A. Adviser Background - Independent Financial Group, LLC (IFG, Adviser, Firm) is a privately owned Registered Investment Adviser (RIA) registered with the Securities and Exchange Commission (SEC) since 2004, a broker/dealer and member of the Financial Industry Regulatory Authority (FINRA) since 2003 and a member of the Securities Investors Protection Corporation (SIPC). Independent Financial Group, Inc., a domestic entity, is the principal owner of Adviser. B. Advisory Services - Adviser offers a variety of financial planning and advisory services through Investment Adviser Representatives (IARs) who are, in most cases, also Registered Representatives (RRs) affiliated with IFG. IARs are independent contractors and may be involved in other business activities including, but not limited to, insurance sales, estate planning and tax preparation. Additional information regarding a particular IAR’s other business activities is disclosed in the respective IAR’s Form ADV Part 2B. The specific types of advisory services to be provided will be determined by the client and the IAR. These services include, but are not limited to, discretionary and non-discretionary portfolio management, asset allocation within a portfolio, day-to-day investment decisions, referrals to third party asset managers, financial planning, Wrap Accounts, and consulting services. Additionally, IFG provides Retirement Plan Services (RPS) to ERISA and non-ERISA retirement plans. As a registered broker-dealer, IFG offers brokerage services; in some instances, advisory clients may also receive brokerage services. Whether an IAR offers a client brokerage or advisory services or a combination of both depends on various factors including client’s needs, stated investment goals and objectives, investment style and trading preferences. Each client should take time to consider the differences between a brokerage and advisory relationship to determine which type(s)of service(s) best serve(s) their needs. In the disclosure section of IFG’s website (www.ifgsd.com) titled “Understanding the Difference between Brokerage and Investment Advisory Services.” IFG provides information to assist clients with determining the most appropriate relationship(s) for their situation. Please note that there is no guarantee that the advisory services offered will result in meeting a client’s goals and objectives nor is there any guarantee of profit or protection from loss. No assumption can be made that any particular advisory service or strategy will provide better returns than other investment strategies. Descriptions of IFG’s advisory programs are provided below. Technology - IAR may utilize AccessPoint, IFG’s primary asset management platform. The AccessPoint platform is provided by Envestnet. Envestnet is a subsidiary of Envestnet, Inc., a publicly held company (NYSE: ENV). Envestnet provides portfolio management services to retail clients as well as institutional clients. Envestnet also provides Adviser with an extensive range of investment advisory services for use by IARs with their clients through its Managed Accounts Network (Private Wealth Management) programs, available through AccessPoint. These programs include Separately Managed Accounts, Unified Managed Accounts and Third‐Party Fund Strategists. In addition to the Envestnet advisory services offered in the programs, Envestnet also offers IARs advisory service tools and services. The services offered by Envestnet include, but are not limited to: (1) assessment assistance regarding the client’s investment needs and objectives; (2) investment policy planning assistance; (3) development of an asset allocation strategy designed to address the client’s objectives; (4) recommendations on suitable style allocations; (5) identification of appropriate managers and investment vehicles suitable to the client’s goals; (6) evaluation of asset managers and investment vehicles meeting style and allocation criteria; (7) engagement of selected asset managers and investment vehicles on behalf of the client; (8) review of client accounts to ensure adherence to policy guidelines and asset allocation; (9) recommendations for account rebalancing, if necessary; (10) online reporting of client account’s performance and progress; and (11) fully integrated back office support systems to IAR, including interfacing with client’s custodian, trade order placement, billing and performance reporting. IARs determine which services and programs to utilize with their clients and may utilize the programs of other third‐party services providers in conjunction with these programs. Custody – Adviser utilizes third-party custodians to custody client assets. Pershing LLC, Charles Schwab & Co., American Funds and other third-party custodians may be approved by IFG from time to time, act as qualified custodians for Program (as such term is defined below) assets, as applicable. In addition, clients will receive account statements from the respective Program custodian. With IFG approval, IARs may also provide additional reporting services to their clients. Clients are encouraged to review and compare the account information in the performance reports and any additional IAR reports to the statements provided by custodians. Portfolio Management Programs – In providing portfolio management services to client accounts, IARs may utilize one or more of the following programs. 1. Adviser Portfolios: AP Client (PWV), CAM Client (JGD), Adviser Plus*(0BW), Adviser Plus II (AGY) and Legacy NPB (NPF): - The AP Client, CAM Client, Adviser Plus, Adviser Plus II and Legacy NPB Programs (each a “Program” and collectively “Programs”) offers participants asset allocation, brokerage services, consolidated reporting and periodic recommendations based on stated investment objectives. To participate in one of these Programs, IAR and client enter into a program specific investment advisory services agreement. Clients may authorize IAR to execute transactions on a discretionary or non-discretionary basis. Non-discretionary accounts are not available in the AP Client Program. Pershing, LLC (Pershing), a BNY Mellon Company based in Jersey City, NJ provides custodial and execution services with respect to these Programs. Program accounts are billed quarterly or monthly in advance or in arrears depending on the agreement between client and IAR. Pershing will provide custodial statements for each Program account. Eligible assets include stocks, bonds, mutual funds, Exchange Traded Funds (ETFs), structured products, fixed income and other securities. When utilizing mutual funds, only no-load or load-waived mutual funds may be purchased within Program accounts. Margin, mutual fund systematic investments, mutual fund systematic withdrawals and options (specifically covered calls and puts) may be permitted in Program accounts as indicated in the advisory services agreement. Options and margin accounts require the client to complete and sign additional forms that need to be reviewed and approved before option or margin activity can occur. 2. CAM Client Schwab (Freedom-One Schwab) Program Services: Adviser has entered into an advisory services agreement with Charles Schwab & Co. (Schwab), to provide custody and execution services for Adviser’s CAM Client Schwab programs. The CAM Client Schwab programs offer participants asset allocation, brokerage services, consolidated reporting and periodic recommendations based on stated investment objectives. To participate in the CAM Client Schwab program, IAR and client enter into a program specific investment advisory services agreement whereby the client directs the opening of a custodial account at Schwab. Client may authorize IAR to execute transactions on a discretionary or non-discretionary basis. Schwab Program accounts are billed quarterly or monthly in advance or in arrears depending on the agreement between client and IAR. Schwab will provide custodial statements for each client account. Eligible assets include stocks, bonds, mutual funds, Exchange Traded Funds (ETFs), structured products, fixed income and other securities. When utilizing mutual funds, only no-load or load-waived mutual funds may be purchased within Schwab Program accounts. Margin, mutual fund systematic investments, mutual fund systematic withdrawals and options (specifically covered calls and puts) may be permitted in Schwab Program accounts as indicated in the advisory services agreement. Options transactions and margin accounts require the client to complete and sign additional Schwab forms that need to be reviewed and approved by Schwab before margin or options activity can occur. 3. Variable Annuity and Variable Life Program Services: Offer the client the opportunity for management of annuity or variable life sub-accounts on a fee basis. Services may include asset allocation, consolidated reporting and periodic recommendations on annuities and variable life insurance based on clients’ stated investment objectives. The services offered consist of but are not limited to:  Initial consultation on the merits and benefits related to various sub-accounts as a component of the client’s total asset allocation.  Directing the investment and reinvestment of the subaccounts in accordance with the client’s investment objectives.  Consultation and advice on re-allocations if and when appropriate.  Monitoring the investments, reviewing, reporting and consulting. To participate in a Variable Annuity and Variable Life Program, IAR and client enter into an investment advisory services agreement. The client may authorize IAR to execute transactions on a discretionary or non-discretionary basis. Variable Annuity and Variable Life Program accounts are billed monthly or quarterly in advance or in arrears depending on the agreement between client and IAR. The applicable sponsor will provide custodial statements for client accounts. 4. Financial Planning and Consulting Services: IAR may provide financial planning and consulting services for a fee. All fees and services

are based upon the complexity of the work, the professional level of the IAR providing the services and other general market factors. The amount to be charged is negotiable and the amount as well as the payment arrangement are outlined in the Financial Planning/Consulting Agreement (FPCA). As agreed, services can be for a one-time deliverable or on-going as specified in the FPCA. Payment arrangement options include charging an hourly fee, a fixed dollar amount or, in certain situations, an on-going fee through a retainer arrangement. Retainer arrangements will generally charge fees on a monthly or quarterly basis; at no time will such fee be charged six months or more in advance of services rendered and/or in an amount of $1,200 or more. Financial planning clients are under no obligation to implement such recommendations through IAR. General categories of financial planning or consulting services include:  Basic Financial Planning or Consultation: Basic financial planning/consulting will identify a client’s current goals and objectives and create a roadmap which assesses the client’s current situation and document steps to help assist the client with addressing their financial goals.  Comprehensive Financial Planning: Comprehensive financial planning takes a holistic planning approach that includes assisting clients with their complete financial picture and incorporating sophisticated technology seeking to help optimize their results.  Advanced Planning / In-Depth Financial Consulting and/or Plan Module: This service is generally an in-depth review and analysis on one or more specific topics that requires specialized knowledge or experience. 5. Third Party Asset Manager Services: IFG has entered into a relationship with a number of third-party asset managers (TPAMs). TPAMs are approved after a due diligence process, and are selected, in part, based on whether they offer competitive products, their technology, their customer service, and their training capabilities. TPAM services include, but are not limited to, model portfolio programs, mutual fund and ETF wrap programs, separately managed account programs and management of the selection and allocation of variable annuity and variable life insurance sub-accounts. TPAM portfolios may consist of a variety of different security types, including stocks, bonds, ETFs, mutual funds, and derivatives. Additionally, certain programs provided by TPAMs are wrap fee programs, whereby the client pays a “wrap fee”, which is an asset-based fee that includes advisory fees, and brokerage service costs under an all-inclusive program fee. The program fees paid by client for wrap accounts may be higher or lower than advisory fees and commissions which the client could negotiate separately for the same services. Information regarding any TPAM wrap fee programs will be provided in the TPAM’s applicable wrap fee brochure. In providing TPAM services, Adviser acts either as a Promoter or as a co-advisor/sub-advisor to the TPAM. Promoter – A Promoter is an entity or person who provides an endorsement for compensation. When acting as a Promoter (formerly called a solicitor) for a TPAM, IFG and IAR do not provide portfolio management services. Instead, IAR will assist the client with selecting one or more TPAMs believed to be suitable based on various criteria such as the client’s stated: risk tolerance, investment objectives, and financial goals. The IAR will be responsible for assessing the suitability of the TPAM products and services against the client’s risk profile. IFG and IAR are compensated for the referral to the TPAM. This compensation generally takes the form of the TPAM sharing a percentage of the advisory fee you pay to the TPAM with IFG and IAR. When IAR acts as a Promoter, the TPAM will provide you with its disclosure brochure and a written Promoter disclosure statement describing the nature of IFG and IAR’s relationship with the TPAM, if any, the terms of the compensation arrangement, and a description of the compensation received for referral to the TPAM. Please consult the applicable TPAM agreement and other information and documentation for further information. Co-Adviser/Sub-Adviser - When acting in a co-adviser or sub-adviser capacity, IAR and the TPAM are jointly responsible for the ongoing management of client’s account. IAR will assist with the completion of the investor profile questionnaire. Responses to this investor profile will assist IAR with understanding client’s investment objectives, financial situation, risk tolerance, investment time horizon and other relevant aspects of your investment needs and goals. Based on the information provided, IAR will assist with determining which TPAM, model and/or portfolio strategy is appropriate. Additionally, IAR will periodically monitor the TPAM’s performance, investment selection, and continued suitability and will advise accordingly. In addition to the advisory relationship that you will have with the TPAM, you will also enter into an advisory relationship with IFG by completing and signing our Account Application and Agreement. As part of establishing an account with the TPAM, you will receive both IFG’s disclosure brochure as well as the TPAM’s disclosure brochure. Since each TPAM is different and involves different types of investment products, it is important that you carefully review all documents provided to you on behalf of the TPAM. These include, but are not limited to:  The TPAM’s Form ADV Part 2A or Disclosure Brochure for specific program descriptions.  The TPAM’s Client Agreement as well as any other agreement entered into regarding a TPAM program, for specific contractual terms (including fees, billing methods, administrative and other fees, etc.).  Any additional disclosure or offering documents provided by the TPAM in connection with investment programs and/or products. The services provided by IFG and IAR through a TPAM are under certain conditions directly offered by them to you. The fees charged by TPAMs who offer their programs directly can be more or less than the combined fees charged by the TPAM and IFG for IFG’s participation in the investment programs. Additionally, the specific TPAM advisory program you select may cost more or less than purchasing these combined services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same service purchased separately include, but may not be limited to the type and size of the account, the historical or expected size or number of trades for the account, the types of securities and strategies involved, the amount of fees, commissions, and other charges that apply at the account or transaction level, and the number and range of supplementary advisory and client-related services provided to the account. Lower fees for comparable services are available from other sources. Client Needs – IAR conducts initial meetings with each potential advisory client to discuss their financial needs, personal goals, risk tolerance, time horizon and overall investment objectives. It is imperative that the client provide accurate and complete information and promptly inform IAR of any material changes in their circumstances so IAR can evaluate if adjustments to the advisory accounts are necessary. Clients may impose restrictions on investing in certain securities or types of securities in most advisory programs. Wrap Program - The various wrap fee programs offered through IAR are available on a discretionary or non-discretionary basis and are tailored to the needs of the client. In order to establish a program account, the client will be required to sign an investment advisory agreement with Adviser. A wrap fee program allows clients to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in client’s account. Transaction fees will be paid by the Firm via individual transaction charges or asset-based pricing arrangements with the broker/custodian. Since the client’s fee is bundled with the costs for executing transactions in client’s account(s), this generally results in a higher advisory fee to the client versus the advisory fee in non-wrap arrangements where the client pays for transaction services separately. IFG and IAR do not charge clients a higher advisory fee based on their trading activity in client accounts, but clients should be aware that IFG and IAR may have an incentive to limit the trading activities in client account(s) because IFG and IAR pay for trading costs. By participating in a wrap fee program, client may end up paying more or less than through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed through to client. IFG offers Investment Model Services that consists of model portfolios managed on a discretionary basis by IFG’s Director, Research & Portfolio Construction. The models cover a range from “Conservative” to “Aggressive Growth” and use various asset classes including but not limited to domestic equities, global equities, fixed income, and liquid alternative investments. The model portfolios will be rebalanced at the discretion of the Director. IFG’s overall compensation may be greater when investors use these services. Client pays an annual advisory fee based on a percentage of assets under management according to the fee schedules provided below. In certain instances, advisory fees are negotiable. An IAR recommending a wrap program to a client receives compensation as a result of client’s participation in the program. The amount of this compensation may be more or less than what the IAR would receive if the client participated in other programs offered by Adviser or paid separately for investment advice, brokerage and other services. Therefore, the IAR may have a financial incentive to recommend one program over other programs or services. 6. Client Assets Under Management: As of December 31, 2023 Adviser manages a total of $6,750,889,023 of which $5,738,255,670 in assets are managed on a discretionary basis and services $1,012,633,353 in non-discretionary assets.