A. Benchmark Investment Advisors, LLC Benchmark Investment Advisors, LLC (“Benchmark” and/or “the firm”) is an Illinois limited liability company and an SEC-registered investment adviser. John Swift and Jamie Tebbe are the owners and managing members of Benchmark. Benchmark has been providing investment management services since December 2011. B. Advisory Services Offered B.1. Asset Allocation Program Based on Benchmark’s analysis of the client’s investment objectives, risk tolerance, investment goals and objectives, Benchmark will determine an asset allocation customized to the client. Clients are advised their account may be managed similarly to other clients with similar investment goals and objectives. Typically portfolios will consist of individual equities, individual bonds, equity and fixed income mutual funds, individual municipal or government/corporate bonds (depending on account and investor tax characteristics and fixed income account size), and exchange traded funds (ETFs). Accounts are managed on a discretionary basis whereby Benchmark will determine the securities to be bought and sold and when such transactions are to take place. Although we may execute these trading and portfolio rebalancing initiatives without prior consultation with the client, under normal market conditions we will seek prior consultation with our clients before executing these initiatives. However, under adverse or fast changing markets we reserve the right as discretionary managers to do what we feel is in the best interests of the client’s portfolio without the necessity of prior consultation with the client. Clients will receive confirmation of all transactions, monthly brokerage statements mailed directly from the custodian, and a quarterly, comprehensive account review directly from Benchmark. Clients who choose to have accounts managed on a non-discretionary basis are advised that such accounts are subject to certain risks. Risks may include but not be limited to the risk of missing market opportunities or the risk of the Advisory Representative not being able to move out of the market in a timely manner until client has been contacted to discuss recommendations for changes within the client’s account and client’s prior authorization has been obtained before any buy, sell or exchange. Therefore, the performance of non- discretionary accounts may fluctuate from those accounts managed on a discretionary basis. Selection of the securities to be held in a client’s portfolio is determined based on consideration of the goals and objectives of the client, the appropriate overall management style of the funds, and the goals and objectives of the client’s overall portfolio. We monitor capital markets closely and provide a strategic asset allocation recommendation for both global equity and global fixed income portfolios. These collectively as described as our Model Portfolios. Each client, based on their individual circumstances, will invest varying proportions of their investable assets into each of these two Model Portfolios. Changes to the model portfolio allocation will generally result in changes to those clients who are invested similarly or identically to the Model Portfolio. Clients are advised there may be tax consequences in non-qualified portfolios as a result of changes to the allocation, but our systems are set up to do execute trades and portfolio rebalancing in a tax efficient manner. Tax loss harvesting during the last quarter of the year will be utilized to increase the after-tax return of non-qualified investment accounts. Clients will have access to their Advisory Representative at any time during normal business hours to discuss their account. Further, should a client’s financial situation change the client must promptly notify Benchmark since changes could impact the management of the client’s account and the suitability of the portfolio allocation. Equity Selection Process The criteria used in selecting individual equities include, among other items, the following:  Economic Performance: Our first step is to recast a company’s financial information into a proprietary economic metric called Economic Margin. Economic Margin is a cash flow based measure that measures the return a company earns above or below its cost of capital, and provides what we believe is a more complete view of a company’s underlying economic vitality. Economic Margin framework takes into account Cost of Capital, Inflation and Cash Flow, which we believe provides a much more accurate representation of management’s ability to create shareholder value and provide comparability across sectors and countries.  Intrinsic Valuation: When buying a company, investors are essentially paying for its future expected performance. Traditional models that lock into a perpetuity tend to assume that a company’s performance will stay constant forever without facing the effects of competition. Research shows, however, that a perpetuity is not economic reality. The extent that a company’s current advantage will recede over time due to competition is referred to as a Decay ratio. Traditional models also do not take into account the concept of steady state growth – the rate at which a company can grow based on its internally generated cash flow less investments required to maintain and replace its asset base. Our methodology combines all 3 factors, economic margin, decay and steady state growth, to calculate intrinsic value.  Momentum: We utilize both Price and Profit Momentum to invest in companies that are not only undervalued based on intrinsic valuation, but also have favorable economic earnings revisions and price movement. Our Profit Momentum translates earnings revisions into economic earnings revisions. Our Price Momentum is based on historical price movement in the company’s stock.  Management Quality: Absent a management team that understands how to create shareholder value, a “cheap stock” is likely to get cheaper. We score each company’s management team on how its strategy links with its economic reality. Wealth creating firms should focus on growing, while firms that destroy wealth should divest and identify core competencies. This process is designed to flag firms that appear financially unstable well in advance of their bankruptcies.  Earnings Quality: Companies have an amazing degree of latitude in preparing their financial statements. As a result, a dollar of net income may not represent a dollar of cash flow. We score the quality of each company’s earnings to determine which are or are not sustainable into the future. Mutual Fund Selection Process The criteria used in selecting mutual funds include, among other things, the following:  Fund performance history  Industry sector in which the fund invests  Track record of the fund manager  Fund’s investment objectives  Fund’s management style and philosophy  Fund’s management fee structure Trading and Portfolio Rebalancing Strategies Benchmark may employ various trading strategies, including but not limited to, dollar cost averaging of cash into the various investments, covered call writing for the purpose of security sales, buy/sell limit and stop orders, short term trading (transactions purchased and sold within

a year) and long-term holdings (i.e. positions may be held for a year or longer). Generally, Benchmark will rebalance portfolios up to four times a year (quarterly). However, more or less rebalancing may occur depending on the performance of the model portfolios. Typically, Benchmark will look to rebalance when the model portfolio sways in either direction 5% or more from the targeted allocation. No trading strategy can provide any assurance of investment success or prevent loss of principal or gain. Clients are advised there will be periods where the performance of their portfolio may be down. No management strategy can prevent market loss or protect a portfolio 100% from market fluctuations. However, the goal is to manage a client’s account through market fluctuations in an attempt to steady the portfolio. Further, clients are advised that transactions in the account, account reallocations and rebalancing may trigger a taxable event for the client, with the exception of qualified accounts such as IRA accounts, 403(b) accounts and other qualified retirement accounts. Income Producing Investments We have in the past created Limited Liability Partnerships and Limited Liability Companies that are wholly-owned by our clients that were set up for the purpose of investing in income producing investments. Examples include farmland that is rented out and investments in real estate tax liens that are currently in good standing with credit worthy property owners. We receive a fee for providing our investment advisory services for these investments that is consistent with the client’s Fee Schedule for the remainder of his/her publicly-traded assets under our management. We have no ownership interest in these investment partnerships and companies, and most of these investment vehicles are wholly owned by one client per vehicle. In several cases we have pooled investments from several clients to invest in assets where the purchase price was too big for just one client to fund. In these cases, the operation agreements make it clear that these are not open-ended investments or satisfy the 1940 Securities Act sufficient to treat these investment vehicles as investment companies. In addition to providing Benchmark with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Benchmark will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Benchmark will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. B.2. Sub-Advisory Arrangement In addition to the services mentioned above, Benchmark has entered into a written agreement with an unaffiliated, registered investment adviser to provide sub-advisory services to adviser’s clients. Under this arrangement, Benchmark manages the assets of the unaffiliated adviser’s clients as requested in accordance with the clients’ investment objectives and the Benchmark strategy selected. The unaffiliated adviser is responsible for initial and ongoing suitability determination and will work directly with the client in selecting the appropriate Benchmark investment strategy. Under this sub-advisory arrangement, the unaffiliated adviser has full discretion to select and hire or terminate its sub-advisory relationship with Benchmark at any time and in accordance with the agreement entered into between the client and the unaffiliated adviser. Benchmark is not a signatory to this agreement, nor does it have any direct contractual agreement with the unaffiliated adviser’s client. Benchmark has limited discretionary authority to manage and trade those client account assets designated by the unaffiliated adviser. B.3. Retirement Plan Services Retirement plan services can be segmented into the following components:  Benchmarking your current 401(k) plan. We benchmark the fees, services and participation metrics of your plan against similar plans using industry leading research. This service satisfies the fiduciary obligations under both ERISA and the new 408(b)(2) fee disclosure rules. We then can make recommendations for any changes to your plan to reduce costs and improve service for your participants.  Performing plan design consulting. A review of the plan design is very important because plan design provisions can make a big difference in whether your plan maximizes the benefits available. These provisions address matching contribution formulas, cross-tested profit sharing allocations, qualification and eligibility issues, and merger and acquisition situations. We will work closely with the provider’s administration experts to ensure that all available aspects of plan design are considered.  Assisting in the design an Investment Policy Statement (IPS). As a plan sponsor, you can minimize your fiduciary liability by implementing an IPS. An IPS outlines a detailed, prudent plan of action for the plan’s investment managers and advisors to follow. It describes the plan’s investment philosophy, risk tolerance and long-term goals to help guide all decisions made regarding the plan. Because the IPS is in writing, it helps prevent misunderstandings between you and the plan’s advisors.  Providing ongoing plan reviews. We review your plan operational metrics such as participation levels, deferral percentages, loans, non-discrimination testing, enrollment and communication services. We also prepare performance analysis of investments utilized by the plan versus benchmarks and/or peer groups; monitor funds selected by the plan sponsor for style drift and correlation with fund investment objectives stated in the IPS; and provide regulatory and compliance updates.  Managing employee communication and investment education. We believe that coordinating enrollment meetings and providing ongoing investment education for participants regarding plan options is a valuable part of our service. That’s why we will be available to your employees by phone and in person for individual consultation. If enrollment and/or education teams from the provider are necessary due to multiple company locations, we will coordinate those efforts. We also provide supplemental educational materials if desired.  Personal customized financial and estate planning for employees. Finally, we will educate plan participants about plan distribution alternatives, provide retirement cash flow analysis, and, whenever necessary, consult with retirees regarding investment asset allocation. C. Wrap Fee Programs Benchmark does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) D. Client Assets Under Management As of December 31, 2023, Benchmark manages $270,182,869 of client assets, all on a discretionary basis. Item 5: Fees and Compensation