Vita Planning Group LLC (“Vita Planning Group”) is a Limited Liability Company located in and organized under the laws of the State of Washington. The firm is principally owned by Karl E. Hansen and Erik H. Hansen. Vita Planning Group LLC primarily offers its advisory services under the name Vita Planning Group LLC (“Vita Planning Group”). Karl E. Hansen and Erik H. Hansen are also principal owners of Vita Insurance Associates, Inc., which operates in the Employee Benefits industry and shares some of its employees with Vita Planning Group. A. Retirement Plan Advisory and Consulting Services The following is a description of the advisory services offered by Vita Planning Group: Vita Planning Group provides advisory services to retirement plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), that are participant-directed defined contribution plans, such as 401(k) plans and 403(b) plans covered under ERISA (“ERISA Plan Clients”). Vita Planning Group may also provide services to Section 457 plans and 403(b) plans not covered under ERISA (“non-ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory or management agreement with Vita Planning Group describing the services that Vita Planning Group will perform for the ERISA plan and its participants. Vita Planning Group provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. Vita Planning Group enters into similar investment advisory or management agreements with non-ERISA Plan Clients, except that the references to ERISA rules described below do not apply in the case of services provided by Vita Planning Group to non-ERISA Plan Clients. ERISA Fiduciary Services Vita Planning Group provides ERISA fiduciary services either as a discretionary investment manager or a non-discretionary investment adviser. Vita Planning Group provides similar fiduciary investment services to non-ERISA Plan Clients. Investment Management Services Vita Planning Group provides investment management services to Non-ERISA Plan Clients and to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity, Vita Planning Group’s investment decisions are made in its sole discretion without the plan client’s prior approval. Each plan client who engages Vita Planning Group to perform investment management services is required to enter into an investment management agreement. Vita Planning Group’s investment management services include developing and implementing an investment policy statement; selecting from a broad range of investment options consistent with ERISA Section 404(c); making decisions about the selection, retention, removal and addition of investment options; providing periodic reporting of investment performance and results; and if the ERISA Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment(s) that will serve as a QDIA. Investment Advisory Services Vita Planning Group also provides 3(21) qualified retirement plan consulting investment advisory services on a nondiscretionary basis and in that capacity, the plan client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of Vita Planning Group’s recommendations or advice. Each plan client who engages Vita Planning Group to perform nondiscretionary investment advisory services is required to enter into an investment advisory agreement. Vita Planning Group’s nondiscretionary investment advisory services include assisting the plan client in developing and implementing an investment policy statement; assisting the ERISA Plan Client in selecting from a broad range of investment options consistent with ERISA Section 404(c); assisting the plan client in making decisions about the selection, retention, removal and addition of investment options, meeting periodically to discuss Vita Planning Group’s investment recommendations; and if the ERISA Client has determined that the Plan should have a QDIA for participants who fail to make an investment election, assisting in the selection of the investment(s) that will serve as a QDIA. The investment options recommended by Vita Planning Group may include managed portfolios developed by Vita Planning Group that use the plan’s investment options. If the plan client decides to use a Vita Planning Group managed portfolio, then Vita Planning Group has full discretionary authority over investment management of the assets invested in the Vita Planning Group managed portfolios including, but not limited to, determination of the asset class allocations and selection of the underlying investments for each portfolio, adjustment of the asset class allocations, and the addition, removal, or modification of the underlying investments. If Vita Planning Group managed portfolios are offered as plan investment options, it will not result in additional compensation to Vita Planning Group. Non-Fiduciary Services Vita Planning Group may also provide non-fiduciary services to ERISA Plan Clients and Non- ERISA Plan Clients or alternatively, may arrange for the plan’s other providers to offer these services, as agreed upon between Vita Planning Group and the plan client. Vita Planning Group’s non-fiduciary services to plan clients include assisting in group enrollment meetings, educating plan participants about general investment principles and the investment alternatives under the plan and educating the plan client as to its fiduciary responsibilities. Vita Planning Group’s nonfiduciary services may also include assisting the plan client in monitoring, selecting and supervising service vendors, performing benchmarking studies and fee analysis, and assisting the ERISA Plan Client in obtaining information needed to prepare the participant disclosures required under ERISA Regulations Section 2550.404a-5, provided that Vita Planning Group is not responsible for verifying the accuracy and completeness of the information provided. For a more detailed description of Vita Planning Group’s fiduciary and non-fiduciary services, the ERISA Plan Client and the non-ERISA Plan Client should refer to the investment advisory agreement or investment management agreement, depending on the business/advisor type. General Information about Advisory Services For each of the above disclosed advisory and management services, Vita Planning Group does not limit its investment recommendations to any specific type of product or security. Vita Planning Group considers the universe

of investment options open to retirement plans. A client’s individual needs and objectives are analyzed to determine appropriate investments and products for the client. Since different types of investments typically involve different types of risk, the firm conducts a risk analysis of the participant population, before recommending a certain investment array. Vita Planning Group manages assets on either a discretionary or non-discretionary basis, and the client is always free to place reasonable restrictions on the types of investments the firm recommends for the client’s portfolio. Vita Planning Group generally recommends an investment allocation consisting of mutual funds, stable value funds, and collective trusts, but other options, including but not limited to exchange traded funds, may be considered if appropriate for a client. Vita Planning Group endeavors at all times to only recommend investments that it feels are suitable for a given client, and the firm makes reasonable efforts to describe in detail any conflicts of interest that may exist. Clients should be aware that all securities investments involve risk, including the possible loss of all or part of an investment. Clients who elect to invest in securities must be willing to bear this risk. Adviser does not participate in any wrap fee programs. As of December 31, 2023, we had a total of $971,926,509 in assets under advisement. Summer Student Loan Certain pre-qualified clients may receive sponsorship free of cost to the Summer Student Loan services program. This sponsorship applies from March 2024 through February 2025. B. Active Asset Management - Tailored Asset Management Services As part of the active asset management process, we will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and tailor a portfolio with appropriate asset allocations and investment strategy(ies). Our recommendations and ongoing management are based upon your investment goals, objectives, and risk tolerance. We will monitor the account, trade as necessary, and communicate regularly with you. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. * Please note that pursuant to the investment advisory agreement you are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. * You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks, or other securities. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. Additionally, trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Periodically, your account may need to be rebalanced or reallocated in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur as required or pursuant to the schedule we have determined together. You will be responsible for all tax consequences resulting from the sale of any security, rebalancing, or reallocation of the account. You are responsible for any taxable events in these instances. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. C. Financial Planning We may provide individualized services to you such as comprehensive financial planning, estate planning, business planning and educational planning. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of virtual or face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant, or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms, and conditions of the relationship. You will also receive this Brochure. You may implement your financial plan through any financial organization of your choice. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. As of December 31, 2023, we had a total of $42,791,471 in discretionary assets under management.