A. Description of Firm Sterling Financial Group. Inc. is an investment advisory firm that oversees clients’ assets and provides a range of comprehensive wealth management services. Our team has the skill and expertise to offer exceptional economic advice and market analysis, as well as a strong network of professionals to refer to for legal and tax advice, enhancing our ability to successfully assist clients in achieving their financial goals. Michael Hatch, Principal and a Director of Sterling Financial Group, Inc. (hereinafter, Sterling Financial Group), has been helping clients in formulating and implementing complex wealth management strategies and managing their assets for over thirty years. Sterling Financial Group was established in 2019 by Michael P. Hatch, CFP, MBA, JD, and is the significant majority shareholder. Mr. Hatch began his career as a financial advisor in 1989 and has operated predecessor firms as a principal since that time. Kody Brown is a minority shareholder of Sterling Financial Group, and also serves as a Director and Secretary of the firm. Berkeley Harrison serves as the firm’s Chief Compliance Officer. Please see Sterling Financial Group’s Form ADV Part 1, Schedule A for additional information. B. Types of Advisory Services Offered 1. Written Financial Planning and Financial Consulting: Written Financial Planning: Sterling Financial Group offers written financial planning services tailored to our clients’ specific circumstances, and such services are typically rendered for a flat fee. Our financial planning services are not tied to the purchase of any product, investment, insurance or other service, and analysis and recommendations are meant to illustrate various strategies, possible cash flow scenarios, and hypothetical tax, estate plan or other philanthropic strategies in an objective manner. This method of creating customized financial plans using a consultative approach assists our clients by considering the client’s unique position and using the array of expertise at our disposal to incorporate strategies appropriate to each individual situation. Creating a written financial plan is an involved process that typically begins with a consultation meeting so our advisors can learn about the client’s goals and objectives and obtain an understanding of the client’s financial situation. Some planning engagements are solely to address a specific issue or transaction while others can require a more comprehensive review. When providing written financial planning, we rely heavily on data and information provided by the client, such as expense and income schedules, investment statements, pension statements, estate plans, and tax returns. These data points and any assumptions used in our planning forecasts are expressly stated in our financial plans. After the completion of our analysis, we customarily provide clients with a written summary of their financial situation, our observations, and recommendations. It should be noted that we will refer clients to an accountant, attorney, or other adviser, as necessary. Written plans are typically completed within three months of the client signing a Client Agreement with us, assuming that all the information and documents we request from the client are provided on a timely basis. Once the written financial plan is completed and delivered to the client, implementation of any recommendations is at the discretion of the client. Clients should understand that a conflict of interest exists when Sterling Financial Group recommends its own investment management services to implement investment recommendations, as the firm will receive additional compensation as a result of performing such investment management services. Any implementation of Sterling Financial Group’s recommendations is entirely at the client’s discretion. Clients can accept or reject at any time some or all recommendations made by Sterling Financial Group and clients retain the authority and discretion on whether to implement any financial planning recommendations (please see Item 5 below for additional information). Financial Consulting: Sterling Financial Group provides financial consulting for an hourly fee or provides such services on a fixed fee or periodic retainer. The financial consulting process is less formal than our written financial planning service and is generally offered when the circumstances of a client’s need for financial consulting advice is anticipated to extend over many months or years, such as a complicated divorce matter, estate or trust settlements, or business transactions. Some financial consulting engagements result in providing the client with a written summary of our observations and recommendations, while other engagements involve our participation in meetings, conference calls and negotiations which will not result in a written summary. We offer financial consulting and expert advice in all the same areas in which we conduct financial planning. The implementation of our financial consulting recommendations is also at the discretion of the client. Educational Expense Planning: As an extension of our Financial Planning & Consulting services, we may help clients evaluate and establish 529 college savings plans. Once established we will periodically review and make recommendations when rebalancing or changing allocations is appropriate. 2. Fee Based Investment Management: Wrap Asset Management: Please see our Form ADV Part 2A: Appendix 1 (Wrap Brochure) for comprehensive information regarding our Wrap Asset Management service. Non-Wrap Asset Management: As part of our Non-Wrap Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances.

Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company’s participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include:  Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.  Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.  Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation, and tolerance for risk.  Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility.  Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. C. Advisory Agreements 1. Information Received by Individual Clients At the onset of the Client relationship, we gather information on each client’s investment objectives, risk tolerance, time horizons, and financial goals. Sterling Financial Group does not assume responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from any of the client’s other professionals (e.g., attorney, accountant, etc.). Under all circumstances, clients are responsible for promptly notifying us in writing of any material changes to the client’s objectives, risk tolerance, time horizon, and financial goals. If a client notifies Sterling Financial Group of any changes, we will review such changes and implement any necessary revisions to the client’s portfolio. 2. Client Agreements and Disclosures Each client is required to enter into a written agreement with Sterling Financial Group setting forth the terms and conditions under which we shall render its services (the “Agreement”). In accordance with applicable laws and regulations, Sterling Financial Group will provide its disclosure Brochure (ADV Part 2A), Brochure Supplement (ADV Part 2B), Form CRS and most recent Privacy Notice to each client prior to or contemporaneously with the execution of the Agreement. The Agreement between Sterling Financial Group and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Our fees (as discussed below) shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither Sterling Financial Group nor the client can assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of Sterling Financial Group shall not be considered an assignment. As further discussed in Item 15 below, all client assets will be custodied with a qualified custodian. All custodial and execution fees assessed for client’s assets remain the sole responsibility of client. D. Participation in Wrap Programs Sterling Financial Group sponsors a Wrap Fee Program. We select investments for client portfolios from securities offered in the Wrap Program. Sterling Financial Group also determines the allocations and sector weights utilized in the Wrap Program. An appropriate allocation and underlying investments are determined through a consultation with the client. Our firm offers individualized investment advice to our Wrap Asset Management clients. General investment advice will be offered to our Financial Planning & Consulting, Retirement Plan Consulting, Referrals to Third Party Money Management clients. Clients are permitted to place reasonable restrictions, or make reasonable modifications to existing restrictions, regarding the management of their Wrap Program account. Please refer to our Form ADV Appendix 1 “Wrap Program Brochure” for additional information concerning the Wrap Program. E. Amount of Client Assets Managed As of December 31, 2023, the total amount of client assets under management by Sterling Financial Group was $321,957,763. Detailed breakdown as follows: Regulatory Assets Under Management Type of Account Assets Under Management Discretionary $ 311,031,852 Non-Discretionary $ 10,925,911 Total: $321,957,763