A. Sentinus LLC Sentinus LLC (“Sentinus” and/or “the firm”) is an Illinois limited liability company principally owned by Tin Goose Holdings LLC. The Managing Member of Sentinus is Sentinus Holdings, LLC. Sentinus has been providing investment advisory and financial planning services since June 2012. B. Advisory Services Offered Sentinus is an independent investment advisory and financial planning firm offering a variety of financial services to individuals and high-net-worth individuals, corporate executive groups, trusts, corporations, partnerships, pension and profit sharing plans, institutional retirement (both ERISA and non-ERISA) plans, tax exempt, and other legal entities. Advisory services may include financial planning, investment strategy, portfolio management, tax preparation, tax and estate planning, as well as recommendation of separate account managers. Discretionary Asset Management Services For its discretionary asset management services, Sentinus receives a limited power of attorney to effect securities transactions on behalf of its clients. Clients may grant Sentinus limited discretionary authority with respect to advisory client assets, including discretion to select third- party managers on behalf of such Sentinus advisory clients. Investment advisory services are provided on either a discretionary or non-discretionary basis, depending on the agreement between the client and Sentinus. Sentinus recommends securities transactions to its clients that include securities and strategies as described in Item 8 of this Brochure. In preparing the asset allocation, Sentinus will analyze each client’s current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance. Sentinus’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk and other personal and financial circumstances, and make appropriate asset allocation recommendations and implementation decisions. Sentinus may engage third-party service providers to assist with the tax and estate planning portion of the services provided to clients. In addition, Sentinus may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Sentinus will monitor those portfolios and make additional recommendations from time to time to rebalance and/or reallocate each client’s investments. Sentinus’s investment advisory services to clients are based on asset allocation models that, as noted above, take into account a client’s personal financial circumstances, investment objectives, and tolerance for risk (e.g., cash-flow, tax, and estate). Sentinus’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the clients current investment portfolio against the client’s personal and financial circumstances as disclosed to Sentinus in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Sentinus. ▪ Analyzing the client’s financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending mutual funds, exchange-traded funds, and individual equity and fixed income securities, each matched to the asset categories in the client’s targeted asset allocation for consideration by the client. ▪ Reporting to the client on a quarterly basis or at some other interval agreed to with the client, information on contributions and withdrawals in the client’s investment portfolio. ▪ Proposing changes in the client’s targeted asset allocation in consideration of changes in the client’s personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client’s investments, and/or the performance of any fund or manager retained by the client. In addition to providing Sentinus with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide Sentinus with any reasonable investment restrictions that should be imposed on the management of their portfolio and to promptly notify Sentinus of any changes in such restrictions or in the client’s personal financial circumstances, investment objectives, goals, and tolerance for risk. On a quarterly basis, Sentinus’s reports to clients will remind clients of their obligation to inform Sentinus of any such changes or any restrictions that should be imposed on the management of their accounts. Sentinus will also contact clients at least annually to determine whether there have been any changes in their personal financial circumstances, investment objectives, and tolerance for risk. Institutional Investment Consulting Sentinus also provides investment consulting and investment advisory services to institutional ERISA (see detailed explanatory note under B.4. below) and non-ERISA retirement plans, trusts, foundations, estates, charitable organizations, corporations, or other business entities. Institutional investment management services typically include portfolio design, asset allocation modeling, preparation of investment policy statements, screening and selection of investment managers, and performance monitoring. Depending on the client’s unique circumstances, Sentinus may provide discretionary or non-discretionary investment consulting services for institutions. Financial Planning Services Clients will receive a written or oral report (depending on the client’s preference) providing them with a detailed financial plan designed to help achieve their stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a recommended asset allocation that serves to diversify the client’s portfolio among different categories of investments, such as small, medium and large capitalization securities; corporate and government fixed income (short-, intermediate- and long-term maturities); emerging market securities (i.e., foreign issuers); and such other asset categories that are suitable in light of

the client’s investment goals, objectives, and risk tolerance. ▪ Preparation of an investment policy statement setting forth the investment plan of the client with specific direction in terms of diversification requirements, tax issues, estate planning issues, risk tolerance, retirement, and other identified objectives of the client, including a targeted rate-of-return objective. ▪ Preparation of a retirement plan that serves to identify whether the client is saving enough and investing in a way that meets retirement objectives in light of the client’s financial circumstances and risk tolerance. ▪ Preparation of cash flow projections to ensure that the client can meet daily living expenses and obligations. ▪ An insurance plan to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ Preparation of an estate plan to ensure that wealth transition, tax, and related issues are met in accordance with the client’s wishes. In many instances, an outside attorney will need to be hired to handle specific legal issues that arise in the formation and implementation of an estate plan. Sentinus, as a matter of policy, does not provide tax advice. ▪ A business exit/continuity plan, taking into account the business and personal goals and objectives of the client, client’s family, employees, and other affected parties. ▪ Coordination of all planning into a single cohesive plan. Sentinus gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client’s current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. 401(k) Portfolio Management Services Sentinus will provide non-discretionary portfolio management services to 401(k) plan participants. The advice will consist of recommending suitable asset allocation based on the plan participant’s tolerance for risk, and investment objectives accounting for the available investment alternatives available to the plan participant. To the extent the client has a self- directed account, Sentinus may recommend a model portfolio of diversified exchange-traded funds. Once the plan participant has engaged Sentinus for this service, Sentinus will provide its recommendations through an automated email notification to the client, advising the client when the portfolio requires rebalancing. As a courtesy, Sentinus will send applicable clients a follow-up reminder within a reasonable period of time after the first email notification to rebalance the portfolio. Any transactions required to effect the recommended rebalancing of the model portfolio will be the sole responsibility of the client. Institutional Retirement Investment Advisory Services Employees in qualified retirement plans are protected by the Employee Retirement Income Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan administrators to put employees’ interests first when managing retirement savings plans. Public retirement systems are governed by similar state laws and often incorporate the protections of ERISA. In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are certain steps that the fiduciary must take. Sentinus is committed to helping fiduciaries understand their roles and to assist them in implementing a process that allows them to fulfill their duties and responsibilities. Sentinus offers government retirement systems, sponsors of employee benefit plans (defined contribution and defined benefit) qualified under the Internal Revenue Code (“IRC”), and other retirement plans not qualified under the IRC (including Taft-Hartley organizations and “church” plans), a range of discretionary and non-discretionary services, including the selection of registered investment companies or other pooled investment funds to be offered under the plan. Sentinus will assist plan fiduciaries in the following: ▪ Investment Selection and Monitoring
• Creating an investment policy statement
• Modeling asset allocations
• Selecting investment managers
• Determining QDIA investment alternatives
• Monitoring the investment options against well-defined risk and return criteria Sentinus’s investment professionals work in partnership with clients to create sound solutions to investment challenges, including:
• Maximizing long-term return while not assuming unnecessary risk
• Creating an optimal portfolio that includes a diverse array of investment options that span the risk/return spectrum
• Keeping plan sponsors current on manager performance and the events that may affect performance ▪ Vendor Search and Selection and Plan Implementation Sentinus also assists its retirement plan clients in selecting trustees, custodians, accountants, actuaries, record keepers, and other service providers. This process involves:
• Generating criteria to identify appropriate service providers
• Developing or responding to requests for proposals
• Evaluating highly rated service provider candidates Once a service provider is selected, Sentinus will assist a client in implementing the client’s retirement plan program. In implementing the program, Sentinus will, among other things, review the plan design, develop performance standards, and review the service provider’s contract. Sentinus also provides assistance with strategic employee education and communications in connection with client retirement plan programs. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Sentinus does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2023, Sentinus had $656,776,264 in discretionary assets under management and $41,209,603 in assets under advisement.