A. Description of the Advisory Firm Curtis Advisory Group, LLC (hereinafter “CAG”) is a Limited Liability Company organized in the State of California. The firm was formed in August 2009, and the owners are Ryan Earl Curtis and Joshua Daniel Hayes. B. Types of Advisory Services Portfolio Management Services CAG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CAG will collect pertinent information which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 CAG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CAG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Client Questionnaire Summary or Appendix A of the Investment Policy Statement (IPS), which is given to each client. CAG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CAG’s economic, investment or other financial interests. To meet its fiduciary obligations, CAG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CAG’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 CAG’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. CAG may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, CAG will always ensure those other advisers are properly licensed or registered as an investment adviser. CAG conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. CAG then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of CAG's client. CAG may also allocate among one or more private equity funds or private equity fund advisers. CAG will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Participant Account Management (Discretionary) CAG also provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement asset allocation and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies similar to our portfolio management services, though using different tools as necessary. CAG uses a third-party platform to facilitate management of held away assets with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Pension Consulting Services CAG offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives • monitoring performance of money managers and investment options and making recommendations for changes • recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning 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. Investment Tracking & Oversight Services The firm also provides independent monitoring and reporting on outside accounts to clients. Investment oversight is defined as providing asset allocation, diversification, performance, fee analysis and guidance for a client’s account(s) that are not being actively managed by the firm. The objective of the service is to provide Clients with a consolidated view of all their accounts and bring potential red flags or opportunities to the attention of the client. The firm does not have trading authority over these accounts and will not make specific investment buy/sell/hold recommendations for clients that use this service. Subscription Services CAG provides a securities rating service to prospective clients

and clients using CAG's other advisory services and it does not entail an additional fee. The firm will not make specific investment buy/sell/hold recommendations for clients that use this service. Services Limited to Specific Types of Investments CAG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. However, CAG primarily utilizes exchange traded funds and open ended mutual funds to manage liquid portfolios on a discretionary basis. we do not restrict any types of investments. on occasion, we will recommend a separate account manager if we feel doing so would benefit the client. in doing so, we may delegate some or all of the discretion to the subadvisor. CAG may use other securities as well to help diversify a portfolio when applicable. Schwab Institutional Intelligent Portfolios® We also offer an automated investment program (“Schwab IIP”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate Schwab IIP. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to Schwab IIP. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of Schwab IIP for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for Schwab IIP. The Platform enables us to make Schwab IIP available to clients online and includes a system that automates certain key parts of our investment process (the “System”). Based on information the client provides to us, we will recommend a portfolio via the System. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of Schwab IIP. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in Schwab IIP. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in Schwab IIP. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in Schwab IIP be maintained with CS&Co. C. Client Tailored Services and Client Imposed Restrictions CAG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CAG on behalf of the client. CAG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 CAG from properly servicing the client account, or if the restrictions would require CAG to deviate from its standard suite of services, CAG reserves the right to end the relationship. Furthermore, we may tailor advisory services by considering the clients current positions, the client’s investment experience, tax status, and cash flow need. For clients with larger accounts, generally over $500,000, we have the ability to custom build portfolios to the clients wishes; restricting certain investments or adding in preferred investment choices. For most smaller accounts, we generally don't allow portfolio customization beyond standard risk tolerance information. 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, and certain other administrative fees. CAG does not participate in wrap fee programs. E. Assets Under Management CAG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 418,166,192.00 $ 525,446.00 December 2023 CAG has $ 14,379,010 in assets under advisement as of December 2023.