A. GuideStream Financial is a corporation formed on June 22, 2009 in the state of Michigan. GuideStream Financial became registered as an Investment Advisor Firm on August 24, 2009. GuideStream Financial is owned by The Free Methodist Foundation. Mark Steven Olson is GuideStream Financial’s President. B. INVESTMENT ADVISORY SERVICES GuideStream Financial provides discretionary and non-discretionary investment advisory services on a fee basis as discussed at Item 5 below. Before engaging GuideStream Financial to provide investment advisors services, clients are required to enter into an Investment Advisory Agreement with GuideStream Financial setting for 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. GuideStream Financial also provides discretionary only investment advisory services to “Institutional Clients”, i.e., endowments, charities, churches, non-profit organizations, pension plans and other faith-based organizations, who generally have an investment timeline of at least five to seven years on a fee basis as discussed at Item 5 below. To commence the investment advisory process, GuideStream Financial will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, GuideStream Financial provides ongoing supervision of the account(s). GuideStream Financial's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of GuideStream Financial), GuideStream Financial may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) GuideStream Financial may provide financial planning and/or consulting services on a stand-alone separate fee basis to clients who have not engaged GuideStream Financial to provide investment management services. Prior to engaging GuideStream Financial to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with GuideStream Financial 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 GuideStream Financial commencing services. If requested by the client, GuideStream Financial may recommend the services of other professionals for implementation purposes, including certain representatives of GuideStream Financial in their separate capacities as licensed insurance agents. (See disclosure at Items 5 and 10 below). The commission compensation earned by an insurance agency and its agents is separate from, and in addition to, GuideStream Financial’s investment advisory fee. The recommendation by GuideStream Financial that a client consider the purchase of an insurance product from an insurance agency presents a conflict of interest, as the potential receipt of an insurance commission compensation by the insurance agency and its agent(s) may provide an incentive for GuideStream Financial to recommend insurance products based on compensation to be received by representative rather than on a particular client’s needs. To minimize the conflict, all commissions received by the individual shall be donated to a benevolent charitable fund. The representative’s insurance services are not material to GuideStream Financial’s advisory operations. 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 GuideStream Financial. 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[s] (i.e., attorney, accountant, insurance agent, etc.), and not GuideStream Financial, 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 GuideStream Financial if there is ever any change in client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising GuideStream Financial’s previous recommendations and/or services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, GuideStream Financial may provide financial planning and related consulting services. Neither GuideStream Financial nor its investment adviser representatives assist clients with the implementation of any financial plan unless they have agreed to do so in writing. GuideStream Financial does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with GuideStream Financial, if desired. GuideStream Financial believes that it is important for the client to address financial planning issues on an ongoing basis. GuideStream Financial’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with GuideStream Financial. Furthermore, GuideStream Financial does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, GuideStream Financial does not prepare estate planning documents or tax returns. To the extent requested by a client, GuideStream Financial may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including certain representatives of GuideStream Financial in their separate individual capacities as licensed insurance agents. 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 GuideStream Financial and/or its representatives. 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[s] (i.e., attorney, accountant, insurance agent, etc.), and not GuideStream Financial, shall be responsible for the quality and competency of the services provided. 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 GuideStream Financial recommends that a client roll over their retirement plan assets into an account to be managed by GuideStream Financial, such a recommendation creates a conflict of interest if GuideStream Financial will earn new (or increase its current) compensation as a result of the rollover. If GuideStream Financial provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), GuideStream Financial 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 GuideStream Financial. GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, 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. Fiduciary Status: Per the Department of Labor: “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.” Accordingly, relative to retirement accounts, “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.” The Free Methodist Foundation d/b/a/ FM Financial (Conflict of Interest). GuideStream Financial is wholly owned by The Free Methodist Foundation d/b/a/ FM Financial (“FMF”), which is a subsidiary of the Free Methodist Church USA. GuideStream Financial and FMF share commonality of officers, directors and employees. FMF serves in a trustee capacity. FMF is an exempt corporate trustee under state law (religious organization). Certain clients for whom FMF may serve as Trustee may also have a separate investment advisory relationship with GuideStream Financial. Neither GuideStream Financial nor FMF maintains physical custody of any client advisory funds or Trust funds. In addition, GuideStream Financial’s President, Mark S. Olson, is also the President of FMF and oversees the Free Methodist Investment and Loan Fund (the “Fund”) and Joshua D. Adams is the Vice President of the Fund and reporting to Mr. Olson. The Fund is a church extension fund into which members, contributors and participants of the Free Methodist Church may invest, including clients of GuideStream Financial. No portion of Fund principal is guaranteed by any governmental authority, including, but not limited to, the Federal Deposit Insurance Corporation (“FDIC”). GuideStream Financial does not exercise any discretionary authority to place any client assets into the Fund, nor does GuideStream Financial provide any investment advisory services to the Fund. GuideStream Financial does not recommend that any client invest in the Fund, and does not receive referral fees, commissions, or any form of compensation from the Fund. Clients who request information from GuideStream Financial about the Fund will be directed to an FMF employee who does not provide investment advice on behalf of GuideStream Financial. A complete discussion of the Fund is set forth in the Fund’s subscription documents, which are provided directly by FMF to each prospective investor for review and consideration. Each prospective investor will generally be required to complete an Investment Application, pursuant to which the investor shall acknowledge and accept the various risk factors that are associated with an investment in the Fund. Based on the relationship between GuideStream Financial and FMF, an introduction to the Fund by GuideStream Financial presents a conflict of interest, because an investment in the Fund provides funds that may be loaned at a margin, which benefits FMF. It remains the client’s decision whether or not to invest in the Fund. GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, remains available to address any questions that a client or prospective client may have regarding this arrangement. GuideStream Charitable Gift Fund d/b/a Legacy Charitable (Conflict of Interest) GuideStream Charitable Gift Fund d/b/a Legacy Charitable (the “Gift Fund”) is a separate 501(c)(3) public charity. When a client chooses to engage GuideStream Financial for financial planning services, a plan may include a charitable giving component. If the client wishes to include charitable giving in their plan, the Gift Fund may be presented as a potential option for fulfillment of the charitable component of the plan. Although it shares a common name, GuideStream Financial does not manage the Gift Fund or operate the Gift Fund. The Gift Fund is a tax-exempt fund into which individuals may choose to contribute to further their charitable endeavors, including clients of GuideStream Financial. The Gift Fund has not been approved by any regulatory authority, nor is any portion of the Gift Fund principal guaranteed by any regulatory authority, including but not limited to the FDIC. The Gift Fund is subject to an annual certified audit. GuideStream Financial does not exercise any discretionary authority to place any client assets into the Gift Fund, nor does GuideStream Financial provide any investment advisory services to the Gift Fund. GuideStream Financial does not receive referral fees, commissions or any form of compensation from the Gift Fund. Clients who request information from GuideStream Financial about the Gift Fund will be directed to a Gift Fund employee. It remains the client’s decision whether or not to donate to the Gift Fund. FMF provides administrative services to the Gift Fund, and, in the past, has been partially reimbursed by the Gift Fund for such services. The relationship between the Gift Fund, GuideStream Financial and FMF presents conflicts of interest as Mr. Olson also serves as the CEO of the Gift Fund and FMF will receive additional fees for the services it provides to the Gift Fund. Clients are therefore reminded that they are under no obligation whatsoever to contribute to the Gift Fund, and that they may contribute to any other unaffiliated charitable fund. A complete discussion of the Gift Fund is set forth in the Gift Fund’s program description and related documents, which will be provided directly by the Gift Fund to each prospective donor for review and consideration. Each prospective donor will generally be required to complete a Donor Application Form. GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, remains available to address any questions that a client or prospective client may have regarding this arrangement. Use of Mutual and Exchange Traded Funds: GuideStream utilizes mutual funds and exchange traded funds for its client portfolios. In addition to GuideStream’s investment advisory fee described below, and transaction and/or custodial fees discussed above, 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). The mutual funds and exchange traded funds utilized by GuideStream are generally available directly to the public. Thus, a client can generally obtain the

funds recommended and/or utilized by GuideStream independent of engaging GuideStream as an investment advisor. However, if a prospective client does so, then they will not receive GuideStream's initial and ongoing investment advisory services. Interval Funds/Risks and Limitations: When and where appropriate, GuideStream may determine to utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short- term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct GuideStream Financial, in writing, not to employ any or all such strategies for the client’s account. Short-Term Trading Fees. GuideStream Financial is not a short-term trader. It manages investment assets consistent with the client’s long-term investment objective. Some of the mutual funds utilized by GuideStream Financial impose a short-term trading fee (generally $50 for funds held less than 30 days). If a client requires a distribution, GuideStream Financial, whenever possible, shall first seek to liquidate funds that either do not assess a short-term trading fee or whose short-term trading fee has expired. Cash Positions. GuideStream Financial continues to treat cash as an asset class. As such, unless determined to the contrary by GuideStream Financial, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating GuideStream Financial’s advisory fee unless otherwise agreed to in writing. 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), GuideStream Financial 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, GuideStream Financial’s advisory fee could exceed the interest paid by the client’s money market fund. However, GuideStream Financial, in its sole discretion, may charge a lesser investment management fee on cash positions maintained in a client’s account. Cybersecurity Risk. The information technology systems and networks that GuideStream and its third-party service providers use to provide services to GuideStream’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in GuideStream’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and GuideStream 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 GuideStream has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that GuideStream 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. emoney. In the event that GuideStream provides the client with access to an unaffiliated vendor’s website such as emoney, and the site provides access to information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer that such access is a substitute for services provided by GuideStream. Rather, if the client utilizes any such content, the client does so separate and independent of GuideStream. Portfolio Activity. GuideStream has a fiduciary duty to provide services consistent with the client’s best interest. GuideStream 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, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when GuideStream determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by GuideStream will be profitable or equal any specific performance level(s). 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, GuideStream shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund available on the custodian’s platform, unless GuideStream 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, 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. Please Note: The above does not apply to the cash component maintained within a GuideStream 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. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any GuideStream unmanaged accounts. ANY QUESTIONS: GuideStream’s Chief Compliance Officer, Joseph Crupper, remains available to address any questions that a client or prospective client may have regarding the above. Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of GuideStream. Generally, with potential exceptions, GuideStream does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by GuideStream will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by GuideStream) will be profitable or equal any specific performance level(s). In addition, there may be other securities and/or accounts owned by the client for which GuideStream does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which GuideStream does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by GuideStream, GuideStream shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent; (3) shall generally consider these securities as part of the client’s overall asset allocation; (4) report on such securities/accounts as part of regular reports that may be provided by GuideStream; and, (5) include the market value of all such securities for purposes of calculating advisory fee. ANY QUESTIONS: GuideStream’s Chief Compliance Officer, Joseph Crupper, remains available to address any questions regarding the above. Non-Discretionary Service Limitations. Clients that determine to engage GuideStream Financial on a non-discretionary investment advisory basis must be willing to accept that GuideStream Financial cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Therefore, in the event that GuideStream Financial 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, GuideStream Financial will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral or
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral; These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, GuideStream Financial does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). GuideStream Financial does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to GuideStream Financial:
• by taking the loan rather than liquidating assets in the client’s account, GuideStream Financial continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by GuideStream Financial, GuideStream Financial will receive an advisory fee on the invested amount; and,
• if GuideStream Financial’s advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), GuideStream Financial will earn a correspondingly higher advisory fee. This could provide GuideStream Financial with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loans. Client Obligations. In performing its services, GuideStream Financial 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 GuideStream Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising GuideStream Financial’s previous recommendations and/or services. Disclosure Brochure. A copy of GuideStream Financial’s written Privacy Notice, written Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an advisory agreement. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by GuideStream Financial) will be profitable or equal any specific performance level(s). C. GuideStream Financial shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment advisor representative will ascertain each client’s investment objective(s). Thereafter, GuideStream Financial 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 GuideStream Financial’s services. D. GuideStream Financial does not participate in a wrap fee program. E. As of December 31, 2023, GuideStream Financial had $188742,858 in assets under management on a discretionary basis and $14,196,500 in assets under management on a non-discretionary basis for a total of $202,939,358.