needs, Ashford may recommend one or more independent investment advisors, which are appropriate to meet the investment needs of that client. Factors considered in making this recommendation include portfolio size, risk tolerance, investment objective, performance history, fee structure and the investment style and philosophy of the independent investment advisor. Clients are referred to the independent investment advisor’s Form ADV Disclosure Document (or other brochure in lieu of the Form ADV Disclosure Document) for a full description of the services offered. Ashford will not receive any referral compensation from the selected independent investment advisors. If Ashford determines that a particular investment advisor is performing inadequately, or if Ashford determines that a different investment advisor is more suitable for a client’s particular needs, then Ashford will recommend the client terminate and / or change the investment advisor. Ashford will assist the client in selecting a new investment advisor and then monitor the investment advisor’s performance. Any change of investment advisor will be in the sole discretion of the client. 4. Hedge Fund, Venture Capital and Private Equity Consulting In addition to the aforementioned services offered to advisory clients within AAP, Ashford assists clients in the selection and performance monitoring of certain investments in non- publicly traded partnerships and companies generally referred to as hedge, venture capital or private equity funds (collectively, the “Funds”). Ashford may recommend to a client such investments and investment managers as Ashford determines will best meet the investment objectives of the client. Ashford will review the Fund's operative documents, and where appropriate, annual audited financial reports and selected compliance filings. At a client’s direction, Ashford will assist in making such investments and retaining selected investment managers. On an ongoing basis, Ashford will review, and maintain current versions of appropriate manager and/or fund records. Ashford will review manager-reported performance, when available, and market and fund commentary sent by the manager from which it will assess their ongoing performance. Ashford will confirm manager reported performance with audited financial statements and individual account balances from K-1s or similarly issued third party statements. While Ashford will generally assess a manager’s reputation, Ashford does not make periodic inquiries of third-party custodians or prime brokers regarding the status of trading positions nor fund balances in commingled accounts. Ashford does not perform independent operational due diligence on the managers and/or Funds. Ashford has no discretionary authority over these managers and/or Funds. Clients should refer to the independent investment manager’s disclosure document, prospectus and/or offering memorandum for a full description of the services offered and fees charged. Ashford will not receive any referral compensation from the selected investments and independent investment managers. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with a client's investment objectives, tolerance for risk, liquidity and suitability. 5. Assets Under Management (AUM) As of December 31, 2023, we were managing $590,829,024 of clients' assets on a discretionary basis and $134,202,888 of clients' assets on a non-discretionary basis. The discretionary assets under management include $52,445,483 of funds held by trusts of which Patrick D. Martin is Trustee or Co-Trustee. The non-discretionary assets under management include $121,757,856 of funds where Ashford is deemed to have custody due to a power of withdrawal granted to us by the client(s).