Fielder offers a variety of advisory services, which include investment advisory, family office, and retirement plan services. Prior to Fielder rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Fielder setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Fielder is the successor entity of Fielder Management, Inc., which was formed in 2009. Frank C. Byrd III is the Managing Member, Chief Compliance Officer and 61.66% owner of Fielder. Stephen L. Korn is the Chief Investment Officer and 33.34% owner of Fielder. Nathan R. Frigge is Partner and 5% owner of Fielder. Fielder had $834,551,544 in assets under management, $790,263,139 of which is managed on a discretionary basis and $44,288,405 of which is managed on a non-discretionary basis (as of March 7, 2024). In addition, Fielder had $ $48,418,673 in assets under advisement (as of March 7, 2024). While this brochure generally describes the business of Fielder, 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 Fielder’s behalf and is subject to the Firm’s supervision or control. Investment Advisory Services Fielder manages client investment portfolios on a discretionary or non-discretionary basis. Fielder manages portfolios on a discretionary basis based upon the client’s objectives, risk tolerance, time horizon and other related factors. For discretionary accounts, Fielder typically constructs a strategic allocation of assets, primarily among individual equity and debt securities, mutual funds (including interval funds), exchange-traded funds (“ETFs”), variable annuity products and Independent Managers (as defined below). Fielder can invest in private placement securities, which can include debt, equity, and/or pooled investment vehicles for the clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, when consistent with the clients’ investment objectives. While Fielder does not currently employ the use of futures or options as a part of its strategy, it has the ability to do so should circumstances warrant their use in the future. Fielder can also provide advice about any other type of investment held in clients’ portfolios. Fielder can also render non-discretionary investment management services to clients. This can relate to assets held in clients’ individual employer-sponsored retirement plans, variable life/annuity products that they own, and/or 529 plans or other products which are not held by the clients’ primary custodians. In so doing, Fielder either directs or recommends the allocation of client assets among the various investment options that are available within the product. Client assets are maintained at the specific insurance company or custodian designated by the product’s provider. Fielder can also provide nondiscretionary advice about any other type of investments otherwise held by clients. Fielder also provides specialized investment management services on an individually-negotiated basis on behalf of certain clients. Fielder 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. Fielder 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 Fielder if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Fielder 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. Retirement Plan Rollover Recommendations When Fielder provides investment advice about a client’s retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to an IRA, or make a distribution from the retirement plan account, we acknowledge that Fielder is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. Fielder operates under a special rule that requires Fielder to act in a client’s best interest and not put Fielder’s interest ahead of a client’s. Under this special rule’s provisions, Fielder must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC, which requires that Fielder:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Fielder ahead of a client when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Fielder gives advice that is in the client’s best interest;
• Charge no more than is reasonable for the services of Fielder; and
• Give a client basic information about conflicts of interest. To the extent Fielder recommends a client roll over the client’s account from a current retirement plan account to an individual retirement account managed by Fielder, please know that Fielder and its investment adviser representatives have a conflict of interest. Fielder can earn increased investment advisory fees by recommending that a client roll over their account at the retirement plan to an IRA managed by Fielder. Fielder will earn fewer investment advisory fees if a client does not roll over the funds in the retirement plan to an IRA managed by Fielder. Thus, Fielder’s investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA. This is a conflict of interest because Fielder’s recommendation that a client open an IRA account to be managed by Fielder can be based on Fielder’s economic incentive and not based exclusively on whether or not moving the IRA to Fielder’s management program is in the client’s overall best interest. Fielder has taken steps to manage this conflict of interest. Fielder has adopted an impartial conduct standard whereby the investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Fielder receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Fielder and Fielder’s supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a client regarding a retirement plan account or IRA, Fielder investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Fielder or its affiliated personnel. Use of Independent Managers As mentioned above, Fielder selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under ©h 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 can also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Fielder evaluates a variety of information about Independent Managers, ©h ©es the Independent Managers’ public disclosure documents, materials supplied by the 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. Fielder also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Fielder 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. Fielder seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Family Office Services Fielder can provide clients with financial planning, investment advisory, reporting, and administration services under the firm’s Family Office Services, which address any or all of the following:
• Financial planning: o Guide proactive planning for client’s family (cash flow, tax, risk, estate, legacy, philanthropy, etc.) o Facilitating and coordinating client’s team of experts (such as attorney, CPA, insurance agent, etc.)
• Investment advisory: o Portfolio management and investment counseling o Sourcing, vetting, and facilitating public and private investments
• Reporting: o Consolidated reporting on client’s accounts and private funds (including performance, cash flows, attribution, and asset allocation)
• Administration: o Tracking, collecting, and facilitating delivery of K1’s and 1099’s to client’s tax professional o Facilitating wire transfers or ACH for bill payment, capital calls, charitable donations, etc. o Providing centralized, secure archiving and organization of clients’ important documents (wills, trusts, deeds, titles, etc.) Fielder’s recommendations are based upon each client’s individual objectives, time horizon, risk tolerance, and other related factors. In performing these services, Fielder is under no obligation to verify any information provided by the client or by the client’s other professionals (such as attorney or accountant). Fielder is expressly authorized to rely on such information. Fielder can recommend its own services as well as those of other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Fielder recommends its own services. The client is under no obligation to act upon any of the recommendations made by Fielder under a financial planning or consulting engagement, nor is the client obliged to engage the services of any recommended professional, including Fielder itself. The client is free to accept or reject any of Fielder’s recommendations and has complete discretion regarding the implementation of such recommendations. It is the client’s responsibility to promptly notify Fielder of any changes in their financial situation or financial objectives so that Fielder can review and revise its prior recommendations and/or current services. Retirement Plan Services Fielder offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Management Services Fielder provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. Fielder will provide the client with continuous and ongoing supervision over the designated retirement plan assets. Fielder will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the client. We also have the power and authority to carry out these decisions by giving instructions, on a client’s behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. Fielder will monitor the investment options of the Plan and add or remove investment options for the Plan. Fielder will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. When a client elects to utilize any of Fielder’s Fiduciary Management Services, then Fielder will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and Fielder hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe tend to reduce these risks for a particular client’s circumstances or for plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, Fielder cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. Fielder will disclose, to the extent required by ERISA Regulation Section 2550.408b-2©, to the client any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b- 2©(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2©(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2©(1)(iv) or (vi), we will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learned of such error or omission. Retirement Plan Participant Services We provide an additional service directly to participants of retirement plan accounts where Fielder has discretion and may leverage an Order Management System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Through an arrangement with Pontera Solutions Inc. (formerly known as “FeeX, Inc.”), an unaffiliated third-party, Fielder is able to gain access to clients’ accounts not held at one of our primary brokerage platforms using the Pontera Order Management System software, to facilitate discretionary investment management of and execute trade orders for retirement plan participant accounts such as 401k or 403b accounts). If clients choose to grant Pontera Solutions Inc. access to these accounts, Fielder can regularly review the investment options in the accounts, as well as monitor, rebalance, and trade them to implement investment strategies the same way we do for their other accounts under our management. Administrative Services Provided by Orion Advisor Services, LLC Fielder has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment adviser to Fielder clients. Clients will not incur additional fees with the firm’s use of Orion.