Milestones Private Investment Advisors LLC (“Milestones”) has been in business since September of 2017. Heather Proctor and Mark Buscher are the firm’s principal owners. Milestones’ focus is on creating and implementing realistic retirement plans for each of its clients, with a holistic approach taking into consideration client’s full financial picture. Financial Planning Financial Planning is the cornerstone of Milestones’ approach to aiding clients in meeting their financial and life goals. We first take into account all of the client’s objectives and goals, and from there decipher what is achievable through our comprehensive planning process. We analyze the client’s income stream in order to produce a blueprint of when retirement can occur and what income is needed to meet the goals of retirement. We will also include analysis of the different cash flows that correspond with the different points of retirement specific to each individual client. Open communication and working with other professionals of our clients is something we believe is an effective way to ensure that our clients are staying on the right track to their goals and overall financial health. If you request, Milestones may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from Milestones. If you engage any professional recommended by Milestones, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Asset Management When asset management services are performed, they are done on either a discretionary or non-discretionary basis. In most cases, Milestones will have a financial plan to guide these decisions to ensure they are within the client’s investment objectives. In the event that a financial plan is not in place, we will gather client investment objectives and information through client dialogue and a review of relevant documents. When services are performed on a discretionary basis, Milestones will not seek specific approval of each change to a client account. For accounts where Milestones has full discretion, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an agreement that outlines the responsibilities of both the client and Milestones. As mentioned, we may provide asset management services on a non-discretionary basis, which means we will manage the clients’ accounts as we do for our discretionary clients, except we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, in which case recommendations not implemented because we are unable to reach a non-discretionary client may not be made on a timely basis and therefore client’s account may not perform as well as it would have had Milestones been able to reach the client for a consultation on the recommendation. Retirement Plan Consulting Services The fiduciaries of self-directed retirement plans (which can include 401(k) plans) are required to, among other things, determine a selection of investments from which the plan’s participants choose for their personal allocation in their individual participant account. Milestones may provide assistance to plan sponsors in meeting this obligation through a consultative relationship including the selection of the plan investment options in accordance with the plan’s objectives, as well as the ongoing monitoring of those options to assist the plan sponsor in determining when changes to these options are needed. This advice is rendered on a non- discretionary basis, meaning the plan sponsor is free to accept or reject Milestones’ recommendations. In addition, if requested by the plan sponsor, Milestones may assist with the review of plan service providers. Wrap Program Milestones Private Investment Advisors LLC Wrap Program (“the “Program”) is a wrap fee program sponsored by Milestones Private Investment Advisors LLC, which has been in business since September of 2017. A “wrap program” is when transaction costs and fees related to the management of the same assets are included in one fee. Milestones may include certain transactional costs in the client’s management fee. Milestones Asset-Based Wrap Program For accounts in the Milestones Asset-Based Wrap Program, Milestones may include certain transactional costs in the client’s management fee. Milestone’s pays a fee to Schwab Advisor Services, division of Charles Schwab & Co., Inc. (“Schwab”) based on the total amount of client assets enrolled in the Wrap Program, thus taking on many of the client’s transaction costs. Fees included in the wrap program include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charges to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for

securities trades executed by a broker-dealer other than Schwab Advisor Services. Because Milestones will be managing the assets of wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. Therefore, there is no difference between how Milestones manages wrap fee accounts and how Milestones manages other accounts. Because of the nature of the Asset Based Wrap fee program, where wrap fees are not tied to an account’s frequency of trading and apply to generally all assets in the account, the wrap fee program client may pay more or less than if the client had compensated Milestones outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Clients whose accounts will be rarely traded should carefully consider whether the Wrap Program is appropriate. Clients are not required to participate in the Asset-Based Wrap Program. Milestones is the sole portfolio manager in the Asset Based wrap program, which means that Milestones receives a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds and ETFs. The remainder of the wrap fee is the management fee payable to Milestones. As discussed more fully in the wrap brochure, the transaction fees paid to Schwab are based on a fixed rate that is based on the total amount of assets Milestone’s clients have in custody with Schwab, where the rate drops as the amount of assets in custody increase. Accordingly, Milestones does not receive greater compensation for placing or not placing trades. However, Milestones does have an incentive to recommend Schwab to clients in order to reduce the fixed fee for transactions. Milestones attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own, evaluating all aspects, including the wrap program asset-based transaction pricing when considering what broker-dealers to recommend. Milestones will receive no additional compensation for offering the wrap fee program. Milestones Transaction-Based Wrap Program For accounts in the Milestones Transaction-Based Wrap Program, Milestones may include certain transactional costs in the client’s management fee. Milestones pays a fee to Schwab Advisor Services, division of Charles Schwab & Co., Inc. (“Schwab”) based on the clients’ transaction costs. Fees in the wrap program include transaction costs for the purchase or sale of securities, including transaction fees for trades placed by other portfolio managers engaged by Milestones under this wrap program, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than the agreed upon custodian. Because Milestones will be managing the assets of the transaction-based wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. Therefore, there is no difference between how Milestones manages wrap fee accounts and how Milestones manages other accounts. Because of the nature of a wrap fee program, the wrap fee program client may pay more or less than if the client had compensated Milestones outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. Milestones may not be the sole portfolio manager for the wrap program, which means that Milestones receives a portion of the wrap fee for our services. Transaction fees are paid to various broker-dealers, mutual funds and exchange traded funds, and the remainder of the wrap fee is the management fee payable to Milestones. The amount payable to Milestones varies depending upon the amount of trading in a client's account. The more transactions in the account, the greater the amount of transaction fees, and therefore the less compensation to Milestones. Accordingly, Milestones has a financial incentive to avoid trading the account. This creates a conflict of interest between the firm and its transaction–based wrap program clients. Milestones attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own and by periodically comparing wrap program client performance against any clients who are not in the wrap program. Milestones will receive no additional compensation for offering the wrap fee program. Clients should refer to the accompanying Milestones Wrap Fee Program Informational Brochure. Assets under Management As of January 10, 2023, Milestones manages $149,846,522 in assets under management for 627 accounts. Of those assets, $80,685,058 in 317 accounts are managed on a discretionary basis.