A. Firm Information Archford Capital Strategies, LLC (“Archford” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of the State of Delaware. Archford was founded in March 2013, and is owned by James D. Maher, Trustee of the Jennifer M. Maher Family Trust. James D. Maher (Principal) serves as the sole trustee of the trust. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Archford. B. Advisory Services Offered Archford offers investment advisory services to individuals, high net worth individuals, trusts, estates, pension and profit-sharing plans, charitable organizations, corporations, and businesses (each referred to as a “Client” or collectively “Clients”). It is Archford’s mission to help its Clients incorporate clear, effective, and comprehensive strategies designed to not only facilitate their finances, but their lives. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Archford’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Archford provides customized investment advisory solutions for its Clients. This is achieved through continuous Client contact and interaction while providing discretionary or non-discretionary investment management and consulting services. Archford works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to develop an investment strategy. Archford primarily allocates client assets among various independent investment managers (“Independent Managers”), mutual funds, exchange- traded funds (“ETFs”), individual debt and equity securities, real estate investment trusts (“REITs”), and options, as well as the securities components of variable annuities and variable life insurance contracts. Additionally, Archford may also recommend that Clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Archford also manages proprietary concentrated investment models which may be recommended to Clients in accordance with the investment objectives of its individual Clients. Where appropriate, Archford may also provide advice about any type of legacy position or other investments held in Client portfolios. Archford’s investment approach is primarily long-term focused, but Archford may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Archford will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by Archford. Archford evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Archford may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Archford may recommend specific positions to increase sector or asset class weightings. Archford may recommend employing cash positions as a possible hedge against market movement. Archford may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 At no time will Archford accept or maintain custody of a Client’s funds or securities except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Market Participation Structured Product - An offering for investment management services with Archford is through the Advisor’s Market Participation Structured Product (“MPSP”), which utilizes Certificates of Deposit and/or other structured products. Clients pursuing this product offering will sign an investment advisory agreement specifically for the MPSP products and the proceeds of the Client account[s] noted in the agreement are then invested into FDIC insured MPSPs, in accordance with the investment objectives of the Client. Held Away Assets - Clients may engage Archford to advise on certain investment products that are not maintained at their primary Custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). Archford may use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts. The platform allows Archford to avoid being considered to have custody of Client funds since there is no direct access to Client log-in credentials to affect trades. Archford is not affiliated with the platform and receives no compensation from them for using their platform. A link is provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance. Client account(s) are reviewed on at least a quarterly basis and allocation changes will be made as deemed necessary. In these situations, Archford directs or

recommends the allocation of Client assets among the various investment options available with the respective products. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. Legacy IRA® Certified Legacy IRA® – Archford offers a charitable IRA program where Clients over the age of 70.5 with an IRA account may elect to have distributions directed to 501(c)(3) organizations as qualified charitable distributions (“QCDs”). Legacy IRA® accounts are primarily limited to providing a systematic process for charitable giving. Charitable Tracker Accounts – Archford offers 501(c)(3) organizations an account where qualified charitable distributions, cash and stock donations are deposited. These accounts are managed on a discretionary basis with low-cost investment strategies which consist of money market funds. Use of Independent Managers – Archford will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). In certain instances, the Client will be required to enter into a separate agreement with the Independent Manager[s]. Archford serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. Archford will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. Archford will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of the Independent Manager[s]. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to acceptance by these third parties. Archford does not receive any compensation from these Independent Managers, other than its investment advisory fee as described in Item 5 below. Under certain circumstances, Archford may accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. Financial Planning Services Archford will typically provide a variety of financial planning services to Clients either as a component of investment management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. In performing these services, Archford is not required to verify any information received from the Client or from the Client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence, or alter retirement savings, establish education savings and/or charitable giving programs. Archford may also refer Clients to an accountant, attorney, or other specialist, as appropriate for their unique situation. For certain financial planning engagements, Archford will provide a written summary of Client’s financial situation, observations, and recommendations. Plans are typically completed within six months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of Archford and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage Archford for investment management services or to increase the level of investment assets with Archford, as it would increase the amount of advisory fees paid to Archford. Clients are not obligated to implement any recommendations made by Archford or maintain an ongoing relationship with Archford. If the Client elects to act on any of the recommendations made by Archford, the Client is under no obligation to implement the transaction through Archford. Retirement Plan Advisory Services Archford provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). Archford’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting some of its fiduciary obligations to the Plan and its Plan Participants. Each agreement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• ERISA 404(c) Assistance
• Benchmarking Services
• Plan Participant Enrollment and Education Tracking
• Performance Reporting
• Conduct Trustee Meetings
• Investment Management Services (ERISA 3(38) or ERISA 3(21))
• Investment Policy Statement (“IPS”) Design and Monitoring
• Ongoing Investment Recommendation and Assistance Certain of these services are provided by Archford serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Archford’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Archford to provide investment advisory services, each Client is required to enter into one or more agreements with Archford that define the terms, conditions, authority, and responsibilities of Archford and the Client. These services may include:
• Establishing an Investment Strategy – Archford, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Archford will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Archford will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Archford will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Archford does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Archford. E. Assets Under Management As of December 31, 2022, Archford manages $821,517,141 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting Archford.