Firm Description and History Strategic Planning Group, Inc. (“SPG” or the “Firm”) is a Massachusetts corporation, formed in 1995, with its principal office in Wellesley, MA. It is registered as an investment adviser with the SEC and has notice-filed its Form ADV in five states. David Rourke is the Firm’s President and majority shareholder. Jarrod Sherman is the Chief Compliance Officer and is also a shareholder. Advisory Services: SPG provides investment advisory services to individuals, including high net worth individuals. SPG offers financial plans (“Plans”) in the form of customized “retirement roadmaps” which forecast the client’s finances, consider the client’s investment goals, current and future income needs and tax situation, and recommend an investment strategy accordingly. SPG may also make recommendations regarding life insurance, long-term care insurance and estate planning. SPG also manages the investment portfolios for certain clients. The investment consists primarily of mutual funds and exchange traded funds (“ETFs”) but may include individual securities. The Advisor charges a flat fee for financial plans; the fee for investment portfolio management is based on a percentage of assets in the account. Financial Planning For clients who elect to receive financial planning, SPG works with its clients to create a custom- designed retirement roadmap (a “Plan”) for each client. In creating the Plan, the Firm creates forecasts of the client’s financial life, and evaluates the suitability of existing investments and customized investment models. Creating the Plan also involves an evaluation of the positioning of a client’s assets, and the way the client receives income, in an effort to minimize income tax while maintaining liquidity. As part of the Plan, SPG also examines the client’s potential needs concerning life insurance, long-term care and estate planning. The Firm does not give legal or tax advice. Investment Management For clients who elect to engage us for investment management, we design an investment account based upon their individual needs, as derived either from the financial roadmap described above or through personal interviews. SPG will schedule quarterly

investment review meetings to review the performance with the client, and to consider any changes that may be warranted to meet the Client’s goals. The investments primarily in mutual funds and ETFs and may include individual securities. SPG builds a customize allocation for each client based on the client’s predetermined debt-to-equity ratio. We follow a rules-based approach and when the portfolio is inconsistent with any of the four rules (7-to-10-year rule, debt to-equity ratio, diversification, fund performance), we make changes to the portfolio. SPG reviews the funds our clients are invested every 30 days. If we decide to exchange a mutual fund or ETF, we do a block trade for all tax-sheltered accounts. For the taxable accounts, we review the costs basis data to determine the timing of the sale. SPGs clients are advised to promptly notify SPG if there are ever any changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions on their accounts. Clients should be aware of investment and other risks, and other information relevant to their investment. Additional information on certain investment risks is provided under Item 8, subsection Market, Security and Regulatory Risks below. Tailored Advisory Services: Advisory services recommendations are tailored to the needs of the individual client. Clients may impose guidelines or reasonable restrictions on certain types of securities or investments, but such restrictions must be provided in writing. Use of Sub-Advisors In rare cases, when a client wishes to pursue a strategy with unusual guidelines or strategies, SPG may enter into a sub-advisory arrangement on the client’s behalf to provide specialized advisory services. Wrap Fee Programs Wrap fee programs generally are arrangements where clients are charged a single fee for both advisory services and brokerage commissions. SPG does not participate in wrap fee programs. Assets Under Management As of December 31, 2023, Strategic Planning Group had $179,175,783 in discretionary assets under management and $4,897,784 in non-discretionary assets under management.