A. The Company PCA has been registered as an investment adviser with the U.S. Securities and Exchange Commission since February 2011. PCA is the trade name of C2P Capital Advisory Group, LLC, a Delaware limited liability company with its principal place of business in Westlake, OH. C2P Enterprises, LLC is the sole member of PCA. The Firm is led by Jason L Smith, Chief Executive Officer, and David Alison, President. This Disclosure Brochure describes PCA’s business. Certain sections also describe the activities of Supervised Persons. Supervised Persons are any of PCA’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), advisor staff with PCA systems access, or employees, or any other person who provides investment advice on PCA’s behalf and is subject to PCA’s supervision or control. This does not include passive C2P Enterprise equity owners or board members who don’t participate in the day-to-day operations of PCA. Separate Advisors are not considered supervised persons and are not supervised by PCA. B. Types of Advisory Services PCA and its Investment Adviser Representatives (“IARs” or “Advisors”) provide financial planning, consulting, and investment management services. Prior to engaging PCA to provide investment advisory services, the client is required to enter into one or more written agreements with PCA setting forth the terms and conditions under which PCA renders its services (the “Agreement”). PCA is responsible for all supervision and suitability outlined by the appropriate regulatory bodies. PCA also operates as a Turnkey Asset Manager Program (“TAMP”), Sub-advisor, Co-Advisor and/or Fund Strategist providing asset management and administrative services which are utilized by registered investment advisers, broker-dealers, and other financial institutions (collectively “Separate Advisors”) for the benefit of their Clients under the platform name. PCA does not have supervisory responsibility for its Separate Advisors. Their RIA bears the responsibility to supervise their own IARs. TAMP Services The TAMP investment services provided by PCA include but are not limited to client billing services, rebalancing, due diligence activities, serving as an operational liaison between the Separate Advisors and custodians, various portfolio management tools, transaction data processing, making available account reports, training, retaining and providing access to certain third-party investment managers and research, and other administration and support services. The services may be completed internally or through affiliated and non-affiliated third parties. Client accounts are administered on a discretionary basis pursuant to instructions received from the Client or Client’s Separate Advisor’s Investment Advisory Agreement allowing PCA and/or third-party investment managers to act on their behalf. Specific TAMP offerings include separately managed accounts, signal-based relationships and AdvisorSelect/PGP Portfolios as more fully described below. Financial Planning Services PCA IARs may provide its clients with a broad range of comprehensive financial planning and consulting services. These services include but are not limited to business planning, investment planning, insurance, retirement planning, estate planning, charitable planning, education planning, and personal financial planning. PCA does not provide legal, accounting or tax advice; however, certain PCA’s Supervised Persons may have other such business practices that are independent of and are not affiliated with PCA. Please refer to the Form ADV Part 2B which accompanies this Disclosure Brochure for more information. PCA’s written financial plans or consultations usually include general recommendations for a course of activity or specific actions to be taken by the client, at the client’s discretion. For example, PCA may recommend that clients begin or revise an investment program, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Clients who engage PCA to provide written financial plans will be provided with a written summary of their financial situation and PCA’s observations and recommendations. For financial consulting arrangements, PCA’s service is typically less formal and may not include a written summary. Plans or consultations are typically completed within six months from the beginning of the engagement, assuming that the client has provided the necessary documentation and other information requested by PCA. Financial Institution Consulting Services PCA provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive PCA’s consulting services relating to assets held with the broker/dealer. Brokerage Customers have entered into a written advisory agreement to receive investment advice. Investment Management Services Clients can engage PCA to manage all or a portion of their assets on a discretionary basis. PCA emphasizes continuous and regular account supervision and may provide advice about any type of investment held within a client’s portfolio. 1. Affiliated Turnkey Asset Management Model Portfolios Program As part of its investment management service, PCA allocates clients’ investment assets among certain investment strategies including a series of separately managed model portfolios made up of mutual funds, exchange-traded funds (“ETFs”), equities and fixed income solutions in accordance with the investment objectives of the strategy. With limited exception, client accounts are managed based on the overall model, rather than specifically to each client’s individual needs. Nonetheless, clients may impose reasonable restrictions on the assets in the program; however, PCA may refuse to accept or to continue to provide investment advisory services with respect to such program assets if it determines such restrictions are unreasonable. PCA IARs are responsible for providing its Clients with individualized discretionary investment management services. PCA is responsible for determining the Client’s risk profile and for selecting the PCA model portfolios that are consistent with the Client’s risk profile. Under the sub-advisory agreement with PCA, PCA provides additional, non-advisory services including assistance in account administration, assistance in trading, billing and record keeping, and performance reporting. PCA is provided with a limited power of attorney, by PCA and the Client, to arrange for execution of trades and rebalancing of model portfolios. The investment management fees charged by PCA, together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, is exclusive of, and in addition to, PCA’s investment advisory fee as described below. PCA has an economic incentive to recommend and use PCA models, for investment management services, in lieu of selecting other programs or unrelated investment advisers, because the compensation PCA and its IARs receive could be more than the amounts we would receive if you participated in another program, and we receive additional non-monetary benefits such as training and access to PCA personnel. 2. Sub-advisory and Co-advisory Services With respect to its Sub-advisory and Co-advisory services, PCA has aligned with investment management companies including BlackRock, Dimensional Fund Advisors, The Vanguard Group, and others to provide its Separate Advisors an investment platform of core portfolio models and specialized strategies to meet the unique needs of their investment adviser representatives (“IARs”) and Clients. The models are managed in a manner substantially similar to the models historically managed by former affiliated firm Valor Capital Management. PCA’s core models provide strategic investment management through a diverse selection of risk- based asset allocation model portfolios. Specifically, PCA’s core models are generally comprised of exchange-traded funds (“ETFs”) and/or mutual funds designed to provide asset class diversification for varying levels of risk tolerance on a pre-tax or post-tax basis. PCA also offers specialized strategies that are designed to complement PCA’s core models by offering unique or specific investment strategies and solutions. Specialized strategies are managed by PCA and/or third parties and may invest in stocks, bonds, mutual funds, ETFs, or other securities in accordance with the investment objectives of the particular strategy. Leveraging one or more of the core and specialized models, PCA helps PCA IARs and PCA Separate Advisors and their IARs navigate the right investment offering, blended portfolio design, and operational implementation to meet the specific needs of their clients. Underlying Client accounts are generally managed based on the overall model, rather than specifically to each Client’s individual needs. However, with respect to PCA’s tax managed portfolios, PCA IARs and Separate Advisors may from time to time provide PCA trade instructions to address specific Client circumstances. PCA will periodically review the model portfolios for rebalancing designed to keep the portfolios consistent with the Firm’s usual and customary target parameters. PCA, PCA IARs, the Separate Advisor, or the Client may elect not to rebalance for a number of reasons including, for example, consideration of a tax strategy, the funds involved are economically insufficient, additional fees and expenses are anticipated, or there are other pending events impacting the decision. PCA enters into sub-advisory or co-advisory agreements with Separate Advisor, whereby PCA invests client assets according to the PCA model portfolio selected by the Separate Advisor and Client. The Separate Advisor and their Clients execute a separate investment advisory agreement, and the Separate Advisor is responsible for providing the Client with individualized discretionary investment management services. The Separate Advisor serves as the primary relationship contact with the client and is responsible for determining the Client’s risk profile and for selecting the PCA model portfolios that are consistent with the Client’s risk profile. Clients should carefully review the investment management agreement executed with the Separate Advisor, as well as the Separate Advisor’s ADV Part 2A - Disclosure Brochure, for a full description of the services to be provided by the Separate Advisor. Under the Sub-Advisor or Co-Advisor Agreement, in addition to asset management services, PCA provides non-advisory services including assistance in account administration, assistance in trading, billing and record keeping, and performance reporting as requested. PCA is provided with a limited power of attorney, by the Separate Advisor and the Client, to arrange for execution of trades and rebalancing of model portfolios. PCA is not responsible for ensuring that the model portfolios are consistent with a Client’s risk profile. Further, PCA will not serve as an investment advisor to individual Clients that are working with a Separate Advisor. Additionally, PCA has established agreements to work with a third-party investment adviser in a sub- advisory or investment research capacity. The sub-advisor is responsible for all investment-related decisions and trading in the client accounts. The Separate Advisor and/or subadvisor may be limited to only manage assets through specific custodians. For more information about what custodians a specific sub-advisor or Separate Advisor is authorized to offer services through, please refer to their ADV. There may be additional fees for the use of the Subadvisor. Please review the sub-advisor’s ADV for more information. PCA retains the authority to hire and fire sub-advisors at our discretion. 3. Strategist Services PCA also provides investment advisory services on a discretionary basis as a Fund Strategist for unified management accounts (“UMA”) by providing one or more its model portfolio strategies to a “Platform Provider”, such as Axxcess Wealth Management and Lockwood. PCA has entered into an agreement as a model manager with the Platform Provider. PCA provides access to some or all of its model portfolio strategies via the Platform Provider’s model management system for which Separate Advisors and Clients can then select for use in a Client account. For UMA managed accounts, PCA is solely responsible for the management of the model portfolio strategies provided to the Platform Provider which have been selected for use in a Client account by a Separate Advisor and/or Client. By utilizing one or more of PCA’s model portfolio strategies via a Platform Provider, the services PCA provides UMA/SMA managed accounts are limited to the following: portfolio design, asset allocation, risk management and security selection. UMA accounts are managed based on the selected portfolio’s stated investment strategy, philosophy, and objective, rather than on each Client’s individual needs. 4. Separately Managed Accounts PCA enters into sub-advisory or co-advisory relationships with investment firms to offer various separately managed accounts (“SMAs”). PCA IARs may recommend that certain clients authorize the active discretionary management of all or a portion of their assets by and/or among certain SMAs, based upon the stated investment objectives and risk profile of the client. The SMA, not PCA, is responsible for all investment and reinvestment-related decisions and trade execution in the client accounts. However, while SMA investment managers regularly monitor the SMA accounts and are responsible for managing the model portfolios on behalf of PCA, the SMA is not acting as your investment advisor and does not possess knowledge of your individual information or investment goals and objectives. Clients will receive both our disclosure brochure and other related documents as well as the SMA’s disclosure brochure and related documents. Each SMA is uniquely structured so please ensure you carefully review the applicable SMA’s disclosure brochure to understand their investment strategy, how they operate, the fees they charge, how investments will be managed, among other matters. Depending on the SMA selected, the client may have the opportunity to authorize

the SMA to vote proxies on their behalf. PCA conducts the initial due diligence on SMAs and ongoing reviews of their management of client accounts for which it charges a fee as described below. PCA retains the authority to hire and fire SMAs at our discretion. Institutional Clients PCA also provides investment management services with respect to fixed income portfolios to institutional clients. Seminars & Educational Events PCA IARs are permitted to hold investment-related seminars and/or educational events to existing clients, prospective clients, and the general investing public. The seminars feature general investment-related advice for educational purposes and can include both securities and non- securities topics. No specific individualized investment advice regarding investment objectives or investment related needs of the attendees, listeners, or audience is rendered during seminars. However, participants are free to schedule meetings with the IAR(s) in an effort to obtain personalized investment advice. Please see “Fees and Compensation” below for further details related to the investment advisory fee charged for these seminars. Advisory Services to Brokerage Customer PCA provides investment advisory services to certain broker-dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s advisory services. Brokerage Customers have entered into a written advisory agreement with PCA. Charitable Accounts PCA and its IARs may advise clients on certain charitable accounts or donor advisor funds available through our custodians or other third parties PCA retains an agreement with. Retirement Plan Services PCA may provide investment advisory services to businesses and non-profit organizations with their 401(k) and employee benefit plans. Trustees and Investment Committees PCA may provide advisory services to investment committees and trustees of Defined Benefit Plans, Non-Participant directed 401(k) plans and Non-Profit Organizations. PCA may act as a 3(21) Investment Fiduciary providing investment advice for a fee to the trustees or committee to implement. Participant Directed Retirement Plans PCA may provide investment advisory services to investment committees and trustees of Participant Directed Retirement Plans. PCA may act as a 3(21) Investment Fiduciary providing investment advice for a fee to the trustees or the committee to implement. Advisory Fees for Held Away Accounts PCA can provide services to Held Away Accounts (accounts with Custodians or Carriers other than the primary approved custodians). PCA will be paid a management fee referenced on the Schedule A of the Client Agreement or equivalent fee disclosure, based on the fair market value of the Client’s Account. This fee will be billed as outlined in Section 5. A. This fee will not be deducted from your Held Away account but will instead be either deducted from a non-qualified account held with PCA or directly invoiced to the client. Client acknowledges that for Held Away Accounts set forth on Schedule A to their agreement or equivalent disclosure, the designated third party shall provide access to PCA and its IARs to submit trades or reallocations on your Held Away Accounts. The designated third party may retain a portion of the fee collected by PCA. Other PCA also may render non-discretionary investment management services to clients relative to variable insurance products, their individual employer-sponsored retirement plans, 529 plans, and/or other products that may not be held by the client’s primary custodian. In so doing, PCA either directs or recommends the allocation of client assets among the various investment options that are available with the product (as further described below) and may receive an advisory fee for these services. Client assets are maintained at the specific insurance company or custodian designated by the product. PCA may also provide non-discretionary investment advisory services to retirement plan participants through their own employer-sponsored defined contribution (i.e., 401K, 403b, 457 TSP) plans using the investment options that are specific to them. PCA may enter into a contract with the plan sponsor to provide such services to plan participants and be paid a fee based on the assets under management for the overall plan. Advisors have the ability to refer clients to a non-affiliated bank that offers securities-based lines of credit. While PCA and/or its Advisors are not compensated, there is a conflict of interest in making the referral as the Firm will retain the assets under management. C. IRA Rollover Considerations PCA provides, as part of its investment advisory services, recommendations for client to withdraw the assets from an employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that PCA will manage on the client’s behalf. If a client elects to roll the assets to an IRA that is subject to PCA’s management, PCA will charge an asset-based fee as set forth in the agreement between the client and PCA. This practice presents a conflict of interest because persons providing investment advice on PCA’s behalf have an incentive to recommend a rollover to a client for the purpose of generating fee-based compensation rather than solely based on the client’s needs. Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if the client decides to complete the rollover, that client is under no obligation to have the assets in an IRA managed by PCA. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, clients should consider the costs and benefits of each option: An employee will typically have four options: 1. Leaving the funds in the employer's (former employer's) plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change PCA encourages clients to understand the trade-offs of each. Clients who are considering rolling over retirement funds to an IRA for PCA to manage should consider beforehand the following: 1. Determine whether the investment options in the employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than PCA’s fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. PCA’s strategy may have higher risk than the option(s) provided to you in your plan. 4. Whether your current plan also offers financial advice. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules, so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. D. Fiduciary Obligations Investment advisers to ERISA Plan accounts and ERISA Plans must adhere to the fiduciary responsibilities under ERISA, as administered by the Department of Labor (DOL). Specifically, in providing investment advisory and investment management services to ERISA Plan accounts and ERISA Plans, PCA and its investment adviser representatives must discharge their duties solely in the interest of the Plan participants and beneficiaries. The DOL issued Prohibited Transaction Exemption 2020-02 that PCA relies upon for rollover recommendations that would otherwise result in a prohibited transaction under ERISA and/or the Code. It can also be used for other nondiscretionary fiduciary recommendations to Retirement Accounts that result in a prohibited transaction as long as its conditions are met. E. Client Tailored Services and Client Imposed Restrictions PCA and its IARs tailor its advisory services to the individual needs of clients. Each portfolio will be initially designed to meet a particular investment goal, which PCA determines to be suitable to the client’s circumstances including investment needs, goals, objectives, risk tolerance, and time horizon. In performing any of the above services, PCA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. PCA typically recommends the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if PCA recommends its or its affiliates’ own services. With respect to PCA’s investment management services, PCA has full investment discretion over clients’ assets and manages those assets in a manner consistent with the clients’ investment objectives and risk tolerance with the exception of unmanaged/client convenience accounts. Clients can impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in PCA’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. With respect to PCA’s financial planning and/or consulting services, the client is under no obligation to act upon any of the recommendations made by PCA or to engage the services of any such recommended professional, including PCA itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of PCA’s recommendations. Clients are advised to promptly notify PCA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon PCA’s management services. PCA also manages a selection of model portfolios that are utilized by Separate Advisors. The portfolios are based on target asset-class allocations that designate specified percentages within multiple securities asset-classes with the intent of creating a diversified investment portfolio of no load institutional mutual funds, ETFs, equities, and fixed income solutions. These models are designed to provide asset class diversification for varying levels of risk tolerance. As a general matter, the models are to be used by Separate Advisors to help clients meet their investment goals, as determined by the Separate Advisor based on their client’s circumstances including investment needs, goals, objectives, risk tolerance, and time horizon. Client accounts are tailored to the client’s specific individual investment goals and objectives. The IAR of the Separate Advisor collects financial and personal information from the client, and then the client and the IAR decide on an asset allocation strategy. The Firm does not maintain a direct relationship with Clients under this arrangement; however, Clients may impose certain reasonable restrictions on the management of their accounts through consultation with Separate Advisors. Nonetheless, PCA may determine that it cannot accept certain restrictions in its sole discretion. F. Wrap Fee Programs PCA does not provide portfolio management services to a wrap fee program(s) for its IARs. Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. If you are accessing PCA through a Separate Advisor your Separate Advisor may participate in a wrap program. In this instance, PCA may provide billing services for that Separate Advisor and may deduct wrap fees from your account according to the instructions provided by the Separate Advisor. If your Separate Advisor charges a wrap fee please review their ADV Part 2A and other disclosure forms for details. G. Assets Under Management PCA provides investment advisory services to clients on a discretionary basis. As of December 31, 2023 discretionary assets under management totaled $2,245,308,171 and assets under advisement totaled $174,343,322.