SimCo is wholly owned by an affiliated accounting firm, Squire & Company, PC, and has been providing advisory services since 2000. As of December 31, 2023, SimCo managed $372,071,575 on a discretionary basis and $5,160,296 on a nondiscretionary basis. In addition, we advised on $91,478,857 of self- directed retirement account assets. Investment Management Services: SimCo manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations, corporations and small businesses. SimCo will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. SimCo uses investment and portfolio allocation software to evaluate alternative portfolio designs. SimCo evaluates the client's existing investments with respect to the client's investment policy statement. SimCo works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by SimCo. SimCo will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. SimCo will typically create a portfolio of passive and/or evidence-based mutual funds and Exchange Traded Funds (ETFs) and may use model portfolios if the models match the client's investment policy. SimCo will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. SimCo primarily recommends mutual funds and ETFs offered by Dimensional Fund Advisors (DFA). DFA sponsored securities follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). SimCo manages securities portfolios on a discretionary or nondiscretionary basis. A client may impose any reasonable restrictions on SimCo’s discretionary authority, including restrictions on the types of securities in which SimCo may invest client’s assets and on specific securities, which the client may believe to be appropriate. Use of Third-Party Sub-Advisers SimCo has retained Buckingham Strategic Partners to act as a sub-advisor for certain client accounts. Buckingham Strategic Partners shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by SimCo. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to Buckingham Strategic Partners, which may include, but are not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by Buckingham Strategic Partners. Each Portfolio is designed to meet a particular investment goal which SimCo has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and Buckingham Strategic Partners will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, SimCo, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact SimCo to determine if changes to an account and the allocation of the assets held in the account are necessary. SimCo may also recommend to advisory clients fixed income portfolios, which consist of managed accounts of laddered individual bond portfolios. The Firm will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to engage a third-party fixed income manager. SimCo has contracted with Buckingham Strategic Partners for sub-advisory services with respect to clients’ accounts. A client agreement, including this discretionary authority granted to SimCo by the client to hire a fixed income subadvisor, may be canceled at any time for any reason upon receipt of 30 days written notice. Pursuant to its discretionary authority, SimCo will engage the

fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain SimCo’s consent prior to the sale of any client securities. On an ongoing basis, SimCo will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. SimCo will periodically, and at least annually, review clients’ investment policy, risk profile and discuss the re- balancing of each client's accounts to the extent appropriate. SimCo will provide to the investment manager any updated client financial information or account restrictions necessary for the investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, SimCo may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: SimCo also provides advisory services to participant-directed employee retirement benefit plans. SimCo will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. SimCo will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. SimCo will recommend changes in the plan's investment vehicles as may be appropriate from time to time. SimCo generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, SimCo also works in coordination and support with Buckingham Strategic Partners. Retirement plan clients will engage both SimCo and Buckingham Strategic Partners. Buckingham Strategic Partners will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. SimCo will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: SimCo also provides advice in the form of a Financial Plan. Clients purchasing this service may receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern: - PERSONAL: Family records, budgeting, personal liability, estate information and financial goals. - EDUCATION: Education IRAs, financial aid, state savings plans, grants and general assistance in preparing to meet dependent’s continuing educational needs through development of an education plan. - TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. SimCo may illustrate the impact of various investments on a client’s current income tax and future tax liability. - DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. - RETIREMENT: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. - INVESTMENTS: Analysis of investment alternatives and their effect on a client’s portfolio. SimCo gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, SimCo suggest the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion.