Lucien, Stirling & Gray Advisory Group, Inc. (hereafter sometimes called “the firm”, “LSG” or “the company”) has been in business since 1992 and is a Texas Corporation offering Investment Advisory Services to individuals, corporations and other business entities, pension and profit-sharing plans, trusts, estates, and charitable organizations. The company’s principal owner is Thomas G. Twombly (President). The company offers investment advisory services through both supervisory and non-supervisory accounts. A supervisory account is one in which continuous investment advice is given based on the individual needs of the client. Individual needs include, for example, the nature of other client assets and the client’s personal and family obligations. A non-supervisory account is one in which a client has elected to follow one or more investment “models” such that the account, or such portion of the account so designated, will mirror the allocations set forth by the model with minimal individual variation. Both supervisory and non-supervisory accounts are charged fees, applied and calculated as described below, based on a percentage of the value of the household assets under management. An investor, in consultation with advisor, may choose to work with any combination of supervisory and non-supervisory accounts so long as the per-account minimum is met. In addition to and independent of ongoing investment advisory services through supervisory and non-supervisory accounts, the company offers advice through individual consultations not included in either of the ongoing services described above. Such consultations are offered on an hourly basis, by quotation, or according to a fixed fee schedule as described below depending upon the type of services desired by the client. The company makes available analyses of and opinions on specific securities on a one-time report basis as described below. Other non-investment advisory services, including for example, consultation on qualified plan design and enrollment, research, and seminars are available as deemed appropriate according to fee schedules published herein or by negotiated contract. Investment advisory services provided by the company will generally relate to Investment Companies registered

under the Investment Company Act of 1940 and their various applications. These applications include mutual fund shares, variable annuities, and variable life insurance. The fee charged by a registered investment advisor for investment advisory services is separate from the annual operating expenses charged by the mutual fund. Fund operating expenses are detailed in the fund prospectus. As a result, investors who choose to use an investment advisor will pay more than the ordinary fees associated with owning a particular security. Investment advisory services will ordinarily not relate on an ongoing basis to other types of securities, notwithstanding the company will furnish analyses of such securities at the request of the client. Investment Companies frequently offer multiple share classes of the same fund, each with differing fee schedules. When recommending the purchase of mutual fund shares to clients in both supervisory and non-supervisory accounts, LSG’s policy is to recommend that clients purchase the least expensive mutual fund share class available to the client at the custodian where their assets are held. On a quarterly basis, the firm will assess which mutual fund share classes are available to its clients to determine the least expensive share class, taking into consideration the client’s needs, preferences, account size, and anticipated activity in the account. LSG will also review and assess previously recommended share classes and, if a lower cost share class has become available, determine whether it is the best interest of its clients to convert to the lower cost share class. The company will maintain various investment models (e.g. Conservative Growth, Retirement Income, etc.…), each with a particular investment objective and policy. Models are under the direction of the firm’s Investment Policy Committee (IPC) which, in applying each model’s objectives and policies, determines the securities to be held and when position changes are indicated. Clients who elect to follow models must file a discretionary authority that permits the Firm to maintain such accounts in conformity with the model. Assets Under Management: On December 31, 2022 the company managed $67,913,353 in discretionary accounts and $30,531,667 in non-discretionary accounts for a total of $98,445,020.