4-A: DESCRIBE OUR ADVISORY FIRM AND IDENTIFY THE PRINCIPAL OWNERS: Wellspring Financial Advisors, LLC (“Wellspring”) is an independent personal wealth management and multi-family office that has been in business since February 2007. We offer holistic financial services to high net worth individuals and families. Our comprehensive offerings include investment advisory, income tax planning and compliance, financial and estate planning, risk management and multi-family office services. Michael Novak is a principal owner with owning more than 25% of the firm. 4-B: DESCRIBE THE TYPE OF ADVISORY SERVICES WE OFFER: At Wellspring, we provide a comprehensive suite of personalized services that cover our clients’ financial and non-financial needs, including: Family & Life Services Multi-family Office Services Many clients lack the resources to create and maintain a traditional separate family office. However, they recognize the importance of independence and objectivity associated with a family office. Wealth preservation is typically of utmost concern—protection from the “first generation earns it, second generation saves it and third generation loses it” phenomenon. Wellspring is a multi-family office providing a variety of financial and personal services to a multitude of affluent families and individuals. Services are tailored to meet the needs of multi-generational families. Working within a family setting and framework is a significant part of our business experience and a core competency. Family Consulting and Education Wealth is a responsibility—one that is not easily taught from generation to generation. At Wellspring, we work closely with our clients and their families to help improve communication among family members, educate them on their finances and assist them in developing and understanding a cohesive financial plan. We seek to increase, and in some cases improve, the quality of dialogue regarding financial matters across the generations. We also promote a sense of involvement that encourages and incorporates input from various family members. Life Planning Life is full of challenges—expected and unexpected, positive and negative. In addition to helping clients achieve their desired financial wellness, Wellspring can be instrumental in preparing and managing their life journey, with the goal of allowing clients to transition from one stage to the next with added confidence. Our familiarity with our clients’ personal and financial affairs, including their attitudes and expectations, enables us to navigate life’s challenges on their behalf. It is our way of helping clients seek to achieve a meaningful and productive life. 4-B: DESCRIBE THE TYPE OF ADVISORY SERVICES WE OFFER (CONTINUED): Personal Financial & Tax Management Comprehensive Financial Planning Financial Planning involves more than just the allocation of assets and minimization of taxes. At Wellspring, we follow a comprehensive, holistic approach that begins with asking a series of diverse questions regarding our clients’ life plans. With this information in hand, we craft a financial strategy that incorporates a deep understanding about all aspects of their financial life and goals. When appropriate, we can coordinate this financial plan across multiple generations. Income Tax Planning, Preparation and Compliance Wellspring’s comprehensive approach to wealth planning includes special attention to income taxes. Not only do we prepare necessary income tax returns, we also provide a tax plan that evaluates and minimizes future liability. So many tax advisors focus on the past—preparation of income tax returns. While this is a necessity, it is the forward-looking tax planning that often adds significant value to the overall financial plan. This proactive income tax planning conducted throughout the year is critical to our clients’ overall comprehensive plan. Through this quarterly approach, we analyze income, deductions and tax strategies for the purpose of reducing overall tax burden to our clients. Wellspring’s income tax planning, preparation and compliance services include thoughtful consideration of income taxes in the implementation of all financial, investment, retirement, wealth transfer and charitable planning. This includes: o Income tax return preparation for all federal, state and local returns o Income tax planning throughout the year to assess current and future liabilities to implement ideas to minimize taxes o Preparation of federal, state and local estimated income tax vouchers and/or income tax withholding recommendations for each calendar year, as needed o Assistance with IRS reviews and audits Estate and Wealth Transfer Individual and Family Plans Individuals and families often have very clear and specific intentions about how their wealth should be transferred or distributed. Unfortunately, whether the transfer is for family, charity or someone else, best- laid plans often do not reflect the most recent changes with regard to wealth, family situation and/or the tax code. At Wellspring, because we are so familiar with our clients’ financial situation and estate objectives, we can help in determining the appropriate and/or desired distribution of our clients’ wealth. We work with our clients’ existing estate attorneys and help oversee the administration of their estates. Our goal is to help maximize the transfer of wealth to whomever our clients intend, in the way in which they intend. Multi-Generational Plans Wellspring can also coordinate estate and wealth transfer plans across multiple generations. We stress the importance of family communication as a key ingredient to any successful plan. Our involvement with the family can foster stronger and more productive communications among the generations, as well as with the family’s trustees. Wellspring’s estate and wealth transfer services are coordinated with your estate attorney and include: o Assistance with the design and implementation of wealth transfer plans, including family and philanthropic distribution techniques o Periodic reviews of estate tax projections, flowcharts and estate documents to help achieve objectives o Assistance with the selection of trustees and ongoing oversight (individual or institutional) o Administration and compliance for nonprofit entities, private foundations, charitable trusts and estates Strategic Philanthropy and Administration At Wellspring, many of our clients believe in sharing the fruits of their financial success. We help them develop a philanthropic plan that addresses their goals and maximizes the financial benefit to them and their charities. We work with their estate counsel to develop a strategic philanthropic plan that addresses their short or long-term goals. Once established, we can also administer the plan to achieve

compliance with our clients’ intentions, income and estate tax law, as well as other regulatory requirements. Wellspring’s strategic philanthropy and administration services include: o Assistance with the operation and administration of non-profit entities, private foundations and charitable trusts o Incorporation of income tax efficiency into the overall charitable plan o Integration of other family members’ charitable intentions into one cohesive family plan Business Succession Wellspring has many clients who successfully run closely-held businesses and need help planning for the future. We help them make these decisions and design a plan that covers both orderly transitions of management and ownership. As in our approach to wealth management, we approach business succession planning holistically. We consider our clients’ influences and goals with their succession plans, providing the foundation for future decisions. Wellspring can also help clients assess where they are, versus where they would like to be. We’ll help implement, review and rebalance the plan. Wellspring’s business succession services include: o Identifying a potential successor and determining the amount of future family involvement o Fostering communication among family members regarding their interests in and ideas for the future of the family business o Developing a plan that helps meet the immediate and future needs of our clients and their businesses o Assisting with the crafting or review of legal documents to put the plan into practice o Monitoring and rebalancing the business succession plan as situations and business environments change o Assisting with the selection of other advisors to address specialty areas of the plan, including compensation and rewards planning, wealth transfer techniques and corporate restructuring Risk Management Wellspring assists clients in identifying, assessing and managing risks. We will help in the development, implementation and ongoing review of a risk management plan. While we do not anticipate the development of a plan that will hold our clients harmless from every event possible, careful planning should help mitigate some of the inherent risk that comes with considerable wealth. We will also carefully weigh the opportunity costs versus risk management and balance this comparison into our analysis. We believe in a merit-based system for selecting agents and products and we work to align our clients with appropriate choices. We do not sell products and we do not benefit in any way when clients purchase products we might recommend. Wellspring’s risk management services include: o Periodic reviews of existing insurance policies (including life, disability, liability, excess liability, health, long-term care and property/casualty) o Analysis to determine appropriate amounts of coverage as situations change o Health insurance planning, including assistance selecting Medicare coverage and any necessary supplemental coverage o Implementation of measures to help safeguard assets and personal information from outside parties, as well as to identity theft prevention o Education and implementation of prenuptial agreements or use of trusts for protection of children’s assets o Review of and implementation of measures to help insulate assets from creditors’ claims Bill Payment Services Wellspring offers bill paying services as mutually agreed upon between the client and the firm. Such services will be billed in accordance with the firm’s financial planning fee arrangements. Investment Consulting At Wellspring, our investment advisory and risk management process starts by getting to know our clients, their families and their unique situations. We ask many questions, some which might seem unusual coming from a financial advisor. We develop a strong and thorough understanding of the things that are important to our clients today as well as their goals for the future. Throughout our relationship, we remain good listeners and work closely with our clients to adjust their investment plan as their life transitions and their goals evolve. We subscribe to an Open Architecture investment philosophy. This means we have no compensatory relationships with any external investment providers. Our loyalty is to the client, not to investment managers. We recommend investments that make sense for the client. We can also tailor our investment services to consider the needs of future generations of the clients. We believe keeping focused on a long-term horizon is the best way to approach capital markets. Occasionally adopting a contrarian point of view, while difficult, is consistent with our belief that booms follow busts and that markets invariably revert to long-term mean valuation. We believe periodic portfolio rebalancing to align asset allocation with a client’s objectives, risk constraints, time horizon and the market’s relative valuation is the greatest source of value added. We recognize that every individual, family and client’s business is different in its own unique way. We deal with different strengths and challenges. This means we need to employ unique solutions to managing each investment risk scenario. We consider every aspect of our clients’ situations—financial and otherwise—to provide investment plan recommendations that fit each client’s needs. We recognize all too often there is a significant difference between what an investor “makes” and what an investor “keeps.” We strive for tax efficiency and attempt to minimize investor expenses in order to maximize after-tax returns. Our focus is on the long-term quality of an investment. 4-C: EXPLAIN HOW WE TAILOR OUR ADVISORY SERVICES TO THE INDIVIDUAL NEEDS OF OUR CLIENTS: Referenced in Item 4-B: Describe the Type of Advisory Services we Offer Please direct your attention to Item 4B for a thorough discussion of the development of a customized client relationship in each of our service areas. Clients create an Investment Policy Guideline with Wellspring. This is the primary way to communicate and document any restrictions on investing in certain securities or types of securities and/or weightings to them. 4-D: WRAP FEE PROGRAMS: Wellspring as a matter of policy and practice, does not sponsor any wrap fee program, defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. 4-E: ASSETS UNDER MANAGEMENT: As of December 31, 2023, Wellspring had the following client assets under management: ASSET TYPE AMOUNT NON-DISCRETIONARY $ 2,648,698,752 DISCRETIONARY $ 980,665,045 TOTAL $ 3,629,363,797