A. Description of the Advisory Firm IVC Wealth Advisors LLC (hereinafter “IVCWA”) is a Limited Liability Partnership organized in the State of Pennsylvania. The firm was formed in November 2014, and the principal owner is Eric Vaughn Landes. B. Types of Advisory Services Portfolio Management Services IVCWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. IVCWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring IVCWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. IVCWA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. IVCWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of IVCWA’s economic, investment or other financial interests. To meet its fiduciary obligations, IVCWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, IVCWA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is IVCWA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services IVCWA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Charles Schwab's Intelligent Portfolios platform We offer an automated investment program (the “program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. The client's portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We us the Institutional Intelligent Portfolios Platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the program. We are independent of and not owned by, affiliated with, or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client's vestment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the "System"). [(Option 1) The System includes an online questionnaire that can help us determine the client's investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that, if we use the online questionnaire, we will commend a portfolio via the System in response to the client's answers to the online questionnaire.] [(Option 2) based on information the client provides to us, we will recommend a portfolio via the System.] The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client's portfolio on ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). [We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab.] Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including

(i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client's brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client's brokerage account for services Schwab provides; and (iv) remuneration Schwab receives from the market centers where it routes ETF trade orders for execution. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of the clients’ assets in the Program. The fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. Selection of Other Advisors From time to time, IVC Wealth Advisors, LLC may recommend that our clients use the services of a third-party money manager ("TPMM") to manage all, or a portion of, their investment portfolio. After gathering information about our clients’ financial situation and objectives, we may recommend that our clients engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, our clients’ financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM's performance to ensure its management and investment style are consistent with our clients’ investment goals and objectives. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate our clients’ assets to other TPMM(s) where we deem such action appropriate. Platform Provider and Subadvisory Arrangement with Vise We have engaged Vise as a platform provider and subadvisor to assist with managing certain clients’ investment portfolios. We maintain discretionary authority to hire and fire Vise. Vise employs automated asset allocation, portfolio analysis, tax management, portfolio rebalancing, and portfolio selection strategies for intermediaries, including us. As part of the service, we are granted access to Vise’s secure website as a tool to monitor and manage client assets. We use Vise’s interactive online platform to create and manage a desired investment strategy for clients. Among other features, Vise’s platform allows us to customize how much exposure to take with respect to specific factors (known as an “active tilt”) such as value, dividend, and size. Vise bases its advice on client investment objectives, restrictions, and preferences, as provided by us and in accordance with the agreements we have entered with Vise. Clients do not have direct access to the Vise platform, and we are responsible for the management of the client’s assets on the Vise platform. Clients must notify us of any specific stocks or securities in which the client is prohibited from investing, and we, in turn, are responsible for notifying Vise. Vise does not verify any information they receive from us or our agent(s) for accuracy. It is our responsibility to promptly notify Vise if there are ever any changes in our client's financial situation or investment objectives. For more information concerning Vise’s investment methods, fees, and risks, please see the Vise Form ADV Brochure. Services Limited to Specific Types of Investments IVCWA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities and non-U.S. securities. IVCWA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions IVCWA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by IVCWA on behalf of the client. IVCWA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. We factor in tax consequences as it relates to asset management. We can customize, at the account level, "do not sell" restrictions on specific holdings. We will also accommodate those clients who wish to be socially conscience investors. These special considerations are identified in the client's investment policy statement. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent IVCWA from properly servicing the client account, or if the restrictions would require IVCWA to deviate from its standard suite of services, IVCWA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. IVCWA does not participate in wrap fee programs. E. Assets Under Management IVCWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 357,491,401.00 $ 460,495.00 December 2023