History and Management The Fiduciary Group, LLC (CRD #221530), succeeded to the advisory business of its predecessor Fiduciary Services Corporation d/b/a The Fiduciary Group (CRD #104731 / SEC # 801-9822) effective April 1, 2015, and continues to do business under the name of The Fiduciary Group (“TFG”). Originally founded in 1970, TFG continues the advisory business of the predecessor firm in all respects. The advisory services and management of TFG remain the same. TFG is managed by TFG’s principals pursuant to a management agreement between TFG Partners, LLC (“TFG Partners”) and TFG. TFG Partners is 100% owned by TFG Principals: Malcolm Butler, President and CEO; Joel Goodman, Chief Investment Officer; and Scott McGhie, Director of Research and Portfolio Management, (“TFG Principals”). The TFG Principals serve as leaders and officers of TFG and are responsible for the management, supervision, and oversight of TFG, including control over advisory services, investment decisions, client services, and fees. Shanon Caddick serves as the Chief Compliance Officer (“CCO”) of TFG. TFG Ownership Structure TFG is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, TFG is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because TFG is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of TFG. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. TFG offers clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. TFG helps clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information. TFG has a business arrangement with SCS Capital Management LLC (“SCS”), who is an indirect, wholly owned subsidiary of Focus LLC, under which certain clients of TFG have the option of investing in certain private investment vehicles managed by SCS. TFG is an affiliate of SCS by virtue of being under common control with it. Please see Items 5, 10, and 11 for further details. TFG Advisory Services TFG primarily provides wealth management services to high-net-worth individuals and families, and investment management services for trusts, estates, pension and profit-sharing plans, nonprofit organizations, and other legal entities. These accounts are managed as separately managed accounts. TFG also provides discretionary investment management services under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) Section 3(38) to participant-directed 401(k) plans. Where requested, the principals of TFG accept appointments in their individual capacity as trustee, executor, and/or power of attorney. Separately Managed Accounts We offer a wide range of services to our clients who own separately managed accounts. Our services include rendering of investment advice and counseling; investment management; asset allocation; selection and discretionary trading of equities, fixed income, and other instruments; and active portfolio management and review. TFG works with each client to establish an appropriate investment policy statement (IPS) based on the client’s objectives, unique circumstances, time horizon, and risk tolerance. Clients can impose reasonable restrictions on TFG’s management of their accounts. TFG generally invests client assets in domestic and international stocks, bonds, mutual funds, and exchange traded funds (“ETFs”). Participant-Directed 401(k) Plans TFG is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. TFG is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, TFG is subject to specific duties

and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). In performing fiduciary advisory services for participant-directed 401(k) plans, The Fiduciary Group is a Section 3(38) Investment Manager under ERISA. Fiduciary advisory services for 401(k) plans include: 1. Discretionary authority to select, monitor, remove, and replace the investment alternatives available to plan participants under the terms of the plan. TFG screens mutual funds using a proprietary filtering process based on generally accepted investment theories. 2. Discretionary authority to develop and amend a formal written Investment Policy Statement (IPS), which establishes the specific standards and processes for investment operations of the plan. 3. Construction and management of asset-allocation model portfolios from which participants may choose. These asset allocation model portfolios utilize the underlying investment options made available to plan participants. Models are constructed to provide a range of asset allocation models based on generally accepted investment theories. TFG does not provide fiduciary investment advisory services to participants at a participant level, only at the plan level. However, TFG provides investment education and guidance to participants so that participants may choose an allocation strategy or portfolio from the available mutual funds that meets their needs, objectives, time horizon, and risk tolerance. As a fiduciary, TFG has a duty of care and of loyalty to clients and are subject to obligations imposed on the firm by the federal and state securities laws. As a result, clients have certain rights that cannot be waived or limited by contract. Nothing in TFG’s agreement with clients should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any nonwaivable rights clients possess. Financial Planning Services TFG offers financial planning services to assist clients in planning for and monitoring progress toward achieving their financial goals such as saving for retirement, funding a child’s education, managing risk through insurance, managing cash-flow prior to and during retirement, and transferring wealth during lifetime and at death. After developing the plan, TFG works with the client to implement and monitor execution of the plan. TFG does not sell any products or receive any financial incentives from third parties tied to recommendations. Trustee, Executor, and POA Appointments When requested, the principals of TFG serve as trustee, executor, or power of attorney for clients. All fiduciary appointments as trustee or executor are held by the firm's principals individually, for a separately contracted fee. When serving as trustee, the individual advisor performs all duties required under the terms of the special or general purpose trust. The trustee manages the trust assets for the beneficiaries according to the terms the grantor has set forth in the trust agreement. The trustee must use his or her best judgment to carry out the grantor's directions and prudently manage the trust assets for the beneficiary. The trustee also performs all administrative duties involved in managing the trust, including distribution of income to the beneficiary, trust accounting and reporting, and tax filing. As trustee, the individual advisor contracts with TFG to serve as discretionary investment manager for the trust assets. As power of attorney for clients, the Firm’s principals approve the payment of bills and request checks and distributions to third parties on the client’s behalf. Our advisory personnel’s service as trustee, executor or pursuant to power of attorney gives them the authority to retain TFG to render investment advisory service presents a potential conflict of interest. However, we accept such appointments only upon the request of our clients. Additionally, when our firm’s principals have the authority to appoint TFG as investment adviser, the trust or other relevant governing document authorizes the retention of our firm. When serving as executor, the individual advisor performs all acts required under the terms of the will including probating the will; identifying, gathering, managing, and protecting probate assets; determining personal and estate tax liabilities; and distributing the estate and making final settlement among all beneficiaries according to the will or special instructions of the deceased. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodians. Client Assets As of December 31, 2023, TFG managed $1,613,411,088 in assets on behalf of approximately 654 households/legal entities and 1,566 separate accounts, of which $1,589,219,940 was managed on a discretionary basis and $24,191,148 was managed on a non-discretionary basis.