SAXWA is wholly owned by an affiliated accounting firm, SAX LLP. SAXWA has been providing advisory services since 1999. As of December 31, 2023, SAXWA managed $1,705,713,352 on a discretionary basis, $33,641,421 on a non-discretionary basis and advised on an additional $ 371,888,574 of self-directed retirement account assets. InvestmentManagementServices SAXWA manages investment portfolios and offers wealth management services for a wide range of clients including individuals/high net worth individuals, qualified retirement plans, trusts, charitable organizations, corporations and small businesses. SAXWA will work with clients to determine the client’s investment specific objectives and investor risk profile. These objectives may be set forth in a written Investment Policy Statement (IPS) that describes an asset allocation that conforms to the client’s risk tolerance level and expected rate of return requirements. SAXWA may evaluate the client's existing investments with respect to the client's investment policy and individual performance. SAXWA will typically, a. Analyze the client's financial condition; b. Recommend options to achieve the client's financial objectives; c. Implement investment strategies; and d. Monitor performance of the client's investment. For certain clients, in addition to managing the client’s investment portfolio, SAXWA may provide various wealth management services including retirement planning, income and estate tax planning, business sale structures, charitable gift planning, college planning, risk management counsel, establishment of and counsel on retirement plans, and assistance with assets outside SAXWA direct management, among other things. SAXWA may work with new clients to develop a transition plan in order to move from the client's existing asset allocation to the asset allocation recommended by SAXWA. SAXWA uses investment and portfolio allocation software to evaluate alternative portfolio designs. SAXWA evaluates the client’s existing investments with respect to the client’s investment objective and tax consequences, among other considerations. SAXWA will then continuously monitor the client’s portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the account as necessary. SAXWA will typically create a portfolio of no-load mutual funds or ETFs, and may use model portfolios if the models match the client's investment policy. SAXWA will allocate the client's assets among various investments taking into consideration the client’s unique ability, need and willingness to take risk. SAXWA primarily recommends portfolios consisting of passively managed asset class and index mutual funds or Exchange Traded Funds (ETFs) and, where appropriate, individual fixed income securities. Consequently, the fund expenses are generally lower than fees and expenses charged by other types of funds. SAXWA primarily recommends mutual funds that follow an evidence-based investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified by the client. SAXWA manages mutual fund and equity portfolios on a discretionary and in more limited circumstances, on a non-discretionary basis according to the investment policy selected by the client. A client may impose any reasonable restrictions on SAXWA’s discretionary authority, including restrictions on the types of securities in which SAXWA may invest client’s assets and on specific securities, which the client may believe to be appropriate. For clients with a significant fixed income allocation, SAXWA generally recommends customized, laddered bond portfolios to clients. In such situations, SAXWA will typically request discretionary authority from clients to manage their fixed income assets. Discretionary authority may be necessary to enable SAXWA to purchase such assets in a timely manner when they are available at quoted prices. Complete customized, laddered fixed income portfolios generally require a minimum level of assets allocated to fixed income. Low-cost, passively managed fixed income mutual funds may be used for smaller allocated amounts. SAXWA regularly monitors credit ratings of client account holdings as reported by Moody’s, Standard and Poor and/or Fitch. SAXWA may, at its discretion maintain or sell securities based on transaction costs and other investment considerations. It is the firm’s policy to hold most, but not all, fixed income assets in client portfolios until maturation absent a material change in credit quality or other investment decisions such as tax-loss harvesting opportunities. Additionally, for clients holding certificate of deposits (CDs), SAXWA will regularly monitor the total CD positions to ensure principal invested in CDs does not exceed FDIC insurance limits. For accounts linked by the same tax-payer identification number, SAXWA examines CD positions within accounts under SAXWA management to look for breaches of FDIC insurance limits on principal invested in CDs. The firm does not monitor for CD positions held away from SAXWA. If clients hold CD positions elsewhere, it is their duty to inform SAXWA. On an ongoing basis, SAXWA will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. SAXWA will provide to third-party investment managers any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. SAXWA utilizes a third-party platform to facilitate the management of held-away assets in which SAXWA has discretionary authority to implement

tax-efficient asset location and opportunistic rebalancing strategies on behalf of the Client. These are primarily 401(k) accounts, 529 Plans, Health Savings Accounts, and other assets which are held at third-party custodians. SAXWA regularly reviews the available investment options in these accounts, monitors and rebalances and implements our strategies in the same way we do other accounts, though using different tools as necessary. SAXWA is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client allowing them to connect a held-away account(s) to the platform. Once Client account(s) are connected to the platform, SAXWA will review the current account allocations. When deemed necessary, SAXWA will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. In limited circumstances, SAXWA utilizes a different third-party platform to facilitate the management of client accounts, including for asset allocation, model portfolios and investment strategies, as well as billing and administrative services. The client accounts managed on this platform were previously managed by an adviser that has been acquired by SAXWA. SAXWA does not use this platform for new client relationships. EmployeeBenefitPlanServices SAXWA also provides advisory services to participant-directed employee retirement benefit plans. SAXWA will analyze the plan's current investment platform, and may assist the plan in creating an investment policy defining the types of investments to be offered and the restrictions that may be imposed. SAXWA will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. SAXWA will recommend changes in the plan's investment vehicles as may be appropriate from time to time. SAXWA will review the plan's investment vehicles and investment policy as necessary. SAXWA will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. ComprehensiveFinancialPlanningServices SAXWA also provides advice in the form of Comprehensive Financial Planning. Clients purchasing this service may receive a written financial report, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern:  Personal: Family records, budgeting, personal liability, estate information and financial goals.  Professional: Cash flow expectations, debt structure, transition planning and office space lease vs. buy decisions  Education: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependent’s continuing educational needs through development of an education plan.  Tax & Cash Flow: Income tax, spending analysis and planning for past, current and future years.  Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.  Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.  Investments: Analysis of clients’ investments and their effect on a client’s portfolio.  Divorce Planning: Address financial issues and decisions that face couples in the process of divorce. SAXWA gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, SAXWA suggests the client work closely with his/her attorney, accountant or insurance agent. SAXWA does not provide any legal or accounting advice. Clients should seek the counsel of a qualified accountant and/or attorney when necessary. Implementation of financial plan recommendations is entirely at the client’s discretion. SpecializedConsultingServices SAXWA can provide an analysis of outside investment managers. Clients purchasing this service will receive a written report. The report may include, among other items, Client asset allocation, diversification, duplication of services, synergy of managers, analysis of fixed income holdings, fees where publicly available, notification of investments with limited transparency and compromised liquidity, and relevance to Client’s financial goals and objectives. UseofIndependentManagers A portion of the client’s assets may be placed with unaffiliated, registered investment advisors (herein Independent Managers). The determination to retain an Independent Manager to advise on a portion of the client’s assets is based on the investment strategies determined and risk tolerance preferred. SAXWA's investment recommendations are based on long-term investment strategies. Clients may be requested by the Independent Managers to sign a separate agreement when investing with that entity. SAXWA will continuously monitor all Independent Managers on behalf of the client, review the performance of each Independent Manager against appropriate benchmarks, and review the investment style of the Independent Manager against the client's investment parameters to ensure the Independent Manager continues to meet the client's investment goals.