Iron Horse Wealth Management, LLC (“Iron Horse”), established in 2012, provides investment management services on a fee-only basis. Iron Horse’s managing member, Dennis Markway, has been active in the industry since 1995. Iron Horse offers financial planning and personalized investment management services to individuals, retirement and profit-sharing plans, trusts, estates, charitable organizations, and corporations. Iron Horse Wealth is a fiduciary and is required to act in a client’s best interest at all times. Financial planning and investment management services are tailored to meet the needs of each client based upon the client’s financial goals, investible assets, tax situation, existing holdings, and preferences. Clients may impose restrictions on investing in certain types of securities as appropriate for their situation. Financial Planning Financial planning services include preparing a plan that includes: cash flow management, education planning, retirement planning, investment planning, risk management and insurance planning, tax planning, estate planning and business succession planning (for business owners). Investment Management The investment management services involve creating an investment portfolio that is tailored to meet the needs and investment/risk objectives of the client. Subject to any written guidelines, which the client may provide, Iron Horse is granted full discretion and authority to manage the account. Accordingly, Iron Horse is authorized to perform various functions, at the client's expense, without further approval from the client. Such functions include the determination of securities to be purchased/sold, as well as the amount of securities to be purchased/sold. Once the portfolio is constructed, Iron Horse provides continuous supervision and rebalances the portfolio as changes in market conditions and client circumstances may require. It is the client's responsibility to notify Iron Horse of any change in financial status or personal data as it occurs. The Adviser uses a third-party platform to facilitate management of held away assets, which are primarily 401(k) accounts, HSAs, and other assets. The platform allows Adviser to avoid being considered to have custody of client funds since Adviser does not have direct access to client log-in credentials. Adviser is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing

them to connect an account(s) to the platform. Once client account(s) is connected to the platform, Adviser regularly reviews the available investment options in these accounts, monitor them, and rebalance and implement Adviser’s strategies. Consulting Services Iron Horse offers consulting related services that may include, but are not limited to, portfolio reviews, investment analysis, and/or asset allocation modeling. Fees associated with such services are based on Iron Horse's hourly rate of $125. Iron Horse 5 of 26 may also perform the contracted services for an agreed upon fixed fee or retainer basis, which is based on an estimate of the number of hours required to complete the contracted services. Under no circumstances will Iron Horse require prepayment of a fee more than six months in advance and in excess of $1,200. Types of Investments Iron Horse typically provides investment advice on mutual fund shares, insurance products (including variable annuities and life insurance) and ETFs (exchange-traded funds). Iron Horse may also provide investment advice on exchange-listed securities, securities traded over-the-counter, foreign issues, certificates of deposit, securities option contracts, REITs (real estate investment trusts), oil and gas interests, and any type of investment held in a client’s portfolio at the inception of the advisory relationship. This may not be an all-inclusive list. General Information All Asset Management Services may be provided on a discretionary or nondiscretionary basis by Iron Horse. Discretion means the trading activity within the Client’s account(s) may be entered by Iron Horse without receiving prior authorization for each trade. This discretion is authorized by the Client in writing (upon signing the specific Investment Management Agreement) and may be revoked at any time by submitting a written request to Iron Horse. Iron Horse has $279,802,956 as discretionary assets under management and $146,487,192 as nondiscretionary assets under management for a total of $426,290,148 of assets under management as of December 31, 2023. Assets are managed on a discretionary basis unless the client prefers otherwise and Iron Horse agrees on a non-discretionary arrangement. The Client will receive confirmations and statements showing all trading activity in the account(s). Iron Horse does not participate in a wrap program.