This disclosure document is being offered to you by Keystone Financial Services (“Keystone Financial”) in connection with the investment advisory services we provide. It discloses information about the services we offer and the manner in which those services are made available to you, our client. We are an investment management firm with locations in Colorado and Arizona. Our main office is located in Loveland, Colorado. We are committed to helping you build, manage, and preserve your wealth and provide assistance to help you achieve your stated financial goals. The firm was incorporated by Joshua P. Nelson, the firm’s principal owner, in December 2010 and became registered as an investment adviser in 2020. We may offer an initial complimentary meeting; however, investment advisory services are initiated only after you and Keystone Financial execute an Investment Advisory Agreement. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES We manage advisory accounts on a discretionary basis. For discretionary accounts, once we have determined a profile and investment plan with you, we will execute the day-to-day transactions without seeking prior consent, but within the expected investment guidelines. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate your assets among individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds, and other public and private securities or investments. Portfolios will be designed to meet a particular investment goal, determined to be suitable to your circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored and rebalanced based on your individual needs, stated goals, and objectives. During personal discussions with you, we determine your objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review your prior investment history, as well as family composition and background. Based on your needs, we develop a personal profile and investment plan. We then create and manage your investments based on that plan. It is your obligation to notify us immediately if circumstances have changed with respect to your goals and financial objectives. Within our discretionary relationship, we will make changes to your portfolio, as we deem appropriate, to meet your financial objectives. We trade your portfolio based on the combination of our market views and your objectives, using our investment process. We tailor our advisory services to meet your needs and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. You have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We have limited authority to direct the custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from you. Where appropriate, we provide advice about any type of legacy position held in your portfolio. Typically, these are assets that are ineligible to be custodied at our primary custodian. You may engage us to advise on certain investment products that are not maintained at your primary custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. FINANCIAL PLANNING Through the financial planning process, our team strives to engage you in conversations around your goals, objectives, priorities, vision, and legacy for the near term and future generations. With your unique goals and circumstances in mind, our team will offer financial planning ideas and strategies to address MARCH 2024 | PAGE 5 your holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and legacy objectives. Our team partners with your other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to coordinate all parties' efforts toward your stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include:  Review and clarification of your financial goals.  Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning.  Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals.  Development of a goal-oriented investment plan, with input from various advisors, regarding tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes retirement accounts, taxable accounts, and trust accounts that require special attention.  Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits; and  Crafting and implementation of, in conjunction with your estate attorney and/or tax adviser, an estate plan to provide for you and/or your heirs in the event of incapacity or death. The firm utilizes financial planning software for your initial and ongoing financial situation. Financial reports will be provided upon your request. An annual review will be provided by the Adviser, if indicated by you and the Adviser, per the agreement. More frequent reviews occur but are not necessarily communicated to you unless immediate changes are recommended. FINANCIAL INSTITUTION CONSULTING SERVICES Keystone Financial provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s consulting services. Brokerage Customers have entered into a written advisory agreement with Keystone Financial. SMA SUB-ADVISOR (“SMA”) & THIRD-PARTY MONEY MANAGERS (TPMM) Occasionally our firm utilizes the services of a SMA or TPMM for the management of your accounts. Investment advice and trading of securities will only be offered by or through the chosen SMA or TPMM. Our firm will not offer advice on any specific securities or investments in connection with the SMA and TPMM programs. Prior to referring you, our firm will provide initial due diligence on third party money managers and ongoing reviews of their management of your accounts. To assist in the selection of a SMA or TPMM, our firm will gather your information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will periodically review third party money manager reports provided to the you at least annually. Our firm will contact you from time to time to review their financial situation and objectives; communicate information to third party money managers as warranted; and assist you in understanding and evaluating the services provided by the SMA or TPMM. You will be expected to notify our firm of any changes in your financial situation, investment objectives, or account restrictions that could affect your financial standing. Our firm takes actions on behalf of you to hire or fire third party money managers used in the implementation of your investment plan and execution of the Advisory Agreement with our firm. MARCH 2024 | PAGE 6 Therefore, the firm has the discretionary authority

to hire or fire the manager or to allocate assets among managers without obtaining your consent. The services provided by the SMA or TPMM include:  Assessment of your investment needs and objectives.  Implementation of an asset allocation.  Delivery of suitable style allocations (e.g., Large Cap, Small Cap, Growth, Value, etc.).  Facilitation of portfolio transactions.  Ongoing monitoring of investment vehicles performance.  Review of your accounts for adherence to policy guidelines and asset allocation.  Recommendations for account rebalancing, when necessary.  Reporting of your portfolio performance and progress.  Engaging selected investment vehicles on behalf of you. PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) 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 current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. RETIREMENT PLAN SERVICES For employer-sponsored retirement plans with participant-directed investments, our firm provides its advisory services as an investment advisor as defined under Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(21) investment advisor, the Plan Sponsor and our firm share fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement between our firm and the Plan Sponsor. Under the 3(21) agreement, our firm provides the following services to the Plan Sponsor:  Screen investments and make recommendations.  Monitor the investments and suggests replacement investments when appropriate.  Provide a quarterly monitoring report.  Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).  Recommend QDIA alternatives.  Recommend non-discretionary model portfolios. We can also be engaged to provide Plan Consulting Services. Plan Consulting Services includes financial education to plan participants, benchmarking the plan services, education to fiduciary committee MARCH 2024 | PAGE 7 members, and monitoring the service provider. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA, and participant education will relate to general principles for investing and information about the investment options currently in the plan. We may also participate in initial enrollment meetings and periodic workshops. DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight of retirement rollovers and transfers. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. EDUCATIONAL WORKSHOP Keystone Financial provides educational seminar sessions for those individuals who desire information on personal finance and investing. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, implications involving changes in marital status, and various other current economic or investment topics. Our workshops are educational in nature and do not involve the sale of insurance or investment products. CONSULTING SERVICES We also provide you investment advice on a more-limited basis on one-or-more isolated areas of concern such as divorce planning, estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. In these cases, you will be required to select your own investment managers, custodian and/or insurance companies for the implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies or other financial professionals ("firms"). You must independently evaluate these firms before opening an account MARCH 2024 | PAGE 8 or transacting business and have the right to effect business through any firm you choose. You have the right to choose whether to follow the consulting advice that we provide. WRAP FEE PROGRAMS We do not offer a wrap fee program. ASSETS As of December 31, 2023, our Firm manages $249,467,629 in discretionary assets under management. We do not currently have any non-discretionary assets to report.