The Holben Group, LLC (The Holben Group) was founded in 2006 by Jeffrey M. Holben and is now owned 70% by Jeffrey M. Holben and 30% by Clinton F. Demming. We are registered with the United States Securities and Exchange Commission (“SEC”) as a Registered Investment Adviser. The fact that we are registered with the SEC does not imply a certain level of skill or training. The Holben Group provides personal financial planning, investment management and related wealth advisory services to individuals, families and their related entities, trusts, estates and family businesses. We work with clients to define financial objectives and to develop strategies for reaching those objectives, some of which may include: identification of financial problems, cash flow and budget management, tax planning, risk exposure review, investment management, education funding, retirement planning, estate planning, charitable goals, special needs planning, family business succession issues, and/or other issues specific to the client. Our firm’s compensation is from fees paid directly by clients. Assets under the direct management of The Holben Group are held, in the client’s name, by independent custodians including Charles Schwab & Co., Inc. (“Schwab”), TIAA or Fidelity Investments. The Holben Group does not have physical custody of client assets but does act as a trustee on one client account. See Item 15 for more details. We may recommend other professionals (e.g. lawyers, accountants, insurance agents, real estate agents, etc.) at the request of the client. Conflicts of interest will be disclosed to the client and managed in the best interest of the client. The firm’s principal office is located at 2000 S. Colorado Blvd., Tower 2, Suite 200, Denver, Colorado, 80222. Regular business hours are from 8:00am to 5:00pm Monday through Friday. The firm can be contacted by phone at 303.691.1970 or by email at TrustedAdvice@TheHolbenGroup.com. The firm’s website is located at www.TheHolbenGroup.com and its Twitter address is @TheHolbenGroup. The Holben Group, LLC Page 5 March 2024 Types of Advisory Services The primary types of advisory service offered by The Holben Group are investment supervisory services (i.e. “asset management”), investment advice and financial planning. In most cases these services are provided as part of an on-going investment management relationship. In certain cases, we will provide one-time, financial planning services. In performing our services, The Holben Group is not required to verify any information received from the client or from the client’s

other professionals. Each client is advised that it remains his/her responsibility to promptly notify The Holben Group when there is any change in his/her financial situation and/or financial objectives for the purpose of reviewing, evaluating or revising previous recommendations and/or services. The following are typical financial planning arrangements offered to clients: Comprehensive Financial Planning This service includes financial planning, implementation and on-going asset management and monitoring. Financial planning may include identification of financial problems, cash flow and budget management, tax planning, risk exposure review, investment management, education funding, retirement planning, estate planning, charitable goals, special needs planning, family business succession issues, and/or other issues specific to the client. In some cases, a written evaluation of the client’s current situation and their goals is provided to the client. The engagement also includes implementation of recommendations accepted by the client, telephone support, meetings as required, on-going financial planning services, reminders of specific courses of action that need to be taken, and quarterly, semi-annual or annual portfolio reviews as negotiated with each client. More frequent reviews may occur but are not necessarily communicated to the client unless immediate, substantive changes are recommended. Concierge Services and Special Projects Projects may be undertaken that are not part of our comprehensive financial planning services discussed above. These services include, but are not limited to: periodic portfolio review, insurance review and financial planning without an on-going investment management relationship. The fees for these projects will be negotiated with the client at the time of engagement and are due at the conclusion of the service. The Holben Group, LLC Page 6 March 2024 Separate Investment Management Services Investment management, without the comprehensive financial planning described above, is not normally provided as a stand-alone service. However, occasionally, we do provide these services to a client’s family, friends or business as part of the client’s financial planning objectives. Customized Services and Relationships The Holben Group advisory services are tailored to the individual needs of clients. Client goals and objectives are clarified in meetings and via correspondence and are used to determine the course of action for each individual client. Clients may impose restrictions on investing in certain securities or types of securities. In most cases, this is done in writing and signed by the client. Managed Assets As of March 2024, The Holben Group managed approximately $174 million in assets in 545 accounts for 155 client households. All our assets under management are managed on a discretionary basis.