Englebert Financial Advisers, LLC (“Englebert” or the “Adviser”) was established in 2019. Christopher Englebert is our Founding Partner & Chief Investment Officer. Jamie Englebert is our President & Chief Compliance Officer. As of April 30, 2024, Englebert managed $125,161,376 of which $125,108,058 was managed on a discretionary basis and $53,318 was managed on a non- discretionary basis. Englebert provides discretionary and non-discretionary advisory services to a variety of Clients, including but not limited to individuals, trusts, estates, corporations, defined contribution plans, defined benefit plans, state municipalities, and charitable organizations in individually managed accounts. Accounts are managed individually based on each Client’s investment objectives, strategy, and restrictions. Clients may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for their account. Simply provide us with your restrictions or guidelines in writing. Non-discretionary portfolio management service means that we must obtain your approval prior to making any transactions in your account. The Adviser may provide Clients with needs-based financial planning services as part of its overall investment management offering. Investment Objective and Philosophy Adviser primarily allocates Clients’ investment management assets among External Investment Advisers (as defined below), separate accounts, mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and/or options in accordance with the investment objectives of the Client. In limited cases, the Adviser may use other types of investments (securities or non- securities, including cryptocurrencies) to help diversify a portfolio when prudent. Financial Assessment As part of the advisory services provided to Clients, the Adviser provides a financial assessment, which takes a comprehensive view of different aspects of the Client’s current financial situation to develop a plan that allows us to help the Client meet their investment goals and objectives. During the financial assessment process, the Client will participate in meetings to identify and prioritize their objectives, gather information, evaluate recommendations, and track progress toward the goals. This could also include meetings with the Client’s other specialized advisors (attorneys, accountants, etc.). Depending on the Client’s objectives, a formal written financial assessment could cover general financial planning, estate planning, educational fund planning, business succession planning, individual tax planning, business planning, retirement planning, corporate retirement planning, risk management, and insurance planning. While the Adviser might make observations relating to legal, tax, or insurance issues, the Adviser does not provide legal, tax, or insurance advice. A financial assessment generally consists of observations, assumptions, strategies, and recommendations. The Client is generally presented with a formal written assessment based on the information they have provided. The Client could choose to implement all or part of the assessment through the Adviser or another professional of their choice. For certain consulting or ad-hoc requests, a written summary might not be provided. For non-clients, we offer financial assessment services under a general consulting agreement for an hourly fee as described in more detail in Item 5 below. Portfolio Management Services Adviser primarily allocates Clients’ investment management assets among External Investment Advisers (as defined below), separate accounts, mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and/or options in accordance with the investment objectives of the Client. In limited cases, the Adviser may use other types of investments (securities or non-securities, including cryptocurrencies) to help diversify a portfolio when prudent. The main investment strategy that we employ is relative strength. We compare individual equities, ETFs, and mutual funds against each other to find the security or asset class that has the best relative strength. At times, this may preclude us from investing in an asset class that may not have the relative strength to meet our criteria. We also employ various “risk management” tools to determine whether or not our portfolios are on “offense” or “defense” according to overall investment conditions. A variety of model portfolios are used to manage Client accounts. The model portfolios are designed to address a wide range of investor needs, from very aggressive to very conservative risk levels. Based on a review of your risk tolerance, investment time horizon, preferences for certain investment strategies and investment options that are available (referred to as “Client Preferences”), and other information that you provide via a Client questionnaire, you will receive an Investment Strategy Proposal (“Proposal”) containing asset allocation and portfolio investments from a series of model portfolios created by us and/or various third parties; and, your assets will thereafter be managed in accordance with the appropriate agreed upon model portfolio. Adjustments will be made to the model portfolios from time to time, in consideration of changes in market conditions and Client needs, and in a manner that is consistent with the long-term orientation of our portfolio management program. Use of External Investment Advisers Englebert may allocate a portion of the Client's assets to certain External Investment Advisers, such as Envestnet, an SEC-registered investment adviser, for active discretionary management based upon

the investment objectives of the Client. Such an arrangement would require the Client to enter into a separate Investment Advisory Agreement with the External Investment Adviser(s). Englebert renders services to the Client relative to the discretionary and or non-discretionary selection or recommendation of the External Investment Advisers. Prior to introducing any Client to another investment adviser, Englebert will be responsible for determining if the External Investment Adviser is properly licensed, notice filed, or exempt from registration with the relevant jurisdiction in which the Client is domiciled. Englebert also monitors and reviews the account performance and the Client’s investment objectives. External Investment Advisers will charge fees in accordance with each External Adviser’s Investment Advisory Agreement with the Client. Any fees charged by the External Investment Advisers are paid by Englebert directly. When recommending or selecting an External Investment Adviser for a Client, Englebert reviews information about the External Investment Adviser such as its disclosure brochure and/or material supplied by the External Investment Adviser or independent third parties for a description of the External Investment Adviser’s investment strategies, past performance and risk results to the extent available. Factors that the Adviser considers in recommending an External Investment Adviser include the Client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. In addition to the Adviser’s written disclosure brochure, the Client also receives the written disclosure brochure of the designated External Investment Advisers. Certain External Investment Advisers may impose more restrictive account requirements and varying billing practices than Englebert’s. In such instances, the Adviser may alter its corresponding account requirements and/or billing practices to accommodate those of the External Investment Advisers. Adviser Managed Annuities In limited circumstances, Clients may be invested in adviser-managed annuities held outside of a managed account for which the Client grants Englebert discretionary authorization to select from the investments available to the Client. Transactions will be implemented through a service provider selected by or affiliated with the insurance company (typically Nationwide) through which the variable annuity contract is purchased. Englebert does not routinely recommend such investments to new Clients, but legacy Clients may hold such investments over which Englebert provides management services. The services and fees will be set forth in the advisory agreement between the Client and Englebert. ERISA Services Certain services are provided as a fiduciary of specifically designated ERISA plans based on applicable definitions (contained in ERISA Section 404(a), IRC §4972, the Investment Company Act of 1940, and state laws). In performing the following services, the Adviser will act as a fiduciary as defined by ERISA Section 3(21) or ERISA Section 3(38). As a 3(21) investment fiduciary, the Adviser provides investment recommendations to the ERISA plan Client and the Client retains ultimate decision-making authority for the investments and may accept or reject the recommendations of the Adviser. Both the Adviser and the Client share fiduciary responsibility. As a 3(38) investment manager, the Adviser makes the investment decisions in its sole discretion without the ERISA plan Client’s prior approval. The services and fees will be set forth in the advisory agreement between you and Englebert. The services provided could include Investment Advice to the Plan Sponsor, Preparation of the Investment Policy Statement (IPS), Investment Menu Design, Selection of a Qualified Default Investment Alternative (QDIA) vehicle, Performance Monitoring, Performance Reports, and Participant Advice. Management of Held Away Assets Adviser offers asset allocation review, rebalancing, and management services for accounts that are not held in the custody of the qualified custodian(s) recommended by our firm. These services are provided through an account aggregation service called Pontera Inc. (“Pontera”). This service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody of the plan custodian(s). We regularly review the available investment options in these accounts, monitor them, and periodically rebalance and implement our strategies using different tools as necessary. If you elect to allow our firm to manage your assets through Pontera, you will be notified via email when the Adviser places trades through Pontera. Services and fees will be clearly set forth in the advisory agreement between you and Englebert. Consulting Services The Adviser may provide non-discretionary consulting services to assist Clients in the due diligence process of reviewing RFPs submitted to Clients by Registered Investment Advisers. Educational Seminars Clients may engage Englebert to provide educational seminars or retirement workshops. Such services may be provided as part of each Client’s Investment Management Services Agreement or under a separate arrangement as determined by Englebert and the Client. Termination of Services If you did not receive our disclosure brochure document(s) at least 48 hours prior to signing an agreement for advisory services with our firm, you will have five (5) business days in which to cancel the agreement without penalty. Thereafter, either party may terminate the agreement in accordance with the terms set forth in the specific agreement.