Established in 1940, Trubee Wealth Advisors, Inc. (the “Firm” or “Trubee”) is one of the oldest, independently-owned, brokerage companies in Western New York. The Firm began offering registered investment advisory (“RIA”) services in 2000. Trubee is employee –owned by its individual contributors, with no one individual more than 25% of the firm. Trubee provides continuous advice to clients regarding the investment of client funds based on the individual needs of the client. The firm consults with the client to obtain detailed financial information, goals, objectives, and other pertinent data to develop a personal investment program for the client and manage accordingly to the portfolio based on that policy. We determines the appropriate investment guidelines, risk tolerance and other factors that will assist in ascertaining the investments to be made that are suitable for the account(s) where an asset allocation model is chosen. Trubee manages discretionary and non-discretionary account ("Account") services tailored to each client’s individual needs. The Firm does not act as portfolio manager or sponsor for any wrap fee programs. It does offer wrap fee products that are sponsored and managed by its custodian, Wells Fargo Clearing Services, LLC. Information regarding those programs is contained in Wells Fargo Clearing Services, LLC’s ADV Part 2A Appendix H. The Firm receives a portion of the management fees charged by Wells Fargo Clearing Services, LLC on those accounts. The Firm provides portfolio management services for individuals and small business and is also actively engaged in business as a broker/dealer and an insurance broker or agent. It sells products and/or provides services other than investment advice to its advisory clients. Clients are free to contact their Trubee Financial Advisor (“Firm Advisor”) at any time for information regarding these services. Firm Advisors perform investment advisory functions based on passing the Series 63 and Series 65 exams. (A Series 66 license is equivalent to successful completion of both the Series 63 and Series 65 exams). Additionally, Firm Advisors may provide investment advisor advice under the auspices of a CFA designation – these are the general standards of education or business experience required of all of the Firm’s employees involved in determining or giving investment advice. Sub-Advisory Business Trubee also

provides access to third-party sub-advisory services for accounts managed by other Registered Investment Advisors (RIA) through individual relationships or established relationships. Trubee establishes relationships through an agreement with third-party sub-advisors, whereby the third-party sub-advisor may act as portfolio manager for certain clients of the Firm. Since Trubee will receive compensation if its clients invest with third party sub-advisory services, a potential conflict of interest exists between those of the Firm and of its clients. The Firm mitigates this potential conflict by ensuring that any recommendations to invest with a third-party sub-advisor are based solely upon the clients’ interests and not any economic considerations on behalf of the Firm or the adviser. The Firm provides continuous and regular supervisory or management services to securities portfolios. Advisory services are tailored to clients based upon their individual needs, financial situation and objectives. Any client may impose restrictions on his/her account but any such restrictions must be provided in writing. ERISA and Individual Retirement Accounts Disclosure When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. As of February 12, 2023, Trubee held $452,500,000 under management on a discretionary basis and $84,100,000 on a non-discretionary basis.