A. Description of the Advisory Firm Summit Investment Advisory Services, Inc. also doing business as Summit Investment Advisors (hereinafter collectively “SIAS” or the “Advisor”) is a limited liability company (“LLC”) organized in the State of Minnesota formed in September 2013. SIAS is a wholly- owned subsidiary of Summit Advisors HoldCo, LLC, which is in turn primarily owned by Summit Advisors, Inc. The principal owner of the Summit Advisors, Inc. is Sean McDermott. B. Types of Advisory Services SIAS offers the following services to advisory clients: Portfolio Management Services SIAS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SIAS creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring SIAS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SIAS seeks to provide investment decisions in accordance with the fiduciary duties owed to its accounts and without consideration of SIAS’s economic, investment or other financial interests. To meet its fiduciary obligations, SIAS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, SIAS’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SIAS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. LPL Financial Sponsored Advisory Programs SIAS may provide advisory services through certain programs sponsored by LPL Financial Corporation (LPL), a registered investment advisor and broker-dealer. LPL charges fees for these sponsored programs that are in addition to the SIAS fee. Below is a brief description of each LPL advisory program available to SIAS. For more information regarding the LPL programs, including the fees that apply and the types of investments available in the programs, please refer to the applicable LPL client agreement. Advisory Services Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion for selecting third party money managers (PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase

and sell on a discretionary basis mutual funds and equity and fixed income securities. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. SIAS will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds (including in certain circumstances exchange traded funds) and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. In the future, the MWP program may make available model portfolios designed by strategists other than LPL’s Research Department. If such models are made available, Advisor will have discretion to choose among the available models designed by LPL and outside strategists. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments SIAS generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), non-U.S. securities, commodities, hedge funds, insurance products including annuities and private placements, but primarily recommends stock and bond mutual funds and ETF's. SIAS may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions SIAS offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs SIAS participates in wrap fee programs, which are investment programs wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. SIAS manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than non-wrap fee accounts. A portion of the fees paid to the wrap account program will be given to SIAS as a management fee. SIAS participates in the following LPL Financial sponsored wrap fee programs: Model Wealth Portfolios (MWP), Optimum Market Portfolios Program (OMP), Personal Wealth Portfolios (PWP) and Manager Access Select Program. SIAS sponsors the following wrap fee program: Summit Investment Advisory Services Wrap Fee Program. E. Assets Under Management SIAS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $452,959024 $3,010,036 12/31/2022