A. Description of Firm A Smarter Way to Invest, Inc. (from herein referred to as “ASWTI” or Smarter Way “SW”) was approved as a State Registered Investment Advisory Firm on November 29 of 2012. ASWTI has since been approved as a SEC Registered Investment Advisory Firm on June 26, 2017. ASWTI was founded by its Principal and Chief Investment Strategist, Ronald J. Briggs Jr. FIC, CRPC®, who began his career in the financial services industry on January 31st,1984 at the age of 18. ASWTI offers Client(s) access to ASWTI’s various services, including but not limited to proprietary dynamic and actively managed investment models & allocations (herein referred to as “models”, “Smarter Way Strategies” or “SWS”) that can be combined to create custom Client portfolios, whereby Registered Investment Advisor Firm(s) (from herein referred to as “RIA”) and their Investment Advisor Representatives (from herein referred to as “IAR”) may utilize the SWS to help assist with their Client’s asset management needs in accordance with their goals, objectives, and risk tolerance. ASWTI receives employee staffing support from Entry Point Advisor Network, Inc. Entry Point Advisor Network is an affiliated entity solely through common control by Kristin Briggs, spouse of Ronald J. Briggs, Jr. Additional details of this arrangement can be found in Item 10 - Other Financial Industry Activities and Affiliations under the C. Relationship/Conflicts section. B. Types of Advisory Services Offered ASWTI provides investment advisory services under the following arrangements: ASWTI is a Third-Party Investment Advisor (herein referred to as a “TPIA”) where its services are retained by the RIA, at an institutional level only, and may be engaged through a variety of relationship and service structures, including full Turnkey Asset Management Program “TAMP” services, Sub-Advisory Separately Managed Account “SMA” services, or Signal Provider services. Additionally, the ASWTI Portfolio Management Team may engage outside consultants, sub-advisors, and other Third-Party Portfolio Managers to best achieve and deliver an array of robust SWS to its institutional and RIA Client(s). The TAMP and SMA programs can be managed on Charles Schwab & Co. Inc.’s (hereinafter referred to as “Schwab”) custodial platform. ASWTI acts solely as the TPIA for the RIA, thereby individual Client(s) cannot hire ASWTI to manage their assets directly. Before enlisting any of ASWTI’s services, the interested RIA is required to enter into one or more agreements with ASWTI. ASWTI will work with RIA’s IARs that will administer various advisory services directly to their Client(s). The IAR responsibilities may include the recommendation of a TPIA, such as ASWTI, for the sole purpose of investment management services for the IAR’s Client’s portfolio. This arrangement between ASWTI and the RIA is set forth in the terms and conditions of the agreement whereas ASWTI renders its services solely as a TPIA (collectively the “Agreement”). The RIA will hire ASWTI to invest Client(s) assets in one or more of the pre-built traditional equity or ETF models, allocations, or a combination thereof. ASWTI provides unique autonomy for RIA Firms to engage its services including the ability for unique custom development and white labeling of its models and allocations. Services offered by ASWTI provided to such Client(s), using its SWS, may pay a higher or lower fee than using comparable (if available) TPIA services or if a Client(s) solely purchases individual securities without the use of any TPIA. Institutional Distribution Services: Recognized as a Manager of Managers, ASWTI may distribute investment management services of other TPIAs and/or Sub-Advisors to RIAs alongside ASWTI’s SWS. In consideration of but not limited to: ASWTI’s research, due-diligence, and ongoing oversite of its distribution services, ASWTI receives compensation based on assets which it or its Sub-Advisor manages. The nature of ASWTI’s payment for such services is described in Item 5. Fees and Compensation. C. Individual Services Investment management of accounts using AWSTI’s SWS are offered to Client(s) of RIAs. In each case, the RIAs will properly establish a relationship between ASWTI and each Client(s) according to the policies and procedures associated with either the TAMP or SMA structure between ASWTI and RIAs. No Client relationship with ASWTI shall be established when an RIA is receiving Signal Provider Services and utilizing trade notices for implementing its own portfolio management strategies directly with its Clients. In every case, the RIAs have the sole direct contact with their Client(s). Once the RIAs have determined an investment strategy that is appropriate for its Client, the IAR may select among ASWTI’s SWS for investment. The RIAs advise its Client(s) concerning the allocation of his or her portfolio among ASWTI’s SWS along with direction to reallocate funds to different models, if necessary. For example, the RIAs could advise the Client(s) to aggregate one or more pre-built SWS or to blend Models to create a custom allocation. In each circumstance, no such advice is provided by ASWTI to the RIA’s Client. All of ASWTI’s communications are directed through the RIAs and, unless specifically requested, AWSTI does not have direct communications with the RIA’s Client(s). ASWTI may communicate with RIAs Client(s) in a generic manner with monthly or quarterly newsletters and/or periodic market & economic updates. The RIA’s Client(s) may impose reasonable restrictions on the management of their account, including the designation of specific securities or a specific category of securities, that should not be purchased for the account or that should not be sold if held in the account, and may reasonably modify such restrictions from time to time. ASWTI reserves the right to decline to accept an account if it determines, in its sole discretion, that the restrictions imposed by Client(s) are not reasonable. The RIA’s IAR and their Client(s) will need to acknowledge and agree that any restrictions placed on the management of the Account imposed by the Client(s) may cause their account performance to deviate from the performance of ASWTI’s chosen securities within its core model. The Client(s) acknowledges and agrees that whereby the Client(s) may restrict a category of Securities that may be purchased for the account due to social screening, ASWTI will determine in its sole discretion the specific Securities in that category. Once the investment decisions concerning the Client(s) allocation among the SWS has been completed by the Client’s IAR, ASWTI will process the provided investment direction typically under a managed account arrangement at the Custodian on a discretionary basis according to its discipline for each SWS. The products utilized in effectuating the SWS may include but are not limited to: various exchange-traded

funds (ETF)’s, leveraged ETF’s, common stock, preferred stock, Structured Notes, Private Equity funds, Reg D securities, MLPs, BDCs, and REITs. Client(s) will acknowledge and grant ASWTI full discretion over the Client(s) assets as to be managed accordingly by ASWTI. Additionally, the Client(s) also has full authority to revoke full discretion and/or terminate all services provided by ASWTI at any time by contacting their IAR. The IAR will contact ASWTI and convey the direction of the Client. Such discretion may include authority to reinvest dividends or authority to manage distributions for the Client(s) as directed. Such discretionary authority, however, is otherwise limited to the purchases and/or sales of securities within the SWS managed by ASWTI. ASWTI will not be obligated to act or offer any advice involving legal action on behalf of the Client(s) with respect to securities or other investments held in the account(s), or the issuers thereof, which become the subject of legal notices or proceedings, including bankruptcies. ASWTI is not authorized to withdraw or transfer any money, securities, or property out of the Client’s account(s), whether in the name of the Client(s) or otherwise. Only the RIA or it’s IAR, with permission from the Client(s), can affect such transactions. ASWTI cannot and will not ever take custody of the Client’s funds, securities, or accounts. Separately Managed Account (SMA): ASWTI’s Separately Managed Account (“SMA”) platform provides access for RIAs to utilize ASWTI’s SWS, as well as other outside TPIA sub-advisor models as part of ASWTIs institutional distribution services. The ASWTI SMA enables advisors to select at their own discretion ASWTI SWS as an investment vehicle to match their Clients’ financial needs, goals, objectives, and risk tolerance. When using the SMA structure, ASWTI traditionally receives an investment management fee based on the certain types of SWS chosen to be used by the RIA and/or total assets under management allocated to ASWTI by the RIAs. These fees are set forth by ASWTI in the SMA Sub-Advisory Investment Management Agreement with the RIA. See Item 5 Fees and Compensation for further details. Turnkey Asset Management Program (TAMP): When using ASWTI’s TAMP services, in addition to the investment management services and access to ASWTI’s SWS, ASWTI shall provide additional RIA supporting duties which may include but are not limited to: Client account performance reporting, Client fee billing, account opening and/or administrative services, software and technology access, training and/or education of investment models, allocations, and strategies, use of risk analysis software or tools (for determination of Client’s financial risk tolerance), portfolio analysis, unique Client strategy case design, and answering or addressing general questions, comments, and concerns for the RIA’s, IARs, or their Client(s). TAMP services are customarily included in a Wrap Fee Program which are made available to the Client(s) and sponsored by the RIA. In consideration of all services provided to RIA, IAR, and their Client(s), ASWTI will receive a portion of this wrap fee as compensation, as outlined in the TAMP Agreement set forth with the RIA. See Item 5 Fees and Compensation for further details. Signal Provider Services ASWTI provides RIAs with the ability access and license trade signals relating to ASWTI’s SWS and the respective investment decisions effectuated by ASWTI in each SWS, including the individual securities selected and target security weightings of the respective SWS, whereby RIA will offer and implement investment portfolio management directly to its Clients. These services are strictly limited to receiving ASWTI’s distribution of trade notices for particular SWS, and the RIA and its IARs retain the sole discretionary authority over (and have the sole responsibility and discretion for) executing or not executing these trade signals for their Clients. ASWTI does not control, supervise, or monitor the investment of any RIA Client accounts under a Signal Provider arrangement, and no Client relationship is established between RIA Client and ASWTI. Additionally, ASWTI does not effect trades or execute any transactions at any custodians under a Signal Provider relationship. RIA retains the sole responsibility for delivering investment portfolio management services to their Clients, and retains the sole discretion for implementing, and/or alternatively, not implementing, any trade signals provided by ASWTI. Performance of any investment strategies offered by RIAs that rely on ASWTI signals will inherently differ from those of the corresponding ASWTI SWS. As RIA is solely responsible for effecting trades and transactions at their discretion, the execution date and time (and therefore corresponding security price) will differ from that achieved by ASWTI SWS. This arrangement between ASWTI and the RIA is set forth in the terms and conditions of the signal provider agreement whereas ASWTI renders its services solely as signal provider (collectively the “Agreement”). For details on fees charged for Signal Provider services, see Item 5 Fees and Compensation. Retirement Plans services: ASWTI makes available TPIA services to RIAs working with qualified retirement plan sponsors and their plan assets. These services may include a proprietary design of SWS using ETF’s or Mutual Funds made available through the custodian administering the retirement plan itself on behalf of the Plan Sponsor and its plan participants. These SWS are specifically designed and weighted with various asset class funds, then managed using a similar methodology and process as provided on the retail side. For further details, please see Item 8 (A) Methods of Analysis/Investment Strategies ERISA Qualified Plans: ASWTI is required to provide certain information regarding its services and compensation to assist the Advisor and plan sponsors of those retirement plans that are subject to the requirements of ERISA in assessing the overall structure of their plan and/or the arrangement with ASWTI, including the reasonableness of compensation for services by ASWTI in accordance with the Department of Labor regulations under Section 408(b)(2) of ERISA. These services and fees are detailed in the agreement at the onset of your relationship with ASWTI. Wrap Fee Program: ASWTI does not currently sponsor a wrap fee program but does receive a pre-determined percentage of the Wrap fee from RIAs offering a Wrap Fee Program and using ASWTI’s portfolio management services. D. Assets Under Management As of December 2023, there are approximately $84,510,000.00 in discretionary assets under management and $ 278,500.00 in non-discretionary assets under management. These assets are not inclusive of any assets that RIAs may be managing through utilizing our Signal Provider services.