Donald V. Davey formed Disciplined Equity Management, Inc. in 2002. DEM provides discretionary investment supervisory services to individuals, trusts, estates, small business owners, pension plans and charitable entities. Each client account is managed according to the specific goals and objectives of the client, as stated in the Investment Policy Statement signed by the client. Therefore, even when using the same investment strategy for more than one client, not all client accounts will necessarily hold identical positions. Any restrictions imposed on the management of the account must be included in the Investment Policy Statement. DEM offers the following investment strategies: Individual Stock Strategies: The US Large-Cap Growth Strategy selects US large-capitalization stocks with above-average long-term and short-term earnings and price trends. The goal of the strategy is to provide long-term capital growth. The US Large-Cap Value Strategy selects US large-capitalization stocks with above-average dividend yields and financial strength. The goal of the strategy is to provide a rising dividend stream in addition to participation in the long- term growth of equities. The Blue Chip Core Portfolio is an equal blend of the Large-Cap Growth and Large-Cap Value Strategies. Mutual Fund and ETF Strategies: DEM may either replace or complement the individual stock strategies with no-load equity and fixed-income mutual funds and/or exchange-traded funds (ETFs). DEM primarily utilizes the Dimensional Fund Advisors family of funds to implement the mutual fund strategies. Separately Managed Accounts (SMA): DEM may elect to engage a sub-adviser to manage a particular strategy within a client’s portfolio through the custodian’s SMA

platform. An SMA would primarily be used for taxable accounts of sufficient size that could benefit from greater diversification and tax management. DEM selects strategies offered by Dimensional Fund Advisors which employ the same low-cost, low turnover, high diversification philosophy they follow in their mutual funds and ETFs. DEM may provide financial planning services to asset management clients. These services are included in the investment advisory services offered and are not subject to additional fees or execution of a separate contract. As of December 31, 2023, DEM has discretionary assets under management of approximately $371,551,837. DEM does not manage any non-discretionary assets. Investment Advice Specific to Retirement Account Rollovers When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care (give prudent advice)
• Never put our financial interests ahead of our clients (give loyal advice)
• Avoid misleading statements about conflicts of interest, fees, and investments
• Follow policies and procedures designed to ensure that we give advice in client’s best interest
• Charge no more than is reasonable for our services
• Give you basic information about our conflicts of interest.