Waterford is a fee-based investment adviser registered with the SEC with its principal place of business located in Orchard Park, New York. Our firm has been in business since 2000. SVT International owns 100% of Waterford Advisors.Gregory L. Kozerski, CPA, CFP®, AIFA, is the majority owner of SVT International and President of Waterford Advisors. As of December 31, 2022 our firm managed $268,906,450 of client assets all on a discretionary basis. Waterford Advisors provided ongoing advisory and consulting services to an additional $38,609,850 in assets under advisement. Portfolio Management Services Waterford provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, income tax situation, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We will manage advisory accounts on a discretionary or non-discretionary basis, as agreed with each client. Account supervision is guided by the objectives of the client which are reflected in their individual Investment Policy Statement (i.e., Aggressive Growth, Capital Growth, Balanced Growth, Conservative Growth or Capital Preservation), as well as tax considerations. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will primarily include advice regarding no-load or load- waived mutual funds and exchange-traded funds (ETFs). The asset allocation within individual portfolios may be different based upon the individual’s income tax situation, cash flow requirements and whether they are in the accumulation or distribution phase of their investment time horizon. Generally, mutual funds or ETFs are used as the underlying investment choice within a client’s portfolio and as such we are generally unable to accommodate individual investment restrictions such as socially responsible investing. We normally recommend that clients establish brokerage accounts with Schwab Institutional, a division of Charles Schwab & Co., Inc. (Schwab), a FINRA registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. We may also use TD Ameritrade Institutional, a division of TD Ameritrade, Inc (TD), a FINRA registered broker – dealer, member SIPC. Waterford is independently owned and operated and not affiliated with Schwab or TD. Model Portfolio Management Services Waterford may also manage portfolios for suitable clients through Orion Portfolio Solutions ("OPS"). OPS offers advisory services to Waterford (but not directly to clients) that consist of access to asset allocation programs and investment reporting services for use in the management of client accounts. Through OPS, Waterford may select asset allocation portfolios which diversify client assets among mutual funds. The mutual funds provided consist of no-load fund families and load-waived class A share funds covering all major asset classes. Currently, Waterford generally uses the Litman Gregory (LG) models or the Vanguard (VG) models at OPS although there are other strategists available which we may utilize. Each model portfolio represents a different asset allocation strategy. OPS retains third-party non-affiliated investment managers to design and manage model portfolios using mutual funds. In determining the initial allocation to be used, the client will complete a questionnaire which will be used to assist the client and Waterford in determining the suitability of OPS for the client. We will furnish continuous advice as to the investment of the client’s account at OPS based on the

client’s needs, current financial situation, financial goals and attitudes towards risk. This process will help us review the client’s situation and enable us to recommend an initial selection of a suitable asset allocation model. We may suggest a reallocation of the client’s portfolio based on changing economic conditions or changes in the client’s individual circumstances. Under the OPS platform, the client will be assumed to have directed that the account be automatically invested in accordance with all adjustments and rebalancing of the asset allocation model unless the client instructs us to terminate such automatic adjustment and rebalancing. Financial Planning Services Waterford provides its clients with a broad range of comprehensive financial planning and consulting services (including non-investment related matters). Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and distribution plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. In general, financial planning will address any or all of the following areas:
• Investment Advisory Services
• Retirement Accumulation and Distribution Planning
• Estate/Wealth Transfer Planning
• Income Tax Planning and Compliance
• Risk Management/Asset Protection Planning
• Elder Care/Long-Term Care
• Education Planning We gather required information through in-depth personal interviews and/or comprehensive questionnaires. Information gathered includes a client's current financial status (i.e. Net-Worth Statement), current and anticipated cash-flows, future goals and attitudes towards risk. We carefully review related documents supplied by the client, including a questionnaire completed by the client, and prepare a summary. Implementation of financial plan recommendations is entirely at the client's discretion. If a client wishes, and to the extent possible, Waterford is available to assist in the implementation of our financial planning recommendations. Our financial planning recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. If requested by the client, we may recommend the services of other professionals (i.e.: attorneys, actuaries, etc.) for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from us. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Waterford if there are ever any changes in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Consulting Services to 401(k), Pension and Profit Sharing Plans Waterford may enter into an agreement to provide guidance to the Trustee(s) or Board of Trustees of 401(k), Pension and Profit Share Plans to assist them in managing their fiduciary obligations and other activities as directed by the Trustee or Board of Trustees. In this capacity, we may attend quarterly meetings, may assist in the preparation of the Investment Policy Statement (IPS), may assist in the selection of investments, monitor client’s investments according to the adopted IPS, and participate in employee communications and education programs. The fee charged for services shall be a percentage of the plan’s assets under advisement and will be contained in a signed Consultation Agreement with each plan trustee.