The Harvest Group Wrap Fee Program (the “Program”) is an investment advisory program sponsored by The Harvest Group. In addition to the Program, The Harvest Group offers a variety of advisory services which include financial planning, investment management and wealth management services. In dealing with clients, the Firm seeks first to evaluate a client’s current, holistic financial situation prior to managing their investments. The Harvest Group then designs and implements an investment plan aimed at achieving a client’s financial objectives. Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with The Harvest Group setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). The Harvest Group was formed in 2016 and is wholly owned by Laurie Ingwersen and Roger Ingwersen. As of December 31, 2022, The Harvest Group managed $185,812,424 of assets on a discretionary basis. While this brochure generally describes the business of The Harvest Group, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on The Harvest Group’s behalf and is subject to the Firm’s supervision or control. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Schwab Advisor ServicesTM (“Schwab”) or another broker-dealer that The Harvest Group approves under the Program (collectively “Financial Institutions”). Wrap Program-Conflict of Interest. The Harvest Group provides services on a wrap fee basis as a wrap program sponsor. Under The Harvest Group’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in The Harvest Group’s Wrap Fee Program Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by The Harvest Group to the account custodian/broker- dealer, The Harvest Group could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. The Harvest Group’s Chief Compliance Officer, Roberta Ambrosi, remains available to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding conflict of interest. Fees for Participation in the Program The Program is offered on a fee basis. The Harvest Group generally offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee generally varies between 100 and 150 basis points (1.00% – 1.50%), in accordance with the following fee schedule: PORTFOLIO VALUE BASE FEE Up to $4,999,999 1.50% $5,000,000 - $9,999,999 1.25% $10,000,000 and above 1.00% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets in the account as of the last day of the previous quarter. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, etc.), The Harvest Group may negotiate a fee rate that differs from the range set forth above. Beginning in 4th quarter of 2020, the account custodian, Schwab, stopped charging transaction fees for individual equities (including ETFs). As the result of Schwab’s decision, total transaction fees paid by The Harvest Group under the Firm’s wrap program decreased. The Harvest Group did not alter its advisory fee schedule as result of this change. Fee Dispersion The Harvest Group, in its discretion, may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. ANY QUESTIONS: The Harvest Group’s Chief Compliance Officer, Roberta Ambrosi, remains available to address any questions that a client or prospective client may have regarding advisory fees. Fee Discretion The Harvest Group, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. Fee Comparison As referenced above, a portion of the fees paid to The Harvest Group are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. As the Firm absorbs certain transaction costs for client accounts within the Program, the Firm has an incentive not to place transaction orders in those accounts or to use securities that do not incur transaction fees, such as no-transaction fee mutual funds and exchange-traded funds and individual equity securities. We mitigate this conflict of interest by disclosing it to clients. Services provided through the Program may cost clients more or less than purchasing these services separately. The number

of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Also, the Program fee charged by the Firm for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Other Charges In addition to the advisory fees paid to The Harvest Group, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges may include mark-ups and mark-downs on brokerage transactions for fixed-income transactions, fees charged by the Independent Managers (as defined below), reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees for trades executed away from Schwab, fees and commission for assets not held with Schwab (such as 401(k) or 529 plan assets), regulatory fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees. As mentioned below, the Firm may recommend clients allocate a portion of their assets to Independent Managers. In addition to the investment management fees charged by those Independent Managers, clients will typically be responsible for paying brokerage commissions and/or transaction charges resulting from securities transactions effected by such Independent Managers. Direct Fee Debit Clients generally provide The Harvest Group and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to The Harvest Group. Alternatively, the Firm may allow certain clients to elect to have the Firm send a separate invoice for direct payment. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to The Harvest Group’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients may withdraw account assets on notice to The Harvest Group, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Where appropriate, The Harvest Group consults with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Commissions and Sales Charges for Recommendations of Securities Clients can engage certain persons associated with The Harvest Group (but not the Firm directly) to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with The Harvest Group. Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), provide securities brokerage services and implement securities transactions under a separate commission based arrangement. Supervised Persons are entitled to a portion of the brokerage commissions paid to PKS, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. Where appropriate, The Harvest Group also recommends no-load or load-waived funds, where no sales charges are assessed. Prior to effecting any transactions, clients are required to enter into a separate account agreement with PKS. A conflict of interest exists to the extent that The Harvest Group recommends the purchase or sale of securities where its Supervised Persons receive commissions or other additional compensation as a result of the Firm’s recommendation. The Firm has procedures in place to ensure that any recommendations made by such Supervised Persons are in the best interest of clients. For certain accounts covered by the Employee Retirement Income Security Act of 1974 (“ERISA”) and such others that The Harvest Group, in its sole discretion, deems appropriate, The Harvest Group provides its investment advisory services on a fee-offset basis. In this scenario, The Harvest Group may offset its fees by an amount equal to the aggregate commissions and 12b-1 fees earned by the Firm’s Supervised Persons in their individual capacities as registered representatives of PKS. Termination of Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. Investment Performance: As a condition to participating in the Program, the participant must accept that past performance may not be indicative of future results, and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by the Firm) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). Client Responsibilities: In performing any of its services, the Firm shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Furthermore, unless the client indicates to the contrary, the Firm shall assume that there are no restrictions on its services, other than to manage the account in accordance with the client’s designated investment objective. Moreover, it remains each client’s responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Firm’s previous recommendations and/or services. Compensation for Recommending the Program The Harvest Group has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation because of clients’ participation.