Confluence History Confluence Wealth Services, Inc. d/b/a Confluence Financial Partners (“Confluence”) was established in 2021 and is principally owned by Confluence Financial Partners, Inc. (the “holding company”). The owners of the holding company are Gregory J. Weimer, James A. Wilding, and Gregory J. Weimer II. As a wealth management firm, Confluence is on a mission to help people plan for a brighter future by focusing on what matters most. The firm builds long-lasting, trusted relationships with clients by going all in, dedicating the team’s resources, energy, and passion into delivering value to every client. Confluence has been providing comprehensive financial planning and wealth management services to individuals, professionals, business owners, corporate executives, retirement plans and businesses since 2013. As a registered investment adviser subject to Section 206 of the Advisers Act, Confluence acts as a Fiduciary related to the conduct of its investment advisory services. As such, Confluence has an obligation to act in the best interest of its clients guided by the core fiduciary duties of loyalty and care. The firm works together to define clients’ unique financial, life, and legacy goals, then crafts a comprehensive plan carefully designed to achieve them. To support this, Confluence is focused on building a team of associates who share an uncommon passion, commitment, willingness to collaborate, and belief that improvement is always possible. Confluence Financial Partners is here to help clients maximize their lives and legacies through thoughtful financial planning, intelligent investing, continual improvement, and exceptional service. It’s believed that this has drawn clients to engage with Confluence for the advice and services that are provided, including investment advisory and wealth planning services described in more detail below. Advisory Services Wealth Management Confluence provides discretionary and non-discretionary wealth management services to a broad range of clients. Wealth management services primarily include investing client assets in proprietary investment strategies advised by the Adviser. Confluence determines the investment objectives and risk tolerance for each wealth management client during the account opening process and reassesses periodically thereafter. Once the client’s risk tolerance, time horizon and investment objective are established, Confluence will recommend a proprietary investment strategy/ies or individually design a portfolio of investments which include one or a combination of stocks, bonds, mutual funds, ETFs, options, allocation models, and other securities and/or contracts relating to the same, including investing assets in short-term money market instruments. We encourage clients to inform us in the event of any significant life changes, such as setting a retirement date, having a child, etc., so that we can perform an assessment to determine the proper investment strategy from that point forward. Typically, we review accounts internally and no less than annually with our clients, which should be sufficient given our long-term strategic approach to money management. Each client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by Confluence. Confluence’s investment strategies are primarily long-term focused, but we may buy, sell, or reallocate positions that have been held less than one year to meet the objectives of a particular strategy or due to market conditions. Retirement Plan Services Confluence provides retirement plan consulting services to sponsors of qualified retirement plans as defined by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The services provided by Confluence vary from client to client and will be tailored to the specific needs of the plan sponsor. Although not intended to be all inclusive, the retirement plan services provided may include plan design consulting, fiduciary best practices assessment, basic compliance reviews, investment policy development, fund menu design, fund manager search and selection, fund replacements, asset allocation modeling, investment monitoring and review, plan committee meetings, provider fee and service reviews, provider management, provider search and selection, transition services to a new provider, Section 404(c) consulting, education program strategy, and employee meetings. Financial Plan Reviews Confluence provides Financial Plan Reviews that encompass a review of the major aspects of each client’s financial situation, focusing on retirement planning, an insurance review, and an investment review. Following

the initial meeting with the client, the Wealth Manager defines the scope of services that will be necessary to perform the client’s Financial Review. Third-Party Money Managers Confluence offers asset management services involving unaffiliated third-party money managers (collectively hereinafter, “Third-Party Managers” or “TPMs”). Through these services, Confluence can provide access to third-party money managers that can manage a portion or all of the client’s assets. Managed Stock Program Confluence offers internally managed stock portfolios that are overseen by the firm’s Investment Advisory Committee. The strategies are actively managed through quantitative analysis of historical fundamental factors, with a focus on large-cap and mid-cap securities domiciled in the United Sates. The strategies do not have a material cash allocation. The firm requires a $100,000 account minimum. IRA Rollovers Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. 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. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and can engage in a combination of these options): (1) Leave the money in the former employer’s plan, if permitted; (2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted); (3) Rollover Employer Plan assets to an IRA; or, (4) Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. Confluence encourages you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment adviser to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. By recommending that you rollover your Employer Plan assets to an IRA advised by Confluence, we will earn fees as a result. In contrast, leaving assets in your Employer Plan or rolling the assets to a plan sponsored by your new employer likely results in little or no compensation to Confluence, with the exception of circumstances in which Confluence is the investment advisor to the plan that you are enrolled in, or if you hire Confluence to provide advice on your individual Employer Plan assets. Confluence has an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by Confluence. Investors can face increased fees when they move retirement assets from an Employer Plan to a Rollover IRA account. Even if there are no costs associated with the IRA rollover itself, there will be costs associated with account administration, investment management, or both. In addition to the fees charged by Confluence, the underlying investment (mutual fund, ETF, annuity, or other investment) can also include fees. Custodial and trading fees also apply. Investing in an IRA with Confluence will typically be more expensive than an Employer Plan. As of December 2023, Confluence had approximately $2.9 billion in discretionary regulatory assets under management and $175 million of non-discretionary assets under management.