A. Description of the Advisory Firm B. Types of Advisory Services investments which may include stocks, bonds, mutual funds (stock funds, bond funds and other asset classes), options, warrants, real estate investment trusts (“REITs”), exchange-traded funds (“ETFs”), alternative investments, and other securities chosen by ACAS. For some clients, it may be determined that an investment portfolio consisting primarily or exclusively of mutual funds is appropriate. In these situations, ACAS may recommend a portfolio allocated among no-load or load- waived mutual funds taking into consideration the goals and objectives of the client and the overall management style of the funds. 3. Financial Planning and Consulting ACAS also provides financial planning services and consulting to clients. Financial planning and consulting services are offered on a comprehensive or a-la-carte (limited focus) basis. Financial plans and consulting may encompass all or some of the following areas of financial concern to the client: Estate Planning Goals Retirement Planning Education Planning Insurance Planning/Risk Management Investments Asset Allocation Review and Recommendations Cash management & certain treasury services Debt Management and Planning Relevant information will be obtained through personal interviews (including a discussion of current financial status, future goals and attitude towards risk) and the review of related documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. However, in general, only products and services that ACAS is able to provide will be offered. Clients should be aware that this practice may create a conflict of interest as ACAS may have an incentive to recommend products and services based on the fees that ACAS may generate, rather than the interests of the client. ACAS furnishes investment advice through investment consulting. The Advisor will collect financial and pertinent information from the Client in order to identify objectives and goals for t h e engagement. The Advisor will use information provided by the Client to identify a recommended strategy. The Advisor will generally consult, advise, and provide ancillary services that are of limited scope, and which are specifically outlined within the Consulting and Limited Advisory Agreement. For more information on consulting please refer to your Consulting and Limited Advisory Agreement. ACAS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring ACAS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. ACAS may request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Selection of Other Advisors ACAS may direct clients to third party money managers that provide discretionary investment management services. In such an event ACAS may receive as compensation a portion of the advisory fee that the client pays to the third-party adviser. Additional details regarding management fees paid to ACAS or third-party managers is set forth in the applicable client agreement. ACAS may also receive referrals from other third-party advisors to provide financial planning, tax planning, investment planning and education planning for clients. ACAS tailors its investment advice according to the needs of clients. As set forth above, ACAS gathers pertinent information regarding clients’ goals, income, tax levels, and risk tolerance levels which is used to construct a client specific plan or portfolio. Clients may impose reasonable restrictions on investing in certain securities or types of securities in accordance with their values or beliefs provided such restrictions do not prevent ACAS from properly servicing the client account, or d require ACAS to deviate from its standard suite of services. ACAS does not participate in wrap fee programs. The Adviser provides advisory services, which include providing retirement Plan Sponsors or other plan fiduciaries (“Plan Sponsors”) investment advisory and management services by assisting plans in establishing and/or maintaining a consistent and ongoing documented process of prudent oversight and due diligence. The Adviser provides services to clients that sponsor a retirement plan that is qualified under the Internal Revenue Code of 1986, as amended (the “IRC”) and/or subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Services may include benchmarking, plan design strategies, analysis, fiduciary consulting and oversight, plan level investment advice and investment fund selection and monitoring services, and some employee education services. The Adviser does not act as, and has not agreed to assume the duties of, a Plan trustee or the “Plan Administrator,” as defined under section 3(16) of ERISA nor as trustee as described by SEC Rule 206(4)- 2. The Adviser has no discretion to interpret the Plan documents, to determine eligibility or participation under the Plan, to provide participant disclosures or communications, to ensure contributions are timely received by the Plan or to exercise any other action with respect to the management, administration or any other aspect of the Plan. The Adviser’s services are offered to assist plan fiduciaries as they carry out their investment related responsibilities and these services should not substitute for or diminish the careful deliberation and determination of plan fiduciaries, after appropriate consultation with their other professional advisers and the review of relevant plan documentation. Non-Discretionary 3(21) Fiduciary Services When the Adviser performs “3(21) Fiduciary Services,” the Adviser will act as a co-fiduciary “investment adviser” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup of investments

to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Adviser will C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs E. ERISA Fiduciary not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. The Adviser will not communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the Adviser’s investment advisory services. The Adviser offers the following 3(21) services:
• Investment screening
• The selection of replacement funds to which existing Plan balances may be transferred
• Assisting clients to finalize a Plan’s investment lineup of funds available for investment by Plan participants and used for other administrative purposes under the Plan
• Quarterly plan review meetings – including review of Investment Funds In the Adviser’s capacity as a 3(21) plan fiduciary, they will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. Discretionary 3(38) Fiduciary Services When a client engages the Adviser to perform “3(38) Fiduciary Services”, the Adviser acts as an “investment manager” (as defined in Section 3(38) of ERISA) with respect to the performance of discretionary fiduciary investment services. Under this arrangement the Adviser is appointed by the Plan Sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions related to the plan assets. Under this arrangement the Adviser is appointed by the plan sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions related to the plan assets. The Adviser will review the investment options available to the Plan through documents provided by the Plan Sponsor and notifies the Plan’s record-keeper and/or the Plan Sponsor the Adviser’s instructions to add, remove and/or replace these specific investment options offered to Plan participants and/or used for administrative purposes under the Plan, according to the criteria set forth in guidelines selected by the Plan Sponsor. The Plan Sponsor retains all authority, responsibility and decision-making for investment options not available on the Plan record-keeper’s platform (i.e., “non-core” investment options, such as employer stock, plan loans, self-directed brokerage accounts, frozen guaranteed investment contracts, and life insurance). The Adviser will retain final decision-making authority with respect to removing and/or replacing investments in the core lineup. The Plan Sponsor will not have responsibility to communicate instructions to any third‐party, custodian and/or third‐party administrator. The data used to determine the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indexes that correspond to these asset classes are not representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indexes and general market conditions. Before a specific investment is selected, other factors such as economic trends, which can influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to determine the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which will be retained or replaced. The Adviser will also monitor the current managed investment line up including the investment’s performance compared to an applicable benchmark. If the Adviser determines that a fund no longer meets the criteria, they will select alternatives and replace them. ACAS has the following approximate assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 274,130,458 $ 0 12/31/2023 Investment Supervisory Services Fees Clients may be charged fees by the Custodian or administrator of the platform or program that are separate and in addition to ACAS’s fee. ACAS’ fee schedule is as follows: Portfolio Size Fee First $500,000 1.50% Next $500,000 1.25% Next $500,000 1.00% F. Amounts Under Management