Momentum Advisors, LLC (“MA”) is a full service, SEC registered investment advisory firm established in 2012, in the state of New York. The firms’ principal owners are Allan Boomer, and William Platt, CFP®. The Momentum Group, Inc. is the sole 100% owner of Momentum Advisors, LLC. Mr. Boomer, MA’s registered principal, also serves as its President, and Chief Compliance Officer. MA focuses on providing its clients a broad range of comprehensive investment management, financial planning, portfolio and asset management services primarily through individual consultations. MA specializes in providing customized services to high-net-worth individuals, foundations and endowments for portfolios in excess of $250,000 that can be managed on a discretionary or non-discretionary basis. MA will consider smaller portfolios on a case-by-case basis. Investment Advisory, Financial Planning, and Business Consulting Services Investment Advisory Services may involve portfolio and asset management, investment recommendations, investment policy statement development and the analysis of strategic and tactical asset allocation. Potential investments include stocks, bonds, options, real estate, hedge funds and private equity investments. Investment advisory consultations can be general in nature or focus on particular areas of interest, depending on the client’s needs. Financial Planning Services may include cash flow and budget management, tax planning, insurance planning, retirement planning, estate planning, philanthropy, and special needs planning. Business Consulting may include franchise business development, acquisition planning, due diligence research, strategic planning, and financial modeling. At inception of the relationship MA completes and provides an evaluation of the client’s current financial condition and discussed goals. The engagement also includes implementation of recommendations accepted by client, on-going communication to ensure client objectives and needs are met, and quarterly written portfolio reviews. Wrap Fee Programs Nothing to Disclose Assets Under Management MOMENTUM ADVISORS, LLC Page 5 of 24 As of March 8, 2023, MA manages approximately $332,046,000 of regulatory assets under management. About $330,350,000 is managed on a discretionary basis and $1,696,000 on a non-discretionary basis. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, Momentum will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Momentum will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, stand-along planning engagements, etc. for which Firm may charge a separate or additional fee). Momentum believes that it is important for the client to address financial planning issues with Momentum on an ongoing basis. Momentum’s fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address planning issues with Momentum. Momentum remains available to address planning issues with the client on an ongoing basis. Please Note: Momentum does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Momentum does not prepare legal documents prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including our principal, Will Platt, in his separate individual capacity as a registered representative of Purshe Kaplan Sterling Investments ("PKS"), an SEC registered and FINRA member broker-dealer, and as licensed insurance agents of our affiliated licensed insurance agency, Momentum Risk Management (“Risk”). 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 Momentum and/or its representatives. Please Also Note: 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 unaffiliated licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Momentum, shall be responsible for the quality and competency of the services provided. Please Further Note-Conflict of Interest: The recommendation by a Momentum representative that a client purchase a securities or insurance commission product from Mr. Platt in his individual capacity as a representative of PKS and/or as an insurance agent of Risk, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment and/or insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products from a Momentum representative or Risk. Clients are reminded that they may purchase securities and insurance products recommended by Momentum through other, non-affiliated broker-dealers and/or insurance agents and agencies. ANY QUESTIONS: MOMENTUM ADVISORS, LLC Page 6 of 24 Momentum’s Chief Compliance Officer, Allan Boomer, remains available to address any questions that a client or prospective client may have regarding the above conflicts of interest. Please Note: Retirement Rollovers-Potential for 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 Momentum recommends that a client roll over their retirement plan assets into an account to be managed by Momentum, such a recommendation creates a conflict of interest if Momentum will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Momentum serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Momentum. Momentum’s Chief Compliance Officer, Allan Boomer, 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. Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Momentum generally recommends that Charles Schwab Inc. or Interactive Brokers to serve as the broker-dealer/custodian for client investment management assets (unless the client requires lending services, and Momentum shall generally recommend JP Morgan). Broker-dealers such as Schwab and Interactive Brokers charge transaction fees for effecting securities transactions. In addition to Momentum’s investment advisory fee referenced in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds, exchange traded funds, individual equity and fixed income transactions, etc., purchased by Momentum or Independent Manager [see below]). Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange- traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Momentum independent of engaging Momentum as an investment advisor.

However, if a prospective client determines to do so, he/she will not receive Momentum’s initial and ongoing investment advisory services. Please Note: In addition to Momentum’ 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). ANY QUESTIONS: Momentum’s Chief Compliance Officer, Allan Boomer, remains available to address any questions that a client or prospective client may have regarding the above. Private Investment Funds. Momentum also provides investment advice regarding private investment funds. Momentum, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds. Momentum’s role relative MOMENTUM ADVISORS, LLC Page 7 of 24 to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Momentum calculating its investment advisory fee. Momentum’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Private Investment Fund Affiliation. Affiliated Private Fund. MA is affiliated with Franklin Morgan Fund 1, LLC, a private investment fund (the “Fund”), the complete description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the Fund’s offering documents. The members of the Fund’s Manager, Franklin Morgan Partners LLC, are officers of MA. MA, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the Fund. If a client determines to become an affiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of MA calculating its investment advisory fee per Item 5 below. MA’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Conflict Of Interest. Because MA and/or its affiliates can earn compensation from the Fund that will generally exceed the fee that MA would earn under its standard asset- based fee schedule referenced in Item 5 below, the recommendation that a client become a Fund investor presents a conflict of interest. No client is under any obligation to become a Fund investor. Given the conflict of interest, MA advises that clients consider seeking advice from independent professionals (i.e., attorney, accountant, adviser, etc.) of their choosing prior to becoming a Fund investor. No client is under absolutely any obligation to become a Fund investor. ANY QUESTIONS: MA’s Chief Compliance Officer, Allan Boomer, remains available to address any questions regarding this conflict of interest. Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. MOMENTUM ADVISORS, LLC Page 8 of 24 Please Also Note: Valuation. In the event that Momentum references private investment funds owned by the client on any supplemental account reports prepared by Momentum, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, the client’s advisory fee shall be based upon the value reflected on the report. Please Note: Fund Liquidity Constraints. Momentum may utilize mutual funds that provide for limited liquidity, generally on a quarterly basis. Thus, if we determined that the fund was no longer performing or if you ever determined to transfer your account, the Fund could not be sold or transferred immediately. Rather, sale or transfer would need to await the quarterly permitted sale date, or longer. Moreover, the eventual net asset value for the Fund could be substantially different (positive or negative) than the Fund value on the date that the sale was requested. There can be no assurance that any such strategy will prove profitable or successful. In light of these enhanced risks/rewards, a client may direct Momentum, in writing, not to employ any or all such strategies for the client’s account. Portfolio Activity. Momentum has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Momentum 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, 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 Momentum determines that changes to a client’s portfolio are neither necessary nor prudent. Clients are still subject to the fees described in Item 5 below, even during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Momentum will be profitable or equal any specific performance level(s). Client Obligations. In performing our services, Momentum 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, it remains each client’s responsibility to promptly notify Momentum if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. 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 Momentum will be profitable or equal any specific performance level(s).