A. S.F. Ehrlich Associates, Inc. (“SFE”) is a New Jersey corporation formed in July 1996. SFE was initially registered as an investment adviser with the SEC, was then registered with various state agencies, and most recently transitioned back to SEC registration effective July 26, 2018. SFE is principally owned by John Zeltmann who is SFE’s President and Chief Compliance Officer. B. SFE offers to provide investment advisory, financial planning, and consulting services to its clients, who generally include individuals, high net worth individuals, and their affiliated trusts and estates. INVESTMENT ADVISORY SERVICES Clients can engage SFE to provide discretionary investment advisory services on a fee- only basis. When engaging SFE to provide investment advisory services, clients are required to enter into an investment advisory agreement with SFE setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. SFE’s annual investment advisory fee is based upon a percentage of the market value of the assets placed under its management. Upon request or as an ancillary part of the investment advisory process, SFE may at its discretion provide financial planning and consulting services without additional charge. If, however, SFE determines that the client seeks or requires financial planning or consulting services that exceed the anticipated scope under the investment advisory agreement, it will offer to provide those services under the terms and conditions of a separate agreement. SFE’s investment advisory services are specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will collaborate with the client to develop investment objectives, which are based upon an assessment of factors that typically include capital preservation, risk tolerance, income production, liquidity requirements, client preferences, asset and liability levels, and investment preferences and restrictions. After developing the client’s investment objectives, SFE will execute on its customized investment strategy. Clients may, at any time, impose restrictions in writing on investing in certain securities or types of securities. Generally, SFE allocates client investment assets among exchange-listed securities, mutual funds, exchange traded funds (“ETFs”), individual bonds and bond funds, cash, and cash equivalents on a discretionary basis. Once allocated, SFE provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may periodically execute account transactions based upon those reviews or other triggering events. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Upon client request, SFE may agree to provide financial planning and consulting services (including investment and non-investment related matters) on a stand-alone separate fee basis. SFE’s financial planning and consulting fees are negotiable depending upon the level and scope of the services required and the professionals providing the services. Before engaging SFE to provide financial planning or consulting services, clients are required to enter into a either a financial planning agreement, or a consulting agreement with SFE setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and a description of the applicable fee that will become due from the client before SFE will begin the process. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. SFE may provide financial planning and related consulting services either as part of the investment advisory engagement or according to the terms and conditions of a stand-alone financial planning agreement. SFE does not serve as a law firm, accounting firm, or insurance agency, and no portion of SFE’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, SFE does not prepare estate planning documents, tax returns, or sell insurance products. Unless specifically agreed in writing, neither SFE nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with SFE, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from SFE and its representatives in that respect. SFE’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. To the extent requested by a client, SFE may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage

the services of any recommended professional who is responsible for the quality and competency of the services they provide. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, SFE will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when SFE determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If SFE recommends that a client roll over their retirement plan assets into an account to be managed by SFE, such a recommendation creates a conflict of interest if SFE will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by SFE. ERISA / IRC Fiduciary Acknowledgment. When SFE provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way SFE makes money creates certain conflicts with client interests, SFE operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, SFE must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that SFE gives advice that is in the client’s best interest; charge no more than is reasonable for SFE’s services; and give the client basic information about conflicts of interest. Asset Aggregation / Reporting Services. SFE may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged SFE to manage (the “Excluded Assets”). SFE’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because SFE does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not SFE, will be exclusively responsible for implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by SFE. Accordingly, SFE will not agree to be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without SFE’s participation or oversight. Client Obligations. When performing its services, SFE is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify SFE if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending SFE’s services or previous recommendations. C. SFE tailors its investment advisory services specifically to the needs of each client. To begin the investment advisory process, an investment adviser representative will coordinate with each client to develop their investment objectives. Then, SFE allocates or recommends that the client allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on SFE’s services. D. SFE does not participate in a wrap fee program. E. As of December 31, 2023, SFE had $150,680,447 in client assets under management on a discretionary basis.