Description of Services and Fees We are a registered investment advisor based in Plymouth Meeting, Pennsylvania. We are organized as a limited liability company under the laws of the State of Delaware. We have been providing investment advisory services since 2006. Michael Piotrowicz is our principal owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Financial Planning
• Portfolio Management Services
• Retirement Plan Consulting Services
• Selection of Other Advisors Financial Planning Services We offer to provide a broad-based, modular, and consultative financial planning services. Financial planning will typically involve providing a variety of advisory services to you regarding the management of your financial resources based upon an analysis of your individual needs. If you retain our firm for these services, we will meet with you to gather information about your financial circumstances and objectives. Once we specify your objectives (both financial and non-financial), we will work to implement your plan to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we prepare the plan, and on the financial information you provide to us. It is recommended that you notify us if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations or use any of our services. For initial comprehensive financial planning engagements, we will generally charge a fixed fee, which will be agreed upon at the start of the advisory relationship. This fee will be based upon various objectives and subjective criteria, including, but not limited to, the complexity of the financial planning and the assets under management. Based on these factors, fees generally range from $10,000 to $100,000 payable in advance. Initial planning services will be rendered within six months of the date of contract or any prepaid, unearned fees will be promptly refunded to you. Therefore, under no circumstances will we require prepayment of a fee more than six months in advance and in excess of $1,200. The agreement between us will detail the scope of the services to be provided, the associated fees, and the agreed upon payment arrangements. We also offer ongoing financial planning/consulting services that may include periodic meetings to review your progress towards stated goals, implementation services, and updates to the existing plan. In the event that you retain us for on-going planning services, we will charge an annual retainer fee. This fee will be determined based on the complexity of your circumstances, individualized needs, the scope of services requested, and the professionals rendering the services. Generally, fees will be billed semi-annually in advance. As our fees and payment arrangements for retainer services are negotiable, fees and arrangements with our other clients may differ. The agreement between us will detail the scope of the services to be provided, the associated fees, and the agreed upon payment arrangements. If you are in need of continuing services but do not wish to contract with us on a retainer basis, we will, at our discretion, make ourselves available for such services based upon an hourly fee. In limited circumstances, you may only require advice on a single aspect of the management of your financial resources. In these instances, we offer financial plans and/or general consulting services that address only those specific areas of interest or concern. Generally, our hourly fee for financial planning services ranges from $100 to $400. The hourly fee is negotiable based on the scope of services requested, the complexity of your individual circumstances, and the professionals providing the services. Such hourly fees are payable after services are completed. You may act on our recommendations with any firm you choose since you are under no obligation to act on our financial planning recommendations. You may terminate the financial planning agreement within five business days after the date when all parties have signed the agreement without penalty. After this five-day period, either party may terminate the agreement upon written notice to the other. If a deposit has been collected by us, a pro rata refund will be sent to you. Conversely, you may incur a pro rata charge for bona fide financial planning and/or consulting services rendered prior to such termination. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet your needs and investment objectives. If you retain our firm for these services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without prior approval for each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Our fee for portfolio management services shall vary (generally, up to 1.25%) based upon various factors, including the total amount of assets placed under management/advisement-see Fee Differentials below). Our annual portfolio management fee is billed and payable quarterly in arrears based on the value of your account on the last day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on your individual circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated previously. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. You may terminate the portfolio management agreement upon written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Portfolio Management services may also be rendered through a sub-advisor in conjunction with the services provided by Betterment, LLC (“Betterment”), an unaffiliated registered investment adviser. Subject to our supervision, input, and oversight, Betterment can be engaged to provide automated discretionary asset management to clients. In such engagements, we work closely with clients to identify their specific financial situation, risk tolerance, objectives, and other factors. This information is then communicated to Betterment, through the Betterment website, and is used by Betterment to automatically invest and reinvest client assets among eligible investment products, which shall generally include exchange-traded funds, mutual funds, other similar equity related index funds, individual stocks, individual bonds, real estate investment trusts, master limited partnerships, money market funds, U.S. treasury funds, cash sweep accounts, and other liquid cash and cash-like vehicles. Alternatively, we may recommend that clients place investment assets in certain asset allocation models made available by Betterment and managed by various third-party providers. In these situations, Betterment would not be granted discretionary authority to manage the client account. Instead, we would allocate and/or recommend a client allocate assets to one or more models, consistent with the client’s financial situation and investment objectives, and we (not Betterment) would retain exclusive responsibility for managing your account. The services to be provided by Legacy and Betterment shall be set forth in separate written agreements between the client and the respective entities. All fees charged by Betterment are separate from and in addition to those fees charged by Legacy. Retirement Plan Consulting Services We also provide retirement plan consulting services, pursuant to which we assist sponsors of self- directed retirement plans with the selection (on either a discretionary, or non-discretionary basis) and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, we may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement are set forth in a retirement plan consulting agreement between us and the plan sponsor. Our negotiable annual fee for retirement plan consulting services varies (up to 1.25% of the value of plan assets) based upon several objective and subjective factors, including but not limited to: the level and scope of the overall services to be rendered, the amount of plan assets, the scope and complexity of the engagement, and the individual(s) rendering services. The annual fee is billed quarterly or monthly in arrears, depending upon the particular plan sponsor and/or the third party administrator’s preference. Either party may terminate the retirement plan consulting agreement upon 30-days written notice. Upon termination, we will charge the plan for the pro-rated portion of the unpaid fee based upon the number of days that services were provided during the billing quarter or month, as applicable. Selection of Other Advisors In addition to the sub-advisory services described above and provided in conjunction with Betterment, we may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action appropriate. Wrap Fee Programs Legacy does not administer or sponsor any wrap fee programs. However, Legacy is a participating investment adviser in an unaffiliated wrap fee and managed account program sponsored by Betterment (the “Betterment Program”). With respect to the Betterment Program, clients pay separate and distinct fees to Betterment and Legacy, as described more fully in Item 5 below. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee payable to Betterment. Participation in a wrap program may cost the participant more or less than purchasing such services separately. Please Note: Since the custodian/broker-dealer is determined by the unaffiliated wrap program sponsor, Legacy will be unable to seek better execution. As a result, clients may receive less favorable net prices on transactions for the account than would otherwise be the case through alternative clearing arrangements sourced by Legacy. ANY QUESTIONS: Our Chief Compliance Officer, Matthew Sgro, remains available to address any questions that a client may have regarding participation in a wrap fee program. Types of Investments We primarily offer advice

on unaffiliated mutual funds, exchange traded funds, independent investment managers, and private investment funds. However, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Assets Under Management As of December 2023, we provide continuous management services for $ 3,580,187,283.00 in client assets on a discretionary basis and $ 55,138,813.00 on a non-discretionary basis. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent specifically requested by a client, we can be engaged to provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc., generally on an additional fee basis (i.e., separate from and in addition to our investment adviser fee for portfolio management services described at Item 5 below) We do not serve as an attorney or accountant, and no portion of our services should be construed as same. To the extent requested by a client, we may recommend the services of other professionals for certain non- investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including our representatives in their separate individual capacities as representatives of M Holdings Securities, a FINRA member and SIPC member and SEC registered broker-dealer ("M Holdings") and as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from us and/or our representatives. Please Note: If the client engages any such professional, recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note-Conflict of Interest: Our recommendation that a client consider the purchase of a securities or insurance commission product from firm representatives in their individual capacities as representatives of M Holdings and/or as insurance agents, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment products based on commissions to be received, rather than on a particular client's need. No client is under any obligation to purchase any securities or insurance commission products from our representatives. Clients are reminded that they may purchase securities and insurance products recommended by us through other, non-affiliated broker-dealers and/or insurance agencies. Our Chief Compliance Officer, Matthew Sgro, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Please Note: Fee Differentials. As discussed above and indicated below at Item 5, we shall generally price our advisory services based upon various objective and subjective factors. As a result, our clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, the level and scope of the overall investment advisory services to be rendered, and negotiations. As a result of these factors, similarly situated clients could pay diverse fees, and the services to be provided by Legacy to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. ANY QUESTIONS: Legacy’s Chief Compliance Officer, Matthew Sgro, remains available to address any questions regarding Fee Differentials. Aggregated Reporting. In conjunction with the services provided by ByAllAccounts, Inc., Quovo, and/or other providers, we may also provide periodic comprehensive reporting services which can incorporate all of the client's investment assets, including those investment assets that are not part of the assets that we have not been provided with discretionary authority to manage (the "Excluded Assets"). The client and/or his/her/its other advisors that maintain trading authority, and not us, shall be exclusively responsible for the investment performance of the Excluded Assets. Our service relative to the Excluded Assets is limited to reporting services, and, to the limited extent expressly requested, non-discretionary consulting services, which does not include investment implementation. We do not have trading authority for the Excluded Assets. As such, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not us, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. In the event the client desires that we provide discretionary investment management services with respect to the Excluded Assets, the client may engage us pursuant to the written terms and conditions of the Portfolio Management Services Agreement between us and the client. Please Note: Retirement Rollovers-No Obligation/Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Legacy recommends that a client roll over their retirement plan assets into an account to be managed by Legacy, such a recommendation creates a conflict of interest if Legacy will earn a new (or increase its current )advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by Legacy. Legacy’s Chief Compliance Officer, Matthew Sgro remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note-Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Legacy independent of engaging Legacy as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Legacy’s initial and ongoing investment advisory services. Pershing/Schwab/Betterment. As discussed below at Item 12, Legacy recommends that Pershing and/or Schwab serve as the broker-dealer/custodian for client investment management assets. Additionally, Betterment Securities serves as the broker-dealer/custodian for participants in the Betterment Program. Broker-dealers such as Pershing and Schwab charge brokerage commissions and/or transaction fees for effecting securities transactions. As discussed more fully above, clients will not incur separate commissions and/or transaction fees when participating in the Betterment Program. In addition to investment management fees, brokerage commissions and/or transaction fees, all clients will also incur, relative to mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). The commissions and/or transaction fees charged by Pershing and Schwab, as well as the charges imposed at the mutual fund and exchange traded fund level, are in addition to Legacy’s advisory fee referenced above and at Item 5 below. Independent Managers. Legacy may allocate a portion of client assets among unaffiliated independent investment managers. In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. Legacy shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Please Note: The investment management fee charged by the Independent Manager[s]is separate from, and in addition to, Legacy’s advisory fee as set forth in the fee schedule at Item 5 below. Betterment Sub-Advisory Arrangement. As described above, Legacy engages Betterment as a sub- advisor for the purpose of assisting Legacy with the management of client accounts. When discretionary investment management authority is granted to Betterment, Betterment retains responsibility for the day-to-day management of the assets placed under Betterment’s management. Betterment shall continue in such capacity until the arrangement is terminated or modified by Legacy, Betterment, or the client. Portfolio Activity. Legacy has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Legacy will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Legacy determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Legacy will be profitable or equal any specific performance level(s). Client Obligations. In performing its services, we shall not be required to verify any information received from the client or from the client's other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify us if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies that we recommended or undertake) will be profitable or equal any specific performance level(s). Unaffiliated Private Investment Funds. Legacy may also provide investment advice regarding unaffiliated private investment funds. Legacy, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Legacy’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. For further information, refer to the offering documents for a complete description of the fees, investment objectives, risks, and other relevant information. Legacy’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Legacy references private investment funds owned by the client on any supplemental account reports prepared by Legacy, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post-purchase is provided by the Fund Sponsor, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date), or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. The client’s advisory fee shall be based upon reflected fund value(s). Please Also Note: Conflict of Interest: Legacy may introduce clients to private investments that are affiliated with Legacy's clients, thereby creating a conflict of interest relative to Legacy's introduction of the investment. Legacy has an economic incentive to introduce the investment to the client (i.e., as result of the introduction, Legacy will assist an existing client from whom it currently earns, and anticipates it will continue to earn, investment advisory fees). Additionally, Legacy may have associates that are invested in the same private investments/funds as clients. This presents a further conflict of interest in that the recommendation to invest in such private investment/fund could be made on the basis of preserving or enhancing the value of the Legacy associate’s investment, rather than on a particular client’s need. Given the conflicts of interest, Legacy advises that clients consider seeking advice from independent professionals (i.e., attorney, CPA, etc.) of their choosing prior to becoming an investor in a private investment. No client is under any obligation to invest in this, or any other, private investment.