Firm Description Acorn Financial Advisory Services, Inc. (AFAS) is a Registered Investment Adviser registered with the U.S. Securities and Exchange Commission (SEC). AFAS is a Virginia Corporation founded in 1996 whose principal office is located in Reston, VA. AFAS is affiliated with Acorn Financial Services, Inc., a subsidiary Virginia Corporation. James M. Gambaccini, CFP® is 100% stockholder of AFAS. AFAS provides personalized confidential financial planning and investment management to individuals, families, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Investment advice is an integral part of financial planning. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial challenges, budgeting, cash flow analysis and debt management, charitable planning, college planning, estate planning, estate wealth transfer, financial coaching, insurance planning and analysis, investment planning and analysis, long term care and analysis, real estate investment analysis, retirement needs analysis, tax planning, and various business studies (qualified and non-qualified employee/executive benefit planning). AFAS is a fee-for-service financial planning and investment management firm. AFAS does not charge commissions. Clients have full discretion to implement advisory recommendations through any firm. There is no obligation to effect transactions through the Investment Adviser in their capacity as a Registered Representative. However, should a client wish to use an Investment Adviser of AFAS for implementation services of commissionable holdings, the firm may recommend a broker dealer. AFAS does not warrant or represent those commissions for transactions implemented through said broker dealer will be lower than commissions available if the client used another brokerage firm. AFAS provides subadvisory investment management services to non-affiliated Registered Investment Advisers and their clients. AFAS may be engaged to build and run model portfolio strategies for investor accounts contracted through separate, appropriately registered advisers. Additionally, these same strategies may be made available to clients of AFAS and implemented through adviser representatives of AFAS. AFAS currently offers 3 platforms for investment management services to clients. AFAS builds and develops model strategies for clients and directly manages these portfolios utilizing Black Diamond for performance reporting and fee calculation. AFAS also engages Buckingham Strategic Partners, BSP, as a third party platform whereby BSP provides administrative and back-office support as well as model portfolios for clients to select from. AFAS also recommends clients consider portfolio management services and strategies available through Assetmark, a wrap fee program offering access to a variety of third party money managers. Investment advice is provided by the Investment Adviser. AFAS does not act as a custodian of client assets. The client always maintains asset control. Investment Advisers may make specific recommendations pursuant to a financial plan or portfolio. There may be potential conflicts of interest in recommending one investment alternative over another. As of December 31, 2023, AFAS manages approximately $1,110,073,209 in assets ($980,040,611 in discretionary accounts plus $130,032,598 in non-discretionary accounts) for approximately 2391 clients. Types of Agreements and Services Offered AFAS provides four services through its Investment Advisers under the following service names: ❖ Financial Planning and Analysis Contract ❖ Annual Maintenance Contract ❖ Portfolio Management Contract ❖ Subadvisory Contract *When contracted, Pension Planning Services are structured under one of the three agreements listed above and described in detail below. FINANCIAL PLANNING AND ANALYSIS CONTRACT The AFAS Financial Planning and Analysis Contract is offered to discuss, design, and review specific financial planning issues within a stated time period. This service is focused on advice and consultation in one or more stated areas of concern, such as budgeting, cash flow analysis and debt management, charitable planning, college planning, estate planning, estate wealth transfer, financial coaching, insurance planning and analysis, investment planning and analysis, long term care and analysis, real estate investment analysis, retirement needs analysis, tax planning, and various business studies (qualified and non-qualified employee/executive benefit planning). The Investment Adviser may also provide specific consultation regarding investments and financial concerns. An Investment Adviser may present the tax aspects of certain investments or strategies in general terms. Within this context, the Investment Adviser does not provide specific tax advice and recommends that all tax questions or strategies should be discussed with the client’s tax professional. In the event a client wishes to retain a qualified Investment Adviser for legal and or tax service outside the scope of the planning agreement, those services must be provided in a separate agreement between the client and Investment Adviser. Financial planning and analysis contract services are provided for a fixed fee. This fee can be renewed annually at the firm and client’s discretion. AFAS provides clients flexibility and optionality around when payments for this fixed fee are made, be it annually, semi-annually or quarterly. MAINTENANCE CONTRACT The AFAS Maintenance Contract is for consultations with an Investment Adviser with a term period of 12 or 24 months. This service establishes an ongoing working relationship between the Investment Adviser and the client to provide regular planning meetings, telephone consultations, emails, participation in educational seminars, articles and information regarding market and economic conditions, and Internet access to investment accounts. The maintenance contract fee is a continuation of the financial planning and analysis contract and the ongoing charge for the service is in addition to any fees charged under a portfolio management agreement. PORTFOLIO MANAGEMENT The AFAS Portfolio Management Contract is for clients needing a personalized approach to implementing an individually customized strategy designed to meet their investment goals and objectives through portfolio monitoring and quarterly reporting. The Investment Adviser develops and recommends a unique strategy based on their knowledge, experience, and understanding of the client’s needs. This individualized approach allows the Investment Adviser and client to work together to achieve the client’s investment goals. Additionally, the client is provided regular planning meetings, telephone consultations, emails, participation in educational seminars, articles and information regarding market and economic conditions, and Internet access to investment accounts. AFAS extends maximum latitude to Investment Adviser and client, within this individualized approach as to the method in which the account will be managed. Prior to rendering service, Investment Adviser reviews a client’s current investment portfolio, obtains necessary information regarding the client’s current and expected financial situation and makes recommendations to clients regarding their portfolios. Additionally, the Investment Adviser will access the client’s financial situation, including investment history, goals, and objectives, and special interests or concerns. AFAS offers several Portfolio Management programs. Within these programs, AFAS Investment Advisers assist clients in making investment decisions that are appropriate based on their unique goals and objectives. The different programs offer clients a personalized approach to implementing an investment strategy through asset allocation, portfolio monitoring and consolidated reporting. The clients will receive a contract from the Portfolio Management company describing their fees and services before any Accounts are opened by the AFAS Investment Adviser. These third-party management fees will be in addition to any fees paid to AFAS in conjunction with the client’s Portfolio Management program. AFAS offers the following Portfolio Management program platforms: Programs available directly through AFAS CUSTOM REPORT –AFAS offers investment advisory management providing customized personal accounts using individual securities, ETFs, bonds, unit trusts,

and non-traded public offerings. A quarterly rebalancing service is available and is designed to assess the change in percentage holdings of each asset class within a portfolio in relation to the total account holdings. Sales are made from the expanded classes (best performing) and purchases are made in the under-performing classes. This serves to closely maintain the target asset class allocation for the overall portfolio. This allocation is determined at the onset of the investment management engagement, and it is reviewed periodically to confirm that it remains appropriate for the client. The quarterly rebalancing service does not require a pre-authorization agreement to trade the approved mutual funds and any individual securities that may be held in the account, consistent with the asset allocation approved by the client and any investment restrictions requested. Investment Advisers may rebalance accounts quarterly to within several percent of the allocation in each asset class agreed upon by the client. In the Investment Adviser’s sole discretion, they may choose not to rebalance because the funds involved are economically insufficient, additional fees and expenses are anticipated, tax impact, account cash flows, or there may by other events pending that would impact the decision. A client may alternatively elect to implement their own asset allocation program by specifying alternative investments to be used in conjunction with their portfolio. In certain circumstances, clients of AFAS may have investments in existing non-AFAS accounts that such clients wish to transfer, without liquidating the investments, to a new or existing account. In this case, the Investment Adviser may or may not offer advice on the types of investment being transferred. The Investment Adviser in their own discretion may allow the client to transfer such investments to an account and adjust the account’s asset allocation program, in whole or in part, to approximate the Investment Adviser’s recommendation. The funds, securities, and percentages may vary somewhat from the regular asset allocation program, but the strategy and the fee structures are similar. Clients have no obligation to act upon the Investment Adviser’s recommendation. If a client elects Investment Adviser’s recommendations, the client is under no obligation to effect the transactions through AFAS, any of their affiliates, or any other company recommended by the Investment Adviser. If a client wishes to implement the plan through AFAS or any of its affiliates, the client will be required to sign an agreement with AFAS, or affiliated companies as appropriate. Certain Adviser Representatives also create and manage active portfolio models and strategies. Examples of these include the StrategicAlpha Core model and the StrategicAlpha Opportunities model. Descriptions of these models are available upon request. It is the job of AFAS and its adviser representatives to discuss with clients when an allocation to these strategies may be appropriate. SUBADVISORY AGREEMENTS – AFAS offers subadvisory investment management services to other non-affiliated, appropriately registered investment advisers. This service entails other registered investment advisers electing to have their clients participate and invest in certain investment model strategies developed by investment adviser representatives of AFAS. In these instances, non-affiliated investment advisers will enter into a Subadvisory Agreement with AFAS, thereby appointing AFAS and its representatives to be the investment manager for a designated portion of that Adviser’s designated client assets or accounts. Under this agreement, AFAS as Subadviser is responsible for the investment and reinvestment of assets of each account in accordance with the Portfolio Strategy selected by the Adviser for each designated account. Programs available through the Buckingham Strategic Partners 3 Party Platform STRUCTURED – Investment Asset Allocation platform is specifically designated to hold SA Funds in target allocations set upfront by the Investment Adviser and client. Asset Class Investing is a passive investment approach that draws on the research of some of the academic community’s most innovative and respected thinkers and economists. As its name suggests, rather than trying to pick stocks or industry sectors, asset class investing focuses on asset classes — which are simply any group of securities (such as U.S. Large Companies and Emerging Markets) that exhibit similar risk and return investment characteristics and perform similarly in any given market environment. Since asset allocation has a significant impact on investment returns, asset class investing carefully controls the investments included in each Asset Class, potentially giving investors truer market returns than similar strategies. While a number of investment vehicles can be employed to implement Asset Class Investing, using institutional mutual funds specifically designed for their asset class characteristics can greatly simplify the process. ADVANTAGE – Investment Asset Allocation platform may hold separate investment securities along with Asset Class Funds (as described above in “Structured”), and will be assigned to specific allocation classes and managed as part of an overall allocated account. SELECT – Investment Asset Allocation platform may hold separate investment securities, non-traditional investments along with the Asst Class Funds (as described above in “Structured”), and will be assigned to specific allocation classes and managed as part of an overall allocated account. It is important to note that within the Select Agreement, the use of SA Funds in these portfolios could have the potential to increase the net fee to the investment adviser. This could create a conflict of interest in the recommendation of SA funds within Select Agreement contracts managed and administered via the BSP platform. It is the intent of AFAS and its adviser representatives to avoid such conflicts of interest and to keep the best interests of the client at the forefront of all recommendations. AFAS reviews select agreement accounts for the presence of SA funds and works to make sure that the net fee to the firm is not increased by their utilization. Additionally, AFAS has created separate disclosure documents for clients in Select Agreements who own SA funds to acknowledge the potential for this conflict of interest. Programs available through Assetmark Assetmark is a company offering wrap fee programs. In a wrap fee account, clients invest in one or more strategies managed by 3rd party investment managers. The costs of this management, administrative expenses, trading expenses, and investment advisory fees are calculated and assessed as one comprehensive fee levied by Assetmark for the bundling of these services. Adviser representatives recommend Assetmark to clients and assist in selecting the investment managers to use on the platform. AFAS has developed policies and procedures to help educate and inform the client about the options outside of the wrap fee program structure that may provide similar options at potentially lower overall expenses. Termination of Agreements Any AFAS Agreements may be terminated at the client’s discretion at any time by giving written notice. Any AFAS agreement may terminated with no fee or penalty within the first 5 days after entering into the agreement. The Portfolio Management Agreement may be terminated by the client or the Investment Adviser by providing written notice to the other party. Termination will occur 30 days thereafter. Fees will be billed on a pro-rata basis in advance for the portion of the calendar quarter completed as of the date of termination. The portfolio value as of the last day of the immediately preceding full calendar quarter is used as the basis for the final fee computation, adjusted for the number of days during the current billing quarter prior to termination. AFAS reserves the right to stop work on any account that is more than 90 days overdue. In addition, AFAS reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in AFAS’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded within 90 days.