Description of Advisory Firm O’Brien Investment Management, LLC (“O’Brien,” “we,” “our,” or “us”) is a privately-owned Limited Liability Company headquartered in Torrance, California. O’Brien is a registered investment adviser with the US Securities & Exchange Commission, with state “notice” filings in CA, AZ and WA. O’Brien was founded in April of 2016 by Michael O’Brien. Advisory Services Offered O’Brien provides investment management services on a discretionary basis. Mr. O’Brien works with clients and has the ongoing responsibility to take action in client accounts, based upon the objectives of the client, as to specific securities or other investments that they purchase or sell in client accounts. Our investment advice and services cover all investments held in custodial accounts that we manage for you. Recommendations for new investments will typically include equity securities, and equity oriented mutual funds and exchange traded funds (ETFs), including stocks and foreign securities listed on US exchanges (ADRs) or foreign exchanges (ordinaries). In addition, O’Brien may recommend fixed income securities fixed income oriented mutual funds and ETFs, including corporate and government bonds, money market funds and cash. There may also be additional types of investments that O’Brien will provide advice on if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. Held Away Accounts Certain Client Accounts subject to Advisor’s services under this Agreement may be held at a custodian that is not directly accessible by the Advisor (“Held Away Accounts”). Advisor may, but is not required to, manage these

Held Away Accounts using the Pontera Order Management System (“Pontera”) that allows Advisor to view and manage these assets. We use a third-party platform (Pontera Order Management System) to facilitate management of held away assets such as 401k, 403b, 529 and defined contribution plan participant accounts, with discretion. The platform provides us with ability to manage Client funds in these accounts through indirect access. We do not have direct access to Client log-in credentials to affect trades, and we do not have custody of the accounts or funds. We subscribe to, but are not affiliated with the platform in any way and receive no compensation from them for using their platform. In order to facilitate use of the platform, a link will be provided to the Client allowing them to connect an account(s) to the platform. The Client is under no obligation to connect an account to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider client objectives, risk criteria, current economic and market trends. The goal is to manage account in the best interest of the Client. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Assets Under Management O’Brien manages client assets in discretionary accounts on a continuous and regular basis. O’Brien currently has approximately $150mm to $200mm in regulatory assets under management. Wrap Fee Programs O’Brien does not sponsor or participate in wrap fee programs.