Description of Advisory Firm BFSG, LLC, doing business as Benefits Financial Services Group (“BFSG”), is a limited liability company formed in the State of Delaware. BFSG, LLC has been in business as an investment adviser, registered with the Securities and Exchange Commission since 2007. BFSG is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, BFSG is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because BFSG is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of BFSG. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. BFSG has two divisions that offer separate advisory services: BFS Wealth Management and BFS Institutional Services. BFSG is managed by John Campbell, Darren Stewart, Christopher Rowey, Tina Schackman, Grace Lau, Patrick Powers, Steven Yamshon, and Michael Allbee (“BFSG Principals”), pursuant to a management agreement between Retirement Plan Consultant Group (“RPCG, LLC”) and BFSG. The BFSG Principals serve as officers and leaders of BFSG and are responsible for the management, supervision and oversight of BFSG. As of December 31, 2023, our assets under management are $1,148,705,835 managed on a discretionary basis and $381,356 managed on a non-discretionary basis and our assets under consultation are $16,003,674,151. Assets under consultation are assets for which we provide ongoing recommendations based upon the needs of the retirement plan sponsor client, as to which specific securities or other investments to make available to its plan participants, as well as other services set forth in the Consulting Agreement. Our Advisory Services BFS Wealth Management At BFS Wealth Management, we believe that through hard work, decades of experience, and precise attention to detail we can help our clients achieve their financial goals. Wealth management is a more holistic service than just offering investment management and may include financial planning, pension consulting, and advising on estate planning and insurance needs. Our commitment is to create fundamentally sound, well-constructed, diversified portfolios tailored to each client’s needs and goals. We monitor the investments to evaluate performance against appropriate market-based benchmarks and modify each portfolio strategy as needed to support a measurable outcome. Individual investors, employer-directed retirement plans, corporations, trust estates, and charitable trusts have all benefitted from our expertise. Through our client focused approach, we offer our clients the following advisory services: Financial Planning To the extent requested by the client, BFSG will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. BFSG will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below, as specified in our contract with you (exceptions do occur based upon assets under management, certain investment offerings such as our Automated Investment Program services, special projects, stand-alone planning engagements, etc., for which BFSG may charge a separate or additional fee). Financial planning is a comprehensive evaluation of your current and future financial state by using currently known variables based on information you disclose to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they impact and are impacted by your entire financial and life situation. You will receive a written or an electronic report, providing a detailed financial plan designed to achieve your stated financial goals and objectives. Please remember to contact us, in writing, if there are any changes in your personal/financial situation so that we can review whether the changes impact our previous recommendations. Please Note: BFSG does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, BFSG does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). 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 BFSG and/or its representatives. If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not BFSG, shall be responsible for the quality and competency of the services provided. Please Note: Planning Limitations. BFSG believes that it is important for the client to address financial planning issues on an ongoing basis. BFSG’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with BFSG. It remains each client’s responsibility to promptly notify BFSG 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 Portfolio Management We offer discretionary and nondiscretionary investment management services in accordance with your individual needs. Through personal discussions about your investment history, financial circumstances, and goals, we determine your investment objectives and develop an asset allocation plan which will guide the management of your portfolio. Target asset allocations range from 100% equities to 100% fixed income and may include private investments. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in private equity
• Non-public real estate investment trusts
• Private investments
• Annuities
• Stock options Our investment strategies typically focus on multi-capitalization publicly listed stocks (ranging from small- to large-sized companies), as well as exchange traded funds and/or mutual funds. When appropriate (i.e., depending on advisory account size or selected investment offering) or when preferred by you, our investment strategies will utilize only exchange traded funds and/or mutual funds. We offer Environmental, Social, and Governance (“ESG”) investment portfolios investing in securities of environmentally responsible and sustainable global companies that make an environmental contribution. Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by BFSG independent of engaging BFSG as an investment advisor. However, if a prospective client determines to do so, he/she will not receive BFSG’s initial and ongoing investment advisory services. In addition to BFSG’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (i.e., management fees and other fund expenses). Please Note: BFSG utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate BFSG’s services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. BFSG may recommend that the client allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. BFSG shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that BFSG shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), advisory account size, management style, performance, reputation, financial strength, reporting, pricing, and research. The client is under no obligation to engage an Independent Manager[s]. You should refer to the selected independent third-party money manager’s Form ADV Part 2A or other disclosure document for a full description of the services offered. Please Note: The investment management fee charged by the Independent Manager([s)] is separate from, and in addition to, BFSG’s investment advisory fee disclosed at Item 5 below. Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, BFSG will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services and uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, BFSG will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: BFSG does not recommend or advocate the purchase of, or investment in, cryptocurrencies. BFSG considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Interval Funds/Risks and Limitations: Where appropriate, BFSG may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct BFSG, in writing, not to purchase interval funds for the client’s account. Unaffiliated Private Investment Funds: BFSG also provides investment advice regarding unaffiliated private investment funds. BFSG, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. BFSG will only recommend private funds to those clients for whom it reasonably believes such an investment to be suitable, given the client’s total portfolio, risk parameters and liquidity needs. BFSG’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of BFSG calculating its investment advisory fee. BFSG’s fee shall be in addition to the fund’s fees. BFSG shall not exercise any discretion as to whether or not a client shall invest in any private fund. Rather, the ultimate investment decision shall remain with the client. BFSG’s clients are under absolutely no obligation to consider or make an investment in any 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 own, 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 BFSG references private investment funds owned by the client on any supplemental account reports prepared by BFSG, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, BFSG shall calculate its fee based upon the latest value provided by the fund sponsor. Please Note: 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 recommended or undertaken by BFSG) will be profitable or equal any specific performance level(s). Automated Investment Program We offer an automated investment program (“Wealth Accumulator”) to individuals which gives clients access to our investment strategies, with limited personalized service and no financial planning services, for a discounted fee. Through Wealth Accumulator, account(s) are invested in a range of investment strategies constructed and managed, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. We also offer Environmental, Social, and Governance (“ESG”) Wealth Accumulator portfolios that focus on ETFs with ESG attributes. Clients utilizing Wealth Accumulator may instruct us to exclude up to three ETFs from the portfolio. Portfolios in Wealth Accumulator are held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“Schwab”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Schwab, to operate Wealth Accumulator. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, Schwab, or their affiliates (together, “Schwab”). We, and not Schwab, are the investment advisor and primary point of contact with respect to the automated investment program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of Wealth Accumulator for our clients, choosing a suitable investment strategy and portfolio for each client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for Wealth Accumulator. The Platform enables us to make Wealth Accumulator available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine each client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. We will recommend a portfolio via the System in response to client answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage client portfolios on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Schwab as part of Wealth Accumulator. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™, Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Credit and Cash Management Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Focus Risk Solutions We help our clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. Services to Retirement Plans BFS Wealth Management advises certain retirement plan sponsors on the selection and monitoring of mutual funds offered to participant-directed retirement plans. Most of our Firm’s services

to retirement plans are offered through BFS Institutional Services. The range of services we provide to retirement plans and our fiduciary responsibilities under ERISA are summarized in the BFS Institutional Services section below. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our clients. However, specific client services and their implementation are dependent upon your Investment Policy Statement, or suitability questionnaire, which outlines your current situation (income, tax levels, and risk tolerance levels) and is used to construct a specific plan to aid in the selection of a portfolio that matches your restrictions, needs, and targets. You can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, specific consultation regarding investment and financial concerns, or any other specific topic. Furthermore, the independent third-party money managers may have asset minimums imposed. You may impose reasonable restrictions on investing in a particular security, a type of security, or industry sectors. You must notify us in writing of specific restrictions. In performing our services, BFSG 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, it remains each client’s responsibility to promptly notify BFSG 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. Miscellaneous Retirement Rollovers (Potential for 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 and penalties). If BFSG recommends that you roll over your retirement plan assets into an account to be managed by BFSG, such a recommendation creates a conflict of interest if BFSG will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, BFSG serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code (the “Code”), or both, which are laws governing retirement accounts. BFSG’s investment professionals will document and disclose the reasons that a recommendation to roll over assets is in your best interest. No client is under any obligation to roll over retirement plan assets to an account managed by BFSG. BFSG maintains policies and procedures designed to ensure adherence with the provisions under ERISA or the Code, or both. BFSG’s Chief Compliance Officer, 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. Portfolio Activity: BFSG has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, BFSG 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, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when BFSG determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by BFSG will be profitable or equal any specific performance level(s). Held-Away Accounts: We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). The data aggregation platform that we use for held-away accounts is provided by ByAllAccounts, a product of Morningstar, Inc. Once the client’s account(s) is connected to the ByAllAccounts platform, we will review the client’s current account allocations. We will rebalance the connected outside accounts consistent with the client’s investment goals and risk tolerance. Client account(s) will be reviewed at least quarterly. We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our clients’ primary custodian(s). Further information about this service is available in Item 5. Custodian Charges/Additional Fees: As discussed below in Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, BFSG generally recommends that Fidelity or Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity and Schwab charge transaction fees for effecting certain securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab and Fidelity, generally (with potential exception) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab and/or Fidelity will not change their transaction fee pricing in the future. Please Also Note: Fidelity and Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. In addition to BFSG’s investment advisory fee referenced in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s account (i.e. primarily certain mutual funds). BFSG’s Chief Compliance Officer, remains available to address any questions that a client or prospective client may have regarding the above. BFS Institutional Services Using the standards set forth in governing law, such as the Employee Retirement Income Security Act (ERISA), California Constitution, Government Code, and the Uniform Prudent Management of Institutional Funds Act (UPMIFA), BFS Institutional Services advises plan sponsors, committees, and fiduciaries in understanding and addressing responsibilities to their plan, participants, and beneficiaries. We emphasize the development and implementation of proactive prudent processes which help fiduciaries provide participants an effective retirement tool, while lowering or limiting their liability. Our team-based approach helps each of our clients have access to the knowledge and expertise of our experienced retirement and investment professionals. We realize that the retirement plan and institutional marketplace is constantly changing, and therefore keeping clients informed is of critical importance. Pension Consulting Services We offer the following services to retirement plan sponsors: Investment & Compliance Consulting We offer ongoing investment and compliance consulting services, which include, but are not limited to, formalizing committee processes, reviewing and recommending investment managers, quarterly investment reviews, annual review of plan costs/revenues and fiduciary education. Unless our discretionary service is used, the retirement plan sponsor retains and exercises, the final decision-making authority for implementing or rejecting our recommendations with respect to investment selection and de-selection. We acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in the Consulting Agreement with you). Vendor Search & Selection/Benchmarking We assist retirement plan sponsors with vendor search and selection processes, including: ▪ Customize Request for Proposal (RFP) based upon client’s needs and objectives ▪ Develop list of vendor candidates to send RFP ▪ Prepare provider analysis with proprietary scoring methodology Fiduciary Structure & Cost Assessment We review service provider arrangements, fiduciary procedural prudence and benchmark plan costs and revenues. ▪ Outline all plan-related costs and revenues back to service providers ▪ Provide comparison on Plan costs and revenues for benchmarking purposes ▪ Review plan design and features ▪ Provide options for potential revenue recapture options, if applicable Discretionary Fiduciary Services We accept discretionary fiduciary responsibility within the meaning of Section 3(38) of ERISA for the investment selection and monitoring process of investment options in a retirement plan (with the exception of company stock) consistent with the investment objective designated by the Plan trustees. In such engagements, BFSG will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and make the investment decisions in its sole discretion without the retirement plan sponsor’s prior approval. BFSG will generally provide services on an “assets under management” fee basis per the terms and conditions of a written agreement between the Plan and the Firm. Participant Education/Communication We can also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement with the plan. For such engagements, we shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by us), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Specifically, we create and deliver educational workshops and enrollment meetings for plan participants under the terms of the Consulting Agreement.
• Create and deliver educational workshops for plan participants
• Prepare customized participant communications
• Conduct enrollment meetings
• One-on-one participant consultations and financial planning (the range of financial planning services we provide to plan participants are summarized in the BFS Wealth Management Services section above and as specified under the terms of the Consulting Agreement with you) Fiduciary Services BFSG is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. BFSG is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, and individual retirement accounts (“IRAs”). As such, BFSG is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Participant Directed Retirement Plans BFSG can also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a written agreement between BFSG and the plan. For such engagements, BFSG shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by BFSG), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Managed Account Service Under our Managed Account Service, we are responsible for managing retirement plan participant accounts until the individual elects to discontinue the Managed Account Service. Eligible participants are enrolled in the Managed Account Service in accordance with rules established by the retirement plan sponsor. Based on personal criteria and financial information provided by the plan sponsor or by each participant, we select investment allocations on a discretionary basis using the investment options that are available within the retirement plan, as defined by the retirement plan sponsor. Company stock, brokerage account holdings, and certain specific other investments may be excluded from our recommendations. Excluded investments are taken into account when making allocation recommendations. Transaction instructions are then sent to the plan provider to implement our recommended retirement strategy in the participant’s plan account. A participant can elect to discontinue participating in the Managed Account Service at any time. Socially Responsible (ESG) Investing Limitations. As noted above, we offer ESG portfolios. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by BFSG), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. BFSG generally relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the funds or portfolio’s underlying company securities meet a socially responsible mandate. Non-Discretionary Service Limitations. Clients that determine to engage BFSG on a non- discretionary investment advisory basis must be willing to accept that BFSG cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, BFSG will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Portfolio Activity. BFSG has a fiduciary duty to provide services consistent with the client’s best interest. BFSG 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, market conditions, fund manager tenure, style drift, account additions or /withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when BFSG determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by BFSG will be profitable or equal any specific performance level(s). Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, BFSG shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless BFSG reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within the BFSG’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of BFSG’s unmanaged accounts. Please Note: Cash Positions. BFSG continues to treat cash as an asset class. As such, unless determined to the contrary by BFSG, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating BFSG’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), BFSG may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, BFSG’s advisory fee could exceed the interest paid by the client’s money market fund. eMoney and MoneyGuidePro Financial Planning Platforms. BFSG may provide its clients with access to an online platform hosted by third party vendors. These platforms allow a client to view their complete asset allocation, including those assets that BFSG does not manage (the “Excluded Assets”). BFSG does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, BFSG’s service relative to the Excluded Assets is limited to reporting only. Therefore, BFSG shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not BFSG, shall be exclusively responsible for such investment performance. Without limiting the above, BFSG shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage BFSG to manage some or all of the Excluded Assets pursuant to the terms and conditions of an advisory agreement between BFSG and the client. These platforms also provides access to other types of information and applications including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by BFSG. Finally, BFSG shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the platforms without BFSG’s assistance or oversight. Client Obligations. In performing our services, BFSG 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, it remains each client’s responsibility to promptly notify BFSG 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. Please Note: 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 recommended or undertaken by BFSG) will be profitable or equal any specific performance level(s). Disclosure Brochure. A copy of the BFSG’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and the BFSG. Client Tailored Services and Client Imposed Restrictions For clients in our Managed Accounts Service, specific participant services and their implementation are dependent upon the participant’s current situation (years until retirement and risk tolerance levels) and is used to construct a participant-specific portfolio that matches restrictions, needs, and targets. For clients in our Pension Consulting, we offer general investment advice. For clients using our Discretionary Fiduciary Services, we usually allow clients to impose restrictions on investing in certain asset classes.