The Advisor and its affiliates operate under the trade name “WEA Member Benefits.” The Advisor, founded in July 2007, is a wholly owned subsidiary of WEA Member Benefit Trust, a trust created to provide individual financial products and services to public school employees and their family members. In general, eligibility for Advisor products and services is limited to public school employees and their family members, subject to certain restrictions and limitations. Services Offered The Advisor is a fee-based investment advisory company offering the following services, billed at an hourly rate: Portfolio Analysis, Retirement Income Projection, Retirement Income Analysis, and ad-hoc hourly consulting. The Advisor also offers Personal Investment Accounts as well as WEA Model Portfolios. The services provided by the Advisor and described in this Brochure are limited to public school employees and their family members, subject to certain restrictions and limitations. A complimentary one-hour (or less) consultation with the Advisor is available to eligible members who would like to discuss asset allocation, retirement savings goals, and/or retirement savings options. We include a complimentary online financial planning portal for WEA TSA Trust 403(b) participants to supplement these consultations. A description of the fee-based services offered by the Advisor is set forth below. Portfolio Analysis The Advisor provides clients with an evaluation of their current investment portfolio(s) and recommended adjustments, if necessary, to align the client’s portfolio with their financial goals, tolerance for risk, and investment objectives. Prior to making recommendations, the client is required to complete an Investor Suitability Profile Questionnaire. Using information from this questionnaire, the Advisor will prepare a Morningstar® Advisor report which, in turn, assists the Advisor with an evaluation of the client’s current portfolio regarding performance, fees, investment style, and investment management. This service does not involve the Advisor making any purchases or sales of securities or other investments on behalf of the client. Rather, purchases or sales of any investment to implement the Advisor's recommendations must be completed by the client, unless the client chooses one of the other services offered by the Advisor (described below) that involve implementation of investment recommendations. Retirement Income Projection A retirement planning tool suitable for clients who are 11–20 years away from retirement. This service provides clients with (i) a projection of retirement expenses, (ii) a Wisconsin Retirement System (“WRS”) pension benefit estimate for the annuity option beginning at the retirement date provided by the client, (iii) a Social Security benefit estimate beginning at the age provided by the client, and (iv) a projection of other retirement income sources (if any) provided by the client. Retirement Income Analysis A retirement planning tool suitable for clients who are within 10 years of retirement or already retired. This service provides clients with a personal meeting with the Advisor for the purpose of: (i) acquiring data concerning client’s assets, liabilities, present and anticipated expenses, present and anticipated obligations, and present and future retirement income and financial goals through the use of an Investor Suitability Profile Questionnaire; (ii) providing the client with an evaluation of the client’s employer-provided retirement benefits, an evaluation and projection of retirement expenses, a WRS benefit estimate and annuity option suggestion, a Social Security benefit estimate and a recommendation at what age to begin, and an evaluation and projection of the client’s other retirement income sources; (iii) providing the client with a summary and general asset allocation strategy (additional information may be required to determine suitability of a particular asset allocation strategy and the client’s risk tolerance level); (iv) providing the client with an estimate of the client’s financial position at retirement; and (v) making recommendations to accomplish the client’s stated retirement objectives. This service does not involve the Advisor making any purchases or sales of securities or other investments on behalf of the client. Rather, purchases or sales of any investment to implement the Advisor's recommendations must be completed by the client, unless the client chooses one of the other services offered by the Advisor (described below) that involve implementation of investment recommendations. Ad-Hoc Hourly Consulting Ad-hoc hourly consulting is available for clients who want the Advisor to perform work outside of the pre- determined services described above. Personal Investment Accounts Model-based accounts managed by the Advisor and held in custody at American Trust Custody, a FINRA-registered broker-dealer and qualified custodian. To set up a Personal Investment Account, clients are required to enter into a Client Service Agreement with the Advisor and a Custodial Agreement with American Trust Custody. Prior to opening a Personal Investment Account, the client must complete an Investor Suitability Profile Questionnaire. The Advisor uses this completed risk profile assessment to discuss with the client the various asset allocation models available under the Personal Investment Accounts program, which include the Ultra Conservative,

Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive models (each, a “PIA Model Portfolio”). The client, either independently or with the Advisor’s assistance, selects one PIA Model Portfolio per account from the various models offered by the Advisor. The client has the option to select a PIA Model Portfolio that does not match their own personal tolerance for risk on the Investor Suitability Profile Questionnaire; an example is an account opened to provide a legacy for heirs. PIA Model Portfolios are managed separately from the WEA Model Portfolios (discussed below). Investments in the PIA Model Portfolios consist solely of investments in pre-screened mutual funds and exchange traded funds (“ETFs”) selected by the Advisor. For all Personal Investment Accounts, a reasonable amount of cash will be reserved and maintained for administrative purposes. This cash amount will not exceed 1% of the total portfolio value. The client has the option to reduce the percentage of the account held in cash by notifying the Advisor. The cash amount is not part of the investible model, and its level is reconciled at portfolio rebalance. Cash balances are included in the account balance for the purposes of calculating assets under management and administrative fees. See Item 5 for information regarding fees. The Advisor periodically reviews the mutual funds and ETFs within each PIA Model Portfolio and makes changes thereto as the Advisor deems appropriate, including rebalancing at least annually (which may have tax consequences for the client). By selecting a Personal Investment Account, the client gives the Advisor the authority to affect any such changes. The Advisor will contact each client enrolled in the Personal Investment Accounts program at least annually to ensure that the PIA Model Portfolio selected by the client is still meeting the client’s needs. The Advisor may require the client to complete a new risk profile assessment at such time. As part of the Personal Investment Account program, clients have the option to meet in-person or by phone with the Advisor to discuss investment goals, income needs and tolerance for risk. In addition, clients have the option to meet with the Advisor to obtain assistance with account registration set-up and account application completion. By signing the American Trust Custody Custodial Agreement, clients consent to receive documents from American Trust Custody by electronic means. Clients generally may revoke consent to receive electronic notifications by written letter of instruction addressed to American Trust Custody and delivered to the Advisor. Clients will have access to view their Personal Investment Account online, but will not have authority to place trades, make changes to their personal information, or request distributions through this medium. Rather, any such actions must be completed through the Advisor. Our general policy is to refuse to accept an investment policy statement for clients enrolled in the Personal Investment Account program. We will, however, accept a client’s reasonable restrictions provided we can automate the restriction on our platform. If we are not able to automate the request, we will reject the account unless the restriction is removed by the client. WEA Model Portfolios Developed by the Advisor under the oversight of the WEA Member Benefits Investment Committee (the “Investment Committee”) and are available as an investment option for participants in the WEA TSA Trust 403(b) and WEA Member Benefits IRA programs. WEA Model Portfolios may be adjusted from time to time at the discretion of the Advisor and the Investment Committee. The Advisor uses Morningstar® Advisor to create the WEA Model Portfolios of pre-selected investment products that approximately complete the allocation model parameters. Prior to investing in a WEA Model Portfolio, the client is prompted to complete an Investor Suitability Profile Questionnaire to independently select the model portfolio allocation deemed to be appropriate from the available portfolios: Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive. Investments in the WEA Model Portfolios consist solely of investments in pre- screened mutual funds and the Empower Guaranteed Stable Investment group annuity contract. Although the Advisor carefully evaluates the composition of the WEA Model Portfolios on a periodic basis, the Advisor makes no representation regarding the likelihood or probability that any or all the WEA Model Portfolios will, in fact, achieve a particular investment goal or fulfill the risk tolerance profile as described for each portfolio. As a self-directed investor, clients in the WEA Model Portfolio program should carefully consider the merit and appropriateness of the available investments in light of personal financial circumstances, including other assets, income, investments, and/or cash flow needs. The Advisor recommends that clients re-assess their investment strategy at least once a year as needs, goals, portfolio, and situations may change over time. Account owners can choose a different WEA Model Portfolio at any time. Redemption fees may apply. Regulated Assets Under Management As of December 31, 2023, the Advisor managed approximately $472,404,489 in assets on a discretionary basis and $0 in assets on a non-discretionary basis.