A. Description of the Advisory Firm Alpha & Omega Financial Management Consultants (hereinafter “A&O”) is a corporation organized in the State of California. The firm was formed in January 1975, and later incorporated in February of 1978, and the owners are Athanasios K. Preovolos, Peter Emanuel Preovolos and the Preovolos Family Trust 1979. Athanasios K. Preovolos is the firm’s Chief Compliance Officer and CLO, Spiro George Preovolos is the firm’s Chief Operating Officer. The firm has been registered with the Securities and Exchange Commission since February 1994 and is currently seeking registration with the State of California, Colorado, Florida, Louisiana, New York and Texas. B. Types of Advisory Services Portfolio Management Services A&O offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. A&O creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 A&O evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. A&O seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of A&O’s economic, investment or other financial interests. To meet its fiduciary obligations, A&O attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, A&O’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 A&O’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. A&O 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, A&O will always ensure those other advisers are properly licensed or registered as an investment adviser. A&O 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. A&O then makes investments with a third-party investment adviser by referring the client to the third-party adviser. A&O will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Model Portfolio Management A&O will invest and reinvest the assets in Client’s account in the securities or other property that comprises a model portfolio for Client based upon Client’s financial circumstances, investment objectives and any special instructions or limits, all as outlined in the IPS. Each Model shall be comprised exclusively of shares of open-end investment companies. Pension Consulting Services A&O 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:
• Providing a sample Investment Policy Statement (“IPS”) for consideration and review by the Sponsor
• Establishing necessary investment categories (“Necessary Investment Categories”) in major asset classes for the Plan’s investment menu, which are designed to ensure the Plan offers a “broad range of investment alternatives” under ERISA Section 404© and the related U.S. Department of Labor regulations (the “DOL Regulations”), as well as certain other optional investment categories (“Optional Investment Categories”);
• Maintaining a list (“Approved List”) of approved investment alternatives in each of the Necessary Investment Categories as well as the Optional Investment Categories. The Approved List is

designed to be used by the Sponsor to select the designated investment alternatives (“DIAs”) for the Plan’s menu in accordance with the guidelines
• Identifying investment alternatives on the Approved List that may serve as the Plan’s Qualified Default Investment Alternative (“QDIA”), if applicable;
• On-going monitoring of the investment alternatives on the Approved List as well as the removal and replacement of investment alternatives from the Approved List from time to time, as necessary;
• Recommending a replacement investment alternative when an investment alternative that is a DIA in the Plan’s investment menu is removed from the Approved List. Any replacement investment alternative that is recommended will also be from the Approved List.
• Preparation and Delivery of Reports: o Portfolio holdings o Quarterly investment summary o Quarterly investment actions o Supplementary investment-related educational information 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. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Services Limited to Specific Types of Investments A&O generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors) and treasury inflation protected/inflation linked bonds. A&O may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions A&O offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s current situation (income, tax levels, and risk tolerance levels). 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 A&O from properly servicing the client account, or if the restrictions would require A&O to deviate from its standard suite of services, A&O reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. A&O does not participate in wrap fee programs. E. Assets Under Management A&O has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0 $ 29,451,402 December 2022