General Overview Intrepid Financial Planning Group, LLC (IFPG) provides discretionary investment management services on a fee basis as discussed at Item 5 below. Before engaging IFPG to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with IFPG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, IFPG will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, IFPG provides ongoing supervision of the account(s). About Intrepid Often asked, IFPG was not named after the car. Rather, our company was named after the aircraft carrier, USS Intrepid. Our founder and former lead portfolio manager, Richard K. Locke, was a crew member on the ship for four years while serving in the United States Navy. The ship was commissioned in 1943 and served our country until 1974. The USS Intrepid now serves as a historic museum in New York Harbor. Mr. Locke was a former practicing CPA who started providing advisory and planning services to clients in 1988. IFPG was formed in 1998 and is a wholly owned subsidiary of Intrepid Financial, LLC of which Mr. Locke’s wife, Joan Locke, is now the principal owner. Currently, 14 tax and accounting professionals (primarily CPA’s) are registered through IFPG as Investment Advisor Representatives (IAR). The IARs are owners of the tax and accounting practices which are independent of IFPG. The IARs supplement their tax and accounting practices with separate financial services entities which utilize IFPG for investment advisory services. The IARs perform basic marketing and service duties on behalf of their advisory clients. These duties include explaining IFPG services to prospective clients, completion of new account applications and risk tolerance questionnaires, periodic meetings with clients to review portfolios, and delivering quarterly statements prepared by IFPG. It is important to note the IARs are not actively involved in the construction of portfolios, asset allocation strategies, buying or selling securities, or selecting investments to include in portfolios. The IARs receive portions of the advisory fees and net income earned by IFPG. Advisory Business - Overview IFPG is a fee-only based investment advisory firm registered with the United States Securities and Exchange Commission (SEC). IFPG is not a mutual fund or hedge fund. Client monies and accounts are not co-mingled with other client monies or accounts. IFPG customizes each client portfolio in an attempt to match the client’s goals, risk tolerance, and expectations. IFPG utilizes both financial and non-financial information from clients in the customization process. Client portfolios are monitored and periodically adjusted. 5 | P a g e S E C F I L E N U M B E R 8 0 1 - 6 1 0 2 0 Upon initiating IFPG services, IFPG executes an Investment Advisory Agreement (IAA) with clients. The IAA details IFPG services and fees. The agreement provides clients the right to terminate IFPG services at any time without any penalty charges. IFPG utilizes Charles Schwab as the primary custodian for client monies. Charles Schwab is a broker-dealer and independent of IFPG, and provides each client with a monthly statement for each account maintained at Charles Schwab. IFPG is listed on the statements as the client’s independent advisor; however, IFPG does not participate in the preparation or delivery of these statements. IFPG investment advisory services are provided on a discretionary basis. Discretionary means clients give IFPG permission to buy and sell investments at IFPG’s discretion without having to consult the client in advance of the transaction. The permission is granted to IFPG at the time the account is opened by signing a Limited Power of Attorney (LPOA). The LPOA is included in Charles Schwab’s account application. The LPOA also authorizes IFPG to deduct its’ advisory fees directly from the account. Although IFPG advisory services are provided on a discretionary basis, IFPG recognizes it is the client’s money. Accordingly, clients are free to request IFPG to refrain from including certain types or categories of investments in their portfolio. Advisory clients are also free to request IFPG to include a specific investment in their portfolio or request IFPG to analyze and provide an opinion on an investment they are considering for inclusion. IMPORTANT: ALL CLIENT CHECKS WRITTEN FOR OPENING AN ACCOUNT OR ADDING MONEY TO EXISTING ACCOUNTS MUST BE WRITTEN AS PAYABLE TO CHARLES SCHWAB & CO. CHECKS CAN NOT BE WRITTEN TO IFPG, AN IAR, AN IFPG EMPLOYEE. Advisory Business – Withdrawing Money From Accounts IFPG clients frequently have needs to withdraw money from their accounts. Retirees often require a systematic amount, often monthly, to meet living expenses. These generally reflect a direct deposit into the client’s personal checking account. IFPG manages these accounts in a manner to ensure funds are available for the monthly disbursement. Clients may also need to make non-periodic withdrawals. In these instances, Federal regulations require the client to notify IFPG in writing (or via email) of the amount and from which account the funds are to be removed. If a request is received via email, IFPG will verify the transaction by placing a call to the client to confirm the request. This is a security practice to protect client accounts. If set up in advance, direct deposit can be used. Otherwise, the client will receive a check directly from Charles Schwab, typically within a week of the request. Overnight mail can be requested at a charge to the client. It is important to note, although IFPG can make a request on behalf of clients to initiate a withdrawal, IFPG cannot access client funds at TD Ameritrade. TD Ameritrade will only forward funds to the client’s address of record or checking account of record, both of which are established by the client. Advisory Business – Customized Portfolios Based upon discussions with individual clients and completion of a risk tolerance questionnaire, IFPG will construct and manage the client portfolio on a customized basis. The portfolios can range from aggressive growth to income-driven. Broadly speaking, the portfolios are assigned percentages of exposure to stock market related investments and income driven investments. Examples would include aggressive growth (90% market, 10% income), balanced (50% market, 50% income), or income-driven (0-20% market, 80-100% income). The IFPG portfolio customization services reflect the availability of numerous market and income percentage allocations. 6 | P a g e S E C F I L E N U M B E R 8 0 1 - 6 1 0 2 0 Advisory Business – Types of Investments IFPG may include an array of different types of investments in client portfolios. These can include exchange traded funds, no-load mutual funds, individual stocks, individual bonds, structured products, and money market funds. Advisory Business – Assets Under Management As of December 31, 2023, IFPG managed $316,089,417 on behalf of clients on a discretionary basis. None of the assets are managed on a non-discretionary basis. The assets managed include retirement roll-over accounts, IRA’s, retirement plan assets, trust accounts, non-profit accounts, joint, and individual accounts. Advisory Business – Client Portfolio Programs IFPG does not require a specified minimum dollar amount clients must commit to its’ advisory services. To accommodate smaller dollar amounts, IFPG has designed two programs referred to as Client Portfolio Advisory Services (CPAS). Program I is for clients with less than $250,000 and those clients having more than $250,000, but with a preference to have no individual common stock holdings in their portfolio. Program II is available to clients

with $250,000 or more and a preference to have individual common stocks included in their portfolio. Advisory Business – Miscellaneous Provisions No Financial Planning or Non-Investment Consulting/Implementation Services IFPG does not provide financial planning and related consulting services matters such as estate planning, tax planning, insurance, etc. Please Note: We do not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as same. Accordingly, we do not prepare estate planning documents, tax returns, or sell insurance products. See disclosure at Item 10 below. Please Note: Retirement Rollovers - Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the 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 client’s age, result in adverse tax consequences). If IFPG recommends that a client roll over their retirement plan assets into an account to be managed by IFPG, such a recommendation creates a conflict of interest if IFPG will earn new (or increase its current) compensation as a result of the rollover. If IFPG provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), IFPG is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by IFPG, whether it is from an employer’s plan or an existing IRA . IFPG’s Chief Compliance Officer, Chad Bailey, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Custodian Charges - Additional Fees As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, IFPG generally recommends that Charles Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Charles Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as 7 | P a g e S E C F I L E N U M B E R 8 0 1 - 6 1 0 2 0 well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Charles Schwab, do not currently charge fees on individual equity transactions, others do). These fees/charges are in addition to IFPG’s investment advisory fee at Item 5 below. Intrepid does not receive any portion of these fees/charges. ANY QUESTIONS: IFPG’s Chief Compliance Officer, Chad Bailey, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity IFPG has a fiduciary duty to provide services consistent with the client’s best interest. IFPG will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when IFPG determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Inverse/Enhanced Market Strategies IFPG may utilize long and short mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. To the contrary, such funds and/or strategy(ies) can suffer substantial losses. In light of these enhanced risks/rewards, a client may direct IFPG, in writing, not to employ any or all such strategies for his/her/their/its accounts. In light of these enhanced risks, a client may direct the Intrepid, in writing, not to employ any or all such strategies for the client’s account. Please Note-Use of Mutual and Exchange Traded Funds: IFPG utilizes mutual funds and exchange traded funds for its client portfolios. In addition to IFPG’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Mutual Fund Share Classes: Custodians such as Charles Schwab generally offer multiple share classes of certain mutual funds. Generally, custodians offer both non-transaction fee funds (“NTF Funds”) and transaction fee funds. NTF Funds are available without a transaction fee, but typically have higher internal expense charges as referenced above. Transaction fee funds generally have lower internal expense charges but require that the client pay a transaction fee to purchase these funds. Higher expenses adversely impact account performance. In addition, certain funds require minimum investment amounts to obtain the lower expense share class. As a result of these share class differences and/or minimum investment amounts. the Firm will generally purchase NTF Funds for its smaller clients on the premise that the smaller amount invested does not justify incurring a transaction fee (i.e., generally for clients with less than $250,000 of assets under management - see Program I below) and/or the investment amount required to obtain the lower expense share class would not be prudent. However, this is not an exact process, and there could be, in hindsight, NTF Funds purchases for which the transaction fee fund would have been more beneficial. ANY QUESTIONS: IFPG’s Chief Compliance Officer, Chad Bailey, remains available to address any questions that a client or prospective client may have regarding mutual funds share classes. A client can direct Intrepid, in writing, to purchase transaction fee funds for his/her account. Client Obligations. In performing our services, IFPG shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s 8 | P a g e S E C F I L E N U M B E R 8 0 1 - 6 1 0 2 0 responsibility to promptly notify IFPG if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by IFPG) will be profitable or equal any specific performance level(s).