A. Description of the Advisory Firm ValueWealth Services, LLC is a Limited Liability Company organized in the state of Maryland. This firm was formed in the year 2004, and the principal owner is Peter Wyrough. B. Types of Advisory Services ValueWealth Services, LLC (hereinafter “VALUEWEALTH SERVICES, LLC”) offers the following services to advisory clients: Investment Supervisory Services VALUEWEALTH SERVICES, LLC offers ongoing portfolio management services and institutional consulting services based on the individual goals, return/income, objectives, time horizon, tax status, liquidity needs and risk tolerance of each client. VALUEWEALTH SERVICES, LLC creates an Investment Plan for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a strategy to aid in the selection of a portfolio that matches the client’s situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment plan • Asset allocation • Client or portfolio consultation • Risk tolerance • Regular portfolio monitoring • Sector Selection • Financial Planning VALUEWEALTH SERVICES, LLC 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 determined via communication with their clients. Selection of Investment Managers and Strategies We can direct clients to ValueWealth Services, LLC for implementation of selected investment management portfolios and strategies. Services Limited to Specific Types of Investments VALUEWEALTH SERVICES, LLC generally limits its money management to mutual funds, individual equities, options, equity-linked CDs, structured notes, and ETF/Ns. VALUEWEALTH SERVICES, LLC may use other securities as well to help diversify a portfolio when applicable. Sub-Advisor Services/Third Party Investment Advisory Services VALUEWEALTH SERVICES, LLC may also use and/or act as a sub-advisor to advisors unaffiliated with VALUEWEALTH SERVICES, LLC. These third-party advisors would outsource portfolio management and/or portfolio strategist services to VALUEWEALTH SERVICES, LLC. This relationship will be memorialized in each contract between VALUEWEALTH SERVICES, LLC and the third-party advisor. FeeX is a Third Party Investment money manger that can be utilized by VALUEWEALTH SERVICES, LLC and its IAR’s Financial Planning and Consultation

Services VALUEWEALTH SERVICES, LLC’S investment management services may include the analysis of a client’s situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help meet specific financial objectives. VALUEWEALTH SERVICES, LLC’S financial planning and consulting services may include many services including but not limited to: existing portfolio evaluation, income planning strategies, debt analysis, and cash flow. In performing these services, VALUEWEALTH SERVICES, LLC is not required to verify any information received from client or from the client’s other professionals (e.g. attorneys, accountants, etc.) and is expressly authorized to rely on such information. VALUEWEALTH SERVICES, LLC may recommend clients, engage the Firm for additional related services. Clients are advised that a conflict of interest exists if clients engage VALUEWEALTH SERVICES, LLC to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by VALUEWEALTH SERVICES, LLC under a financial planning or consulting engagement. C. Client Tailored Services and Client Imposed Restrictions VALUEWEALTH SERVICES, LLC offers a similar suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon ValueWealth Services, LLC and client’s investment outlook which takes into account each client’s situation as described in the Investment Supervisory Services under Item 4. 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 VALUEWEALTH SERVICES, LLC from properly servicing the client account, or if the restrictions would require VALUEWEALTH SERVICES, LLC to deviate from its standard suite of services, VALUEWEALTH SERVICES, LLC reserves the right to review and/or 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, fund expenses, and any other administrative/platform fees. VALUEWEALTH SERVICES, LLC does not participate wrap fee programs. E. Amounts Under Management VALUEWEALTH SERVICES, LLC has the following approximate assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 196,905,039.00 0 December 2023