A. Description of the Advisory Firm Cadent Capital Advisors, LLC (hereinafter “CCA”) is a Limited Liability Company organized in the State of Oklahoma. The firm was formed in January 2012, and the principal owners are Philip Andrew Mooberry, Ann Dagg, Todd Taylor, and Curtis Rice. B. Types of Advisory Services CCA offers the following services to advisory clients: Portfolio Management Services CCA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CCA evaluates the current investments of each client and then will reallocate in accordance to their risk tolerance levels and time horizon. CCA will provide a review of the client’s investments at least annually. Risk tolerance levels are documented in the Investment Policy Statement, which is reviewed as needed with clients. The client should notify CCA regarding any changes in your situation that may affect your financial condition, investment objective or risk tolerance. CCA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCA’s economic, investment or other financial interests. To meet its fiduciary obligations, CCA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, CCA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CCA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Other Advisers CCA may direct clients to third-party investment advisers. Before selecting other advisers for clients, CCA will always ensure those other advisers are properly licensed or registered as investment adviser. Subadviser Services CCA may also act as a subadviser to advisers unaffiliated with CCA. These third-party advisers would outsource portfolio management services to CCA. This relationship will be memorialized in each contract between CCA and the third-party advisor. Retirement Plan Consulting Services CCA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting include, but is not limited to: o Liaison to Service Provider and TPA o Education Services to Plan Committee o Development of Investment Policy Statement o Participant Enrollment and Education o Benchmarking Services o Monitoring of Plan Fees o Creation and Implementation of Fund List o Ongoing analysis and recommendation of Investment Funds o Annual Review with Plan Committee These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Advisory Services to Brokerage Customers CCA provides investment advisory services to certain broker-dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s advisory services. Brokerage Customers have entered into a written advisory agreement with CCA. Financial Planning Individual Financial Planning Services Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Financial Planning may be provided at no cost as part of the investment management process. Divorce Financial

Planning Services Divorce Financial Planning may include but is not limited to: Gathering financial details relevant to Client’s divorce, analysis of income and expenses. Financial budget planning and modeling, analysis and illustration of potential settlement scenarios, work with personal tax professionals to evaluate tax consequences of various settlement proposals, examining retirement and insurance issues, preparing inventories and financial settlement scenarios, and evaluating sources of income for alimony or spousal support. Services Limited to Specific Types of Investments CCA generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), commodities, hedge funds, private equity, private placement and insurance products including annuities. CCA may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, 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. There are conflicts of interest that CCA and its investment adviser representative have in making an IRA or 401k plan rollover recommendations. The conflict CCA has in making any IRA or 401k plan rollover recommendation is CCA will earn a new (or increase its current) advisory fee if you do rollover to an IRA or 401k plan advised by CCA. The CCA investment advisor representative making an IRA rollover or 401k plan recommendation has the same conflict as CCA. As they will earn a new (or increase its current) advisory fee as a result. C. Client Tailored Services and Client Imposed Restrictions CCA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCA from properly servicing the client account, or if the restrictions would require CCA to deviate from its standard suite of services, CCA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. CCA does not participate in any wrap fee programs. E. Assets Under Management CCA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $533,606,838 $83,244,516 December 2023 CCA also has $641,011,392.18 in assets under advisement. Assets under management include securities portfolios for which CCA provide continuous and regular supervisory or management services. While assets under advisement refer to assets on which CCA provides advice or consultation but for which CCA does either not have discretionary authority or does not arrange or effectuate the transaction.