5 Third-party Advisory. Finally, APIA may recommend individuals to third-party investment advisers. Before recommending other advisers for such individuals APIA will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where required. Individuals will, after such recommendation by APIA, enter into a separate advisory agreement with the third-party investment adviser and receive any required disclosures from the third-party investment adviser. APIA will not monitor the performance or strategy implemented by such third-party investment advisor. APIA will typically receive a fee from third-party advisers to which it refers clients. See Item 14, below. In all cases, APIA provides investment decisions in accordance with the fiduciary duties owed to its accounts and without consideration of APIA’s economic, investment or other financial interests. To meet its fiduciary obligations, APIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, APIA’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 APIA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Advisory Services for Employee Benefit Plan Clients In certain cases, APIA offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) on a non-discretionary or discretionary basis. APIA provides advice with respect to such matters as: (1) identifying with plan fiduciaries the plan’s investment objectives and restrictions; (2) recommending or selecting, as engaged, money managers to manage plan assets in ways designed to achieve objectives; (3) recommending, in the case of non-discretionary consulting, or selecting, in the case of discretionary consulting, investments (e.g. mutual funds, ETFs or other investment vehicles) available to plan participants; (4) monitoring performance of money managers and investments and making recommendations for changes; (5) advising on the selection of other service providers, such as record keeper, custodian, administrator and/or broker-dealer; and (6) providing participant financial education, including webinars, newsletters and, where requested, virtual or in person access to advisors. In addition, when providing discretionary services, APIA will select investments for the plan, replace and rebalance investments, and manage model portfolios, if any, available through the plan. In other cases, APIA may direct clients to third-party investment advisers. Before selecting other advisers for clients, APIA will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where required. Clients will enter

into a separate advisory agreement with the third-party investment adviser and receive the separate disclosure brochure of any selected third-party investment adviser. Financial Planning and Consulting Financial planning and consulting may include but are not limited to: investment planning; estate planning; life insurance; retirement planning; college planning; investment due diligence; and cash flow planning. Educational Workshops and Seminars APIA provides educational workshops and seminars for groups desiring general advice on investments and personal finance. Topics may include issues related to financial planning, educational and estate planning, or various other economic and investment topics. Information presented will NOT be based on any one person’s need nor does APIA provide individualized investment advice to attendees during our general sessions. Services Limited to Specific Types of Investments When managing portfolios, APIA generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities, ETFs, and treasury inflation protected/inflation linked bonds. APIA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions APIA will tailor a program for each individual client. APIA may use “model portfolios” together with a specific set of recommendations for each client based on the client’s personal restrictions, needs, and targets. Depending on the specific engagement, APIA may review cash flow needs, tax status, stage of life, and estate planning considerations in addition to gathering information on a client's risk tolerance. Depending on the advisory services provided to the client, the client generally may impose reasonable restrictions on investing in certain securities or groups of securities. 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 other administrative fees. APIA does not participate in any wrap fee programs. E. Assets Under Management APIA has the following assets under management: Discretionary Amounts Non-Discretionary Amounts Date Calculated $142,879,000 $229,134,000 02/16/2023 A. Fee Schedule Fees for Individual Wealth Management Clients Advisory Services. APIA’s fees for these services are negotiable depending on the specific type of investment management services to be rendered (as detailed in the Agreement), but generally will be calculated as a percentage of total assets under management according to the following schedule: Total Assets Under Management Maximum Annual Fee $0 - $500,000 2.50% %500,001 - $1,000,000 2.00% $1,000,001 - $2,000,000 1.5% $2,000,001 - $5,000,000 1.25% $5,000,000 - $10,000,000 1.00% $10,000,001 – And Up 0.65%