JT Stratford, LLC (“JT Stratford,” “us,” “we”, “our”) is a limited liability company organized under the laws of the State of Georgia on June 28, 2010, and wholly owned by D. Todd Ferguson. JT Stratford was first registered at the state level with Georgia on February 22, 2011. We transitioned to registration with the SEC on July 22, 2015. Currently, we are registered as an investment adviser with the SEC and notice filed with the appropriate states in which notice filings are required in order to provide the investment advisory products and services described within this document. Please note that certain states do not require us to notice file if we have five or fewer clients that reside in a particular state. Please note that our registration as an Investment Adviser does not imply any level of skill or training. As of December 31, 2023, we had regulatory assets under management on a discretionary basis of $644,802,257, non-discretionary basis of $48,812 and assets under advisement1 of $60,735,237, for a total asset under management is $705,586,307. We offer investment advisory services to individuals, pension and profit-sharing plans, charitable organizations, and corporations. This Disclosure Brochure provides you with information regarding our qualifications, business practices, and the nature of advisory services that should be considered before becoming our advisory client. Please contact Amanda S. Bruner, Chief Compliance Officer, if you have any questions about this Brochure. Individuals associated with us will provide our investment advisory services. These individuals are appropriately licensed and qualified to provide advisory services on our behalf. Such individuals are known as Investment Advisor Representatives (IARs). Below is a description of the investment advisory and financial planning services we offer. For more details on any product or service please reference the advisory agreement or speak with your JT Stratford IAR. Investment Advisory Services Our IARs provide continuous and regular investment advisory services on a discretionary or non-discretionary basis to you in connection with establishing and monitoring of your 1 Assets under advisement represent assets in which we provide consulting services and for which we have neither discretionary authority, the ability to arrange or effect the purchase or sale of recommendations provided to and accepted by the ultimate client, or the authority to hire or fire recommended third party managers without client consent. Inclusion of these assets will make our total assets number different from assets under management disclosed in Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management. investment objectives, risk tolerance, asset allocation goals and time horizon. In addition, our IARs may provide information and research about investment products and strategies, and review portfolio performance reports. You have the opportunity to place reasonable restrictions or constraints on the way your account is managed; however, such restrictions will impact the composition and performance of your portfolio. For these reasons, the performance of the portfolio may not be identical with our average client. We offer investment advisory services through “Advisor Managed Fee Based Accounts”. We primarily use Schwab to custody client assets. Services provided may be available from other providers for lesser fees. In addition, you may buy securities (e.g., mutual funds, exchange-traded funds, etc.) outside of certain programs without incurring the technology fee identified under Item 5. Fee-Based Advisor Managed Accounts We have the ability to offer certain investment advisory services that we believe allow IARs to effectively meet your investment needs and preferences. Based on consultations with you, the IAR determines your investment goals and risk tolerance. The Advisory- Managed accounts give IARs the ability to customize asset allocation, investment selection, and investment strategies to meet your individual financial situation and investment objectives. Several factors may influence the IARs’ selection of your account structure including but not limited to 1) account size, 2) anticipated trading frequency, 3) anticipated securities to be traded, and/or 4) management style. In each account structure, the IAR may manage and provide advice on securities, including but not limited to, mutual funds, stocks, bonds, exchange traded funds (ETFs), limited partnerships (LPs), and options. Furnishes Advice to Clients on Matters Not Involving Securities We offer financial plans encompassing, but not limited to, the following: - Personal Financial Planning; - Insurance and Estate Planning; - Capital Need Analysis; - Tax & Cash Flow; - Retirement Planning; - Investment Analysis and Planning; - Education Planning; - Business Planning; and - Performance Reports Financial planning information will be obtained through personal interviews concerning your current financial status, future goals, and attitudes towards risk. Related documents that you supplied are carefully reviewed, along with data gathered from you, and a written report is issued. Employer Retirement Plan Services Employer Retirement Plan Services consists of reviewing the Plan’s investment options; recommending a portfolio structure;

recommending appropriate changes in portfolio holdings (investment options) consistent with the Plan Sponsor Company 401(k) Plan’s (“Plan”), pursuant to Section 401(a) of the Internal Revenue Code of 1986, Investment Policy Statement (“Investment Policy”); and advising the Plan Sponsor in support of the Plan Sponsor’s fiduciary role under the Plan. However, in a non-fiduciary capacity, our role will be limited to acting as the asset manager/advisor to the Plan. We will also provide to the Plan Sponsor guidance and investment weightings for asset allocation portfolios (“Portfolios’) offered under the Plan. Initially, we will establish Portfolios each with a different investment horizon and risk and reward criteria; additional Portfolios may be established at a later date. We will construct and monitor the Portfolios consistent with the policies and criteria set forth in the Investment Policy. Our services shall primarily include: a. Portfolio review and performance analysis; b. Fund weightings for each asset allocation model; c. Managed models for employees electing to give JT Stratford discretionary authority. d. Periodic discussion of changes in the weightings from previous asset allocations; e. Review of timing of asset allocation model rebalancing; f. Review of each mutual fund's historical returns; g. Anticipated returns for each asset class that is represented by a mutual fund; and h. Such additional services as the parties may agree to from time to time. The Plan Sponsor will appoint an independent corporate trustee or custodian (the “Custodian”) to take and maintain possession of all of the assets in the Plan. Neither we nor any of our “affiliates” will act as Custodian. Sub-Advisory Arrangements We have independently entered into sub-advisory agreements with unaffiliated registered investment advisors (“sub-advisor”) whereby the sub-advisor will manage certain designated assets in client portfolios (each a “Designated Portfolio” and collectively, the “Designated Portfolios”). Depending on the sub-adviser, we will either engage them directly or you will be required to enter into a separate agreement with the sub-advisor that defines the terms in which the sub-advisor will provide its services. Any recommendations made by the sub-advisor shall be made on a discretionary or non- discretionary basis subject only to the investment objectives and restrictions we imposed by written notice to the sub-advisor. Prior to engaging the services of the sub-advisor, we will consult with you and determine your financial situation and individual needs, including, without limitation, your investment objectives, and restrictions. In addition, we will perform initial and ongoing oversight and due diligence with each sub-advisor to ensure the strategy remains aligned with your investment objectives and overall best interest. It is, however, your obligation to notify either us or the sub-advisor (depending on who the sub- advisor is engaged) in writing of any changes in your financial situation. A complete description of the sub-advisor’s services and compensation relating to this arrangement will be disclosed in the sub-advisor’s Form ADV Part 2 and/or the advisory agreement, which will be provided to you at the time an agreement for services is executed and an account is established. We serve as your primary advisor and relationship manager. Your IAR will be available to answer questions you may have regarding the portion of your account managed by the sub-advisor and will act as the communication conduit between you and the sub-advisor. The sub-advisor may take discretionary authority to determine the securities to be purchased and sold for your account. However, we will direct the sub-advisor of the custodian in which to effect all transactions. IRA Rollover Recommendations For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to you. 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 an exemption that requires us to act in your best interest and not put our interest ahead of yours. Under this exemption, 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Wrap Fee Program We do not intend to offer wrap fee service at this time.