Description of the Firm This brochure describes the business of CSIA. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of CSIA’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on CSIA’s behalf and is subject to CSIA’s supervision or control. CSIA, a wholly-owned subsidiary of Conrad M. Siegel, Inc. was founded in July 2002 and currently provides financial planning, consulting, and investment management services. The Firm is principally owned by the Parent Company. Prior to engaging CSIA to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with CSIA setting forth the terms and conditions under which CSIA renders its services (collectively the “Agreement”). Financial Planning and Consulting Services CSIA provides its clients with a broad range of comprehensive financial planning and consulting services. These services are customized for the individual client, but generally include retirement planning, investment planning, risk management, education planning (i.e., college savings), and estate planning. In performing its services, CSIA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. CSIA may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if CSIA recommends its own services. The client is under no obligation to act upon any of the recommendations made by CSIA under a financial planning or consulting engagement or to engage the services of any such recommended professional, including CSIA itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of CSIA’s recommendations. Clients are advised that it remains their responsibility to promptly notify CSIA if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising CSIA’s previous recommendations and/or services. Educational Services CSIA provides personalized and/or non-personalized investment-related educational training to certain clients. These services generally address issues involving employee participation in employer- sponsored retirement plans. CSIA holds employee educational meetings for many of its 401(k) clients and can provide participants with personalized education. The Firm does not contract with participants or charge a fee to participants but can include these educational services as part of the overall services it provides to its 401(k) clients. Fiduciary Oversight Services As a 3(21) fiduciary or 3(38) fiduciary under the Employee Retirement Income Security Act of 1974 (“ERISA”), CSIA provides guidance for clients by managing some or all of their fiduciary responsibilities. CSIA offers an array of oversight services to ensure compliance with the ERISA Fiduciary Rule. CSIA drafts Investment Policy Statements (“IPS”) and monitors them on a quarterly basis while providing notification and a recommended course of action if a client’s fund falls below the criteria set forth in the IPS. CSIA also meets with retirement plan sponsors to discuss the total cost associated of administering the plan. Similarly, CSIA also analyzes sponsors’ mutual fund usage, performances vs. benchmarks comparison and qualified default investment alternatives. Investment Management Services Clients can engage CSIA to manage all or a portion of their assets on a discretionary or non- discretionary basis. As further discussed in Item 8 (below), CSIA primarily allocates clients’ investment management assets among mutual funds, ETFs (as defined below) and collective investment trusts, in accordance with the investment objectives of the client. CSIA also provides advice about any type of investment held in clients' portfolios with the exception, in certain circumstances, of company stock. CSIA also renders non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, CSIA either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Additionally, CSIA serves as an ERISA 3(38) investment manager for a Pooled

Employer Plan (“PEP”) whereas Conrad M. Siegel, Inc. serves as the Pooled Plan Provider. Conrad Siegel’s PEP program allows unrelated employers to join the same qualified retirement plan, providing benefits such as reduced plan expenses and reduced fiduciary liabilities. Client Tailored Engagements CSIA tailors its advisory services to the individual needs of clients. CSIA consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. CSIA ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify CSIA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon CSIA’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in CSIA’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Siegel Select Portfolios Where deemed appropriate, certain investment management and financial planning services are provided by the Firm through the Siegel Select Portfolios (“SSP” or “Siegel Select Portfolios”) Program. Through SSP, CSIA offer clients a range of investment strategies the Firm has constructed and manages. Each strategy consists of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation in accordance with the investment objectives of the client. SSP portfolios are held in a brokerage account opened by the clients at Charles Schwab & Co., Inc. (“Schwab”). CSIA uses the Institutional Intelligent Portfolios platform offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Schwab, to make SSP available to clients online and includes a system that automates certain key parts of the Firm’s investment process (the “System”). The System includes an online questionnaire that helps CSIA determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that the Firm will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but CSIA then makes the final decision and selects a portfolio based on all the information the Firm has about the client. The System also includes an automated investment engine through which CSIA manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). The Firm charges clients a fee for its services as described below in Item 5. Clients whose portfolios are managed through SSP generally do not pay brokerage commissions or any other fees to Schwab as part of SSP. CSIA currently does not pay SPT fees for its services in SSP. Wrap Fee Programs Except to the extent described above, CSIA does not sponsor or participate in any wrap fee programs. DOL PTE 2020-02 Compliance CSIA is also 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 the laws governing retirement accounts when CSIA provides investment advice to individual clients regarding individual retirement accounts. The way CSIA makes money creates some conflicts of interests, so CSIA ensures to operate under a special rule which requires the Firm to act in the individual clients’ best interest and not put CSIA’s interest ahead of the individual clients. Pursuant to this special rule’s provisions, CSIA must: - Meet a professional standard of care when making investment recommendations (give prudent advice); - Never put the Firm’s financial interests ahead of individual clients when making recommendations (give loyal advice); - Avoid misleading statements about conflicts of interest, fees, and investments; - Follow policies and procedures designed to ensure that CSIA gives advice that in the best interest of individual clients; - Charge no more than is reasonable for services; and - Provide basic information about conflicts of interest (which is further discussed throughout this Brochure). Assets Under Management As of June 30, 2023, the Firm had approximately $7,774,909,225 in assets under management, of which $2,597,808,878 was managed on a discretionary basis. Additionally, $5,177,100,347 was managed on a non-discretionary basis.