A. Deane Retirement Strategies, Inc. (“we” or “Deane Retirement”) is a Louisiana corporation formed on March 3, 1993. Deane Retirement became registered as an Investment Adviser Firm in August 2007. Deane Retirement is principally owned by Keith L. Deane, Chief Compliance Officer and Managing Director and Todd C. Tillery, Managing Director, Secretary, and Treasurer B. As discussed below, Deane Retirement offers to its clients (generally: individuals, high net worth individuals, trusts, estates, pension and profit sharing plans, etc.) discretionary investment advisory services and, to the extent specifically requested by a client, financial planning, retirement planning and/or related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage Deane Retirement to provide discretionary investment advisory services on a fee basis. Before engaging Deane Retirement to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Deane Retirement setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, Deane Retirement will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the Deane Retirement’s balance portfolio strategies. Once allocated, Deane Retirement provides ongoing supervision of the account(s). Both Individual Clients and Company Sponsored Retirement Plans may choose to engage Deane Retirement to provide discretionary investment advisory services on an annual fee basis, based upon a percentage (%) of the market value of the entire assets placed under Deane Retirement’s management. This advisory service is designed for clients whose assets to be managed by Deane Retirement are generally $1,000,000 and above. Assets managed below $1,000,000 are subject to a minimum quarterly fee, which results in a higher percentage than the fees quoted in the fee schedule provided in Item 5 below. Deane Retirement’s annual investment advisory fee compensates for investment advisory services, and, to the extent specifically requested by the client, may include financial and retirement planning and/or consulting services. See Financial Planning and Consulting Services below. If financial and retirement planning services are included as part of the advisory engagement, but the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Deane Retirement), Deane Retirement may determine to charge for such additional services, the dollar amount of which will be set forth in a separate written notice to the client. Deane Retirement manages client accounts, on a discretionary basis, guided by a balanced management style portfolio. The description of the Balanced Management Style is as follows: Balanced Management Style Profile Philosophy on Investing We use stocks, bonds, and cash holdings as the building blocks for our Balanced Style portfolio. Our goal is to combine these three asset classes to produce high, but sustainable, portfolio growth while minimizing portfolio volatility. The segment of the portfolio that is dedicated to each asset class is determined after a review of the current opportunities and risks in the investment markets. The final result is a diversified portfolio of approximately 35-45 positions consisting of stocks, bonds, and cash that work together, not as separately managed, uncoordinated silos. During periods of abnormal market distress, we may also employ specific strategies using non-leveraged, Inverse Stock and/or Bond exchange traded funds (“ETFs”), up to an approximate 10% maximum share of the portfolio, to cushion portfolio declines. The normal turnover target for the portfolio is 50% per year. However, turnover may exceed this target at times if market conditions dictate a need to limit risk or present unusual opportunities to enhance potential gains. Please Note: Higher account turnover could adversely impact after-tax gains in a non-qualified account. Inverse/Enhanced Market Strategies. Deane Retirement may use exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. To the contrary, such funds and/or strategy(ies) can suffer substantial losses. In light of these enhanced risks/rewards, a client may direct Deane Retirement, in writing, not to employ any or all such strategies for their accounts. Portfolio Stock Allocation Our starting point for building the portfolio is always the stock allocation because stocks usually provide the greatest return opportunities while contributing the most to portfolio risk. Typically, approximately 60% of the portfolio is allocated to U.S. stocks of all sizes across a wide range of industries. International stocks from other developed markets around the world can be included in the allocation, to further increase diversification and opportunity. We prefer to include stocks that pay a dividend, but we sometimes include non-dividend paying stocks when the return potential is attractive. We believe that the best investments are in companies that possess sustainable competitive advantages, avoid excessive indebtedness, and employ a shareholder friendly management team that is committed to increasing the value of the company. We strive to purchase stocks at significant discounts to their intrinsic values or when our measures of market demand for stocks are favorable. We will also hold market sector based ETFs if deemed appropriate. Market index ETFs will be used to fill the foreign allocation in the portfolio. Portfolio Bond Allocation Bonds are included to reduce portfolio risk and volatility while providing a source of return that is more stable and predictable than the return from stocks. Bonds are typically allocated to approximately 35% of the portfolio. The core of the allocation consists of U.S. Treasury bonds bought individually or via ETFs. This core serves as the portfolio risk reducer. To enhance returns, we may also include investment grade mortgages, corporate bonds, and preferred stocks, if we believe they are attractive in the current market environment. Any of these may be bought individually or through ETFs, as appropriate. In some circumstances, the portfolio may also purchase high yield bond and dollar index ETFs. Portfolio Cash Allocation The portfolio will typically (but not necessarily) hold a 5% cash allocation for liquidity and transactional purposes. A client’s cash allocation will be included for advisory fee billing purposes. Index ETFs: Individual client accounts valued at less than $100,000, are managed consistently with the above descriptions, but investments are limited to index ETFs. No individual stocks or individual bonds are utilized in these accounts. FINANCIAL PLANNING AND CONSULTING SERVICES To the extent specifically requested by a client, Deane Retirement may provide financial and retirement planning and/or consulting services (including investment and non- investment related matters) as part of the advisory engagement. 401(k) DISCRETIONARY INVESTMENT ADVISORY SERVICES FOR INDIVIDUALS The individual client with an employer retirement plan account can determine to engage Deane Retirement to provide discretionary investment advisory services with regard to the investments in the client’s Plan Account, pursuant to the terms and conditions of an executed Planning and Investment Advisory Agreement for individual clients. Deane Retirement’s investment advisory fees are separate from any other fees attributed to investments in the client’s 401(k) plan account and/or charges levied by the plan’s custodian or third party administrator. Individual Discretionary 401(k) Services The client can engage Deane Retirement to manage the assets in the client’s 401(k) plan, guided by the Balanced Management Style referred to above. Deane Retirement’s discretionary management of the client’s 401(k) account is available only with web-access to the client’s plan and does not include the ability to change beneficiaries or issue 3rd party payments from the client’s 401(k) account. Deane Retirement will be responsible for determining and making the 401(k) account transactions. However, if a brokerage window account is not available to the client, Deane Retirement will be forced to limit the clients’ investment selections to the index funds available on the client’s 401(k) plan’s fund menu, and Deane Retirement will be unable to provide the client with 401(k) quarterly or annual performance reports. Deane Retirement will manage individual client accounts without a brokerage window meeting the conditions of this paragraph on a discretionary basis. Deane Retirement will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Deane Retirement of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the Deane Retirement to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Deane Retirement calculating its advisory fee. 401(K) PLAN “COLLECTIVELY MANAGED ACCOUNT” PROGRAM FOR COMPANY PLANS A 401(k) plan sponsor, in its capacity as a plan fiduciary, may engage Deane Retirement directly to manage the plan accounts of all participants, guided by their Balanced Management Style. Deane Retirement will manage the plan accounts on a discretionary basis as an investment manager under ERISA in a “Collectively Managed Account” established by the plan for the benefit of all participants. Plan participants do not direct the investment of their plan account, in this instance. In some cases, however, if the plan sponsor has determined, in its sole discretion, to offer the availability of self-directed brokerage accounts as an investment option, plan participants may elect to direct the investment of some or all of their plan account through a self-directed brokerage account rather than have their plan account managed by Deane Retirement in the “Collectively Managed Account”. The Collectively Managed Account Program is governed by the terms and conditions of an executed Retirement Plan Investment Advisory Agreement between Deane Retirement and the plan sponsor. Deane Retirement may also offer non-advisory, non-fiduciary services to the plan and its participants through the Collectively Managed Account Program, such as education and training for select employees of the plan sponsor, and general financial and investment education for plan participants. Deane Retirement may assist with the conversion of the plan to a platform served by a Third Party Administrator (“TPA”) who has been pre-approved by Deane Retirement, or will work with a plan’s existing TPA, subject to acceptance by Deane Retirement in its sole discretion. The plan is responsible for the final selection of any TPA working on behalf of the plan. MISCELLANEOUS Fiduciary Acknowledgment. Deane Retirement represents that it and its

representatives are fiduciaries, including as defined under ERISA, with respect to any investment advice provided by Deane Retirement or its representatives. Limitations of Non-Investment Consulting/Implementation Services. If specifically requested by the client, Deane Retirement may provide consulting services regarding non- investment related matters, such as retirement planning, estate planning, tax planning, insurance, etc. Deane Retirement will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, extraordinary matters, special projects, stand-alone planning engagements, etc. for which Firm may charge a separate or additional fee). Please Note. Deane Retirement believes that it is important for the client to address financial planning issues on an ongoing basis. Deane Retirement’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 Deane Retirement. Neither Deane Retirement, nor any of its representatives serves as an accountant, and no portion of Deane Retirement’s services should be construed as accounting, legal or insurance brokerage services. Accordingly, we do not prepare estate planning documents or tax returns. Unless specifically agreed in writing, neither Deane Retirement or its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or monitor any financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with Deane Retirement, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from Deane Retirement. To the extent requested by a client, Deane Retirement may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, licensed insurance agents, company retirement plan third party administrators, etc.). The client is under no obligation to engage the services of any recommended professional. If the client engages any recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. The preceding sentence shall not limit or waive any applicable rights under federal or state law, including securities laws and fiduciary obligations that cannot be limited or waived. It remains the client’s responsibility to promptly notify Deane Retirement if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Deane Retirement’s previous recommendations and/or services. Investment Performance. The client must be willing to accept that past performance does not guarantee future results and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by Deane Retirement) may not: (1) achieve their intended objective; (2) be profitable; or (3) equal historical performance level(s). Retirement Plan 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 Deane Retirement recommends that a client roll over their retirement plan assets into an account to be managed by Deane Retirement, such a recommendation creates a conflict of interest if Deane Retirement will earn a new (or increase its current) advisory fee as a result of the rollover. If Deane Retirement provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Deane Retirement is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Deane Retirement. Deane Retirement’s Chief Compliance Officer, Keith Deane, remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such a rollover recommendation. Portfolio Trading Activity or Inactivity. Deane Retirement has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Deane Retirement 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 and/or a change in the client’s investment objectives. Based upon these factors, there may be extended periods of time when Deane Retirement determines that upon review trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of account of inactivity. Cash Positions. Deane Retirement continues to treat cash as an asset class. As such, unless determined to the contrary by Deane Retirement, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Deane Retirement’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), Deane Retirement 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, Deane Retirement’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Deane Retirement’s Chief Compliance Officer, Keith Deane, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Trade Error Policy. Deane Retirement will reimburse accounts for losses resulting from Deane Retirement’s trade errors but will not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within Deane Retirement’s custodian firm account and Deane Retirement retains the net gains and losses. Cybersecurity Risk. The information technology systems and networks that Deane Retirement and its third-party service providers use to provide services to Deane Retirement’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Deane Retirement’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Deane Retirement are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Deane Retirement has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Deane Retirement does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Reporting Services. Deane Retirement, through Black Diamond, can also provide account reporting services, which can incorporate client investment assets that are not part of the assets that Deane Retirement manages (the “Excluded Assets”). Unless agreed to otherwise, the client and their other advisors that maintain trading authority, and not Deane Retirement, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, Deane Retirement does not provide investment management, monitoring or implementation services for the Excluded Assets. If Deane Retirement is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Deane Retirement shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client can engage Deane Retirement to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Deane Retirement and the client. Other Assets. To the extent that Deane Retirement provides advisory monitoring or review services for client investment assets for which Deane Retirement does not maintain custodian access or trading authority (including initial and ongoing consideration of such assets as part of the client’s asset allocation), Deane Retirement may determine to include such assets in its advisory fee calculation per Item 5 below. Disclosure Brochure. A copy of Deane Retirement’s written disclosure statement as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) will be provided to each client before, or contemporaneously with, the execution of the applicable form of agreement for either an individual(s) or a plan. Client Obligations. In performing its services, Deane Retirement will 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. Clients are responsible to promptly notify Deane Retirement if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Deane Retirement’s previous recommendations and/or services. C. Deane Retirement provides investment advisory services specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Deane Retirement will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). An individual client may impose reasonable restrictions, in writing at any time, bearing on Deane Retirement’s services. Plan clients in the Collectively Managed Account program will determine, as a fiduciary of the plan, that the Balanced Management Style is appropriate for the long term investment needs of the plan and its participants. D. Deane Retirement does not provide investment advisory services on a wrap fee basis. E. As of December 31, 2022, Deane Retirement had $188,627,498 in client assets under management on a discretionary basis.