A. Courage Miller is a Delaware Limited Liability Company formed and registered as an investment adviser in August 2008. Ralph Courage is Courage Miller’s principal owner, who serves as Managing Member and Chief Compliance Officer. B. Courage Miller offers investment advisory services, retirement plan consulting services, and financial planning and related consulting services to its clients, who generally include individuals, high net worth individuals, charitable organizations, corporations and other entities, pensions, and profit sharing plans. INVESTMENT ADVISORY SERVICES Clients can engage Courage Miller to provide discretionary or non-discretionary investment advisory services on a fee-only basis. Courage Miller’s annual investment advisory fee is based on a percentage of the market value of the assets placed under Courage Miller’s management. The investment advisory fee compensates for initial and limited financial planning and consulting services that Courage Miller provides in its sole discretion as part of the investment management process, or as specifically requested by the client and upon Courage Miller’s agreement. Before engaging Courage Miller to provide investment advisory services, clients enter into an investment advisory agreement with Courage Miller setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fee that is due from the client. Courage Miller tailors its investment advisory services to the specific needs of each client. Before providing investment advisory services, an investment adviser representative will collaborate with the client to develop investment objectives, which are based upon an assessment of factors that typically include: capital preservation; risk tolerance; income production; liquidity requirements; client preferences; asset and liability levels; and investment restrictions. Then, Courage Miller will allocate or recommend that the client allocate investment assets consistent with the designated investment objectives. Courage Miller primarily allocates client investment assets among various individual equity (stocks), debt (bonds), mutual funds, fixed income securities and exchange traded funds (“ETFs”) (including inverse ETFs and mutual funds that are designed to perform in an inverse relationship to certain market indices) on a discretionary or non- discretionary basis in accordance with the client’s designated investment objectives. Once allocated, Courage Miller provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may periodically execute or recommend execution of transactions for the account based upon those reviews or other triggering events. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Courage Miller may offer to provide financial planning and consulting services (including investment and non-investment related matters, including tax planning, estate planning, insurance planning, cash flow analysis, etc.) on a stand-alone separate fee basis. Before engaging Courage Miller to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Courage Miller setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before Courage Miller will begin to provide services. RETIREMENT PLAN SERVICES Courage Miller offers retirement plan consulting services to sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement between Courage Miller and the plan sponsor will be set forth in a Pension Consulting Agreement. If Courage Miller performs these services in an ERISA Section 3(21) capacity, it will assist the plan sponsor with the development of investment policy statements, and then the selection and monitoring of investment alternatives from which plan participants may choose in self-directing the investments for their individual plan retirement accounts. Upon request by the plan sponsor, Courage Miller may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. If the plan sponsor chooses to engage Courage Miller in an ERISA Section 3(38) capacity, Courage Miller may provide the same services as described above, but may also: create specific asset allocation models that Courage Miller manages on a discretionary basis, which plan participants may choose in managing their individual retirement account; and/or modify the investment options made available to plan participants on a discretionary basis. MISCELLANEOUS ERISA / IRC Fiduciary Acknowledgment. When Courage Miller provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way Courage Miller makes money creates some conflicts with client interests, Courage Miller operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Courage Miller must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that Courage Miller gives advice that is in the client’s best interest; charge no more than is reasonable for Courage Miller’s services; and give

the client basic information about conflicts of interest. 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 Courage Miller recommends that a client roll over their retirement plan assets into an account to be managed by Courage Miller, such a recommendation presents a conflict of interest if Courage Miller will earn a new (or increase its current) advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to an account managed by Courage Miller. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, Courage Miller may provide consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. Courage Miller does not serve as a law firm, accounting firm, or insurance agency, and no portion of Courage Miller’s services should be construed as legal, accounting, or insurance implementation services. Unless specifically agreed in writing, neither Courage Miller nor its representatives are responsible to implement any financial plans or financial planning advice, provide ongoing financial planning services, or provide ongoing monitoring of financial plans or financial planning advice. Clients are solely responsible to revisit the financial plan or financial planning advice with Courage Miller, if desired. Courage Miller’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. Clients retain absolute discretion over all financial planning and related implementation decisions and are free to accept or reject any recommendation from Courage Miller and its representatives in that respect. Upon specific request, Courage Miller may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are not obligated to engage the services of any recommended professionals, who are responsible for the quality and competency of the services they provide. Asset Aggregation / Reporting Services. Courage Miller may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged Courage Miller to manage (the “Excluded Assets”). Courage Miller’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because Courage Miller does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not Courage Miller, will be exclusively responsible for directly implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third- party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by Courage Miller. Accordingly, Courage Miller will not agree to be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third-party reporting platforms without Courage Miller’s participation or oversight. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, Courage Miller will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when Courage Miller 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 portfolio trading inactivity. Client Obligations. When performing its services, Courage Miller is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Courage Miller if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Courage Miller’s services or previous recommendations. C. Courage Miller provides investment advisory services specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with each client to develop their investment objectives. Then, Courage Miller will allocate or recommend that the client allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Courage Miller’s services. D. Courage Miller does not participate in a wrap fee program. E. As of December 31, 2023, Courage Miller had $344,850,581 in assets under management on a discretionary basis and $37,150,070 in assets under management on a non-discretionary basis.