A. Describe the services, including the types of portfolio management services, provided under each program. Indicate the wrap fee charged for each program or, if fees vary according to a schedule, provide your fee schedule. Indicate whether fees are negotiable and identify the portion of the total fee, or the range of fees, paid to portfolio managers. Beacon Capital Management (hereinafter “Beacon”) offers wrap fee program services to its Investment Supervisory and Investment Advisory Services clients that will utilize TD Ameritrade or Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab) as their custodian. Beacon participates in a wrap fee program, which is an investment program where the investor pays one stated fee that includes management fees and transaction costs from the custodian. Beacon does manage the investments in the wrap fee program. Beacon does not manage those wrap fee accounts any differently than non- wrap fee accounts. A portion of the fees paid to the wrap account program will be given to Beacon as a management fee. Beacon offers the following wrap investment services to advisory clients (“Client”): 1. Investment Supervisory Services Beacon offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Beacon creates an Investment Management Planning Questionnaire for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy
• Personal investment policy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring Beacon evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Beacon will request discretionary authority via an Investment Advisory Agreement from client in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Management Planning Questionnaire, which is given to each client. 2. Investment Advisory Services Beacon provides Investment Advisory Services to clients who are introduced to Beacon through investment advisor representatives who represent registered investment advisors and broker dealers (“Firm”). Investment Advisory Services for a client require the Firm, through its representatives, to introduce and assist clients in establishing a relationship with Beacon. The Firm maintains responsibility for assisting the client in understanding and determining the most appropriate services and strategies provided by Beacon; communicating with clients to answer client inquiries, update client information, and acquire suitability information; providing documents, including Beacon’s ADV, to clients as required under federal or state law and regulation; and provide suitability and model updates to Beacon as necessary. Once the Firm and its representatives have worked with client to determine the most appropriate portfolio strategy to be used for the client account, Beacon will manage the client account continuously based upon the strategy’s goals and objectives. As Beacon manages the client account, the client account’s actual stock-to-bond ratio will deviate around the target stock-to-bond ratio of the model portfolio. Although the client account’s target stock-to-bond ratio will be maintained, Beacon may change the specific mutual funds, Exchanged Traded Funds (“ETFs”) or other investments being used in the client account at Beacon’s discretion. Beacon provides four model portfolios, each of which has conservative, balanced, and aggressive strategies within it. The descriptions of the model portfolios below are not meant to be comprehensive, but rather provide a brief overview of Beacon’s strategies. a. Beacon Vantage 1.0 Models The Beacon Vantage 1.0 Models (“1.0 Models”) utilize an asset-class diversification strategy emphasizing small company stocks and value equities. The core equity allocation tends to invest in small company and value equity mutual fund products diversified across domestic, international and emerging markets. The core bond allocation seeks to apply equal weight to intermediate government and inflation protected investment products. There are three 1.0 Models – Aggressive, Balanced, and Conservative. The underlying mutual funds are the same in all 1.0 Models, with different allocations of equity and fixed income products to meet the investment objectives of each respective 1.0 Model. The 1.0 Models utilize a risk optimization process that manages volatility with a strict risk budget for each Model. During periods when small company and value equities are experiencing high volatility, the Model’s allocation is shifted to a heavier fixed income allocation to stay within the risk budget. The same but opposite principle is applied when small company and value equities have relatively low volatility. The minimum account size for the Beacon Vantage 1.0 Portfolio strategies is typically $25,000. b. Beacon Vantage 2.0 Models The Beacon Vantage 2.0 Models (“2.0 Models”) utilize a market sector diversification strategy for its equity allocation, a duration diversification strategy for its fixed income allocation, and a single ultra-short duration fixed income allocation for its most defensive position. The model uses objective, pre-determined benchmarks to determine when to invest in each allocation. A cash position is maintained for each Vantage 2.0 Portfolio. There are no sales loads with this strategy. There are three 2.0 Models – Aggressive, Balanced, and Conservative. The underlying ETFs and the buy/sell signals are the same in all 2.0 Models, with different allocations of equity and fixed income allocations to meet the investment objectives of each respective 2.0 Model. For the Balanced and Conservative models, there is always a fixed

income allocation. The minimum account size for the Beacon Vantage 2.0 Portfolio strategies is typically $25,000. c. Beacon Vantage 3.0 Models The Vantage 3.0 Models (“3.0 Models”) also offer diversification with proprietary targeted loss reduction protections at the holding level. Each holding within a Vantage 3.0 portfolio moves independently and is designed to quantitatively buy in and sell out of equity and fixed income products upon pre-determined market signals. A cash position is maintained for each Vantage 3.0 Portfolio. There are no sales loads with these strategies. There are five 3.0 Model strategies:
• 3.0 Vantage Sector, which is based on sector diversification. There are Conservative, Balanced, and Aggressive models, all of which have the same holdings but vary in the allocation to the fixed income ETFs to reflect the risk tolerance of the model. The minimum account size is typically $25,000.
• 3.0 Vantage Alternative, which seeks equal investment across commodities and private equity investment ETFs. The minimum account size is typically $25,000.
• 3.0 Vantage Bond, which targets an equal weight of the extended duration, longterm, intermediate-term, and inflation protected ETFs. The minimum account size is typically $25,000.
• 3.0 Vantage American Funds U.S., which is comprised American Funds mutual fund products intended to reflect general United States market trends. The minimum account size is typically $5,000.
• 3.0 Vantage American Funds International, which is comprised of American Funds mutual fund products intended to reflect general international market trends. The minimum account size is typically $5,000.
• 3.0 Vantage Market, which is designed to generate market level returns, mostly using higher-risk equities. The minimum account size of the Beacon Vantage 3.0 Market Portfolio strategies is typically $5,000. As of December 2022 Total Wrap Assets Under Management Maximum Annual Fee (including wrapped fees) Maximum Annual Fee to Beacon (excluding wrapped fees) $2,509,921,427 1.80% for Investment Supervisory Services .55% for Investment Advisory Services 1.80% for Investment Supervisory Services .55% for Investment Advisory Services There is a minimum annual fee of $400 charged by Beacon for both Investment Supervisory and Investment Advisory services. These fees are negotiable, and the final fee schedule is attached in the Investment Advisory Contract/Investment Management Agreement/Solicitation Disclosure Statement. Fees are paid monthly or quarterly in advance or in arrears depending upon Client situation, and Clients may terminate their contracts with ten days’ written notice. For fees charged in arrears, no refund policy is necessary. For fees charged in advance, refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract/new account package. Advisory fees are withdrawn directly from the Client Account with Client written authorization. The Client may also pay fees and expenses related to the Client’s investments in the underlay mutual funds, ETFs or other investment vehicles used within their account. A description of these fees and expenses can be found in each funds’ prospectus. Services similar to those offered by Beacon may be available elsewhere for more or less than the amount Beacon charges for investment advisory services rendered to Clients enrolled in our wrap program. For additional information regarding Beacon’s Fees and Compensation for advisory services provided, please see Item 5 of Beacon’s ADV Part 2A. Beacon limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, third party money managers, REITs, insurance products including annuities, and government securities. Beacon may use other securities as well to help diversify a portfolio when applicable. B. Explain that the program may cost the client more or less than purchasing such services separately and describe the factors that bear upon the relative cost of the program, such as the cost of the services if provided separately and the trading activity in the client's account. The program may cost the Client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program including the cost of the services if provided separately and the trading activity in the Client Account. C. Describe any fees that the client may pay in addition to the wrap fee, and describe the circumstances under which clients may pay these fees, including, if applicable, mutual fund expenses and mark-ups, markdowns, or spreads paid to market makers. Although the wrap fee program is one fee for all management and brokerage services, there may be additional fees not associated with the management of Client Account. These fees may include trading fees, national securities exchange fees, wire transfer fees, or other fees required by law. D. If the person recommending the wrap fee program to the client receives compensation as a result of the client's participation in the program, disclose this fact. Explain, if applicable, that the amount of this compensation may be more than what the person would receive if the client participated in your other programs or paid separately for investment advice, brokerage, and other services. Explain that the person, therefore, may have a financial incentive to recommend the wrap fee program over other programs or services. Neither Beacon nor any representatives of Beacon receive any additional compensation for the participation of Client’s in the wrap fee program. However, compensation received may be more than what would have been received if Client paid separately for investment advice, brokerage, and/or for other services. Therefore, Beacon may have a financial incentive to recommend the wrap fee program to clients.