Sandra Cleveland and Marshall Rathmell own BCR Wealth Strategies which has been providing advisory services since 2002. As of March 31, 2024, BCR Wealth Strategies managed $367,325,029 on a discretionary basis. BCR Wealth Strategies offers financial planning and wealth management, consulting and investment management services to individuals, pension and profit sharing plans, trust estates, charitable organizations, corporations and business entities. BCR Wealth Strategies, depending upon the engagement, offers its services on a fee basis which may include hourly and/or fixed fees as well as fees based upon assets under management. Prior to engaging BCR Wealth Strategies to provide any of the foregoing investment advisory services, the client will be required to enter into one or more written agreements with BCR Wealth Strategies setting forth the terms and conditions under which BCR Wealth Strategies shall render its services. Financial Planning and Consulting BCR Wealth Strategies offers a broad range of financial planning and consulting services (which may include tax-related services, litigation support and expert witness services as well as other non-investment related matters). A financial plan consists of the following topics as applicable: clarifying and prioritizing goals, cash management, retirement planning, education planning, risk management, income tax planning, estate tax planning and investment planning. BCR Wealth Strategies may recommend the services of itself and/or other professionals to implement financial planning and consulting recommendations. Clients are advised that a conflict of interest exists if BCR Wealth Strategies recommends its own services. A client is under no obligation to act upon any of the recommendations made by BCR Wealth Strategies under a financial planning/consulting engagement and/or engage the services of any such recommended professional, including BCR Wealth Strategies. The client retains absolute discretion over the implementation of all such financial planning/consulting decisions and is free to accept or reject any of BCR Wealth Strategies’ recommendations. Investment Management Services Based on a client’s individual circumstances, BCR Wealth Strategies will manage a client portfolio(s) of investment assets. Clients may grant BCR Wealth Strategies discretionary authority to manage client portfolios by arranging for the purchase and sale of client investments through the client’s investment account(s), or BCR Wealth Strategies may provide nondiscretionary services requiring the consent of the client prior to BCR Wealth Strategies arranging for the purchase or sale of any investment. BCR Wealth Strategies will primarily allocate clients’ investment management assets among mutual

funds and exchange traded funds. BCR Wealth Strategies may also exercise discretionary authority provided by the client to select a third party, unaffiliated investment manager to the extent it determines necessary for specific investment management services, primarily involving the management of large fixed income securities portfolios. BCR Wealth Strategies also may render non-discretionary advice to clients relative to: (1) variable life/annuity products that they may own, and/or (2) their individual employer- sponsored retirement plans. In so doing, BCR Wealth Strategies either directs or recommends the allocation of client assets among the various mutual funds available within the variable life/annuity product or retirement plan. The client assets shall be maintained at either the specific insurance company that issued the variable life/annuity product which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. 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 and/or the Internal Revenue 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 interests 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. Retirement Plan Consulting BCR Wealth Strategies provides consulting services in connection with a “participant directed” retirement plan established pursuant to Section 404(c) of Employee Retirement Income Security Act (“ERISA”). BCR Wealth Strategies provides services on either a discretionary or non-discretionary basis based on the consulting agreement. Information for all clients: Each client is advised that it remains such person’s responsibility to promptly notify BCR Wealth Strategies if there is ever any change in such person’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising BCR Wealth Strategies’ previous recommendations and/or services.