Page 4 A. The Legacy Financial Group, Inc. The Legacy Financial Group, Inc. (“Legacy Financial” and/or “the firm”) is an Oklahoma corporation. The firm was formed in 2005 as the successor to a firm previously formed in 2000. Legacy Financial is principally owned by Kevin K. King. B. Advisory Services Offered Legacy Financial’s clients hire us to build broadly diversified global portfolios and to provide financial planning services to help them reach their goals. B.1. Portfolio Management Services For its discretionary portfolio management services, Legacy Financial receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. Legacy Financial’s portfolio management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. Legacy Financial will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances Legacy Financial’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances and make appropriate recommendations and implementation decisions. Legacy Financial may refer third-party service providers to assist with the tax and estate planning portion of the services provided to clients. In addition, Legacy Financial may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Legacy Financial’s portfolio management services to clients take into account a client's personal financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). Legacy Financial’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to Legacy Financial in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Legacy Financial. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds and ETFs. Page 5 ▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments,

and/or the performance of any fund retained by the client. In addition to providing Legacy Financial with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Legacy Financial will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Legacy Financial will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. B.2. Pension Consulting Services Legacy Financial provides non-discretionary retirement plan services. Legacy Financial will 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. B.3. Financial Planning Services Legacy Financial’s clients hire us to build broadly diversified global portfolios and to provide financial planning services to help them reach their goals. Legacy Financial is a financial services company that assists its clients in reaching their goals by offering integrated planning that includes services such as investment, retirement, tax, estate, and risk management. The scope of such services will be based upon mutual consent of the firm and the client prior to the engagement. Legacy Financial will make referrals to applicable insurance specialists, tax accountants, and estate planning lawyers as necessary to assist clients. Based on the client’s needs, Legacy Financial will provide one or more of the following services: ▪ Customized financial plan ▪ Investment planning ▪ Retirement and cash flow planning ▪ Income tax planning ▪ Estate planning and wealth transfer ▪ Company benefits planning ▪ Education planning ▪ Risk management Page 6 C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Legacy Financial does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2022, Legacy Financial managed $335,700,000 on a discretionary basis and $0 million on a non-discretionary basis. Item 5: Fees and Compensation