WRFA is owned by Partners of the accounting firm WebsterRogers LLP and has been providing advisory services since 1999. As of December 31, 2023, WRFA managed $345,624,116 on a discretionary basis and $128,841 on a non-discretionary basis. Investment Management Services WRFA works with a client to determine the client's investment objectives and investor risk profile and implement a suitable investment plan. WRFA uses investment and portfolio allocation software to evaluate alternative portfolio designs. WRFA evaluates the client's existing investments with respect to the client's investment plan. WRFA works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by WRFA. WRFA will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. WRFA will typically create a portfolio of no-load mutual funds or exchange traded funds (ETFs) and at times will implement model portfolios if the models match the client's investment policy. WRFA will allocate the client's assets among various investments taking into consideration the client’s risk profile and investment objectives. WRFA primarily selects portfolios consisting of mutual funds and ETFs that incorporate the concepts of Modern Portfolio Theory. Client portfolios may also include individual equity and fixed income securities. WRFA manages client portfolios on a discretionary or nondiscretionary basis. A client may impose any reasonable restrictions on WRFA’s discretionary authority, including restrictions on the types of securities in which WRFA is permitted to invest client’s assets and on specific securities, which the client does not believe to be appropriate. In certain circumstances, clients already own individual securities. WRFA will monitor these securities and recommend their sale or retention, as appropriate. On an ongoing basis, WRFA will consult with clients as needed to address any client-specific issues, such as significant life events, changes in cash flow needs or any other matter that might affect portfolio allocation. WRFA will periodically, and at least annually, review client's investment goals and risk profile. Pursuant to its discretionary authority, in certain circumstances, WRFA will retain one or more third party managers (Subadvisors) to employ a specific investment strategy consistent with the client’s investment objectives. The Subadvisor will be provided with the discretionary authority to invest client assets in separately managed accounts (SMAs) that are custodied separately from assets directly managed by WRFA. WRFA maintains its fiduciary responsibility over subadvised portfolios and is responsible for the due diligence and ongoing monitoring of any Subadvisors. The Subadvisor will charge a management fee for its services. For subadvised accounts, WRFA will offset its fee by the rate charged by the subadvisor, up to 100% of the management fee that would have been charged if the account was managed directly by WRFA. We utilize a third-party platform to facilitate the management of held-away assets in which we will have discretionary authority to implement tax-efficient asset allocation and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, 529 Plans, HSAs and other assets which are held at third-party custodians. We regularly review the available investment options in these accounts, monitor and rebalance and implement our strategies in the same way we do other accounts, though using different tools

as necessary. WRFA is limited by the universe of investments offered by the custodian(s) for these held-away accounts. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the client allowing them to connect a held-away account(s) to the platform. Once the client’s account is connected to the platform, WRFA will review the current account allocations. We seek to align the client’s held-away account(s) with their overall investment time horizon, risk tolerance, and investment goals. When deemed necessary, WRFA will rebalance the account considering client’s investment profile, as well as changes in economic and market trends. In addition to managing the client’s investment portfolio, WRFA consults 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, and establishment and design of retirement plans, among other things. These consultations are not specifically identified as contractual terms between the client and WRFA and will be provided as mutually deemed necessary by WRFA and the client. WRFA offers investment consulting and/or financial planning services apart from the Investment Management Services listed above. Among other things, WRFA will work with clients to determine the client's investment objectives and investor risk profile, and will analyze the client's current investment program, making recommendations (including asset allocation models) where appropriate. Investment Consulting and Financial Planning Services provide advice on various financial planning topics as mutually deemed necessary by WRFA and a client. Employee Benefit Retirement Plan Services WRFA also provides advisory services to the sponsors/plan fiduciaries of participant- directed retirement plans. WRFA 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 any restrictions imposed. WRFA will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. WRFA will recommend changes in the plan's investment vehicles as appropriate from time to time. WRFA will review the plan's investment vehicles and investment policy as necessary. WRFA will also assist the plan sponsor/trustee with selecting a third-party administrator for plan administration and assist the plan to coordinate activities with an administrator. WRFA will recommend one or more third party administrators that generally offer platforms enabling transactions in securities recommended by WRFA, and daily account access to participants. In certain circumstances, an attendee at a participant education meeting asks the WRFA person leading the session to address issues specific to that attendee's situation. The WRFA representative could then choose to privately address that person's questions. Any such specific advice will be provided to that participant only and at no charge, in the hope the participant would be interested in using WRFA's services. All such specific advice is entirely separate and distinct from the education services provided to pension plan participants by WRFA. WRFA 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.