A. Alpha Omega is a limited liability company formed on February 27, 2009 in the state of Delaware (subsequent to which it converted to limited liability company under laws of the Commonwealth of Virginia). Alpha Omega became registered as an Investment Adviser Firm in April 2009. Alpha Omega is principally owned by Clay Hilbert and Everett Reveley, and Clay Hilbert is the firm’s Managing Partner. B. INVESTMENT ADVISORY SERVICES Alpha Omega provides discretionary and/or non-discretionary investment advisory services on a fee-only basis. Alpha Omega’s annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under Alpha Omega’s management. Before engaging Alpha Omega to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Alpha Omega 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. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Alpha Omega will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Alpha Omega provides ongoing monitoring and review of account performance, asset allocation and client investment objectives. FINANCIAL PLANNING AND CONSULTING SERVICES Alpha Omega may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) in conjunction with its investment advisory services or on a stand-alone separate fee basis. Prior to engaging Alpha Omega to provide planning or consulting services on a stand-alone basis, clients are generally required to enter into a Financial Planning and Consulting Agreement with Alpha Omega 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 prior to Alpha Omega commencing services. FAMILY OFFICE SERVICES Some families have complex financial situations that require specialized service. Alpha Omega views the investment advisory process as an integral part of the financial foundation for a family’s lifestyle and legacy. Proper planning is the blueprint that allows clients to achieve their goals. Alpha Omega takes pride in being the family wealth guardian, trusted counselor and investment specialist. By working closely with family members, Alpha Omega begins by evaluating the unique needs of each client. When developing the investment strategy, Alpha Omega takes into account all objectives, constraints and risk tolerances that shape life's priorities. Alpha Omega’s goal is to provide substantial value to its clients’ lives in specific areas. Sound, comprehensive planning and investment management is at the core of Alpha Omega’s services. Financial Planning Alpha Omega works closely with clients to identify their financial goals, understand their financial situation and create a financial plan tailored specifically to them. Alpha Omega coordinates with other professionals to help clients implement investment, tax and estate strategies. Alpha Omega updates the client’s plan as the client’s life and the financial landscape evolves. Investment Strategy and Implementation Alpha Omega implements an investment plan that is aligned with the client’s goals. Alpha Omega carefully selects and actively monitors client investments and delivers understandable reports that clearly display how investments are doing. Family Philanthropy Alpha Omega can help clients develop and implement a philanthropic plan that uses clients’ talents, interests and resources to make a positive and lasting impact on the community. Household Finance Alpha Omega helps clients get organized. Alpha Omega can assume the administrative burdens of day-to-day household finance – like paying bills, coordinating insurance coverage and managing household information. Alpha Omega understands the big picture as well as the finer details of clients’ financial lives. Family Education Alpha Omega wants to help all members of a family attain a level of financial understanding that allows them to participate comfortably in planning for the future. Alpha Omega does this through individual consulting on routine matters as well as more substantial education for entire families. Alpha Omega can help clients structure, plan or facilitate family meetings. RETIREMENT PLAN CONSULTING Alpha Omega also provides retirement plan consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, Alpha Omega may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between Alpha Omega and the plan sponsor. MISCELLANEOUS Limitations of Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Alpha Omega may provide financial planning and related consulting services. Neither Alpha Omega nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Alpha Omega does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Alpha Omega, if desired. Alpha Omega may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance consulting, etc. Neither Alpha Omega, nor any of its representatives, serves as an attorney, accountant, or insurance agent and no portion of Alpha Omega’s services should be construed as same. To the extent requested by a client, Alpha Omega may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, 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 Alpha Omega. If the client engages any recommended unaffiliated 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 licensed professional (i.e. attorney, accountant, insurance agent, etc.), and not Alpha Omega, shall be responsible for the quality and competency of the services provided. Each client is advised that it remains the client’s responsibility to promptly notify Alpha Omega if there is ever any change in client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising Alpha Omega’s previous recommendations and/or services. Cash Positions. Alpha Omega continues to treat cash as an asset class. As such, unless determined to the contrary by Alpha Omega, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating the 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), Alpha Omega 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, Alpha Omega’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Alpha Omega shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Alpha Omega 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. The above does not apply to the cash component maintained within a Alpha Omega 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. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Alpha Omega unmanaged accounts. Non-Discretionary Service Limitations. Clients that determine to engage Alpha Omega on a non-discretionary investment advisory basis must be willing to accept that Alpha Omega cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Therefore, in the event that Alpha Omega would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Alpha Omega will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Independent Managers. Alpha Omega may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers, available through the Schwab separate account management platform, 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. Alpha Omega shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Alpha Omega shall consider in recommending Independent Manager(s) include the client’s designated investment objective(s) and the Independent Manager’s size, investment style/philosophy, process, management team, performance, and pricing. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Alpha Omega’s advisory fee as set forth in Item 5. Unaffiliated Private Investment Funds. Alpha Omega may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Alpha Omega’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. Alpha Omega’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Risk Factors: 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. Fund Valuation: If Alpha Omega bills an investment advisory fee based upon the value of private investment funds or otherwise references private investment funds owned by the client on any supplemental account reports prepared by Alpha Omega, the value for all private investment funds owned by the client will reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. Socially Responsible (ESG) Investing Limitations. 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: 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 Alpha Omega), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Alpha Omega generally relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. 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). If Alpha Omega recommends that a client roll over their retirement plan assets into an account to be managed by Alpha Omega, such a recommendation creates a conflict of interest if Alpha Omega will earn new (or increase its current) compensation as a result of the rollover. If Alpha Omega provides a recommendation as to whether a client should engage in a rollover or not, Alpha Omega 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 Alpha Omega. Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by Alpha Omega independent of engaging Alpha Omega as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Alpha Omega’s initial and ongoing investment advisory services. In addition to Alpha Omega’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 (e.g. management fees and other fund expenses). Cryptocurrency: Cryptocurrency is a digital currency that can be used to buy goods and services but 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, Alpha Omega 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. Alpha Omega does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Alpha Omega considers such an investment to be speculative. 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. Portfolio Activity. Alpha Omega has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Alpha Omega 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, mutual fund manager tenure, style drift, and/or a change in the client’s investment objectives. Based upon these factors, there may be extended periods of time when Alpha Omega determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Client Obligations. In performing its services, Alpha Omega 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, each client is advised that it remains their responsibility to promptly notify Alpha Omega if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Alpha Omega’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that Alpha Omega and its third-party service providers use to provide services to Alpha Omega’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Alpha Omega’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Alpha Omega 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 Alpha Omega has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Alpha Omega 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. Disclosure Statement. A copy of Alpha Omega’s written Brochure and Client Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. C. Alpha Omega shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Alpha Omega shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Alpha Omega’s services. D. Alpha Omega does not participate in a wrap fee program. E. As of December 31, 2023, Alpha Omega had $910,651,980 in assets under management on a discretionary basis and $84,573,785 in assets under management on a non- discretionary basis for a total of $995,225,765.