WFS was founded in February 1982 and has been a wholly-owned subsidiary of Sandy Spring Bank since 2005. Sandy Spring Bank is a wholly-owned subsidiary of Sandy Spring Bancorp, Inc., a Maryland corporation (“SSB”). SSB is the holding company for Sandy Spring Bank, and its principal subsidiaries SSB Wealth Management, Inc. and WFS. WFS is a fee-only investment adviser registered with the SEC that provides investment advisory services to individuals, high net worth individuals, retirement and profit sharing plans, charitable organizations, and corporations and other business entities. WFS’s investment philosophy stresses diversified portfolios tailored to each client’s individual circumstances and specific goals using the processes described below. WFS’s investment management goal is to optimize the return on each client’s portfolio while keeping within the individual’s risk tolerance, time horizon, and tax and wealth objectives. Clients receiving any of the services provided by WFS may impose restrictions on WFS with respect to investing in certain securities or types of securities. Descriptions of the services offered by WFS appear below. Investment Management Services When providing investment management services (“Investment Management Services”), WFS generally develops with each client an understanding of the client’s financial circumstances and goals, the client’s risk tolerance level, and the client’s investment objectives and guidelines based on information provided by the client. Based on this review of information, WFS will develop asset allocation guidelines for the client. WFS will periodically re-evaluate the client’s asset allocation guidelines and, as appropriate, gather additional information about the client’s financial circumstances, goals, risk tolerance, and investment objectives and guidelines. Discretionary Services WFS will generally manage client investment portfolios on a discretionary basis pursuant to an investment management agreement with the client. As a discretionary investment adviser, WFS will have the authority to supervise and direct the portfolio without prior consultation with the client. Non-Discretionary Services While WFS generally manages client investment portfolios on a discretionary basis, clients may choose to have their portfolios managed on a non-discretionary basis. Clients who choose a non- discretionary arrangement retain responsibility for all actions taken with respect to the portfolio(s). Accordingly, the client must be contacted by WFS prior to the execution of any trade in the portfolio(s) under management, which could adversely affect the performance of the portfolio(s). As of December 31, 2023, WFS managed $ 2,148,382,303 in discretionary assets under management and $14,059,263 in non-discretionary assets, for a total of $ $2,162,441,566 through 890 client relationships. Financial Planning Services WFS provides financial planning services (“Financial Planning Services”) to clients through a five- step process that includes identifying goals, analyzing data, providing recommendations, assisting with implementation, and periodically reviewing projected outcomes. A comprehensive financial plan typically begins with a review of the client’s balance sheet to determine net worth and titling of assets. WFS then reviews, among other things, cash flow, income taxes, insurance, investments, estate planning documents and similar core areas of review, to the extent applicable, as the basis for WFS’s Financial Planning Services. Financial Planning Services may include projections (e.g., retirement cash flow projections), which include a number of assumptions made from discussions with clients regarding financial and retirement goals, as well as alternate scenarios based on changes in the assumptions. WFS’s Financial Planning Services may also include a detailed review of and recommendations with respect to the following areas:
• Insurance
• Education funding
• Stock option exercise strategies
• Business form and succession planning
• Other financial areas as mutually agreed upon by WFS and the client WFS will meet with clients to review a prepared financial plan and follow up with them to help with implementation as needed. The client will determine whether or not to implement recommendations made by WFS as part of the Financial Planning Services. If requested, WFS will work with a client’s own professionals (e.g., accountants and attorneys) or one recommended from WFS’s network of professionals for implementation purposes. Clients are under

no obligation to engage the services of any professional WFS recommends. If the client engages a professional recommended by WFS, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. WFS recommends an annual meeting to discuss changes in circumstances and goals and related matters. Upon request, WFS may involve multiple generations in Financial Planning Services to facilitate family financial planning. Because potential conflicts of interest exist with the exchange of intergenerational information, WFS attempts to minimize these conflicts by treating each household as its own fiduciary relationship. WFS will only share information across households with each household’s consent. As an alternative to the comprehensive financial plans described above, WFS may, at the request of a client, produce a limited financial plan that addresses one or more of the areas listed above, as mutually agreed by WFS and the client. Fees charged with respect to the production of a limited financial plan will be negotiated between WFS and the applicable client in advance. Personalized Consulting Services WFS offers personalized consulting services (“Personalized Consulting Services”) to address the unique needs of high net worth individuals. WFS customizes each Personalized Consulting Services relationship, seeking creative solutions to clients’ financial needs while coordinating with other professionals as WFS deems appropriate. Personalized Consulting Services may include, but are not limited to, the following:
• Asset management
• Client specific projects
• Business planning
• Education planning
• Estate planning
• Financial planning
• Individual securities research
• Investment management
• Legacy and philanthropic planning
• Retirement planning
• Strategic planning
• Succession planning
• Venture deal analysis The client will determine whether or not to implement recommendations made by WFS as part of the Personalized Consulting Services. As a subset of WFS’s Personalized Consulting Services, WFS provides ongoing planning consultation through its Foundational Planning program. The goal of this service is to provide clients with an introduction into financial planning and budgeting. WFS will initially gather information on the client’s financial data, needs, and goals. WFS will assist clients with, among other things, preliminary balance sheets and cash flow statements, and will work with clients towards their budgeting, debt management, insurance, investment management, and employer provided benefits selection goals, as discussed and agreed upon with the client. As part of the Foundational Planning services, WFS will assist clients with implementing one or more of the foregoing as requested. Retirement Plan Services WFS offers consulting services to 401(k) and other employer-sponsored retirement plans (“Retirement Plan Services”). In providing such services, WFS works with the plan trustees to provide the following initial and ongoing services:
• Establishment of an Investment Policy Statement
• Analysis, review, and recommendation of investment selections
• Annual plan review
• Attendance at annual investment committee meeting
• Preparation of participant newsletters
• Educational meetings for employees
• Continuing individual participant support Investment selection includes a review of available investment fund categories, based on regulatory guidelines and administrative capabilities. WFS will then select the requested number of funds, which will be no less than three, based on, among other factors, performance, stability of management, expenses, portfolio mix, and risk. WFS will prepare an annual review of current investment options and participation and include recommendations to the plan trustees. For each 401(k) and similar plan, WFS will generally conduct initial participant meetings to present retirement planning education and summarize the investment options available within the plan. If requested by the plan, WFS will make annual or semi-annual presentations to plan participants to provide plan awareness, investment education, retirement planning advice, and other information. Additional communication to plan participants may include a newsletter describing the plan’s investment options and performance. Newsletters may also include a market commentary and additional articles of interest and may be prepared either semi-annually or quarterly.