A. FA is incorporated in the State of Minnesota and has been operating since 2013. FA is registered with the Securities & Exchange Commission (“SEC”) as a Registered Investment Advisor (“RIA”). Feltl and Company (“F&C”) is registered with the SEC as a Broker-Dealer of investment securities (“BD”) and is currently inactive as a RIA. F&C is also incorporated in the State of Minnesota and has been operating since 2002. Registration with the SEC as either a BD or RIA does not imply a certain level of skill or training. FA acquired F&C’s RIA business on January 1, 2013 and is operated as a separate legal entity, however they are considered affiliates due to common ownership. FA is a privately-held corporation. All of FA’s stock is owned by John C. Feltl. RBC Clearing and Custody (“RBC”) provides clearing brokerage services on both F&C’s BD and FA’s RIA business. Advisory clearing services are described in more detail in Item 10(C) below. B. FA offers three types of advisory account programs (“RBC Program Accounts”) through its relationship with RBC as Sponsor: 1. RBC Advisor – (formerly Advisor) is a client-directed, non-discretionary, advisory program centered on the advice and service the Investment Advisory Representative (“IAR”) provides to their clients. RBC Advisor allows clients to purchase no-load and load-waived mutual funds in addition to other securities. 2. Consulting Solutions – (formerly Resource II) is a fee-based program that lets the IAR offer clients access to private account management from institutional money managers across the country. RBC conducts due diligence on the independent money managers (“RBC Program Managers”) that are included in the RBC Programs. 3. RBC

Unified Portfolio (RBC UP) – (formerly Total Strategy) allows clients to bring their investments together in one account, including RBC Program Managers, mutual funds and exchange-traded funds. C. Each FA advisory client, regardless of the account program, must choose a Risk Profile. Based on the client’s chosen Risk Profile, stated investment needs and objectives, and the IAR’s discussions with the client, the IAR will propose one of the three account programs described in Item 4B. above. If the Consulting Solutions or RBC Unified Portfolio is selected, the IAR will then propose specific RBC Program Managers. If RBC Advisor is selected, the IAR will then propose an appropriate asset allocation and specific investments for the client’s approval. In all of the account categories, the client may accept or reject the IAR’s recommendations, request alternative ideas, and/or suggest different strategies. D. All three types of accounts described above are deemed “wrap fee” programs. The differences in how these three types of programs are managed are discussed in Item 4B. above. FA receives a portion of the advisory fee on all types of advisory accounts. E. FA has approximately $121 million in assets under management (“AUM”), as of March 26, 2024. FA does not consider any of its advisory accounts to be “discretionary.” Although the Consulting Solutions and RBC UP Program Managers do exercise discretion in choosing investments, the role that FA and its IARs play on such accounts is non-discretionary – i.e., FA’s role is limited to assisting the client in choosing a RBC Program Manager. Thus, FA deems that all of the assets that it has under management are properly characterized as “non-discretionary.”