The Advisor began operations in April of 2014. The Advisor is a limited liability company owned by David Marion, Kristina Alley, and David Kantor. SFA provides the following advisory services: SFA provides investment management and financial planning services for high net worth individuals and families, institutions, charitable organizations and trusts. In order to provide prudent financial planning and investment management services, we believe it is important to understand a client’s complete financial profile. We work with clients carefully outlining their goals as they relate to their assets/ liabilities, cash flow, cost of living, risk tolerance and long term planning. In managing investment portfolios for our clients, portfolios consist of multi-asset class investments, comprised of active and passive investment vehicles selected and approved through our firm’s research process. SFA provides advice with respect to limited types of investments as described in greater detail below. Page 3 of 12 – Form ADV Part 2A Our Mission SFA’s mission is to help clients achieve their financial goals by creating a long term financial plan that incorporates the successful management of their investment portfolios. We believe that we offer clients a combination of depth of experience, an open, transparent approach and a culture focused on the best interests of our clients. Our interests should always be aligned with, and subordinated to, those of our clients. SFA is a fiduciary to each of our client relationships. To maintain a close alignment of interests between ourselves and our clients, we personally invest in the same portfolios that we recommend for our clients. Finally, we strive to maintain a high level of service for our clients. Clients should expect a positive client service experience including frequent and clear communications. Financial Planning Our clients receive financial planning advice as an important component of establishing their investment objectives for the long term management of their investment portfolios. The process starts with a detailed conversation with the client about their objectives, time horizon and tolerance for risk. We then request information from each client in order to prepare a summary balance sheet. We also request information about their family situation, income sources, current and expected cost of living, insurance, retirement plans, estate planning, etc. We request contact information for their other advisors such as attorneys and tax advisors. Once the information is assembled, we will prepare an overview and outline recommendations to assist the client with better aligning their finances and other planning with their personal goals and financial situation. Except for the investment portfolios that SFA directly oversees, the client is responsible for implementation of any other financial planning recommendations. We help our clients keep track of the recommendations and review implementation, as necessary. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from SFA. A client’s financial plan is reviewed and adjusted on an ongoing basis, as needed. Financial planning services are available to clients as part of investment management engagements. Clients may utilize those services at their option. SFA also may be engaged for financial planning services on a stand-alone basis. Investment Philosophy Our approach is focused on managing risk, which we believe is essential to achieving investment objectives regardless of a client’s particular tolerance for risk. We believe that active management of portfolio allocation is critical to risk mitigation and investment success. Tactical portfolio changes

are only made based on high conviction ideas. Portfolio changes are made if the change is viewed to be asymmetrically favorable for our clients. We do not adhere to benchmark allocations and believe that strict adherence to benchmarks yields mediocre results. Finally, an important aspect of a successful investment process is the containment of costs. Hidden fees, excessive transaction costs Page 4 of 12 – Form ADV Part 2A and adverse tax consequences hinder investment performance and must be minimized to the extent possible. Client Experience All client portfolios are governed by an investment policy statement which outlines, among other things, risk tolerance, asset allocation parameters, time horizon, distribution needs and specific restrictions. Restrictions in client portfolios are subject to approval by SFA to determine whether our firm can add value to a client’s investment portfolio within the restrictions imposed by the client. Each client is advised that it is the client’s obligation to notify SFA of any change in financial circumstances or investment objectives. SFA will then review with the client whether a change in their investment portfolios is, in SFA’s opinion, recommended. SFA shall not independently verify any information received from the client or from the client’s other professionals and is authorized to rely on such information. SFA does not provide tax or legal advice. Clients requiring assistance on issues outside of financial and investment advisory topics should consult a tax advisor, legal counsel and/or other professionals for expert opinions. Upon client request, SFA may recommend the services of other professionals such as attorneys, accountants, insurance agents, etc. The client is under no obligation to engage the services of any SFA- recommended professional. SFA has no affiliation, financial or otherwise, with any such professionals. Our primary source of compensation is a fee based on a percentage of assets managed. For financial planning-only engagements, we charge an hourly rate. In certain situations, we will consider consulting engagements where a fixed fee is negotiated. We accept no product-based fees nor any other form of compensation from outside sources. SFA does not participate in any wrap fee programs. As of December 31, 2023, SFA had $170,827,000 of assets under management. $166,055,000 is managed on a discretionary basis and $4,772,000 is managed on a non- discretionary basis. SFA had a further $40,746,000 of assets under advisement. Miscellaneous SFA may recommend that a client roll over employer sponsored retirement plan assets to an Individual Retirement Account (IRA) managed by SFA. As a result, SFA may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their former employer or roll the assets to a plan sponsored by a new employer would likely result in little or no compensation for SFA. Thus, SFA has an economic incentive to encourage an investor to roll plan assets into an IRA that it will oversee. No client is under any obligation to roll over plan assets to an IRA managed by SFA or to open an IRA with SFA. SFA’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding its Page 5 of 12 – Form ADV Part 2A prospective engagement and the potential conflict of interest presented by such engagement. On an accommodation basis, SFA may agree to administer certain accounts on a non- managed basis. In such cases, SFA will not be responsible for providing management on either a discretionary or non-discretionary basis. The scope of services and fee will be outlined in the relevant addendum to the investment management agreement.