General Information The Adviser, a Georgia limited liability company, was formed in February 2017.
Investment Consulting & Portfolio Management The Adviser provides non-discretionary investment consulting as well as discretionary portfolio management to retirement plans, including defined benefit plans, defined contribution plans, 401(k) plans, 403(b) plans and 457 plans, trusts, charitable organizations, endowments, foundations, corporations, individuals and high net worth individuals.
InvestmentGoals&Objectives At the outset of each client relationship, the Adviser discusses the client’s investment objectives and identifies the major investment goals of the client. Based on the information provided by the client, the Adviser will identify the portfolio structure, allocation model, and investment strategies to be utilized with respect to the client.
The Adviser typically considers the client’s assets, its capital structure, its operating expectations and its mission. The Adviser may consider the tax implications for a client of strategies that may be used. In addition, the Adviser may consult with the client’s outside professionals (e.g., legal, and tax), to ensure the client’s strategy is consistent with the client’s larger wealth plan and/or investment objectives and goals. With respect to certain matters, the Adviser may advise clients to seek the assistance of outside professionals and coordinate with these outside professionals.
A client’s strategy generally will be updated from time to time when requested by the client, or when determined to be necessary or advisable by the Adviser based on updates to the client’s financial or other circumstances.
ImplementingtheStrategy To implement a client’s investment strategy, the Adviser will make recommendations for the client’s investment portfolio on a non-discretionary basis or manage the client’s investment portfolio on a discretionary basis, in each case pursuant to an advisory agreement with the client. When acting as a non-discretionary investment adviser, the Adviser must receive authorization from the client before executing trades in the account(s) under management. In such instances, the client retains the responsibility for the final decision with respect to all actions taken in the portfolio. When acting as a discretionary investment adviser, the Adviser has the authority to supervise and direct the trading within the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on the Adviser in the management of investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship; however, restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each investment portfolio is treated individually by giving consideration to each investment for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment

objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of the Adviser.
SeparateAccountManagers The Adviser may recommend or select one or more Separate Account Managers (each, a “Manager”) for a particular client through either the managed accounts program offered by Raymond James & Associates, Inc. (“Raymond James”) or through the Managed Account Select Program offered by Charles Schwab & Co., Inc. (“Schwab”). The Adviser’s access to various Managers allows the Adviser to offer a wide variety of manager styles and provides the opportunity to utilize more than one Manager. Factors that the Adviser considers in recommending/selecting Managers generally include the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) generally will be granted discretionary trading authority to provide investment supervisory services for the portfolio. Under certain circumstances, the Adviser retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. In other cases, the client will ultimately select one or more Managers recommended by the Adviser.
The Adviser will monitor the investment approach and performance of the Manager(s).
Retirement PlanConsultingServices The Adviser may provide retirement plan consulting services to employee benefit plans, which include defined benefit plans, defined contribution plans, 401(k) plans, 403(b) plans and 457 plans and their fiduciaries based upon an analysis of the needs of the plans. In general, these services may include existing plan review, asset allocation advice, money management services, communication and education services, investment performance monitoring, and/or ongoing consulting.
FinancialPlanning The Adviser may provide financial planning services to those individuals in need of such services in conjunction with portfolio management services. The Adviser will use the Goal Planning and Monitoring (“GPM”) software provided through Raymond James to create and monitor a financial plan unique to each individual to whom such services are provided.
WrapProgram The Adviser may utilize the Managers available in a wrap fee program sponsored by Raymond James (the “Raymond James Wrap Program”). A wrap fee program is one that charges a single fee (the “wrap fee”) for the Adviser’s fee, the fees of any Manager(s) and the brokerage commissions and transaction expenses incurred by the account. The Raymond James Wrap Program offers a wide variety of Manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client.
Principal Owners Kurt Hennek and Matthew Bauder are the principal owners of the Adviser.
Type and Value of Assets Currently Managed As of December 31, 2023, the Adviser managed approximately $1,737,942,568 on a discretionary basis and $11,860,644,932 on a non-discretionary basis.