JTAM is owned by the accounting firm Jackson Thornton & Co., PC and has been providing advisory services since 1999. As of December 31, 2023, JTAM managed $1,534,417,673 on a discretionary basis and $14,178,780 on a non-discretionary basis. JTAM also advised on $266,667,486 of retirement plan assets including its parent company’s retirement plan. Managed funds and advised funds totaled $1,815,263,939 representing 969 client relationships. InvestmentManagementServices JTAM works with each client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. JTAM uses investment and portfolio allocation software to evaluate alternative portfolio designs. JTAM evaluates the client's existing investments with respect to the client's investment policy statement. JTAM works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by JTAM. JTAM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. JTAM will typically create a portfolio of no-load mutual funds and exchange traded funds (“ETFs”) and will use model portfolios if the models match the client's investment policy. JTAM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. JTAM primarily recommends portfolios consisting of passively managed asset class and index mutual funds, as well as ETFs. JTAM primarily recommends mutual funds and ETFs offered by Dimensional Fund Advisors (DFA). DFA-sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. JTAM manages mutual fund and equity portfolios on a discretionary basis according to the investment policy selected by the client. This discretionary authority will be limited to the authority to periodically rebalance client accounts, including rebalancing as necessary to add or withdraw funds from a client's account, and to harvest tax losses. Any such discretionary rebalancing by JTAM will be done only within the asset allocation limits approved by the client in the client's investment policy statement. JTAM also provides non-discretionary investment management services to a small number of accounts. JTAM may also recommend fixed income portfolios to advisory clients, which consist of managed accounts of individual bonds. JTAM will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, JTAM will retain an independent separate account manager (“Independent Manager”) for the management of client portfolios. The Independent Manager will be provided with the discretionary authority to invest client assets consistent with the client's Investment Policy Statement. The Independent Manager will also monitor the

accounts for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). JTAM has hired Buckingham Strategic Partners (“BSP”) as the primary Independent Manager. In certain circumstances, as determined by JTAM and the client, JTAM engages DFA as an Independent Manager to manage portfolios of individual securities for clients. In these instances, DFA’s fees are separate, distinct, and in addition to JTAM’s advisory fees. On an ongoing basis, JTAM will answer clients' inquiries regarding their accounts and review periodically with clients the performance of their accounts. JTAM will periodically, and at least annually, review each client's investment policy, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. JTAM will provide to the Independent Manager any updated client financial information or account restrictions necessary for sub-advisory services. Additional Personal Financial Advice In addition to managing the client’s investment portfolio, JTAM will consult with clients on various financial areas including income and estate tax planning, business sale structures, college financing planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans, and trust designs, among other things. These wealth management consultations are available to all investment management clients. JTAM does not charge separately for these services and reserves the right to provide such additional services to clients as necessary and appropriate to the client’s financial situation. Participant‐DirectedRetirementPlanServices JTAM also provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. JTAM will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. JTAM will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. JTAM will recommend changes in the plan's investment vehicles as may be appropriate from time to time. JTAM generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, JTAM also works in coordination and support with BSP. Retirement plan clients will engage both JTAM and BSP. BSP will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. JTAM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.