A. Description of the Advisory Firm This firm has been in business since August 1997 and the principal owner is Gerald C. Steffes. B. Types of Advisory Services Steffes Financial, Ltd. (hereinafter “Steffes Financial”) offers the following services to advisory clients: Discretionary Investment Advisory Account Management Steffes Financial offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Steffes Financial creates an Investment Policy Statement for each client, which outlines the client’s current situation (investment objectives and risk tolerance levels) and then outlines an investment strategy (the Investment Policy Statement). Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Steffes Financial evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Steffes Financial will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Individual Qualified Retirement Account and Tax-Deferred Annuity Investment Consulting Steffes Financial provides Retirement Account and Tax-Deferred Annuity Investment Analysis and Asset Allocation Recommendation services to individual qualified retirement account participants and Tax-Deferred Annuity owners on an individual per engagement basis. Steffes Financial provides recommendations and advice to individual plan participants regarding the investment choices within the participant’s qualified retirement plan. Steffes Financial does not undertake any obligation for the implementation of the client's retirement account asset allocation changes. Implementation of any asset allocation recommendations is entirely at the discretion of the client. The client is under no obligation to make any product purchases through Steffes Financial. Financial Planning Steffes Financial provides financial planning and/or consulting services to individuals and institutions that are consistent with the clients’ financial and tax status, in addition to their risk profile and return objectives. Steffes Financial will also provide general non-securities advice on topics that including tax and budgetary, estate and business planning. Financial plans and financial planning can include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt planning. These services are based on hourly fees and the final fee structure is documented in the Financial Planning Agreement. Steffes Financial does not provide delivery of a written financial plan. Qualified Retirement Plan Services Steffes Financial offers qualified retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services Steffes Financial provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. Steffes Financial will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Investment Selection Services. Steffes Financial will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. Steffes Financial will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and Steffes Financial does not serve as administrator or trustee of the plan. Steffes Financial does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). Steffes Financial acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Steffes Financial will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Steffes Financial to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Steffes Financial (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. If Client has elected to receive only Fiduciary Consulting Services and no Fiduciary Management Services as described under Fiduciary Management Services below, then Steffes Financial and you will acknowledge and agree that we (a) have no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of your retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of your retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of your retirement plan or the interpretation of your retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of your retirement plan as defined in ERISA. Our clients represent that employment of Steffes Financial, and any instructions that have been given to us with regard to the qualified retirement plan are consistent with applicable plan and trust documents. Our clients will agree to furnish Steffes Financial with copies of such governing documents, upon request. Fiduciary Management Services If a client uses our Fiduciary Consulting Service, Steffes Financial offers the client our Fiduciary Management Services, which is discretionary investment selection. Steffes Financial will monitor the investment options of the Plan and add or remove investment options for the Plan. Steffes Financial will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. If you elect to utilize any of Steffes Financials’ Fiduciary Management Services, then Steffes Financial will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and Steffes Financial hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined

by the advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. Steffes Financial provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. Steffes Financial will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Steffes Financial’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. Steffes Financial will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Steffes Financial will disclose, to the extent required by ERISA Regulation Section 2550.408b- 2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Retirement Plan Rollover Recommendations When Steffes Financial, Ltd. provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Steffes Financial, Ltd. is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way Steffes Financial, Ltd. makes money creates conflicts with your interests so Steffes Financial, Ltd. operates under a special rule that requires Steffes Financial, Ltd. to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Steffes Financial, Ltd. must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Steffes Financial, Ltd. ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Steffes Financial, Ltd. gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Steffes Financial, Ltd.; and
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Steffes Financial, Ltd., please know that Steffes Financial, Ltd. and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Steffes Financial, Ltd. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Steffes Financial, Ltd. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Steffes Financial, Ltd. receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Steffes Financial, Ltd. and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Steffes Financial, Ltd. or our affiliated personnel. Services Limited to Specific Types of Investments Steffes Financial generally limits its investment advice and/or money management to mutual funds, exchange traded funds, equities, bonds, fixed income, and debt securities. Steffes Financial has the potential to also use other securities to help diversify a portfolio. C. Client Tailored Services and Client Imposed Restrictions Steffes Financial offers the same suite of services to all clients. However, specific client financial strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (investment objectives and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients are allowed to impose written restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Steffes Financial from properly servicing the client account, or if the restrictions would require Steffes Financial to deviate from its standard suite of services, Steffes Financial reserves the right to end the relationship. D. Wrap Fee Programs Steffes Financial does not participate in any wrap fee programs. E. Amounts Under Management Steffes Financial has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 289,138,241 $ 206,019,308 12/31/2023