Allen Capital Group, LLC (ACG) is registered as an investment adviser with the Securities and Exchange Commission (SEC) since July 2005 and Mark Allen is the sole managing member of ACG. The other members of ACG are Jenny Nichol, Travis Portwood, Steven Wilbur, Philip McBride, Kent Koch, Michael Stanton and Shane Wissmann. ACG offers an Investment Management Program, Financial Planning Services, a Retirement Plan Advisory and Review Program and Trust Services to its clients. As an Investment Adviser, ACG is a Fiduciary, meaning we must put client needs first, and provide advice in client’s best interest. When we offer investment advice to retirement accounts covered by ERISA, we must also comply with ERISA’s fiduciary standards. Investment Management Program ACG provides investment management program services, defined as giving continuous advice to clients based on their individual needs through ACG’s Investment Management Program accounts. ACG obtains financial information on the ACG Client Investment Profile Questionnaire and other new account documents from prospective clients to determine the suitability of establishing Investment Management Program accounts and to determine the appropriate investment management strategies that are specific for each client account that is established with ACG. Clients may impose restrictions on the type of investments that may be included in their Investment Management Program accounts. ACG uses discretionary trading authority to buy, sell and direct investments within the client accounts, including reinvestment of proceeds from assets sold and income attributable to client accounts in cash, cash equivalents, bonds, shares of common or preferred stock, unit investment trusts, ETF’s, mutual funds, options, variable annuity sub-accounts, or other alternative securities selected by ACG for client accounts. ACG has established a relationship with Pontera Solutions Inc. (Pontera). Pontera is a technology firm that provides service platform solutions to investment advisers, such as ACG, that advise and/or manage held away client accounts, such as qualified plan participant accounts. The Pontera platform allows ACG to receive feeds from held away accounts, analyze accounts, plan fees, and execute trades. The Pontera service platform allows ACG to integrate the management and advise of held away accounts into ACG’s adviser services and programs. Flat Fee - Outside Account Advice – Clients that are being provided Investment Management Services under an ACG Investment Management agreement may also have ACG provide them Flat Fee- Outside Account Advice on other accounts. These outside accounts may or may not be ERISA accounts. ACG may have the ability to trade these accounts on a discretionary basis. Selection of Other Advisors - In some instances, the management of client accounts are delegated to other investment advisors that have sub-advisor agreements with ACG or separate agreements with clients. In such instances, the other investment advisors will have discretionary authority to manage client accounts. A complete description of each of these other investment advisor’s’ services is described in their Form ADV Part 2A Disclosure Brochures. When another investment advisor is used in a client account the client will be provided the other investment advisor’s Form ADV Part 2A Disclosure Brochure. A client may always place limitations on the use of other investment advisors by ACG. Financial Planning Services ACG provides Financial Planning Services to clients. Financial Planning Services include investment related planning and non-investment related planning services. When providing financial planning services, ACG will obtain financial information and documents from clients to determine the appropriate advice to be provided to them. ACG provides the following Financial Planning Services:  Current Plan Results Reviews  Flat Fee - Qualified Retirement Plan Reviews  What If Planning Scenario Comparisons  Monte Carlo Investment Analysis Simulations  Life Insurance/Disability Needs Analysis  Long-Term Care Needs Analysis  Trust and Estate Planning reviews  Other planning services as required ACG’s Financial Planning Services are tailored to the individual needs of each client. ACG obtains financial information from prospective clients to determine the suitability of ACG’s Financial Planning Services. Each client may impose limits on the type of Financial Planning Services provided to them by ACG. The Financial

Planning Services being provided by ACG do not include investment management services, nor do they include the regular review of client’s investment assets. If client wants to have ACG manage their investment assets, a separate Investment Management Program agreement must be entered into with ACG for separate and additional fees. If a Financial Planning Service client chooses to implement the advice of an ACG IAR, the client may do so through the IAR in their separate capacity as an ACG IAR, and/or an independent insurance agent. Financial Planning Services are generally provided along with our Investment Management Services and without an additional fee. ACG reserves the right to charge separately for its Financial Planning services when the plan is complex and/or provided as a standalone service. If a Financial Planning Service client chooses to purchase insurance recommended through a financial plan, any earned commission will be paid to ACG. This represents a conflict of interest and clients are advised that they are under no obligation to purchase any insurance products. Retirement Plan Advisory and Review Program ACG provides a Retirement Plan Advisory and Review Program which may include a Second Opinion Survey for Plan Sponsors and their Qualified Retirement Plans. The covered qualified retirement plans include 401(k) Plans, Defined Contribution Plans, Profit Sharing Plans, and Defined Benefit Plans and other qualified retirement plans (collectively referred to as Qualified Retirement Plans). Depending on the agreement with the Retirement Plan, ACG may act as an ERISA Section 3(38) Investment Manager Fiduciary that makes investment management decisions and has discretionary authority for Qualified Retirement Plan assets, or an ERISA Section 3(21) Limited Services Fiduciary that only makes recommendations to Qualified Retirement Plans. Qualified Retirement Plans may receive position/performance reports from ACG describing Qualified Retirement Plans performance and holdings. Qualified Retirement Plans will receive a monthly Plan statement from the Custodian showing the Plan activity as well as Plan holdings. Estate Planning Services ACG offers Estate Planning services in conjunction with EncorEstate Plans. EncorEstate Plans provides access to software and tools designed to develop estate plans for clients. Depending on the needs of the client, Estate Plans may include a Trust, Power of Attorney, Medical Power of Attorney or Advance Health Care Directive, or Will. Additional documents will be produced by EncorEstate Plans. ACG will guide the client through the necessary questions and responses to assist in the creation of the documents. ACG will coordinate with local attorneys in certain circumstances. Trust Services ACG can provide trust services to its clients through an affiliation with National Advisors Trust Company, FSB (“NATC”). NATC is a federally chartered trust company regulated by the Office of the Comptroller of the Currency (“OCC”) and is a member of the Federal Deposit Insurance Corporation (“FDIC”). ACG offers trust services through a private label trade name, “Allen Capital Trust,” a Trust Representative Office of NATC. By law, ACG’s client assets are segregated from the capital assets of NATC and are not subject to potential NATC creditor claims. ACG and NATC are not related entities. The terms and conditions of a client’s engagement of NATC, including the fee payable by the client to NATC, are outlined in a separate agreement between the client and NATC. ACG may recommend the services of other trust companies, chartered in different states. The client is under no obligation to engage the services of any recommended trust company. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from ACG and its representatives. ACG does not receive any compensation (direct or indirect) from any trust company for these referrals. The terms and conditions of a client’s engagement with the trust company, including the fee payable by the client, are outlined in a separate agreement between the client and the trust company. Assets Under Management and Advisement ACG has $998,471,163 of assets under discretionary management in its Investment Management Program as of December 31, 2023. ACG does not manage assets on a non-discretionary basis in our Investment Management Program. ACG has $76,939,197 of assets under non- discretionary advisement in its Retirement Plan Advisory and Review Program as of December 31, 2023.