A. Description of the Advisory Firm Seros Financial, LLC is a Limited Liability Company organized in the state of Arizona. The entity was formed in August of 2011. The principal owner is Jeremy Windell Smith. B. Types of Advisory Services Seros Financial, LLC (hereinafter “Seros”) offers the following services to advisory clients: Portfolio Management Services In providing portfolio management services to your account, your Investment Advisor Representative (IAR) may utilize one or several programs that Seros Financial has authorized through relationships with other financial service firms that are custodians and/or registered investment advisors. Seros Financial has agreements with these financial service firms to provide custodial services, brokerage services, investment management services and reporting/billing services, which are further described as follows:
• Custodial services that involve the safekeeping of your assets in an account for your benefit.
• Brokerage services that involve the buying and selling of investments in your account.
• Investment management services that involve the management of assets for your benefit.
• Reporting/Billing services that involve account related reporting and fee billing for various fees. Portfolio Management Programs can be provided in different capacities. Below is a brief description of the main types of programs. A more detailed description is provided further down in this section. The brief descriptions are as follows:
• Managed Accounts: Managed accounts are accounts that are held at custodians (sometimes referred as Third-Party Custodians). Currently, Seros utilizes the institutional divisions of the following custodians: Charles Schwab and Axos Advisor Services. Custodians may be pre-designated by the retirement plan sponsor or the employer of the retirement plan. These accounts are typically referred to as Self- Directed Accounts.
• Directly Held Managed Accounts: In limited situations, an IAR may also provide portfolio management services to clients who have pre-existing accounts held directly at product sponsors such as mutual fund and variable annuity companies.
• Third Party Money Manager (TPMM) Services: These arrangements involve the utilization of a TPMM to primarily assist with investment management services. In any of the aforementioned Portfolio Management Programs, the client will enter into an investment advisory agreement (This term may vary and can also be referred to as the Investment Management Services Agreement, Client Services Agreement, Investment Advisory Agreement, etc.) with Seros Financial. Managed Accounts IAR’s may also open and manage accounts at one or more authorized Custodians, who are also registered broker/dealers that act in the capacity of a custodian and are not affiliated with Seros Financial. The Custodians provides safekeeping of your assets along with varying levels of custodial service and support to both you and your IAR. Selection of Other Advisors Seros may direct clients to other investment advisors commonly referred as Third Party Money Managers (TPMM). Seros will be compensated via a fee share from the advisors to which it directs to those clients. This Relationship will be disclosed in each contract between Seros and the client. The fees shares will not exceed any limit imposed by any regulatory agency. Before selecting TPMM for clients, Seros will always ensure those TPMM are properly licensed or registered as investment advisor. TPMM services may be offered in different ways, but they are primarily offered in the following manner:
• Solicitor Arrangements (aka Referral Model): These are arrangements where the IAR refers you to a TPMM to manage your account. The IAR receives a solicitor fee from the TPMM for referring the business.
• Strategist Arrangements (aka Sub-Advisor or Advisor Platform): These are arrangements where the IAR may utilize one or more TPMMs to manage a client’s account or a portion of a client’s account. In these cases, this is not a solicitor arrangement and there is no solicitor fee. In some cases, these strategist arrangements are facilitated as part of a platform that may also involve the use of Separately Managed Accounts (SMAs) and/or Unified Managed Accounts (UMAs). Financial Planning and Consulting Services Pursuant to a Financial Planning & Consultation Services Agreement, your IAR will meet with you to gather important financial information, outline financial goals, identify financial problems, assess investment risk tolerance and define investment objectives based on the specific needs, whether you are an individual or business. Areas for discussion and planning for individuals may focus on cash flow management, taxes, children’s education funding and goals, retirement and/or estate planning. Areas for discussion and planning for businesses may focus on cash flow management, taxes, employee benefits, and/or succession planning. IAR’s will gather specific financial information from you in order to provide you with a written

financial plan or provide ongoing consulting services. Generally, such financial planning & consulting services involve the preparation & delivery of a financial plan. However, in other cases this service can also be to merely provide you various financial analyses through various reports (such as asset allocation, risk assessments, retirement income planning, securities analysis, cash flow analysis, budgeting, etc.). Or, in other cases, the service can also be to merely provide you advice, insights and guidance to consult you on your financial needs, circumstances and objectives in conjunction with actionable items that you may have to execute on your own (such as managing your participant account at an employer retirement plan (i.e., 401k or 403b). Analyses may encompass a variety of factors, including but not limited to, current and anticipated assets and liabilities, insurance, savings, investments and anticipated retirement or other employee benefits (such as 401k, 403b, pensions, etc.). The advisor has the discretion to provide all of the aforementioned services, in whole or in part, based on your specific needs & objectives. The specific financial planning arrangement will be agreed upon by you and your IAR in accordance to a Financial Planning & Consultation Services Agreement. Retirement Plan Services 1. Seros has the ability to and may provide fiduciary and/or non-fiduciary services to retirement plans (i.e., 401k, 403b, etc.). Retirement plans may or may not be subject to the U.S. Department of Labor’s Employee Retirement Income Security Act (ERISA). Regardless of whether the retirement plan is subject to ERISA, IAR’s are capable of providing services to a retirement plan. 2. Retirement plan documents typically designate one or more persons, such as the plan trustee(s), to undertake fiduciary responsibility for the operation of the retirement plan. Such persons are known as Responsible Plan Fiduciaries (RPFs). Pursuant to a Retirement Plan Services Agreement (RPSA), an IAR can offer the following types of services to a retirement plan. Please refer to the agreement for a more detailed description of these different types of services. a. ERISA Fiduciary Services
• Selection of Investments
• Assessment of Investments
• Participant Investment Advice
• Investment Policy Statement Individually Designed
• Investment Policy Statement Review
• Performance Monitoring b. Non-ERISA Fiduciary Services
• Third Party Service Provider Liaison
• Employee Enrollment
• Employee Education
• Vendor Review/Conversion 3. IAR is not permitted to act in the capacity of an RPF on behalf of a client’s retirement plan. Services Limited to Specific Types of Investments Seros generally limits its investment advice to mutual funds, equities, bonds, fixed income, REITs, insurance products including annuities, and government securities. Seros may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Seros offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. 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 any other administrative fees. Seros does not participate in any wrap fee programs. E. Amounts Under Management Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $245,643,113.00 $15,198,384.00 December 2023