A. Description of the Advisory Firm Transparent Wealth Consulting LLC (hereinafter “TWCL”) is a Limited Liability Company organized in the State of New York. The firm was formed in January 2016, and the principal owner is Colleen Fitzpatrick Knapp. B. Types of Advisory Services Portfolio Management Services TWCL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TWCL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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 TWCL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TWCL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. TWCL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of TWCL’s economic, investment or other financial interests. To meet its fiduciary obligations, TWCL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TWCL’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 TWCL’s policy to allocate investment opportunities and transactions

it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Pension Consulting Services TWCL offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Services Limited to Specific Types of Investments TWCL generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs, treasury inflation protected/inflation linked bonds and non-U.S. securities. TWCL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions TWCL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by TWCL on behalf of the client. TWCL may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent TWCL from properly servicing the client account, or if the restrictions would require TWCL to deviate from its standard suite of services, TWCL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. TWCL does not participate in any wrap fee programs. E. Assets Under Management TWCL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 41,446,022 $0.00 December 2023