Advisory Firm Description Ballast Advisors has been registered as an investment adviser since January 2017. Listed below are the Firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). - Parnell & Associates, Inc. - Gerczak & Associates, LLC - S. Schmidt & Associates, LLC As of December 31, 2022, Ballast Advisors has $473,462,064 in assets under management. - $455,182,233 of which was managed on a discretionary basis - $18,279,831 of which was managed on a non-discretionary basis While this brochure generally describes the business of Ballast Advisors, 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 Ballast Advisors’ behalf and is subject to the Firm’s supervision or control. A copy of Ballast Advisors’ written Brochure as set forth on Part 2 of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of a written Advisory Agreement. P a g e 5 | 35 Types of Advisory Services Ballast Advisors offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Ballast Advisors rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Ballast Advisors setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Within the scope of our financial advisory and consulting services offered, clients may choose to engage in the following areas:
• Financial planning for Individuals and Businesses
• Cash flow management
• Trust and estate planning
• Financial reporting
• Investment consulting
• Insurance planning
• Retirement planning
• Risk management
• Charitable giving
• Distribution planning
• Tax planning and preparation
• Manager due diligence While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement, as described below. In performing these services, Ballast Advisors is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Ballast Advisors may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Ballast Advisors or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Ballast Advisors under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for P a g e 6 | 35 the purpose of reviewing, evaluating or revising Ballast Advisors’ recommendations and/or services. Some of the services described above are provided by a third party engaged by the Firm. Specifically, if not provided by the Firm, tax services are provided by a Third Party engaged by Ballast Advisors, or an affiliate of Ballast Advisors, Ballast Tax & Business Services, LLC, or other third party. Investment Advisory and Wealth Management Services Ballast Advisors manages client investment portfolios on a discretionary or non-discretionary basis. In addition, Ballast Advisors may provide clients with “wealth management services” which includes a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. Ballast Advisors primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage Ballast Advisors to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Ballast Advisors directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally

maintained at the underwriting insurance company or the custodian designated by the product’s provider. Use of Independent Managers As mentioned above, Ballast Advisors may select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Ballast Advisors evaluates a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the P a g e 7 | 35 Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Ballast Advisors also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Ballast Advisors continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Ballast Advisors seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Retirement Plan Consulting Services The Firm provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Executive Planning and Benefits
• Plan Review and Evaluation
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Ballast Advisors as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Ballast Advisors’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. The Firm also provides discretionary investment management services to certain retirement plans. P a g e 8 | 35 Retirement Plan Rollovers – No Obligation / Conflict of Interest A client or prospective client leaving an employer has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Ballast Advisors recommends that a client roll over their retirement plan assets into an account to be managed by Ballast Advisors, such a recommendation creates a conflict of interest if Ballast Advisors will earn new (or increases its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Ballast Advisors. Client Investment Objectives and Restrictions Ballast Advisors tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Ballast Advisors consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Ballast Advisors if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Ballast Advisors determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. In performing its services, Ballast Advisors 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. P a g e 9 | 35