Forefront is a registered investment adviser owned by Carl Schultz providing advisory services since 2018. As of December 31, 2022, Forefront has $178,937,829 in discretionary assets under management and $19,932,382 in non-discretionary assets, for a total of regulatory assets under management of $198,870,211 to report. Forefront manages investment portfolios for individuals, high net worth individuals, trusts, businesses and institutions. Forefront will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. Forefront will utilize the financial information provided by the client to analyze, model and develop strategies and solutions to help the client meet its goal. Forefront evaluates the client's existing investments with respect to the client's investment policy statement. Forefront works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by Forefront. Forefront will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and will review with the client periodically regarding the account as necessary. Investment Management Services Forefront provides its clients with a broad range of services, as described above and in more detail below. Forefront advises its clients by delivering tailored family-centric wealth management services and solutions. These services are based on a comprehensive understanding of each of its client’s current situation, past experiences, and future goals. With this acquired knowledge we create, analyze, model, strategize, and implement goal-oriented investment solutions. These solutions become our client’s investment policy. This policy and our matched strategies are designed to be risk appropriate, cost effective and tax minimizing. Forefront’s strategies are built around meeting the long-term needs of our clients. Forefront is also adaptive, ready, and able to adjust when there are material changes in markets, tax laws, or whenever there are changes in the lives of our clients, their families and their businesses. For the majority of our client’s advisory accounts, Forefront provides in-house discretionary portfolio management for all, or portions of their portfolio. Forefront strategies are consistent with the clients desired investment strategy. Where appropriate, Forefront may also provide advice about many types of legacy positions or other investments held in client portfolios. Clients may engage Forefront to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts (to the extent permissible without an insurance license) and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Forefront will direct or make recommendations on a non-discretionary basis for the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or custodian for the plan trustee or administrator and the client will be solely responsible for effecting the recommended trades. Forefront’s investment strategies are typically categorized as growth, growth & income, income, or stable value. These strategies are also blended to match acceptable risk tolerances. Our risk models are classified as conservative, moderate, or aggressive. Forefront will continuously and regularly manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). Clients are permitted to place reasonable restrictions on investing in certain securities. Forefront’s investment advisory services consist primarily of: 1. assessing client needs and goals; 2. financial planning designed to meet those goals; 3. developing an appropriate portfolio asset allocation to achieve the client’s objectives; and 4. implementing the asset allocation by directly managing, recommending, or otherwise assisting in the client’s selection of: a. particular investment strategies (i.e., active, passive, alternative strategies); and b. specific investment managers or passive investment vehicles that employ those strategies. Depending on a particular client’s needs and goals, or the nature of a particular tactical tilt, Forefront may or may not recommend a tactical change in that client’s asset allocation. To implement our recommended strategic and tactical asset allocations at the client portfolio level, Forefront typically recommends strategies in each of the portfolio’s selected asset classes. To execute these strategies, Forefront offers in-house discretionary portfolio management. Forefront will also from time to time recommend unaffiliated, third-party investment managers, funds, and other investments that employ that strategy. Examples of the kinds of investments Forefront recommends include, without limitation: individual equities, bonds, mutual funds, exchange traded funds, options, limited partnerships such as hedge funds or private equity, or managed accounts. To evaluate the securities, funds, and managers Forefront recommends to our clients, Forefront employs both quantitative and qualitative techniques. These tools help us to identify securities, funds, managers, and other investments that are well-suited to our client’s investment and financial objectives. To the extent a Forefront client decides to invest with an outside manager or in a particular fund, those managers and funds will have their own investment practices. Those investment practices are described in each manager or fund’s Form ADV, or in its offering or other disclosure documents. In addition, selected money managers or funds typically have discretion to determine the type and amount of securities to be purchased or sold for the client for that portion of the client’s assets managed by the money manager or fund. We utilize a third-party platform to facilitate the management of held-away assets in which we will have discretionary authority to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, 529 Plans, HSA’s, and other assets which are held at third-party custodians. We regularly review the available investment options in these accounts, monitor and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect a held-away account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The

goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Financial Planning & Consulting Services Forefront offers different levels of financial planning and consulting services to help clients identify, prioritize and work towards their goals and objectives. Our consulting services give clients the ability to receive a broad range of financial advice and services. Our process starts with an extensive review of a client’s family situation, which includes assets and liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk capacity-focused simulation to get a detailed cash flow analysis and proposed asset allocation. Together, this information is analyzed to develop a proposed financial plan, which is designed to be dynamic in nature, ever-evolving due to life changes, along with changes in cash flow needs, risk tolerance, time horizon, or investment objectives. For a list of services available, please refer to the Family Office Services list below. While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management services, as part of a comprehensive wealth management engagement. In performing these services, Forefront is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.), and is expressly authorized to rely on such information. Forefront may recommend clients engage the firm for additional related services, or we may recommend other professionals to implement our recommendations. This creates a conflict of interest because the firm will have an incentive to recommend additional services based on the compensation to be received, rather than solely based on your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from the other professional or his or her firm. Implementation of financial planning recommendations is entirely at your discretion. You have complete freedom in selecting a financial adviser to assist you with implementing the recommendations made in your financial plan and are under no obligation to act on the advice of Forefront. Financial planning recommendations are of a generic nature and are not limited to any specific product or service offered by a broker dealer or insurance company. Should you choose to implement the recommendations contained in the plan, Forefront suggests you work closely with your attorney, accountant and/or insurance agent. Forefront will act solely in its capacity as a registered investment adviser and does not provide any legal, accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney when necessary. As part of our advisory services, we may assist clients with tax harvesting and will work with the client’s tax specialist to answer any questions related to the client’s portfolio. Wrap Fee Program Forefront also offers portfolio management services through a wrap fee program. A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Please refer to our Wrap Fee Brochure for more information on our wrap-fee program, Forefront Flex. This is provided as Appendix 1 to this Brochure. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open- end mutual funds or other long-term investment products. Family Office Services Forefront may also provide boutique family office services, including discretionary, and non-discretionary investment advice, to a select group of families, businesses, and institutions. Forefront advises private family clients by delivering tailored family-centric wealth management services and solutions which are customized to address each family’s wealth dynamic. These tailored services are based on a comprehensive understanding of each family’s unique circumstances, asset base, interests and financial goals. Our services are complemented by customized solutions such as succession planning, M&A consultation, trust alignment, investment consolidation and planning, as well as a diverse array of tax-centric estate planning solutions. Clients are permitted to place reasonable restrictions on investing in certain securities. Forefront provides its clients with a broad range of services, as described below: Asset Management ➢ Investment Planning ➢ Risk-Based Asset Allocation ➢ Discretionary Portfolio Construction and Management ➢ Defined Contribution Plan Investment Advice ➢ Tax Advice and Consulting Liabilities Management ➢ Debt and Liability Planning ➢ Liquidity and Cash Flow Management ➢ Budget Planning ➢ Asset Location Strategies Risk Management ➢ Insurance Analysis and Planning ➢ Asset Protection Strategies ➢ Business Continuity Planning ➢ Service Provider Selection, Fee and Expense Negotiation ➢ Investment Transaction Verification ➢ Consolidated Asset and Investment Portfolio Reporting ➢ Performance Monitoring ➢ Will and Trust Preparation ➢ Estate Valuation and Settlement ➢ Executor and Probate Services ➢ Trust Management and Support Trust, Estate and Fiduciary Services ➢ Multi-Generational Estate Planning: Family Governance and Succession Planning ➢ Investment Manager Selection Independent Managers Forefront may retain third-party investment advisers to manage a portion of the clients’ assets. Pursuant to the terms of the investment advisory agreement, Forefront will have the discretion to hire and terminate these third-party advisers. Forefront currently partners with Adhesion as our UMA platform provider. When utilizing the Adhesion platform, investment strategy recommendations will be provided by the Independent Manager(s) and communicated to Adhesion as the overlay manager of UMA platform. Taking into consideration such things as tax-loss harvesting, avoiding high-penalty trades due to wash-sales and other trading considerations, Adhesion will then provide trading instructions to the account custodian (TradePMR, TD Ameritrade, Schwab) for execution. Reporting Services Forefront also provides consolidated portfolio reporting services for our clients’ family assets. Clients who request that Forefront report on their investments and assets receive a customized monthly “global” consolidated report. As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s request, the client’s consolidated report may also include certain non-financial assets (e.g., real assets). In such instances, Forefront relies on the client to provide current and accurate price or other valuation information for those assets to be included in the client’s consolidated account report. Forefront does not independently verify, and expressly disclaims responsibility for, the accuracy of any non-financial asset values clients provide to us to include in their reporting.