Advisory Business and Ownership 3D/L Capital Management, LLC (“3D/L”) is registered with the Securities and Exchange Commission (“SEC”) as a registered investment advisor. On June 15, 2022, 3D/L was acquired by Freedom Advisors Group LLC (“Freedom”). This resulted in a change of control. Freedom also owns EQIS Capital Management, Inc. 3D/L provides a full suite of institutional and retail products and services, ranging from investment portfolios to a state-of-the-art Turnkey Asset Management Platform (TAMP) with service for RIAs and financial advisors to ERISA retirement plan investment management services. As of December 31, 2022, 3D/L managed approximately $574,113,231 in discretionary regulatory assets under management and provided advisory services to an additional $139,340,898 in participant-directed defined contribution plans, third-party platforms, and consulting arrangements. Types of Services Offered 3D/L provides discretionary investment advisory services to separately managed accounts and pooled investment vehicles and through sub-advisory relationships. 3D/L provides non-discretionary investment advisory services to registered investment advisers, corporations, institutions, individuals and other legal entities. 3D/L also offers administrative services to other financial intermediaries. This suite of services is branded as the “3D/L Managed Account Program” or “3D/L MAP.” The services include but are not limited to: custodial account set up; asset transfer; account administration; client and advisor reporting; trading for 3D/L-managed strategies as well as those provided by sub-advisors and model providers; customer billing; Promoter billing and payment; client and advisor online portal administration; sales & marketing support; and other back and middle office services. Investment advisory services include advice with respect to a broad range of U.S. and non-U.S. securities, no- load mutual funds and/or exchange traded funds or exchange traded notes (herein after collectively, "ETFs"), certificates of deposits, bonds, interval funds, group annuity accounts providing a stable value solution to IRA owners and other assets, as discussed below, as well as model portfolios which are based on the client’s investment objectives. 3D/L will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The Adviser will use model portfolios if the models match the client's investment policy. 3D/L manages portfolios designed by its investment team and also manages portfolios designed by the investment teams within other model-providers or sub-advisors contracted to provide those model portfolios. 3D/L offers its services directly to institutions and through properly registered financial service intermediaries. These services are also be offered on a sub-advisory or model-provider basis by 3D/L, as is the case with Envestnet™ and several intermediary-specific managed account platforms. Additionally, 3D/L offers its portfolio modeling and other services to retirement plan sponsors through several custodians and on several retirement plan platforms including, but not limited to: Vestwell, Empower, Ascensus; MidAtlantic Trust’s ModelxChange; Professional Capital Services (PCS); and others. INVESTMENT MANAGEMENT SERVICES Discretionary investment advisory services are provided to clients in accordance with the terms and restrictions of such client’s investment advisory agreement, investment management agreement, partnership agreement, and agreements and documents governing investment products in which clients are invested (collectively, the “Governing Documents”). These investment advisory services include advice with respect to a broad range of U.S. and non-U.S. securities and instruments and other assets, as discussed below, as well as model portfolios which are based on the client’s investment objectives. With respect to non-discretionary accounts, 3D/L provides model portfolios to registered advisors and other entities which are not customized to the circumstances of the end client. This also includes 3D/L’s due diligence and advisory services covering specialty investments such as interval funds and stable value contracts. Institutional Investment Advisory Business: We offer our services directly to defined benefit, municipal, Taft Hartley and other retirement plan clients in both a full-service investment advisory capacity and as an investment-only offering. The investment strategies employed to fill the needs of these institutional investors are typically designed specifically for that institution and can or cannot employ 3D/L’s model-based investment implementation methodology. 3D/L will meet with institutional clients on a periodic basis, as requested, and will also meet with client’s consultant or advisor if they utilize one. 3D/L also provides discretionary investment management services to institutional investors through a collective investment trust for ERISA and non-ERISA qualified retirement plans. Non-Discretionary Sub Advisory Services: 3D/L will provide non-discretionary sub-advisory services to other investment managers and advisors. These services are provided on a non-discretionary basis since the investment manager or advisor to whom these services are provided to, using an investment platform, may elect to use all or only part of the model portfolio or index structure provided by 3D/L. Additionally, 3D/L does not select the broker or time of execution for orders resulting from the provision of non-discretionary sub-advisory services. Advisory Services through Promoters and Referral Arrangement: Financial advisors who introduce customers to 3D/L in return for a portion of the fee charged by 3D/L under a Promoter agreement are referred to as “Promoters.” Promoters are independent contractors and are not employees of 3D/L. The solicitation services provided by the Promoters will include, but are not limited to: assisting the prospective client in understanding the services provided by 3D/L; assisting the prospective client in understanding the investment management strategy(ies) offered by 3D/L or a sub-advisor or model provider; assisting the client in determining the custodian that will be used for a particular account; assisting the prospective client in the suitability assessment process by helping prepare an investment policy statement (“IPS”); assisting the prospective client in the completion of all new account paperwork; introducing the prospective client to 3D/L; maintaining ongoing contact with the client so as to maintain current information regarding the client's financial situation and investment objectives; conveying any changes in the clients information, financial status, and/or financial objectives to 3D/L; communicating any concerns of the client to 3D/L; and, serving as the client’s primary liaison with 3D/L. Under a referral agreement, 3D/L will engage third parties to serve as co-fiduciary, marketing agent, promoter, and referral source for the purpose of introducing and referring prospective clients to 3D/L for investment advisory services. Upon signing an investment advisory agreement, 3D/L will provide solicited/referral clients ongoing discretionary investment management services. Referral Agreement Advisors also serve as co-fiduciaries. 3D/L will periodically revise the utilized investment products, adjust the strategic asset allocation, and/or rebalance the investment portfolio as deemed appropriate, within the parameters of the IPS and in accordance with any restrictions specified by the client. 3D/L will respond to inquiries directly from each client, however in most circumstances the soliciting/referring advisor will be the primary liaison between the client and 3D/L. Advisory Services Available Through a Separate Account Management Arrangement: 3D/L also acts as a Separate Account Manager on the Managed Account Marketplace Program sponsored by Charles Schwab & Company, Inc. (“Schwab MAM”) and the Separate Account Exchange (“SAE”) sponsored by TD Ameritrade. Under these arrangements, the client is a client of both the introducing advisor and 3D/L under a “Dual Contract” arrangement. 3D/L provides the introducing advisor sufficient information and documentation to evaluate 3D/L's services and recommend a particular strategy to his/her client. When 3D/L is contracted for management by the client/introducing advisor, 3D/L manages the account based on the terms of the contract and direction from the introducing advisor. 3D/L only bills the client account for 3D/L’s investment management fee and does not share any of its fees with the introducing advisor. Advisory Services Available Through a Direct Arrangement: 3D/L will take on clients through a direct arrangement where the client contracts with 3D/L directly (“Direct Arrangement”). 3D/L also has a small group of Investment Advisor Representatives (“IARs”) who exclusively use the investment management and administrative services of 3D/L and the sub-advisors and model managers available through 3D/L MAP. Direct clients and clients of these IAR's are provided with the same portfolio models and services as clients introduced under the separate account management arrangements. In certain circumstances, IARs have their own legal business entities whose trade names and logos are used for marketing purposes and can appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of 3D/L. The IARs are under the supervision of 3D/L, and the advisory services of the IAR are provided through 3D/L. 3D/L has the arrangement described above with the following advisory firms:  Sterling Group  Strada Wealth Advisors The above arrangements are part of 3D/L's retail investment management business. Under the Promoter, Referral and Direct arrangements, the client works with the soliciting/referring advisor or IAR to determine which portfolio or portfolio(s) is/are appropriate for their particular investment account. Based upon information supplied by the prospective client, the Promoter, referring advisor or IAR will produce an IPS using tools provided by 3D/L MAP, typically through an online application. The IPS will assist in defining the criteria and in outlining the appropriate investment guidelines upon which 3D/L will base investment account or model portfolio recommendations. Additionally, 3D/L will construct an asset allocation and make specific investment recommendations or use a portfolio model provided by a sub-advisor or model-provider, if selected, that are aligned with the client's Investment Policy Statement. Under the Separate Account Management arrangement, the introducing advisor selects the appropriate 3D/L model based on his/her knowledge of the client's objectives and risk tolerances. Their introducing advisor, as a fiduciary working on the client's behalf, is able to instruct 3D/L to change models on behalf of the client. For retail investment management client accounts, 3D/L will ensure that the following conditions are met and maintained: 1. 3D/L will manage each client's account on the basis of the parameters defined in the IPS and any reasonable investment restrictions the client may impose; 2. For Direct clients, 3D/L will obtain sufficient client information to be able to provide individualized investment advice to the client. For Schwab MAM Clients, TD SAE and Morgan Stanley, 3D/L will manage to the objectives specified by the client's Investment Advisor. At least annually, 3D/L, the client's Promoter or the client's IAR will contact the client to determine whether there have been any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. For Direct and Solicited clients, 3D/L will request on a quarterly basis that clients notify them in writing if there have been changes in the client's financial situation or investment objectives and/or if the client wishes to impose investment restrictions or modify existing restrictions; 3. Each client is able to impose reasonable investment restrictions on the management

of their account (See disclosure in Item 12 pertaining to the trading of accounts with restrictions); 4. Each client will receive custodial statements, at least quarterly, with a description of all account activity; and, 5. Each client will retain certain indicia of ownership of the securities and funds in the account, e.g., the ability to withdraw securities, vote proxies (at client’s discretion), among others. Platform Advisory Services (Sub-Advisory Services): 3D/L offers its investment strategy and portfolio modeling services through other investment advisors on a sub-advisory or model-provider basis. In these cases, the client contracts with the other advisor for investment management services and uses 3D/L's investment models, asset allocation strategies and buy/sell signals to manage the client accounts. As a sub-advisor or model-provider, 3D/L's role is limited to providing the investment manager with 3D/L's proprietary investment strategies, training on those strategies, any updates to the strategies and marketing and sales support to promote the use of the strategies by advisors using the investment managers suite of services. Such investment managers and service providers include Envestnet Asset Management, Inc. (“Envestnet”), LPL, Sowell among others. Additionally, Envestnet can offer 3D/L’s strategies to other brokerage firms and investment advisory firms via there private- labeled "Investment Manager Marketplace" services. 3D/L retains the right to approve, or decline being included on any additional platforms through Envestnet. Group Trust Advisory Services (Sub-Advisory Services): Reliance Trust Company (“Reliance Trust”) has selected and retained 3D/L to provide investment advisory services with respect to Series Four of the Group Trust designated as the “Reliance Trust Company Advisors Portfolios Programs Collective Investment Trust” (herein referred to as the “Collective Trust”) to be offered exclusively to plan sponsors of tax-qualified employee retirement plans held in employee benefit trust and agency accounts by Reliance Trust. 3D/L monitors and makes recommendations regarding the purchase and sales of securities within the 3D/L Global Portfolios Fund account managed by Reliance Trust. The Collective Trust is designed primarily for defined contribution plans, including 401(k), money purchase and traditional profit-sharing plans. Acting as a non-discretionary sub-advisor, 3D/L periodically makes recommendations for investment changes in the portfolios when such changes are deemed advisable. 3D/L proposes such specific investment recommendations to Reliance Trust; however, Reliance Trust makes the final decision as to the specific securities, funds or assets and mix that will comprise the Collective Trust. Clients should refer to the Collective Trust’s Offering Statement for further details and the terms of this investment product. Full Service Retirement Plan Services: 3D/L offers investment advisory services to defined contribution (“DC”) retirement plan sponsors. The firm provides two types of advisory services to DC plan sponsors as outlined below. ERISA Section 3(38) Investment Management Services: For Promoter Introduced Plans: For DC Plans introduced to 3D/L by Promoters, 3D/L coordinates the efforts of a record keeper, custodian and third-party administrator, if needed, (collectively “Service Providers”) and helps the Promoter introduce the various parties and roles to the plan sponsor client. 3D/L acts as an ERISA Section 3(38) fiduciary and selects the investment options for the plan, produces an IPS for the plan and assists the Service Providers with coordinating a plan conversion. On an ongoing basis, 3D/L manages the risk-based or target-date model portfolios within the plan and monitors the additional investment options (“Stand-alone”) selected for inclusion within the plan. The monitoring of the Stand-alone investments is managed in part through the use of the Fiduciary Investment Reporting Manager (FiRM) system which uses an investment screening and evaluation process developed especially for fiduciary retirement plan investors. The fee charged to the plan, or directly to the plan sponsor if requested, is typically billed quarterly, in arrears and is based on total assets within the plan. Part of the fee is paid to the Promoter based on the details specified in the Promoter Disclosure document approved and signed by the plan sponsor. For Adviser Introduced Plans: The same suite of services is provided to the plan sponsor as described in the preceding paragraph except that 3D/L does not share its fee with the introducing advisor. Under this scenario, the introducing advisor bills the plan or plan sponsor directly and typically acts as an ERISA Section 3(21) fiduciary. A sub-set of adviser-introduced plans are plans introduced by advisers affiliated with Cambridge Investment Research, Inc. (“CIR”) and administered by Cambridge Retirement Plan Services (“RPS”). 3D/L will act as 3(38) fiduciary on these plans, if contracted by the plan sponsor however, 3D/L’s model portfolios will be managed by CIR with 3D/L acting as sub-adviser to CIR. Fiduciary Investment Management for Open Architecture Tax Exempt Employers 3D/L has been engaged by National Life Group (“NLG”) to provide fiduciary investment management services for retirement plan clients using NLG’s Balanced Opportunities Platform, a retirement platform for non-profits, government entities and other eligible employers using 403(b), 457 and certain other tax advantaged retirement plans. 3D/L reviews the mutual fund options available on the Platform and maintains a recommended list of no- load mutual funds that are offered to plan sponsors if the plan sponsor chooses to use the fiduciary oversight feature available through the Balanced Opportunities Platform. The fee for this service is charged at the plan level. 3D/L also structures globally diversified balanced portfolios using the mutual funds available through the platform. These model portfolios are offered as investment choices to plan participants if the plan sponsor chooses this service from the Balanced Opportunities Platform. The fee for this service is charged at the account holder or participant level and is only charged to those who use the service. Defined Contribution Investment Only (“DCIO”): DCIO Managed Models: These services include 3D/L’s construction and management of portfolio models that are then made available to retirement plans either through the management of the model portfolios in a retirement plan record keeping system or through a unitization system such as Mid Atlantic Trust’s ModelXchange™ system. In both cases 3D/L acts as a 3(38) fiduciary for the management of the model portfolios only. 3D/L is paid a fee only on the assets within the model portfolios. The model portfolios may be risk-based, target-date or both. 3D/L has partnered with Newfound Research, LLC (“Newfound”) to provide the 3D/L-Newfound PrudentPath™ Target Date Portfolio Series. This suite of target-date portfolios utilizes ETFs for defined contribution plan sponsors. 3D/L will advise the Target Date Portfolio Series and Newfound will sub-advise and provide tactical integration to 3D/L’s aggressive target date series. As mentioned above, 3D/L provides services through advisers affiliated with CIR. 3D/L will offer portfolio models through CIR and RPS on an investment-only basis as well. In this case 3D/L will act as sub-advisor to CIR who will act as investment manager for the portfolio models. DCIO through Collective Investment Trusts (“CIT’s”): 3D/L’s risk-based models are also available to retirement plan sponsors through the use of CIT’s sub-advised by 3D/L and managed and distributed by Reliance Trust. These CITs are priced daily, trade in full and fractional shares and are available to retirement plans whose service providers trade and settle through NSCC. In all cases above, except with the CIT’s, written agreements are executed between 3D/L and plan sponsors for the above services which spell out the level of service provided by 3D/L. 3D/L's investment advisory services are provided to the plan sponsor only and not to individual plan participants. Financial Planning Services: 3D/L also offers financial planning services through its IARs, primarily to individuals. Financial planning typically involves providing a variety of analyses based on a multiple step process regarding the management of financial resources designed to meet an individual client’s financial needs and goals. Each financial plan is tailored to the circumstances of the client based on information obtained from the client. The IAR will typically meet with the client to identify and prioritize goals and future needs, and gather information necessary to perform analyses, conduct evaluation, and formulate recommendations. The information gathered would normally cover income, expenses, current and anticipated assets and liabilities; including, but not limited to, savings, investments, retirement and employee benefits, current expenses, planned expenses, and debt. Based upon the IAR’s analyses and evaluation, a written financial plan will be developed using approved financial planning software, currently eMoney Advisor®, Orion Planning and Income Conductor® that proposes recommendations for a general course of action and/or specific steps to be taken by the client. These recommendations are designed to help the client attain the goals established, however, the written financial plan will not contain recommendations with respect to the advisability of purchasing any specific investment, insurance contract or other property. 3D/L offers the following Financial Planning Services:  Investment Planning – analyzing the current cash flow, risk tolerance, time horizon and goals of a Client in an effort to design asset allocation strategies that will optimize portfolio composition to achieve objectives.  Education Planning – estimating education costs and explaining strategies that will help fund the education of children, grandchildren, or others. This could involve information pertaining to the post- secondary financial aid process.  Retirement Planning – estimating retirement income and expenses and applying strategies focused on both the accumulation of assets and the distribution of such during retirement to identify the adequacy of funding.  Budget/Cash Flow Planning – compiling information of assets, debt, current inflows and outflows and analyzing it to determine how the cash flows will affect goals and objectives. A client can engage 3D/L to perform one or more of the planning services described above. The analyses and recommendations provided through these planning services are based upon the information provided by the client and their advisors, economic and tax considerations, and the Financial Planner’s judgment. The Financial Planner is prohibited from providing legal or tax advice, and 3D/L strongly encourages their clients to work with their legal and tax advisors prior to implementing any recommendations listed in the written financial plan. The delivery of the written financial plan and the execution of the acknowledgement letter by the client signify the end of the Financial Planning Services engagement and 3D/L has no responsibility to keep the plan current. The client is under no obligation to purchase any investment or insurance product from the 3D/L in connection with the delivery of the written financial plan. If a client reengages 3D/L to update or revise a previously delivered written financial plan, it will be deemed a new advisory relationship, and the client will be required to execute a new Financial Planning Services Agreement and may incur additional Financial Planning Service fees. The client can choose to implement the recommendations of the written financial plan with an investment professional of their choice. 3D/L does not offer legal advice or tax advice. Wrap Fee Programs We offer a wrap fee program as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed similarly and are offered separately to provide financial advisors a choice of pricing structures. Please refer to our Wrap Fee Program Brochure for a full description of these services.