A. Overview and Ownership Northern Capital Retirement Services, Inc. (herein referred to as “NCRS”) offers comprehensive retirement plan services to employers, retirement plan sponsors, trustees and participants. NCRS specializes in a full range of retirement plan options including 401(k), 403(b), Defined Benefit (e.g., Cash Balance), SIMPLE IRA plans, and SEP retirement plans, working with their corresponding third-party administrators, recordkeepers, custodians and platforms. Although founded in 2012, NCRS has been providing advisory services through its predecessor firm and current affiliate Northern Capital Management, Inc. since 1992. In 2012, NCRS was formed to focus separately and solely on retirement plans. James K. Wilson is the founder and principal owner of both firms. B. Types of Advisory Services All clients (also referred to as “plan sponsor”) can receive consultation and assistance with determining the plan type that will best fit their needs (e.g., 401(k), SIMPLE IRA Plan). This is more common for start- up plans but can also be conducted for plans that are already established as well. In making a recommendation on the plan type, NCRS will take into consideration the client’s goals and the level of benefit they wish to provide to their plan participants (e.g., whether to provide an employer match or not). This process includes assistance with selecting the trust company or qualified custodian that will hold the plan assets. NCRS can also evaluate and make recommendations to assist the plan sponsor with the selection of other third parties such as record keepers, third party administrators (TPA), and other professionals. NCRS ultimately services the client as the Investment Advisor to the plan and works closely with other third parties in administering the plan. Specific services each plan will receive are detailed in the client’s Financial Advisory Agreement (FAA). In general, services are provided based on the plan type and are described in greater detail below. Services provided to 401(k) and 403(b) plans: The 401(k) and 403(b) plans NCRS services most commonly utilize a “menu of investment options” (also referred to as the Designated Investment Alternatives and Qualified Default Investment Alternatives). Participants allocate their plan assets within the menu of investment options. NCRS will work in collaboration with the plan sponsor to develop a written Investment Policy Statement (IPS). The IPS details the criteria used for selecting and monitoring the menu of investment options to be used by participants within the plan. The IPS is reviewed and maintained on an ongoing basis to ensure compliance with stated objectives. To manage the menu of investment options, NCRS serves as an ERISA 3(38) Investment Manager. This means that our firm is granted discretionary authority to select asset classes, and investment options, according to the terms of the IPS. NCRS conducts ongoing due diligence on the menu of investment options and will make changes as we deem appropriate. To assist the plan sponsor with their fiduciary obligations to the plan, NCRS will prepare an Annual Report and offer to present the information to the plan sponsor. Plan review meetings are offered annually and more frequently, upon request. General topics outlined in the report include:
• Identification of plan fiduciaries and covered service providers

along with their roles and responsibilities.
• Review the Investment Policy Statement and plan investments.
• Overall plan fees and expenses as compared to benchmarks.
• Review participant education and communication strategies to ensure participants are properly informed about the plan, its features, and the menu of investment options available to them. Northern Capital Retirement Services, Inc. Page 4 NCRS also offers a host of services to the participants of the plan. These services include:
• Enrollment materials such as orientation booklets and forms.
• Educational support focused on plan features, investment options, plan mechanics, and distribution options.
• Investment advice and assistance with allocating within the menu of investment options.
• Unlimited access by phone or email to the NCRS team.
• Education and news articles posted to our website, distributed by email and/or via social media channels. Services provided to SIMPLE IRA and SEP IRA plans: All assets within a SIMPLE IRA or a SEP IRA plan are held in IRA accounts that belong to the participants. As a result, NCRS does not manage the assets held in these accounts. Instead, our role is to assist the plan sponsor by assisting in the setup of new plans and providing education to participants of the plan, commonly on an annual basis. These services include:
• Enrollment materials such as orientation booklets and forms.
• Educational support focused on plan features, plan mechanics, and distribution options. The plan sponsor and participants can contact our firm at any time for consultation about the plan. Services provided to Defined Benefit plans (e.g., Cash Balance plans): Defined Benefit plans are managed according to an Investment Objective model that is selected based on plan information to include participant demographics and plan goals. All plan assets are “pooled” together and held in a single trust account on behalf of all participants. The plan sponsor is required to make sure actuarially determined contributions to the plan on behalf of participants occur and are invested in such a way to match actuarially determined "benefits" owed to participants in retirement. NCRS will work in collaboration with the plan sponsor to develop a written Investment Policy Statement (IPS). The IPS is used to establish an investment strategy that reflects the plan’s investment objectives for management of the plan. The IPS is reviewed and maintained on an ongoing basis to ensure compliance with stated objectives. NCRS will then discretionarily manage the plan assets consistent with the selected Investment Objective. See Item 16 – Investment Discretion for more information on this process. C. Tailoring of Advisory Services and Investment Solutions Advice and services are tailored to each client’s needs and based on the type of plan. If a client wishes to impose restrictions on investing in certain securities or types of securities, this will be documented in the Investment Policy Statement. D. Wrap Fee Programs NCRS does not participate in wrap fee programs. E. Assets Under Management Total assets under management as of December 31, 2023: Discretionary Assets: $231,970,685 Non-Discretionary Assets: $ 0 Total Assets: $231,970,685 Northern Capital Retirement Services, Inc. Page 5