A. Description of the Advisory Firm Clayton Financial Group, LLC (“CFG”), was formed on April 2015 and is based in the State of Missouri. CFG and has been providing investment advisory services since 2015. CFG’s principal owners are Kenneth John Bower and Matthew Joseph Bower. Kenneth Bower, Matthew Bower, Julie Bahr, Christopher Michalak, Patrick Britt, , and Kelly Richert are all Managing Directors of Clayton Financial Group. B. Types of Advisory Services ASSET MANAGEMENT CFG offers asset management services to advisory Clients. CFG will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the Client elects to use CFG on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing CFG to determine the securities to be bought or sold and the amount of the securities to be bought or sold. CFG will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use CFG on a non-discretionary basis, CFG will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, CFG will obtain prior Client approval on each and every transaction before executing any transaction. ERISA PLAN SERVICES CFG offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. 3(38) Investment Manager. CFG acts as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. CFG would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5).
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. The Advisor’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not providing fiduciary advice as defined by ERISA to the Plan participants. Advisor will

not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. CFG may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Plan Sponsor. 3. CFG has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. FINANCIAL PLANNING AND CONSULTING Financial planning services include an evaluation of a Client's current and future financial state will be provided by using currently known variables to predict future cash flows, asset values and withdrawal plans. CFG will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Topics generally reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial goals, including funding a college education for the children, buying a larger home, starting a business, retiring on time or leaving a legacy.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month.
• Long-term investment plan: Include a customized asset allocation strategy based on specific investment objectives and risk. This investment plan sets guidelines for selecting, buying and selling investments.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax favored investment vehicles that can reduce taxation of investment income.
• Estate and Legacy Planning: Identify ways to meet the client’s long-term legacy goals through related to estate planning and gifting. Regular review of beneficiaries, powers of attorney, and trustees shall be completed as well as reviewing methods that may reduce potential federal estate tax.
• Executive Benefits Planning: Assist Client in managing his/her executive benefits including but not limited to deferred compensation arrangements, stock options, stock purchase plans, restricted stock units (RSUs). Strategies shall include tax planning strategies to mitigate the taxation of income as well as investment planning for the purchase or sales of company stock. If a conflict of interest exists between the interests of CFG and the interests of the Client, the Client is under no obligation to act upon CFG’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through CFG. C. Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with CFG. D. Wrap Fee Programs CFG does not participate in a Wrap Program. E. Amounts Under Management As of December 31, 2023, CFG provides management services for: Discretionary Assets: Non-Discretionary Assets: $527,031,772 $994,618,088