KEB Asset Management, LLC d/b/a KEB Wealth Advisors (“KEB”) is owned by 28 individual members and has been providing advisory services since 1999. As of December 31, 2023, KEB managed $865,556,204 on a discretionary basis and $67,868,016 on a non-discretionary basis for a total of $933,424,220 in assets under management. Additionally, KEB advised on $124,828,640 of self-directed retirement account assets. Investment Management Services: KEB manages investment portfolios for individuals, trusts, partnerships, corporations, not-for-profit organizations and retirement plans. KEB will work with a client to determine the client's investment objectives and investor risk tolerance and will design a written investment policy statement ("IPS”). KEB uses investment and portfolio allocation software to evaluate alternative portfolio designs. KEB evaluates the client's existing investments with respect to the client's IPS. KEB works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by KEB. KEB will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. KEB will typically create a portfolio of no-load mutual funds and exchange-traded funds (“ETFs”), and may use model portfolios if the models match the client's investment policy. KEB will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. KEB primarily recommends portfolios consisting of passively managed asset class and index mutual funds and ETFs. KEB primarily recommends securities offered by Dimensional Fund Advisors (“DFA”). DFA-sponsored investments follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s IPS. KEB manages equity portfolios on a discretionary and nondiscretionary basis according to the IPS selected by the client. Clients may impose any reasonable restrictions on KEB’s discretionary authority, including restrictions on the types of securities in which KEB or any third-party money manager (“TPMM”) may invest client’s assets and on specific securities, which the client may believe to be appropriate. KEB may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. KEB requires discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, KEB may retain a TPMM for the ongoing management of all or some of a client’s portfolio. KEB utilizes BSP as the primary TPMM for client portfolios. The TPMM will be provided with the discretionary authority to invest client assets in securities consistent with the client’s IPS. The TPMM will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost-basis information). On an ongoing basis, KEB will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. KEB will periodically, and at least annually, review clients’ IPS, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. KEB will provide to the TPMM any updated client financial information or account restrictions necessary for the

investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, KEB may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: KEB also provides advisory services to employee retirement benefit plans. KEB will generally recommend a third-party administrator for plan administration, which may provide online bundled services and an opportunity for plan sponsors to provide diversified portfolios to their participants along with daily account access, valuation and investment education. KEB 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 the restrictions that may be imposed. KEB will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. KEB will recommend changes in the plan's investment vehicles as may be appropriate from time to time. KEB generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, KEB also works in coordination and support with Buckingham Strategic Partners, LLC (“BSP”) and other 3(38) fiduciary providers (“fiduciary provider”). Retirement plan clients will engage both KEB and the fiduciary provider. The fiduciary provider will administer to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. KEB 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. Financial Planning Services: KEB also provides financial planning advice. Clients purchasing this service may receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives or with a written plan addressing a specific financial planning topic. In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Tax & Cash Flow: Income tax and spending analysis and planning for current and future years. KEB may illustrate the impact of various investments on a client’s current income tax and future tax liability.
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio. KEB gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, and a written report is prepared. Should a client choose to implement the recommendations in the plan, KEB suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion.