The Firm RIS was started in 1992 and became a corporation formed under the laws of the State of Michigan in 1993. In 2009, RIS merged with IFSG Planning Associates, Ltd. and Pattern Recognition Management, Inc. Each was a State-registered investment adviser owned separately by RIS’s original two principals, K. Larry Hastie and R. Griffith McDonald. The two merged firms had been in business since 1982 and 1990, respectively. RIS has been registered with the SEC since 2010. RIS’s current principal owners are Brock E. Hastie, H. Todd Kephart, John B. Goff and Karen A. Chapell. Each serve as a Managing Partner of RIS. Currently, eleven individuals associated with RIS provide its investment advisory services. Where applicable, these individuals are appropriately state-licensed, qualified and authorized to provide advisory services on behalf of RIS. Such individuals are known as Investment Adviser Representatives (“IARs”). RIS provides its investment advisory services using Active Management which could include the Seasonal Strategy. On a periodic basis, RIS conducts a formal review and re-allocates assets when deemed necessary. RIS exercises discretionary trading authority, as described in Item 16 to direct the purchases, sales redemptions, liquidations and disposition of securities. Using that authority, we can also exchange/modify “core equities” or “core fixed income and non-equities” in a portfolio at any time, as deemed necessary. The strategies used by RIS for each client are set forth in the client’s Investment Policy Statement. Investment advisory services are provided through accounts established at Pershing Advisor Solutions, LLC (“Pershing”), a subsidiary of The Bank of New York Mellon Corporation, member FINRA/SIPC, SEI Private Trust Company (“SEI”), TIAA, Fidelity Investments (“Fidelity”) or other custodians. Asset Management and Review RIS offers Asset Management and Review services where the investment advice provided is custom tailored to meet the needs and investment objectives of our clients. We use the custodial, trading, reporting and other services of Pershing and SEI to facilitate our Asset Management and Review services to our clients. Whether client assets are held at Pershing or SEI, RIS follows a six-step process when managing our client accounts: 1. Determine the client’s risk profile and investment objectives. RIS determines the client’s investment objectives, investment time horizon, risk profile and other personal characteristics by means of an interview process that may involve the completion of a questionnaire. 2. Set a relevant Investment Policy for the client. RIS uses the information from Step 1 to develop the client’s Investment Policy Statement that determines the range; high (fully invested) and low (defensive) equity positions. . 3. Make initial asset allocation recommendations. RIS uses the mutual funds and other investments available at Pershing or SEI to create a broadly-diversified portfolio that includes many asset classes and investment styles. At SEI, RIS can use its basic portfolio models or customize them to meet the needs of clients. Initially, RIS recommends changes in the client’s investments, investment strategy, investment allocation, or financial plan, either verbally or in writing. RIS may give recommendations in connection with the review of a client’s current investments or a client’s expressed financial needs or objectives. 4. Rebalance or change the client’s portfolio. RIS uses its discretionary trading authority and Seasonal Strategy to make substantial rebalancing changes in clients’ holdings, generally twice a year, to take advantage of patterns we have observed in financial markets. RIS also makes other changes in clients’ portfolios as market conditions, mutual fund characteristics or other factors warrant. 5. Review the performance of clients' investments. RIS periodically reviews accounts in light of each client’s stated financial goals, investment objectives, risk tolerance, other personal characteristics, and in the context of other investment portfolios under RIS’s supervision. (See Item 13). 6. Report results. RIS provides regular reports on the current status and performance of clients’ holdings and benchmarks as provided in the Agreement. Pershing and SEI provide separate reports showing holdings, cash flow, transactions and asset allocation and provide annual tax reports for taxable accounts. SEI also provides a separate report showing market value, cash flows, gains and losses, asset allocation and performance as it relates to market indices. As of December 31, 2023, RIS had $2,421,756,308 in assets under discretionary management and none under non-discretionary management. Asset Monitoring and Review RIS offers Asset Monitoring and Review services for clients’ retirement accounts (including IRAs, 401a, 401k, 457 and 403b accounts) maintained with the client’s employer and/or held at independent custodians, including TIAA and Fidelity. RIS may also offer this service to non-retirement client accounts. RIS can recommend an initial asset allocation based upon the client’s stated financial goals, investment

objectives, risk tolerance, other personal characteristics, and other investment portfolios under RIS’s supervision. RIS then periodically monitors and makes changes to clients’ assets in the frequency RIS deems appropriate, including using RIS’s Seasonal Strategy. RIS also provides account quarterly performance reports or arranges for the account’s custodian to do so. Selection of Other Advisers RIS may refer its clients to various third-party advisers (“TPAs”) for asset management services. All TPAs to whom RIS refers clients must be registered investment advisers with the U.S. Securities and Exchange Commission or the appropriate state authority(ies). After gathering information about a client’s financial situation and investment objectives, an IAR of RIS assists the client in selecting a particular third-party adviser/program. For initial manager search and evaluation and ongoing consulting services, RIS considers a number of factors in determining which TPAs to recommend to clients, including but not limited to performance, investment objectives, fees and methods of analysis. TPAs which RIS recommends may not achieve the best rate of returns or charge the lowest fees in comparison to other TPAs. Clients will sign investment advisory agreements with the TPA of the program selected. The client or TPA, in accordance with the provisions of those agreements, can terminate the advisory relationship. Retirement and Financial Planning The scope of these services is defined in the financial planning agreement executed by a client in advance of the engagement. RIS provides most of these planning services on a one-time basis to address specific client needs. The financial planning agreement can be terminated by either Party within five days of the date of acceptance without penalty to the client. After the five-day period, either party, upon receipt of written notice from the other, can terminate the agreement. In the event of termination, the client will be charged financial planning fees for the work completed by RIS. Retirement Plan Consulting Services RIS offers the following Retirement Plan Consulting Services: RIS will conclude an agreement with a Plan Sponsor to provide Retirement Plan Services to the client. RIS then meets with Plan Participants to discuss Plan features and benefits and to provide employee education. On an as needed and requested basis, RIS will meet with individual Participants and recommend an initial asset allocation for each Participant. Thereafter, upon request, RIS will meet with individual Participants to review their portfolio and recommend any changes to their asset allocation. RIS will not have any responsibility to implement any advice given to the Participants or to monitor the Participants’ portfolios unless a Participant signs a separate advisory agreement to provide those services. The client agreement can be terminated by either party within five days of the date of acceptance without penalty to the client. After the five-day period, either party, upon receipt of written notice from the other, can terminate the agreement. In the event of termination, prorated fees will be charged based on the asset market value on the date notice is received. These accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). RIS will provide consulting services to the Plan fiduciaries as described above. The Plan fiduciary must make the ultimate decision as to retaining the services of such investment advisers as RIS may recommend. The Plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the Plan. RIS is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to Section 3(21) of the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (the “Code”), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Code that include among other things, restrictions concerning certain forms of compensation. Retirement Plan Accounts RIS can assist clients with retirement plan accounts and this assistance may present a conflict of interest. When clients’ leave an employer there are typically four options regarding an existing retirement plan account and you may use a combination of these options: 1) if permitted, leave the funds in your former employer’s plan; 2) if rollovers are permitted and you have a new employer with a plan available, rollover the funds to your new employer’s plan; 3) rollover to an Individual Retirement Account (“IRA”), or; 4) withdraw or cash out your funds from the plan which may have adverse tax consequences depending on your age. In situations where RIS is not already managing your retirement account and recommends that you roll over your retirement plan assets into an account to be managed by RIS, such a recommendation creates a conflict (benefit to RIS) when we earn an advisory fee on your rolled over funds. You are under no obligation to roll over retirement plan assets to an account managed by RIS.