We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed in the State of California. Our firm has been in business as an investment adviser since 2004 and is owned 100% by Robert D. Chatterton, President. We offer the following advisory services: Asset Management: We offer discretionary and non-discretionary asset management services based on the individual needs of the client. Understanding your personal situation is very important to the services we provide. Therefore, we will have detailed discussions with you to understand your current financial situation and investments, goals, risk tolerance and investment objectives. The investment objective you select will guide us in managing your account. Our firm recommends that certain clients allocate investment assets among the various mutual fund asset allocation models, underlying mutual funds, and/or independent investment manager programs offered through SEI Investments Company (“SEI”). SEI is a global asset management company and sponsor of its own proprietary mutual funds. SEI Private Trust Company (“SEI Trust”), a subsidiary of SEI, serves as custodian for each SEI account (SEI and SEI Trust collectively referred to as “SEI”). SEI provides each client with reporting services, including consolidated monthly statements, quarterly performance reports, and year-end tax reports. SEI enables investment advisers such as our firm to offer our clients mutual fund asset allocation models, underlying individual mutual funds, and investment management programs that are not otherwise available to the general public. As part of its overall investment management program, SEI offers quarterly rebalancing of each client’s investment assets for the purpose of maintaining the assets in accordance with the client’s previously designated percentage (%) asset allocations for the SEI account, if elected by the client. If a client desires automatic account rebalancing, he/she must first provide such authorization directly to our firm, who will then advise SEI accordingly. If the client selects a customized model rather than an SEI asset allocation model, the client’s account will not be eligible for automatic rebalancing by SEI. In this case, our firm will provide recommendations or rebalancing based on the client’s goals and objectives. Our firm shall not remove clients’ account from SEI to another program without the client’s consent. The fees charged by SEI are exclusive of, and in addition to, our firm’s investment management fee. In addition to our firm’s investment management fee, the client, relative to all mutual fund purchases, shall also incur charges imposed at the mutual fund level (e.g., management fees and other fund expenses). Our firm intends to primarily allocate investment management assets of our client accounts among various investment management programs offered through SEI Investments Company (“SEI”) and various independent investment managers on either a discretionary or non-discretionary basis, as elected by our client and in accordance with the investment objectives of our client. In order for us to manage your assets, you will be required to enter into an investment advisory agreement with Chatterton & Associates and an agreement with SEI. The agreements will set forth the terms and conditions of our relationship, including the amount of your investment advisory fee. You will retain all rights of ownership on your account, including the right to withdraw securities or cash and vote proxies. In addition, you will also have the ability to impose restrictions on investing in certain securities or types of securities at the time you open an account. Chatterton & Associates provides financial industry informational newsletters to clients on a regular basis free of charge. Chatterton & Associates also hosts occasional free educational seminars for current and prospective clients. Retirement Plan Advisory and Consulting Services: Chatterton offers Retirement Plan Advisory and Consulting Services to employee benefit plans and their fiduciaries. We will acknowledge our status as a fiduciary under Sections 3(21) and 3(28) of the Employee Retirement Income Security Act of 1974 (“ERISA”). Section 3(21) of ERISA

applies to any investment consulting services we provide to Plans covered by ERISA and Section 3(38) of ERISA applies to when we provide discretionary investment services to Plans covered by ERISA. There are important differences among these services in terms of the type of service, structure and administration, and fees. Please review this brochure carefully as you decide which of these services is appropriate for your investment needs. Retirement Plan Consulting Services
• We can assist Plans by acting as a liaison between each Plan and its service providers, product sponsors and/or vendors. In such cases, Chatterton shall act only in accordance with instructions from the Client on investment or Plan administration matters and will not exercise judgment or discretion.
• We provide education, training, and guidance for the members of a Plan Committee with regard to plan features, retirement readiness matters, or duties and responsibilities of the Committee, including education with respect to fiduciary responsibilities.
• We can assist with participant education, which may include preparation of educational materials or conducting general investment education seminars and meetings for Plan participants.
• We can assist with the preparation, distribution and evaluation of “requests for proposals” or “requests for information,” finalist interviews, and conversion support with respect to service providers.
• We provide benchmarking services with comparisons of Plan data to data from prior Plan years and/or a benchmark group of similarly situated plans. Discretionary Investment Advisory Services When acting as your investment manager under Section 3(38) of ERISA, Chatterton can assist Clients in the development of an Investment Policy Statement (IPS) and provide discretionary investment management services to Plans, including:
• We provide ongoing and continuous discretionary investment management with respect to the asset classes and designed investment alternatives available under the Plan in accordance with the IPS.
• We offer a selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• We monitor investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and determining next steps with investment options.
• We meet with Clients on a periodic basis to discuss the periodic investment reports and investment decisions.
• We provide asset allocation services to participants of the Plan as an asset allocation tool among the Plan’s designated investment alternatives.
• We provide assistance in educating participants regarding how the asset allocation service functions and how it differs from the Plan’s designated investment alternatives. Non-Discretionary Investment Advisory Services
• We can assist the Plan in the preparation or review of an investment policy statement (“IPS”) after consulting with client.
• We provide ongoing investment recommendations. Chatterton will recommend, for consideration and selection by Client, specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. We will recommend for consideration and selection by Client, investment replacements if an existing investment is determined by the Client to no longer be suitable as an investment option.
• We provide ongoing investment monitoring. Chatterton will perform ongoing monitoring of investment options in accordance with the criteria provided by the Client to the Chatterton.
• We can assist in identifying for client an investment product or service in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA for Plans subject to ERISA.
• We provide Periodic Performance Reporting As of December 31, 2023, we had approximately $1,054,329,820 in regulatory assets under management, approximately $189,929,846 of which was managed on a discretionary basis and approximately $864,399,974 of which was managed or advised on a non-discretionary basis.