ISCA is a wholly owned subsidiary of ISC Group, Incorporated (“ISC Group” or “ISCG”). ISC Group and ISCA are located at 3500 Oak Lawn Ave, Suite 400 Dallas, TX 75219. ISC Group was incorporated in 1989 and ISCA. was founded in 1994. ISC Investment Management, LLC (“ISC Investment Management”) is the majority shareholder of ISC Group. Scott A. Hayes is the President and CEO of ISC Group and the majority shareholder of ISC Investment Management. The names ISC Advisors, ISC Group, and ISCA are often used interchangeably in the day-to-day operations of the Firm. All contracts, correspondence, sales literature and advertising that require registration under the Investment Advisers Act of 1940 (“Advisers Act”) are provided through ISCA. Services Offered Financial planning The Firm provides financial planning services in the areas of retirement planning, financial planning, personal tax and cash flow planning, estate planning, insurance planning, divorce planning, college planning, and compensation and benefits planning, among others and such services are provided based upon a negotiated hourly rate. Once the scope of financial planning services has been agreed upon, a determination will be made as to the applicable fee to be charged. The final fee, subject to negotiation, is directly dependent upon the facts and circumstances of the client's financial situation and the complexity of the financial plan or service(s) requested. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, the Firm will notify the Client and will request that the client pay an additional fee. The Firm reserves the right to determine whether the financial planning fees will be waived or offset by advisory fees and/or additional compensation earned in the implementation process. The scope and complexity of the financial planning services that were provided will determine the waiver or offset of the fee. In general, the financial plan will address the following areas of concern: Personal: family records, budgeting, personal liability, estate information and financial goals. Tax and Cash Flow: Income tax and spending analysis and planning for the past, current and future years. We illustrate the impact of various investments on the client’s or clients’ current income tax and future tax liability. Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. 1 2 Retirement: Analysis of current strategies and investment plans to help the clients achieve their retirement objectives. Investments: Analysis of investment alternatives and their effects on client portfolios. ISCA gathers required information through personal interviews. Information gathered includes a client’s current financial status, future goals, attitudes towards risk and other relevant information. After this information is obtained, ISCA and its advisor representatives (“Advisor” or “IAR”) make recommendations for the client. Should the client choose to implement the recommendations contained in the plan, ISCA suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client’s discretion. Limited Services: Clients can also receive investment advice on a more limited basis. This includes advice on only isolated areas of concern such as estate planning, retirement planning, or another specific topic. ISCA also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, ISCA provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Financial Plan recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. All recommendations are of a generic nature. Pension Consulting Services As an investment adviser, ISCA also provides pension consulting services to employers that are contemplating starting, transferring, or amending their employer-sponsored retirement plan(s). In this capacity, ISCA meets with senior management and key personnel to design and operate retirement plans and retirement plan documents that meet the employer’s needs and comply with all applicable rules and regulations. ISCA will provide the following services: Institutional accounts are typically employer sponsored qualified retirement plans under section 401(a), 401(k), 403(b), or 457 of the IRS Code. (1) ISCA provides fiduciary and/or non-fiduciary services to such Plan Clients and such capacity shall be disclosed in writing to the Plan Client. (2) ISCA will implement the investment plan after having reviewed the applicable investment options with the client. Investment options selected include the use of load and no-load mutual funds. In the case of load mutual funds, ISCA will refund whenever possible. Other products recommended and utilized include closed-end mutual funds, fixed and variable annuities, insurance GIC products, unit investment trusts, certificates of deposit, exchange traded funds (“ETF”), individual stocks, bonds, government securities, and municipal securities. (3) ISCA will conduct periodic due diligence reviews of the Plan’s reports, investment options and recommendations. (4) ISCA will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and will make recommendations as necessary to maintain or remove and replace investment options. (5) ISCA also provides services to individual plan participants including education, enrollment assistance, and as requested from time to time, one on one consultations regarding investment recommendations. When providing individual plan participant consulting services, ISCA will review the plan participant’s financial situation, goals, and objectives as well as the investment options available in the retirement plan. ISCA will make such recommendations from the list of available investment options in the retirement plan account as are deemed appropriate and consistent with the plan participant’s stated investment objectives and risk tolerance. These services do not constitute asset management services for the participant’s retirement plan account. The plan participant will determine whether or not to implement the advice provided. The implementation of any trades in the participant’s retirement plan account is the participant’s responsibility. ISCA represents that it is not subject to any disqualification as set forth in Section 411 of the Employee Retirement Income Security Act (“ERISA”). In performing fiduciary services for a Plan Client, it is acting as a fiduciary of such Plan as defined in Section 3(21) under ERISA for purposes of providing non-discretionary investment advice to the Plan and plan participants. The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to participants under ERISA. In the event that the Firm serves as a fiduciary for a particular Plan Client, the Firm receives fiduciary fees for those services. Retirement Accounts – DOL Disclosure We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“Code”), as applicable, when we provide investment advice regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to collectively sometimes herein as (“Retirement Accounts”). To ensure that ISCA will adhere to fiduciary norms

and basic standards of fair dealing, we are required to give advice that is in the "best interest" of the retirement client. The best interest standard has two chief components, prudence and loyalty. Under the prudence standard, the advice must meet a professional standard of care and under the loyalty standard, our advice must be based on the interests of our retirement clients, rather than the potential competing financial interest of ISCA. To address the conflicts of interest with respect to our compensation, we are required to act in your best interest and not put our interest ahead of yours. To this end, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Managed Accounts Program The Firm has developed a proprietary managed account program called Pathways (“the Program”) to assist clients in meeting their investment goals and objectives. The Program seeks to maximize risk-adjusted returns over the long-run according to each portfolio’s objectives. The Program is managed by an investment committee at the Firm that meets frequently to discuss the underlying funds, asset allocation, and forward-looking market and economic expectations. The Program is offered through various custodial and brokerage accounts as an actively managed overlay consisting of either mutual funds or exchange-traded funds and is managed according to one of five managed model portfolios: (1) Conservative Income - focused on preserving capital and attempts to protect investors with shorter time horizons from losses. The majority of this portfolio is invested in fixed income securities with a small portion in equities and is the most conservative model available. Lower potential gains are offset by reduced volatility and investment risk. The Conservative Income Model is designed for shorter time horizon investors that tolerate minimal market fluctuation and are less concerned with long-term growth of capital. (2) Income – primarily attempts to avoid short-term loss, but still seeks somewhat higher returns over the long term (3) Balanced – intended to provide returns that are expected to outpace inflation over the long term to investors who are equally concerned with risk and return (4) Growth - designed to provide wealth accumulation to investors with intermediate to long term time horizons. This portfolio may have higher than average volatility and potential short-term losses to achieve desired returns. (5) Aggressive Growth – designed for investors who have a longer time horizon and to provide wealth accumulation. Investors may experience volatility and short-term losses in portfolio value in exchange for the chance to achieve higher returns over the long term. Model Portfolios are managed according to the general categories of objectives and risk tolerances defined above and are not tailored to the individual needs of the clients. The Program is currently offered as a portfolio management option to the Firm’s corporate clients for utilization in connection with their employer-sponsored qualified retirement plans. The Program is purely optional. Participants can start or stop this program at any time and can alternatively select to self-direct their individual retirement plan(s) rather than rely on the Firm’s Managed Portfolio Program option. The Program is offered through the Firm, its registered representatives or investment advisory representatives acting in their separate capacity as IARs of the Firm, based on the Firm’s independent registration as an investment adviser with the Securities and Exchange Commission. Clients that participate in the program will receive Part 2A of the Firm’s Form ADV in accordance with SEC regulations. If the disclosure brochure is not delivered to the Client at least 48 hours prior to entering into the Agreement, the Client can terminate the Agreement within five business days without penalty. After the five-day period, either party can terminate the agreement by providing written notice to the other. Upon termination, any prepaid fees will be prorated to the date of termination and unearned fees will be returned to the Client. The fees for the Managed Account Program generally range from 0% to 1.3% depending upon the Firm’s negotiated arrangement with a Client. Fee Schedule: For investment advisory services, ISCA will generally charge a fee based upon a percentage of assets under management. Fees are negotiable and will not exceed a maximum of one point three percent (1.30%) per year. ISCA will alternatively charge an hourly fee and/or a flat rate fee. These fees will likewise be negotiated as per the executed client agreement. Use of Sub-Advisors ISCA may delegate some of its investment advisory functions over a particular client account or accounts to another investment adviser (“Sub-Advisor”), at ISCA’s discretion or the Client’s request. While ISCA will remain your primary investment adviser and continue to render investment advisory services to the Client relative to the ongoing monitoring, review of account performance, asset allocation and client investment objectives, the Sub-Advisor will assume day- to-day investment management of your assets managed by the Sub-Advisor. In such a case, the Client shall execute the ISCA's Sub-Advisor Disclosure and Acknowledgement Form, which grants the Sub-Advisor day-to-day responsibility for the active discretionary management of the assets allocated to the Sub-Advisor for portfolio management. Prior to delegating advisory functions, ISCA will perform due diligence on the Sub-Advisor, enter into a sub-advisory contract with the Sub-Advisor, and supervise the services provided by the Sub-Advisor. ISCA retains authority to engage or terminate Sub-Advisors. ISCA will inform clients prior to engagement or termination of the Sub-Advisor to which it delegates investment advisory functions. ISCA’s role will be to monitor the overall financial situation of the client, monitor the investment approach and performance of the Sub-Advisor, and to assist the client in understanding the investments in the client’s account. Clients will be provided with each Sub- Advisors Privacy Policy Notice and Form ADV Part 2A Brochure, which contains important information regarding the strategies, fees and risks of the Sub-Advisor. Publications of Periodicals or Newsletters ISCA publishes free newsletters written by the company or purchased from a third-party. Newsletters will be distributed on paper or electronically. No specific information about performance, past or expected, or particular securities will be discussed except for publicly known facts such as prices and benchmark performance such as the S&P 500 Index and Dow Jones Industrial Average. Educational Seminars/Workshops ISCA Advisors will conduct workshops free of charge and open to the public on various topics of financial planning and investments. These are general in nature and are not meant to represent financial or tax advice for a specific person. No specific information about performance, past or expected, or particular securities will be discussed except for publicly known facts such as prices and benchmark performance such as the S&P 500 Index and Dow Jones Industrial Average. Assets Under Management Total Assets under management as of 12/31/2023: $1,284,165,122. Accounts managed on a discretionary basis: $477,728,657. Accounts managed on a non-discretionary basis: $806,436,465.