4 | P a g e OVERVIEW Dempsey Lord Smith, LLC is an investment adviser registered with the Securities and Exchange Commission with its principal place of business in Rome, Georgia. DLS began conducting business in 2007. DLS is owned by the following individuals: Jerry Eskel Dempsey, Jr. (CEO); John Hayward Lord (CCO); Ernest Liddell Smith (Vice President, Sales & Marketing); and Duvan Ledbetter Brock (Vice President, Recruiting and Sales). Jerry Eskel Dempsey owns 28% of the firm while the remaining individuals each have a 24% ownership interest in DLS. As of March 31, 2024, DLS managed $585,613,076 of Client’s assets, all of which are managed on a discretionary basis. The following paragraphs provides details of the different programs and services offered to Clients. PORTFOLIO MANAGEMENT DLS provides portfolio management services on a discretionary basis and non-discretionary basis. DLS will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. As appropriate, we also review and discuss a Client’s investment history, family composition, and background. The information may be collected by DLS through questionnaires, account forms completed by the Client, or through communication with the Client. DLS will utilize information obtained from the Client to tailor the Client’s portfolio to the needs of the Client. The Client may impose reasonable restrictions or guidelines on the management of the Client's assets, including limitations on the purchase or sale of securities, types of securities, or industry sectors. Assets managed by DLS may be invested in a wide variety of securities, including but not limited to mutual funds, equities, bonds, exchange traded funds, and other security types. Managing assets on a discretionary basis allows DLS to purchase, sell, invest, reinvest, exchange, and trade the assets in the account(s) of the Client, subject to any restrictions imposed by the Client. This means DLS will have the authority to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions without first seeking approval of the transaction by the Client. For non- discretionary portfolio management, all portfolio decisions require prior approval by the Client. DLS requires all accounts of Clients receiving this service to be maintained through our firm, a broker-dealer registered with the Securities & Exchange Commission (“SEC”), Financial Industry Regulatory Authority (“FINRA”), and applicable states, and other qualified custodians. Accounts maintained through DLS are introduced to and custodied by National Financial Services (“NFS”), who holds Client assets as well as executes and settles transactions. Clients will receive account statements from the custodian no less than quarterly concerning all transactions, balances and portfolio holdings within their account. 5 | P a g e MODEL PORTFOLIO MANAGEMENT PROGRAM DLS provides portfolio management services on a discretionary basis and non-discretionary basis using one or more asset allocation model portfolios professionally managed by DLS. DLS offers a Growth and Income Portfolio, an Income Portfolio, and an ETF/Mutual Fund Portfolio. Growth & Income Portfolio The Growth & Income Portfolio seeks to grow the principal value of the investment portfolio and generate income with a moderate risk profile. The portfolio may use different types of securities, including but not limited to stocks, bonds, mutual funds, real estate investment trusts, exchange-traded funds, etc. Income Portfolio The Income Portfolio seeks to generate income with a moderate risk profile. The portfolio may use different types of securities, including but not limited to stocks, bonds, mutual funds, real estate investment trusts, exchange-traded funds, etc. ETF/Mutual Fund Portfolio The ETF/Mutual Fund Model seeks to grow the principal value of the investment portfolio, and generate income with a moderate risk profile. The portfolio will use mutual funds, and exchange traded funds to diversify the portfolio's investments. DLS will obtain pertinent information concerning the Client such as financial condition, investment objectives, and tax status. The information may be collected by DLS through questionnaires, account forms completed by the Client, or through communication with the Client. Based on this information, DLS determines if a model portfolio is appropriate for the Client. The portfolio is managed based on the portfolio's goal, rather than on each Client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Managing assets on a discretionary basis allows DLS to purchase, sell, invest, reinvest, exchange, and trade the assets in the account(s) of the Client, subject to any restrictions imposed by the Client. This means DLS will have the authority to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions without first seeking approval of the transaction by the Client. For non- discretionary portfolio management, all portfolio decisions require prior approval by the Client. DLS requires all accounts of Clients receiving this service to be maintained through our firm. Accounts maintained through DLS are introduced to and custodied by National Financial Services (“NFS”), who holds Client assets as well as executes and settles transactions. Clients will receive account statements from the custodian no less than quarterly concerning all transactions, balances and portfolio holdings within their account. 6 | P a g e WEALTH MANAGEMENT PLATFORM – FIDELITY MANAGED ACCOUNT SOLUTIONS PROGRAM Overview DLS offers Clients the opportunity to receive professional portfolio management through third party asset managers as part of a wrap fee program. DLS is a participant in the Fidelity Managed Accounts Solution Program (“FMAX Program”) offered by National Financial Services, LLC. (“NFS”). NFS is a registered investment adviser that operates a technology platform to assist DLS in providing a variety of managed account offerings, recommending asset allocations or specific third party asset managers and/or investment products to our Clients. NFS is not affiliated with DLS. A complete description of the FMAX Program and the services provided by NFS are outlined in NFS’s ADV Part 2 Brochure which you should read carefully. DLS will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. As appropriate, we also review and discuss a Client’s investment history, family composition, and background. The information may be collected by DLS through questionnaires, account forms completed by the Client, or through communication with the Client. Upon obtaining sufficient information, DLS will provide the Client with an asset allocation strategy. DLS will then proceed with performing management searches of various third party asset managers. Based on the Client's individual circumstances and needs, DLS determines which third party asset manager’s portfolio management style is appropriate for that Client. Factors considered in making this determination include account size, risk tolerance, the opinion of each Client and the investment philosophy of the selected asset manager. Once a third party asset manager is selected, the third party asset manager will create and manage the Client's portfolio based on information supplied to the manager by DLS to tailor the portfolio to the Client. The Client may or may not be able to impose restrictions or guidelines on the management of the Client's assets, including limitations on the purchase or sale of securities, types of securities, or industry sectors. The type of securities that may be utilized by the third party asset manager may vary from manager to manager based on investment style, limitations on types of securities the manager utilizes, and overall philosophy of a third party asset manager. DLS monitors the performance of the third party asset manager(s). If we determine that a third party asset manager is not providing sufficient management services to the Client, or is not managing the Client's portfolio in a manner consistent with the Client’s information, then we may recommend the Client replace managers. Client meetings are available on a regular basis, or as determined by the Client, to review the account. At least annually, we meet with the Client to review and update, as necessary, the Client's information. However, should there be any material change in the Client's personal and/or financial situation, we should be notified immediately to determine whether any review and/or revision of the Client's strategy is warranted. Assets of the Client will be managed on a discretionary basis by the third party asset manager. Managing assets on a discretionary basis allows the manager to purchase, sell, invest, reinvest, exchange, and trade the assets in the account(s) of the Client, subject to any 7 | P a g e restrictions imposed by the Client. This means the manager will have the authority to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions without first seeking approval of the transaction by the Client. See the ADV Part 2 of NFS for complete details. Assets will be custodied at National Financial Services, LLC, or other qualified custodian. At a minimum, Clients will receive account statements from the custodian no less than quarterly concerning all transactions, balances and portfolio holdings within their account. The following paragraphs provide details on each option available under the Managed Account Solutions Program. Separately Managed Account DLS offers a Separately Managed Account Program through our relationship with NFS. This provides our Clients with access to more than 200 investment strategies available from over 75 portfolio managers selected by NFS through their due diligence and portfolio manager evaluation processes. The Separately Managed Account Program is designed to provide our Clients the ability to tailor an investment portfolio to their specific financial needs such as diversification or tax-conscious investing, along with affording Clients further customization of their portfolio by placing reasonable investment restrictions on the types of assets allowed within the account. Portfolio managers are recommended based on the Client’s investment objectives and other information provided. Manager changes would be recommended if DLS’s or NFS’s due diligence reviews indicate the portfolio manager is no longer suitable for a particular investment strategy or if a Client’s investment objectives change. The minimum account value for the Separately Managed Account Program is $100,000. Multi-Manager Account DLS offers a managed account option available through NFS where one or more Subadvisers are selected to manage the Client’s assets on a discretionary basis. This investment strategy delivers the benefits of a traditional separately managed account in a single diversified portfolio. NFS exercises investment discretion over the account and each account is initially structured based upon the Client’s risk tolerance and objectives.

The minimum account value for the Multi-Manager Account Program is $50,000. Wrap Strategists Mutual Fund & ETF Wrap Portfolio (“Wrap Strategists”) Wrap Strategists consists of independent professional third party money managers (i.e. “strategists”) who provide models of mutual funds and/or ETFs. The strategies include, but are not limited to the following: ICON Advisers, Inc. (mutual funds), Russell Investments (mutual funds), Fund Evaluation Group (managed portfolios), Standard & Poor’s Investment Advisory Services (MAP mutual fund portfolios), Standard & Poor’s Investment Advisory Services (MAP ETF Portfolios), Symmetry Partners (mutual fund portfolios), PMC ETF Solution, and PMC Tactical ETF (Core and Total Return portfolios). This program offers the Client professional money management, performance reporting, and associated service and support. The minimum investment in this program is typically $5,000 or more depending on strategist selected. 8 | P a g e Advisor Directed Unified Managed Account Through our relationship with NFS, DLS offers the Advisor-Directed Unified Managed Account (“UMA”) Program, which allows Clients access to multiple investment strategies through the use of Separate Account Managers (“SAMS”), mutual funds and/or ETFs to facilitate diversification within an individually managed account. The Advisor-Directed UMA features NFS as overlay portfolio manager, whose role includes managing the asset allocation of the account on a discretionary or non-discretionary basis and coordinating trading across investments. Each Advisor-Directed UMA is initially structured based upon the Client’s stated goals and objectives. The minimum account value for the Advisor Directed UMA Program is $50,000. PMC “SIGMA” and Select Mutual Fund Solution Program (“PMC”) PMC is a mutual fund wrap program consisting of portfolios sub-managed by Envestnet Asset Management, Inc. (Envestnet). This program offers the Client professionally managed portfolios of mutual funds to meet the financial goals and objectives of the Client. Envestnet will use both proprietary PMC mutual funds, and when deemed appropriate, non-proprietary mutual funds to construct the mutual fund portfolios. The minimum investment in this program is $25,000. Strategic Adviser Portfolios Program (“SAP”) SAP is a mutual fund wrap program consisting of portfolios sub-managed by Strategic Advisers, Inc., a wholly-owned subsidiary of Fidelity Investments. This program offers the Client professionally managed portfolios of mutual funds to meet the financial goals and objectives of the Client. The minimum investment in this program is $50,000. WEALTH MANAGEMENT PLATFORM – DLS WRAP FEE PROGRAM Overview DLS offers Clients the opportunity to receive professional portfolio management through DLS as part of a wrap fee program. DLS will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. As appropriate, we also review and discuss a Client’s investment history, family composition, and background. The information may be collected by DLS through questionnaires, account forms completed by the Client, or through communication with the Client. Upon obtaining sufficient information, DLS will provide the Client with an asset allocation strategy. DLS will seek to tailor the Client’s portfolio to their individual needs. The Client may impose reasonable restrictions or guidelines on the management of the Client's assets, including limitations on the purchase or sale of securities, types of securities, or industry sectors. Assets managed by DLS may be invested in a wide variety of securities, including but not limited to mutual funds, equities, bonds, exchange traded funds, and other security types. The minimum investment in this program is $10,000. Assets of the Client may be managed on a discretionary basis or non-discretionary basis by the third party asset manager. Managing assets on a discretionary basis allows the manager to purchase, sell, invest, reinvest, exchange, and trade the assets in the account(s) of the Client, subject to any restrictions imposed by the Client. This means the manager will have 9 | P a g e the authority to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions without first seeking approval of the transaction by the Client. For non-discretionary portfolio management, all portfolio decisions require prior approval by the Client. In choosing a wrap fee program as opposed to another program managed by DLS, the sole difference is that all custodial, brokerage, and other non-product fees are included in the wrap fee as opposed to other programs. Portfolios are not managed any different. DLS receives a portion of the wrap program fee. Accounts of Clients receiving this service will be maintained through our firm, a broker-dealer registered with the Securities & Exchange Commission (“SEC”), Financial Industry Regulatory Authority (“FINRA”), and applicable states. Accounts maintained through DLS are introduced to and custodied by National Financial Services (“NFS”), who holds Client assets as well as executes and settles transactions. Clients will receive account statements from the custodian no less than quarterly concerning all transactions, balances and portfolio holdings within their account. ADVISOR REFERRAL PROGRAM The Advisory Referral Program is another program through which Clients can obtain professional portfolio management services through a third party asset manager. In this program, DLS has entered into separate agreements with third party asset managers for Clients to be able to utilize the services of third party asset manager. DLS will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. As appropriate, we also review and discuss a Client’s investment history, family composition, and background. The information may be collected by DLS through questionnaires, account forms completed by the Client, or through communication with the Client. Based on the Client's information, DLS determines which selected third party asset manager’s portfolio management style is appropriate for that Client. Factors considered in making this determination include account size, risk tolerance, the opinion of each Client and the investment philosophy of the selected third party asset manager. The third party asset manager may or may not tailor a portfolio to the needs of the Client. The Client may or may not be able to impose restrictions or guidelines on the management of the Client's assets, including limitations on the purchase or sale of securities, types of securities, or industry sectors. The type of securities that may be utilized by the third party asset manager may vary based on investment style, limitations on types of securities the manager utilizes, and overall philosophy of a third party asset manager. Assets of the Client may be managed on a discretionary or non-discretionary basis by the third party asset manager depending on their policies. Managing assets on a discretionary basis allows the manager to purchase, sell, invest, reinvest, exchange, and trade the assets in the account(s) of the Client, subject to any 10 | P a g e restrictions imposed by the Client. This means the manager will have the authority to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions without first seeking approval of the transaction by the Client. For nondiscretionary portfolio management, all portfolio decisions require prior approval by the Client. Clients should refer to the asset manager's Firm Brochure or other disclosure document for a full description of the services offered by the third party asset manager. Assets may be custodied at National Financial Services, LLC or through another broker- dealer custodian selected by the third party asset manager. On an ongoing basis, DLS monitors the performance of the third party asset manager(s). DLS will meet with the Client on a regular basis, or as determined by the Client, to review the account. We will, when needed, suggest changes in the Client's portfolio (''rebalancing''), to more effectively address each Client's goals. The Client may then instruct the third party asset manager to make any or all of the changes we recommended. These recommendations are our own, and are neither recommended nor approved by any third party asset manager. At a minimum, Clients will receive account statements from the custodian maintaining the Client’s assets no less than quarterly concerning all transactions, balances and portfolio holdings within their account. Complete details concerning a third party asset manager’s services can be found in their ADV Part 2 Brochure. FINANCIAL PLANNING & CONSULTING SERVICES DLS provides financial planning and consulting services. Financial planning services may include, but are not limited to, investment selection/asset allocation, portfolio reviews, periodic Client consultations, retirement planning, estate planning, education planning, cash flow/budget/income analysis, business retirement planning, employee benefits analysis, business succession planning, and/or insurance planning and analysis. The Client may select any or all of these services from DLS. DLS will rely on objectives and financial profile information provided by the Client to make recommendations on various types of investments, or insurance products to help Client achieve his/her financial objectives, as applicable. Further, DLS will utilize such information to provide guidance on steps and actions the Client can take to achieve other objectives. All financial planning services are tailored to the needs of the Client. Financial planning services provided are based on the professional judgement of DLS, and Client understands that DLS cannot guarantee that the Client's financial objectives can be met. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the Client. 11 | P a g e Should the Client choose to implement the recommendations contained in the plan, we suggest the Client work closely with his/her attorney, accountant, insurance agent, and/or financial advisor. Implementation of financial plan recommendations is entirely at the Client's discretion. The Client is under no obligation to use DLS for implementing recommendations. Upon mutual agreement, a written report may be provided to the Client concerning recommendations by DLS. The financial planning recommendations and any written financial plan issued by DLS will be presented to the Client within six months of the contract date, provided that all information needed to prepare the financial plan or make recommendations has been promptly provided by the Client. PENSION CONSULTING SERVICES DLS provides pension consulting services. Pension consulting services may include, but are not limited to, investment selection/asset allocation, portfolio reviews, periodic Client consultations, investment policy statement preparation, monitoring of investment performance, employee communications, and benefits analysis. The Client may select any or all of these services from DLS.