Description of the Advisory Firm Turning Point Financial (hereinafter “Turning Point”) is an independent financial planning and wealth counseling firm registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. Corporation organized in the State of Maryland. The firm was formed in January 1994, and the entity changed its name in 2003 to Turning Point Benefit Group, Inc., the registered entity with the State of Maryland. “Turning Point Financial” is the trade name for Turning Point Benefit Group, Inc., which are not separate legal entities. The firm is owned and managed by Mary K. Troxell, President and shareholder. Types of Advisory Services FINANCIAL PLANNING Turning Point provides financial planning and investment management services to clients based on each person’s individual needs and circumstances. Financial planning can be offered as a stand-alone, fee- based service or in conjunction with ongoing investment management. Likewise, investment management services can be accessed by clients with or without financial planning. In some cases, Turning Point uses a team-based approach to deliver financial planning advice, and we are structured to provide these services as fiduciaries. Team members involved in the planning process can include the Investment Advisor Representative (“IAR”), the financial planning team (Para-planner and/or CFP®), and service support personnel as required. When a client engages Turning Point to create a financial plan, they complete a data gathering process and/or provide information about their financial situation. Either the IAR or a member of the financial planning team conducts the first meeting to obtain clarifying information about a client’s personal goals and wishes and will uncover questions or concerns about their financial lives. This process is modified as needed, based on the complexity of the client’s situation. Internally, the Turning Point team reviews the data provided by the client and builds out a draft of the financial plan. Plans are dynamic and created to address multiple scenarios and goals. Turning Point provides a highly collaborative planning process with the client, which is either in person, by phone or through a web meeting. The client’s financial profile, objectives, and the plan’s findings are evaluated together. Typically, a comparison of various scenarios and financial projections based on our recommendations or changes are offered throughout the process. Depending on the complexity of the planning recommendations, solutions may be offered after the plan is evaluated. Plan recommendations may include but are not necessarily limited to investment or insurance solutions, changes to a client’s savings rates/cash position/or cashflow. Suggestions may be made for modifications to the stated goals, a plan for debt restructuring, details for making large purchases or paying large bills (i.e., college tuition or assisted living costs), estate planning techniques, etc. The final plan is provided in print or electronic copy and is delivered to the client’s secure web portal. All recommendations are based on the individual client needs and are provided within a framework of ethical standards of conduct, including:
• Acting with honesty, integrity, competence, and diligence.
• Exercising due care.
• Maintaining confidentiality and protecting the privacy of client information.
• Acting in the client’s best interests.
• Avoiding, or disclosing and managing, conflicts of interest.
• Acting in a manner that reflects positively on the financial planning profession. Once the initial plan is delivered, the client can continue with financial planning services for a flat annual fee and receive on-going financial plan monitoring and adjustment services. Services provided may include, but are not limited to, basic plan adjustments throughout the year and typically two financial plan review meetings annually – one investment/tax planning focused discussion and one financial plan update discussion. Adjustments to the plan are made based on the client’s reported changes to their circumstances (and through various reporting mechanisms provided by Turning Point). If no changes are reported, the plan is updated with current investment and insurance data and is reviewed with the client. Turning Point may also provide modular planning services to meet a client’s needs. These services may include but are not limited to:
• Cash Flow Management, through COMPASS Financial Planning and a al a carte cash flow management service, “Cash Flow Lasso”.
• Investment Management Recommendations for Non-Supervised Assets (i.e. company sponsored retirement plans, etc.)
• Retirement Planning and Pension and Social Security Options
• Business and Individual Insurance Analysis
• Education Planning
• Estate Planning
• Tax Planning (not including tax preparation and filing)
• Financial Recovery after Divorce or Death of a Spouse/Partner
• Employer Group Plan Services “Modular” plans are quoted individually prior to the first planning meeting. Financial plans are based on a client's financial situation and information provided at the time the plan is presented. Clients must promptly notify Turning Point if their financial situation, goals, objectives, or needs change. Clients are under no obligation to act on any financial recommendations made by Turning Point or any associated person of Turning Point. Should a client choose to act on any of the recommendations, the client is not obligated to implement solutions through Turning Point. INVESTMENT MANAGAGEMENT Turning Point offers Investment Management Services to its clients either in combination with financial planning and tax services, or as a stand-alone offering. If a client is not engaging Turning Point to provide financial planning, Turning Point will provide an investment plan that contains a basic overview of the client’s investment goals and objectives. Turning Point offers investment management services on a discretionary basis. Through personal consultations with the client, Turning Point gathers specific financial data to develop a client's personalized profile, which includes their investment objectives, current financial position, risk profile, investment time horizon, tax situation and liquidity needs. Turning Point uses specific third-party tools to identify the client’s behavioral and financial risk profile (tools may include SEI’s Risk Profile, PreciseFP, TIFIN©, etc.). Based upon this data, Turning Point will determine an appropriate portfolio management strategy from the array of options available and monitored by the firm. These may also include asset management services offered by Turning Point Financial or a third-party adviser. Our advice is generally limited to exchange-listed securities, mutual funds, ETFs, individual bonds or United States governmental securities, and corporate debt securities. Under our discretionary portfolio management services, clients grant our firm discretionary authority to manage the account according to the overall goals established for the investment account, indicated by the client’s Investment Policy Statement (IPS) or Investment Proposal. Within the discretionary authority, the client grants permission for Turning Point to adjust the allocation within the framework of the established goals of the portfolio and select specific securities within the portfolio for each account. Discretionary authority is granted by the Investment Advisory Agreement. If the account is part of the Managed Account Solution program at SEI, discretionary authority is granted by the Investment Advisory Agreement and the appropriate trading authorization forms signed by the client. In line with our discretionary portfolio management services, we offer our clients Asset Management services. Our Asset Management services utilize customized model portfolios and strategies that align with our clients’ overall goals established for the investment account, indicated by the client’s Investment Policy Statement (IPS) or Investment Proposal. For these model portfolios and strategies, the client grants Turning Point discretionary authority. The client expressly grants permission for Turning Point to adjust the allocation within the framework of the established goals of the portfolio and/or strategy and select specific securities within the portfolio for each account. Use of these model portfolios and strategies will incur an additional asset management fee, paid to Turning Point Financial, as outlined below. SEI Private Trust Company clients with qualifying investible assets may also access the Managed Account Solution Program (“MAS”) on SEI’s platform which includes additional individual investment managers and third-party asset managers. The MAS also enables clients to place certain limited restrictions on individual securities, asset classes or types of securities. In this case, Turning Point and the appropriate third-party manager will attempt to meet the requests of clients with regards to limiting specific types of investments (i.e., as in socially responsible or morally responsible investing), but cannot guarantee 100% abstinence from the restricted securities or assets. Turning Point regularly monitors client investment accounts and exercises discretionary authority within the portfolio to maintain the investment objective, which may include the ability to hire and fire managers who are, in the opinion of Turning Point, no longer meeting the objectives of the portfolio. Ongoing discretionary investment management is executed as further described below. Third Party Asset Management and Other Investment Advisory Services Turning Point primarily uses professional sub-advisors as part of our routine asset management services. Our philosophy is to work with those managers and firms that have focused expertise and skill in investment management. Turning Point selects those third-party managers who provide access to the adviser or investment management team on behalf of our clients. Before selecting or recommending advisers to assist Turning Point in managing assets for clients, Turning Point ensures that those advisers are properly licensed or registered. Turning Point reviews the ongoing performance of third-party or sub-advisers as a part of the client's portfolio review or during our routine portfolio management. Turning Point’s sub-adviser investment management relationships are with CWM Advisors, LLC, and SEI Investments Management Company (“SIMC”), federally registered investment advisers. Portfolios are primarily held and maintained on the SEI Private Trust Company custodial platform. Turning Point also works with SEI Investments Management Company and SEI Private Trust Company and its affiliates are collectively referred to in this document as “SEI”. SEI includes the investment

advisory firm SEI Investments Management Corporation [CRD#105146] (“SIMC”) and the broker-dealer SEI Investments Distribution Co. [CRD#10690]. Turning Point may also periodically establish relationships with other custodians or third-party advisors to provide the appropriate solutions to our clients. Turning Point has no general contractual obligation to recommend an asset or service of any sub-adviser or third-party asset manager and does not provide advice to clients based on any obligation to a product sponsor, investment company or sub-adviser. Turning Point may add additional sub-advisers or third-party managers to assist with client investment management solutions (each of their respective ADVs are available online at www.adviserinfo.sec.gov). Through the SEI and Charles Schwab custodial platforms, Turning Point offers clients access to various investment models, asset allocation portfolios and separately managed account solutions. The account services that are provided to clients are shared between the sub-adviser and Turning Point and generally include the following: 1. Collecting information about clients and assisting them in selecting the appropriate program and in designating assets to be managed; 2. Assisting clients in determining their investment objectives, investment time horizons, and risk profiles; 3. Assisting clients in selecting an asset allocation policy within the parameters of the program selected; 4. Making investment recommendations consistent with the asset allocation policy; 5. On-going monitoring of the client's portfolio and recommending changes to the investment strategy as warranted; and 6. Serving as primary client contact, including periodically conferring with clients about their accounts and responding to client inquiries. Turning Point, in working alone and with sub-advisers and third-party investment professionals, offers customized investment solutions and standard investment models to meet the needs of our clients. Once the investment solutions are implemented, Turning Point contacts the client to schedule an investment review meeting on an annual basis. In addition, clients can contact Turning Point with updates to their financial situation or goals or ask questions about their investment account. The client review meetings are conducted either in person, by phone or via a web meeting. At the investment review meeting, a reassessment of the client’s situation, including their investment objectives and risk tolerances will occur. Based on these findings, Turning Point may recommend and/or make modifications to the overall investment allocation or solution as required. On occasion, third-party asset managers and sub-advisers will provide financial sponsorship for Turning Point’s educational or marketing efforts. This sponsorship may create a conflict of interest for Turning Point because it creates a theoretical incentive for Turning Point to recommend solutions to its clients as such sponsorship and any future sponsorships reduces Turning Point’s out-of- pocket costs to purchase materials or host events. Turning Point addresses these conflicts of interest by providing disclosure of the arrangements, expenses, and associated conflicts of interest to clients in this Disclosure Brochure and by reminding clients that they are under no obligation to work with Turning Point or third-party asset managers. Retirement Plan Services Turning Point assists employer clients with group retirement plan options by assessing their group and recommending a plan that best meets the needs of the owners and business at large. In some cases, Turning Point will also offer individual asset management services for a client with a workplace retirement plan that is not managed by Turning Point. In such instances, Turning Point will either provide non-discretionary asset allocation recommendation under a Financial Planning Services Agreement OR will work with appropriate third-party asset managers through the client’s self-directed brokerage option within the plan. Individuals utilizing the self-directed brokerage account option with third-party asset managers generally gain access to additional investment solutions for which they are charged a fee. These fees are typically deducted from the investments in the self-directed brokerage account, and a portion of that fee is then remitted to Turning Point. Tax/ Accounting Services: Turning Point has a team of Certified Public Accountants and other professionals that provide tax services (return filing, tax planning and projections, etc.) accounting services and business valuation services. Financial planning and investment clients are under no obligation to utilize tax/accounting services at Turning Point Financial, however, ongoing planning clients are provided a credit toward tax preparation and/or tax planning fees. Additional Information Business Succession The firm has a team-based approach to clients whereby one or more advisor and/or financial planner provides services to the end users clients. If any one of the advisors or financial planners were to become unable to perform their regular duties regarding client activities, Turning Point Financial would substitute another suitable advisor, financial planner, or team of people to care for the client’s needs, as necessary. This team-based approach provides a high level of comfort for clients, especially since the duties and nature of the overall financial plan are recorded at the firm’s operations level. Clients of the firm are provided with contact information for all custodians who maintain their investment accounts. Normal operation of their custodial investment accounts is not impaired by, and does not depend on, a change to advisors or key personnel at this RIA. The owner of this RIA has an emergency succession plan which includes insurance funding for key employee replacement for both the owner and the COO. This enables continued operations and leadership in the event of an unexpected disability or death of either person. Cyber Security Turning Point uses industry standard cyber security software to conduct comprehensive ongoing scans. Along with our IT partners, we regularly evaluate and monitor the technologies and interface systems that are utilized by Turning Point and the team members. This effort evaluates gaps and vulnerabilities, builds defenses against security threats and provides continuous proactive services to detect and prevent security breaches before they occur and/or reduces potential security threats. Turning Point Financials’ detailed policies and procedures are developed to meet the laws and regulations of a NIST CSF framework and Personal Identifiable Information (PII) requirements for the State of Maryland. In addition, security protocols identified through the scans and those targeted for development, will meet, or exceed minimum requirements from the SEC and FINRA data security guidelines. PROTECTED BUSINESS PROCESSES AND SYSTEMS INCLUDE:
• File Storage
• Email
• Mobile Devices
• Servers and Workstations
• Backups/Disaster Recovery Systems
• Network Systems Including Firewalls
• Remote Access
• Database Applications Including, Both Managed Internally as Well as Off- Premises at Cloud Data Centers Managed By 3rd Parties The Registered Investment Advisor requires ongoing training and testing for staff and advisors (both employees and independent contractors), data scans to uncover sensitive areas that are potentially compromised, protection of data flow in a live environment, and a structure to organize security and compliance as well as policies and procedures so that every team member and every department understands the protocols with regards to data security. Client Tailored Services and Client Imposed Restrictions Turning Point seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Turning Point’s economic, investment or other financial interests. To meet its fiduciary obligations, Turning Point attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Turning Point’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 Turning Point’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients. Since different types of investments typically involve different types of risk, Turning Point conducts a risk analysis for the client and his/her overall portfolio before recommending a certain investment solution. As an investment advisor that offers financial planning services, if a conflict exists between the interests of the investment advisor and the interests of the client, they are under no obligation to act upon Turning Point's recommendations, and should a client choose to act on any of the recommendations made by Turning Point, the client is under no obligation to effect transactions through Turning Point unless a separate asset management agreement is executed. Portfolio management services include, but are not limited to, the following:
• Investment Strategy • Investment Policy
• Asset Allocation • Asset Selection
• Risk Tolerance • Regular Portfolio Monitoring Turning Point will tailor an investment program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Turning Point on behalf of the client. Turning Point may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients in certain programs may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Turning Point from properly servicing the client account, or if the restrictions would require Turning Point to deviate from its standard suite of services, Turning Point reserves the right to refuse to impose such restrictions or end the relationship. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Turning Point does not participate in wrap fee programs. Assets Under Management Turning Point has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 310,006,374 $0 December 2023