FOCUS FINANCIAL PARTNERS, LLC JFS Wealth Advisors, LLC (JFS), successor to the firm founded in 1986, is part of the Focus Financial Partners, LLC (Focus LLC) partnership. Specifically, JFS 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 JFS is an indirect, wholly owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of JFS. 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. JFS 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. JFS 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 individual retirement accounts (IRAs), ERISA plans, and ERISA plan participants. As such, JFS 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 non-waivable rights you possess. Wealth Management Services (WM) Wealth Management Services include continuous investment management and personal financial planning. Refer to the “Financial Planning Services” section below for details regarding JFS’ approach to financial planning. Providing investment management and financial planning services together under one fee schedule is called the Lifetime Planning Continuum®. JFS Wealth Advisors, LLC provides continual advice to a client regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, JFS develops a Financial Goal Plan and creates and manages a portfolio based on the Plan. JFS will manage advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client. A Financial Goal Plan is developed to determine the appropriate investments, investment timeframes, and levels of risk. The Plan is developed as follows:
• Gather client information.
• Consult with the client to determine goals and objectives.
• Review basic financial data, which typically includes overviews of assets and liabilities, cash flow, tax situation, short-term events, long-term goals, risk management, and estate structures.
• Identify the need for additional professional advice, such as legal, tax, accounting, etc. A client may decide to complete a Financial Goal Plan in phases rather than complete a full Plan at one time. The typical areas of a Plan are investment planning, retirement planning, cash flow analysis and budgeting, risk assessment and insurance needs analysis, tax planning, estate planning, and education planning. A client may impose restrictions on the types of securities included in the portfolio (ex. use only socially responsible securities). However, most clients do not impose restrictions, nor do we suggest that they do. The primary custodians used for client accounts are Charles Schwab & Co., Inc., Fidelity Investments, and National Advisors Trust Co. Client accounts are typically invested in no load mutual funds or Exchange Traded Funds (ETFs), although other securities can be used depending upon the unique needs, circumstances, and risk tolerance of the individual client. Investment Advisory Services (IAS) For those individuals who do not wish to engage JFS for the Wealth Management Services referenced above, JFS offers its Investment Advisory Services (IAS) platform. Under IAS, the client receives services limited to JFS’ allocation (and automatic rebalancing) of the client’s assets typically among various mutual funds or ETFs consistent with the client’s investment objectives. JFS remains available to provide personal financial planning and consulting services on a fixed fee basis upon client request. Financial Planning and Advisory Services JFS provides a range of financial planning and consulting services, which focus on analyzing a number of different aspects relevant to a client’s financial situation, including:
• Personal Financial Statements
• Cash Flow Analysis and Budgeting
• Cash Management
• Investment Planning and Asset Allocation
• Retirement Planning
• Estate and Legacy Planning
• Tax Planning
• Risk management, Risk Assessment and Insurance Needs Analysis
• Business Planning
• Distribution Planning
• Family Educational Planning Proper financial planning is an ongoing process. Life’s circumstances change, and a client’s goals and opportunities change over time. JFS believes that ongoing planning and advice are key factors in developing and maintaining an investment strategy and that an ongoing relationship should be maintained between the client and JFS. Financial planning services are typically provided in the form of a Financial Goal Plan. While a Financial Goal Plan typically encompasses a broad range of financial planning topics, JFS will focus on specific financial planning topics based on the client’s request and unique needs. Specific services are agreed upon in advance. Clients are engaged under a specific engagement letter that details the nature of the services and the fixed fee amount. These engagement letters can be terminated by the client without penalty by giving written notice of termination within five business days of executing a contract for services. The fixed fee is non-negotiable and non- refundable after the five-day grace period and is typically payable in full upon completion of contracted services. Held-Away Assets JFS implements 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 custodians. Tax Preparation Services JFS offers to provide tax return preparation services to its clients on a fixed fee and/or hourly basis. The fixed price or hourly rates depend upon the professional providing the service and the complexity of the return. Clients are engaged under a specific engagement letter that details the nature of the services and the fixed fee amount and/or that hourly charges apply. These engagement letters can be terminated by the client without penalty by giving written notice of termination within five business days of executing a contract for services. The fee is non-negotiable and non-refundable after the five-day grace period and is payable in full upon completion of contracted services. Advisory Services JFS typically provides investment advice as a part of Financial Goal Plans issued to clients. The advice is general in nature and includes guidance on asset allocation strategies and alternatives to achieve strategies. Fees for this service are charged on a fixed fee basis. Clients are engaged under a specific engagement letter that details the nature of the services and the fixed fee amount. These engagement letters can be terminated by the client without penalty by giving written notice of termination within five business days of executing a contract for services. The fixed fee is non- negotiable and non-refundable after the

five-day grace period and is typically payable in full upon completion of contracted services. Consulting Services JFS provides other services for clients, as requested, on a fixed price and/or hourly basis. If applicable, hourly charges are based on JFS’ standard hourly rates. These services include, but are not limited to business consulting and strategy, periodic investment reviews, and benefit plan analysis. Clients are engaged under a specific engagement letter that details the nature of the services and the fixed fee amount and/or that hourly charges apply. These engagement letters can be terminated by the client without penalty by giving written notice of termination within five business days of executing a contract for services. The fee is non-negotiable and non-refundable after the five-day grace period and is typically payable in full upon completion of contracted services. Business Retirement Plan Services and Business Retirement Plan Advisory Services JFS assists retirement plan sponsors with the following investment fiduciary services as set forth in JFS’ investment advisory agreement or investment management agreement.
• As an ERISA 3(38) investment manager, JFS’ investment services provided on a discretionary basis without the ERISA plan sponsor/client prior approval include: investment screening, selecting, and monitoring. JFS’ service offering typically includes creation of managed portfolio models.
• As an ERISA 3(21) investment manager, JFS’ investment services provided on a non- discretionary basis include: investment screening, selecting, and monitoring. JFS’ service offering typically includes creation of managed portfolio models. However, the ERISA plan sponsor/client retains and exercises the final decision-making authority for implementing or rejecting JFS’ recommendations.
• Additional fiduciary services provided by JFS may include: screening, selecting, and monitoring of the Plan’s Qualified default investment alternative and revision or creation and maintenance of the Plan’s Investment Policy Statement (IPS). JFS assists retirement plan sponsors with the following non-fiduciary services as set forth in JFS’ investment advisory agreement or investment management agreement.
• Qualified and non-qualified retirement plan design;
• Group and individual employee education and counseling; and
• Investment committee and plan sponsor fiduciary education. Custodians of retirement plan Trustee accounts and retirement plan participant accounts include Charles Schwab & Co., Inc., Charles Schwab Bank, Matrix, Fidelity Institutional, Mid Atlantic, Ascensus Trust, Reliance Trust Co., Commonfund, and Tecum Capital Partners. JFS’ Business Retirement Plan Services and Business Retirement Plan Advisory Services are fee-based, and clients are engaged under a specific contract for services. These contracts can be terminated by the client without penalty by giving written notice of termination within five business days of executing a contract for services. After the five-day period, a client can terminate the agreement at any time with a thirty-day written notice. 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). Please see Items 5 and 10 for a fuller discussion of these services and other important information. We also 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 these services and other important information. Miscellaneous Non-Discretionary Service Limitations Clients who decide to engage JFS on a non-discretionary investment management or advisory basis must be willing to accept that JFS cannot effect any account transactions without obtaining prior written or verbal consent to any such transactions from the client. Accordingly, in the event of a market correction during which the client is unavailable, JFS will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s written or verbal consent. Client Obligations Each client retains the responsibility to promptly notify JFS if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, and/or revising JFS’ previous recommendations or services. When performing requested services, JFS will not be required to verify any information received from the client or from the client’s other professionals. JFS is expressly authorized to rely on such information. Financial Planning and Non-Investment Consulting/Implementation Services Neither JFS, nor any of its employees, serves as an attorney. Accordingly, none of JFS’ services should be viewed as those provided by an attorney. When requested by a client, JFS recommends the services of other professionals for the implementation of certain financial planning recommendations or other non-investment implementation purposes (ex. attorneys, accountants, insurance agents/agencies, etc.), including JFS’ related licensed insurance entity. Clients are under no obligation to engage the services of any recommended professional. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from JFS. If any client engages a recommended professional, and a dispute arises afterward relative to that engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Conflict of Interest A potential conflict of interest exists for retirement plan rollovers. 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):
• Leave the money in the former employer’s plan, if permitted;
• Roll over the assets to the new employer’s plan, if one is available and rollovers are permitted;
• Roll over the assets to an Individual Retirement Account (“IRA”); and/or
• Cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If JFS recommends that a client roll over their retirement plan assets into an account to be managed by JFS, such a recommendation creates a conflict of interest if JFS will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by JFS. JFS’ Chief Compliance Officer, August Santillo, 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. The recommendation by JFS that a client purchase an insurance commission product from JFS’ related insurance entity, JFS Risk Management, LLC, presents a conflict of interest. The receipt of commissions by JFS Risk Management, LLC provides an incentive to recommend insurance products based on commissions to be received rather than on a particular client’s need. However, JFS does have a duty at all times to act in the client’s best interest. No client is under any obligation to purchase any insurance commission product from JFS’ related insurance entity. Clients are reminded that they may purchase insurance products recommended by JFS through other, non-related insurance agencies. JFS’ Chief Compliance Officer, August Santillo, remains available to address any questions that clients or prospective clients may have regarding this or any other conflict of interest. Dimensional Fund Advisors Mutual Funds JFS 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 were to terminate JFS’ 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. In addition to JFS’ investment advisory fee described in Item 5 below, and transaction and/or custodial fees that may be charged by the account custodian, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Assets Under Management JFS manages $3,389,350,596 in client assets as of December 31, 2023 of which $2,940,390,726 are discretionary and $448,959,870 are non-discretionary.