5 (ii) Financial Planning and Consulting: We offer a variety of financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we would generally provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we typically do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. IRA Rollover Considerations As part of our consulting and advisory services, we may provide you recommendations and advice concerning your employer retirement plan or other qualified retirement account. We may recommend you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA") that we manage. If you elect to roll the assets to an IRA that we manage, we will charge you an asset-based fee as described in Item 5. This presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating an asset management fee rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. Many employers permit former employees to keep their retirement assets in their company plan. Current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Rollover the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage, you should carefully consider the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your current plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets in a 401k or retirement account and you are still working, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401k may offer more liability protection than a rollover IRA; each state varies. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA and you may be able to make penalty free

withdrawals from your 401K as early as age 55. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or home purchase. 9. If you own highly appreciated company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing the following services offered by our firm: Asset Management. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their account. In the rare instance that we would allow restrictions, it would be limited to the following services: Asset Management. We do not manage assets through our other services. D. Participation in wrap fee programs. We only offer Wrap Fee Program to clients previously with Financial Design & Management, Inc. (FDM Legacy). The program is designed to assist you in clarifying your investment needs and obtaining professional asset management for a convenient single "wrap" fee on a discretionary or non-discretionary basis. Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage, clearance custodial, and administrative services. Clients’ portfolio transactions will be executed without a commissions-charge in a wrap fee arrangement. We typically manage wrap fee accounts similarly to non-wrap fee accounts. However, several factors may influence the selection of the account structure, including but not limited to: 1) The client’s preference for a “wrap” vs. transaction charges per trade on certain or all securities. 2) Account size. 3) Anticipated trading frequency. 4) Anticipated securities to be traded. 5) Management style. 6) Long term investment goals. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by paying transaction costs separately with another advisor. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged by broker-dealers, and the advisory fees charged by investment advisers. We will review with clients any separate program fees that may be charged to clients. As we absorb certain transaction costs in wrap fee accounts, we may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. To minimize this conflict, we manage accounts similarly, whether in a wrap program or not, and periodically review the activity and associated costs to assess whether the wrap account is in the clients’ best interest. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis. We manage $244,390,283 on a discretionary basis and $76,049 on a non-discretionary basis as of December 31, 2022. We are required to describe our brokerage, custody, fees and fund expenses so you will know how much you are charged and by whom for our advisory services provided to you. Our fees may be negotiable. Therefore, clients with similar assets under management and investment objectives may pay higher or lower fees than other clients. A. Description of how we are compensated for our advisory services provided to you. (i) (a) Asset Management: Assets under management Annual Percentage of assets charge*: $0-$4,999,999 1.00 % $5,000,000+ Negotiable *Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the value of your account on the last day of the quarter. Fees in excess of 2% are in excess of industry standards. Similar advisory services can be obtained for less. (b) FD&M Legacy Account: Advisory fees will be charged in advance of each calendar quarter. The quarterly advisory fee will be based on the value of the account on the last business day of previous quarter. We reserve the right to adjust billing for material interim additions to or withdrawals from the account during the quarter. Fee adjustments for additions and withdrawals made from an account will be reflected on the next billing cycle. The adjustment is calculated based on the number of days the money was under management and your fee schedule. To simplify accounting, your fee each quarter will be rounded up/down to the nearest dollar. Some quarters a client may pay slightly more and some quarters slightly less than the exact formula amount. Over time, such rounding will tend to average out to the exact formula amount. Portfolio Size Quarterly Fee Annual Fee First $100,000 0.40 - .45% 1.6 - 1.8% Next $150,000 0.35 - .45% 1.4 - 1.8% Next $250,000 0.325 - .35% 1.3 - 1.4% Next $500,000 0.275% 1.1% Next $1,000,000 0.2 - .25% 0.8 - 1% Next $3,000,000 0.1625 - 0.1875% 0.65% - 0.75%