Armor Investment Advisors, LLC is a private fiduciary wealth management and asset preservation firm. Armor was established in 2005 and is owned by partners Jeffrey R. Miller, John V. Purrington, Matthew C. Miller, Graham F. Shepherd, Allison R. Miller, and Adam J. Morgan. John Purrington is the principal owner, meaning that he owns 25% or more of Armor. We hold ourselves to a fiduciary standard with respect to our clients and their wealth:
• We will always put the clients’ best interests first, ahead of our own and those of our firm and its employees. We will always act as a fiduciary.
• We will act with prudence; that is, with the skill, care, diligence, and good judgment of a professional. When selecting investments, we will act as the client’s agent, seeking the best investments at the best prices at all times.
• While neither we nor anyone can promise superior investment returns, we will provide impartial advice.
• We will always be truthful with our clients, providing full and fair disclosure of all important facts, including our compensation from all sources, as well as fees we pay to others on our clients behalf.
• We will always seek to avoid conflicts of interest. We will fully disclose any potential conflicts, and place the client’s interest first at all times. Our management philosophy is to always work as a Team, not only among ourselves but also with external resources and with our clients’ attorneys, accountants, and other professional parties. As of December 31, 2022, Armor managed $293,718,341 for clients on a discretionary basis. In addition, Armor advised 401(k) plan assets of $24,540,147 which are not included in this total. The types of advisory services provided by Armor can generally be grouped into four categories:
• Comprehensive financial planning for individuals and families
• Investment management for individuals, families, and foundations
• Investment consulting services
• Investment consulting services to participant directed retirement plans Before engaging Armor to provide advisory services, clients are required to enter into one or more written agreements with Armor setting forth the terms and conditions under which Armor will perform its services. Investment Discretion refers to the sole or shared authority (whether or not exercised) to determine what securities or other assets to purchase or sell on behalf of a client. Financial Planning As a family’s wealth increases, risk management and wealth preservation grow in importance. Financial planning, estate planning, investment management, and asset protection are all forms of risk management, but the risks addressed by each are different. A comprehensive planning process incorporates all areas. We begin our comprehensive planning process by defining and understanding our client’s goals, identifying risks to their attainment, and designing strategies for managing those risks. Planning requires an ongoing analysis of changing conditions with corrections and adjustments in response to these. Planning is an ongoing process, not a static plan. For this reason, we look at all financial planning engagements as lasting at least twelve months. We execute planning for our clients, not with static documents, but with ongoing Risk Assessments and Action Plans. These are highly personalized because every client’s goals and risks are unique. Armor’s Financial Wellness Service offering is a tailored financial planning offering for individuals and families who are high earners that have not yet accumulated the assets to warrant paying Armor’s minimum fee for Investment Management, but desire financial planning, investment guidance, and a personal ongoing relationship. We organize the Risk Assessments and Action Plans into the following broad categories which we review for corrections and adjustments each time we meet.
• Current and Future Income Protection
• Leverage and Debt Management
• Accumulation and Investment Planning
• Asset Protection
• Longevity Planning
• Estate Planning and Distribution Our investment management decisions are built on an understanding of the goals for the rest of our clients’ lives (financial planning) and for the legacies to our client’s children, grandchildren, and charities (estate planning). We find that the essence of our value to our clients is our personal wealth management process and not just a stand- alone approach to investment management. Investment Management Our approach to investment management seeks to balance long-term goals and return expectations with current income needs and the risk of volatility. We constantly ask whether, in addition to managing market risks, we also are managing the unique risks that could affect the achievement of each client’s personal goals. For this reason, our comprehensive Financial Planning services are incorporated into our Investment Management offering with no additional fee. Prior to entering into an investment advisory arrangement, we work with each client to understand their individual situation. For each group or pool of accounts we manage, we create a Client Investment Policy Statement. The Client Investment Policy Statement documents the accounts to be managed as part of the pool as well as any non-managed assets that

should be considered as part of the asset allocation decision. The pool’s time horizon and income needs, coupled with the client tax situation are documented as well as any unique restrictions which might be imposed. Like a financial plan, the Client Investment Policy Statement is a living document which must be reviewed and updated at least annually. Clients are advised to promptly notify Armor if there are any changes to their financial situation or investment objectives, or if they wish to impose restrictions on the management services. Once we have documented a client’s particular situation, we build a custom portfolio meeting the individual needs of that client. Our investment management process is described in Item 8, below. Investment Consulting Our approach to investment consulting is similar to our approach to financial planning, except that investment consulting clients generally are institutional entities (companies, charitable trusts, foundations, and other tax-exempt entities). Our approach emphasizes risk management. We focus on identifying the investment objectives of our clients and designing risk-managed strategies that seek to achieve these. The steps in our investment consulting process include:
• Identification of client goals and cash needs
• Identification of risks to goal-attainment
• Adoption of a written Investment Policy Statement
• Design of asset allocation and other investment strategies, guidelines and policies
• Selection of risk and performance benchmarks for ongoing monitoring
• Recommendation of investment managers or funds
• Ongoing monitoring of risk management and performance Our investment consulting clients often have multiple investment pools, each of which has its own goals and needs. Examples are capital reserves, endowment funds, and pension assets. Distinct policies, strategies, and monitoring processes are usually required for each situation. Our investment consulting services differ from investment management services in that our consulting services do not include the day-to-day selection of securities or trading. Investment Consulting to Participant Directed Retirement Plans A special type of investment consulting that we provide is our advice to participant directed retirement plans, such as 401(k) and 403(b) plans. Our approach, as well as the steps in the process, is very similar to those in our other consulting services; but differences result from the fact that there often are hundreds of participants in a plan, each of which has different goals and needs. Differences also result from the ERISA The Employee Retirement Income Security Act of 1974 is a federal law that establishes minimum standards for pension plans. application of federal pension laws to these plans. The fiduciary responsibilities of plan sponsors, trustees, and investment advisers are great. It is crucial that all fiduciaries understand their responsibilities. We help educate fiduciaries and share ERISA 3(21) responsibility with the plan sponsors and trustees. Upon request, we also will assume a higher level of fiduciary responsibility by written acceptance of our status as a 3(38) plan fiduciary. In all cases, special requirements that apply to participant-directed retirement plans include:
• Investment choices that are made available to participants must be prudently selected and provide a broad range of risk and return characteristics.
• Participants must have access to information on the suitability and performance of each choice.
• Participants must receive full and adequate disclosure about possible investment costs, volatility, losses and market fluctuations.
• Each investment choice must be well-diversified.
• Participants must have the ability to change their choices at least quarterly. As with other investment consulting services, the development of a written Investment Policy Statement is an essential part of the process. This written policy statement also specifies the ways in which the plan is meeting the special requirements for participant directed plans. Additionally, we recommend a number of characteristics that we consider essential to the success of participant directed retirement plans. These include:
• Low total costs, including the expense ratios of funds in the plan, recordkeeping, custody, administration and investment advisory fees.
• Manageable number of choices including a variety of asset classes. Attempting to meet fiduciary responsibilities by offering too many choices can be counter-productive. We recommend limiting the number of funds. For more sophisticated plan participants, inclusion of a “brokerage window” option can also be beneficial. In summary, our goal is to give prudent, expert advice to participant directed retirement plans. In providing investment consulting advice we share ERISA 3(21) fiduciary status with plan sponsors and trustees. If, in addition to this, we are appointed by the plan trustees to take over discretionary control of plan assets, we become an ERISA 3(38) fiduciary, and as such are solely responsible for the selection, monitoring, and replacement of a plan’s investment options.