Copper Leaf Financial, LLC (hereinafter “Copper Leaf”) is owned by John W. Davis and Bret L. Hodgdon has been providing advisory services since 2016. As of December 31, 2023, Copper Leaf managed $189,173,652 on a discretionary basis and none on a non- discretionary basis. We also have $10,061,761 of assets under advisement for participant- directed retirement plans. Copper Leaf’s investment advisory services are offered through a comprehensive wealth management process centered around holistic financial planning. The process involves the following steps: Discovery: Exploration and identification of values, goals, circumstances and data. Investment Analysis: Preparation of analysis and development of an Investment Policy Statement outlining a client’s current financial situation relative to goals and objectives. Development of Investment Plan: Selection of a portfolio and strategies that will correspond with a client’s specific situation and objectives. Implementation: Providing for transition and on-going services for the management of client accounts in accordance with investment and wealth objectives. Regular Progress Meetings: Contact with clients to determine if financial circumstances or investment and wealth objectives have changed requiring alternative strategy. Advanced Planning: Meeting client’s financial priorities beyond the basics, including life transitions, wealth transfer, wealth protection, charitable giving, etc. Wealth Management Services Copper Leaf is a fee-only financial planning and investment advisory firm, providing personalized, comprehensive wealth management services to individuals, families, trusts, charitable organizations, pensions and corporations who seek an in-depth, on-going, long term relationship with a trusted guide in financial matters. Three major components make up our approach to wealth management: holistic financial planning, investment management, and advanced planning. All wealth management services at Copper Leaf begin with financial planning through a thorough analysis of all aspects of a client’s existing financial circumstances, investment portfolios, savings, cash flow, aspirations & goals, taxes, retirement plans, liabilities, estate plans, etc. Financial Planning Services: In order to provide true wealth management, Copper Leaf requires each wealth management client to complete an initial financial plan. Our financial planning process is designed to help clients identify life goals, analyze the financial impact of choices, and determine how we may help prudently accomplish client’s objectives. We achieve this through the planning process described above, which involves gathering information and data, interviews designed to uncover and identify a client’s true goals, objectives, aspirations and priorities, and a comprehensive analysis and review. In general, the financial plan provides the foundation for all investment recommendations and decisions moving forward. Investment Management Services: Investment management and consulting is the astute management of investments over time to assist our clients in achieving their financial goals based on our initial and on-going planning work. It requires that Copper Leaf deeply understand our clients’ most important challenges and then design an investment plan that takes clients’ entire situation, time- frame and tolerance for risk into account, and that describes an approach that will maximize clients’ probability of achieving those unique goals. Investment management services include, but are not limited to, the following: Investment Strategy, Personal Investment Policy, Asset Allocation, Asset Selection, Asset Location, Risk Tolerance, Regular Portfolio Monitoring, Rebalancing, Tax-Loss Harvesting Copper Leaf designs a written investment policy statement (IPS) for each client, which outlines the client’s current situation and a plan to aid in the selection of a portfolio that matches each client’s specific needs. Copper Leaf uses financial planning and investment advisory software and processes to further examine the client’s objectives, risk parameters, liquidity needs, time horizons, tax circumstances, and family dynamics. Additional discussions and analysis may examine topics including income and cash flow requirements, business holdings and exit strategies, investments (including retirement accounts and retirement income resources), philanthropy, insurance, income tax and estate and legacy planning, pre-retirement preparation, retirement income planning and sustainability analysis. The client’s existing investments and activities will then be evaluated with respect to the client’s investment policy statement and plan. Copper Leaf will work with new clients to develop a plan to transition from any existing portfolio to the portfolio and strategies recommended by Copper Leaf. The client’s financial plan and IPS is dynamic and will be updated as appropriate and as circumstances change. Copper Leaf will then continuously monitor the client’s portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the strategies and accounts as necessary. Copper Leaf will typically create a portfolio of no-load mutual funds and exchange traded funds (ETFs) and may use model portfolios if the models match the client's investment policy. Copper Leaf will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. Copper Leaf primarily recommends portfolios consisting of passively managed asset class and index mutual funds or exchange-traded funds (ETFs). Copper Leaf primarily

recommends securities offered by Dimensional Fund Advisors (DFA), AQR, Bridgeway, Stone Ridge and Vanguard. DFA and Vanguard sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. Copper Leaf manages portfolios on a discretionary basis according to the investment policy selected by the client. A client may impose any reasonable restrictions on Copper Leaf’s discretionary authority, including restrictions on the types of securities in which Copper Leaf may invest client’s assets and on specific securities, which the client may believe to be appropriate. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). Copper Leaf may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds or fixed income securities. Copper Leaf will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, Cooper Leaf will retain an independent separate account manager (“Independent Manager”) for the management of client portfolios. The Independent Manager will be provided with the discretionary authority to invest client assets in securities consistent with the client’s Investment Policy Statement. The Independent Manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). Copper Leaf has retained Buckingham Strategic Partners (“BSP”) as its primary Independent Manager. In certain circumstances, Copper Leaf will pursue other investment strategies on behalf of the client and can retain Parametric Portfolio Associates LLC to create other strategies to assist with tax management or other individual client needs. Parametric Portfolio Associates LLC is an unaffiliated third-party sub-adviser. On an ongoing basis, Copper Leaf will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. Copper Leaf will periodically, and at least annually, review client’s investment policy, risk profile and discuss the re-balancing of each client’s accounts to the extent appropriate. Copper Leaf will provide to the Independent Manager any updated client financial information or account restrictions necessary for Independent Manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, Copper Leaf may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and estate planning & trust designs, among other things. Copper Leaf does not participate in or sponsor any wrap fee programs. Copper Leaf does not sell insurance or commissioned investment products, nor does it accept commissions as a result of any product recommendations. Copper Leaf does not pay referral or finders fees. Copper Leaf does not prepare taxes, but may refer clients to our affiliate, Davis & Hodgdon Associates CPAS PLC (see further below in Item 10). Copper Leaf will also work with any other advisors who provide our clients with professional advice. Copper Leaf provides consulting to businesses or non-profit clients for retirement plan evaluation, investment analysis, investment advice, etc. Employee Benefit Retirement Plan Services: Copper Leaf also provides advisory services to participant-directed employee retirement benefit plans through third party administrative services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. Copper Leaf will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Copper Leaf will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. Copper Leaf may refer clients to Davis and Hodgdon Associates, and clients may choose to engage Davis and Hodgdon to prepare analysis, consulting, or recommendations regarding employer sponsored retirement plans. Clients are responsible for any fees payable to Davis and Hodgdon. For certain retirement plans, Copper Leaf also works in coordination and support with Buckingham Strategic Partners, LLC. (Please see Item 10). Retirement plan clients will engage both Copper Leaf and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. Copper Leaf will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.