A. General Description of Advisory Firm The Burney Company (Adviser) is an SEC- registered investment advisor based in Reston, Virginia. The Burney Company provides comprehensive financial advisory and investment management services to clients to meet their financial needs and retirement goals. We offer a suite of services and tailored advice based upon the unique needs of each client. We seek to maximize long-term returns through proprietary fundamental/quantitative techniques and equity research tools. We are committed to acting as a fiduciary, and none of our advisors receive commissions or fees based on the sale of certain types of products. We offer our services on a fee basis, based on assets under management. The company was founded by Brig. General John C. Burney in 1974, who pioneered work in this area. We have advisors located throughout the country and are licensed to conduct business in every state. The principal owners of the company are Lowell Pratt, Bill Stewart, Martin Walsh, Alex Shen, Richard Bauchspies, Gil Green, and Tom Hunt. B. Investment Advisory Services The Burney Company offers discretionary investment advisory services and portfolio management mostly for individual investors but will also service the portfolios of small businesses, pension and profit- sharing plans, trusts, estates, and charitable organizations. If you participate in our discretionary portfolio management services, we require you to allow our firm to determine the specific securities and the number of shares of securities to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. The Burney Company does not exercise discretion with respect to asset allocation or offer asset allocation advice unless the client elects to engage Burney’s Wealth Management division for financial planning services. (Note: Wealth Management clients will be provided with our Wealth Management ADV Part 2A). Sub-Advisory Services to Registered Investment Advisors We offer sub-advisory services to unaffiliated third-party managers (the Primary Investment Adviser). As part of these services, we will manage assets delegated to our firm by the Primary Investment Adviser. While we are responsible for the overall management of the assets

delegated to our firm, we will not communicate investment recommendations or selections directly to the Primary Investment Adviser. C. Availability of Tailored Services for Clients While equities provide the greatest long-term return opportunity, non-equity allocations are used to create income, provide stability, and enhance portfolio diversity. Bonds, Preferred Stocks, Real Estate Investment Trusts (REITs), Master Limited Partnerships (MLPs), Managed Futures, private credits, and International Equities are the major diversifying assets. However, how much to allocate to each is much more than just a function of age. Temperament, investment experience, income requirements and an investor's actual time horizon (investing for themselves vs. their heirs) are integral. Burney does not exercise discretion with respect to asset allocation or offer asset allocation advice unless the client requests financial planning services through Burney Wealth Management but will execute other than all equity investment plans when directed to do so by a client. Clients who elect a 100% equity allocation will have Capital Appreciation and/or Total Return as their primary investment objective and demonstrate a risk tolerance sufficient to accept the volatility inherent in a portfolio limited to equity securities. Clients have the option to place limitations on which securities may be purchased for their accounts. For example, liquor or nuclear power companies may be prohibited. Some clients elect to have their portfolios managed as clones of the company’s master portfolio. In such cases, securities bought and sold mirror the transactions in the master portfolio. There is no discretion to vary from the master portfolio without client consent. Our Customized Portfolios, model portfolios, and the Burney Master Portfolio combine a strategic perspective on Size and Style with Burney's time-tested stock selection methodology. The Master Portfolio provides a classic value-oriented approach, while customized and model portfolios are more adaptive to each client's specific situation. D. Wrap Fee Programs The Burney Company is not involved in "wrap fee" arrangements. E. Managed Assets The Burney Company’s total discretionary assets under management are approximately $2.68 Billion as of December 31, 2023. Each Portfolio Manager manages his/her own accounts. There are no non- discretionary assets.