Form ADV Part 2A, Item 4 TLC Group Investment Advisors, LLC’s is registered with the U.S. Securities and Exchange Commission. Leeward Wealth Inc., 100% owned by Mary Magdalene Chuhinka Kurtz (CRD Number 2151100), is a ninety- nine percent equity owner of the firm with Mrs. Kurtz owning directly the remaining one percent. John Eric Arrington (CRD Number 2168202) is Chief Compliance Officer of the firm. The firm is not publicly owned or traded. As of December 31, 2023, the firm managed, on a discretionary basis, $88,495,585 which represented 327 accounts and on a nondiscretionary basis, managed $47,124,284 which represented 15 accounts. Client assets are managed on an individualized basis. Clients may impose restrictions on their accounts. The firm does not sponsor any wrap fee programs. TLC Group Investment Advisors, LLC (the “Firm”) is an investment adviser providing consulting, and investment management services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities. The Firm offers its services on a fee basis based upon assets under management. Prior to engaging the Firm to provide any of the foregoing investment advisory services, the client will be required to enter into one or more written agreements with the Firm setting forth the terms and conditions under which the Firm shall render its services (collectively the “Agreement”). In performing its services, the Firm shall not be required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. The Firm may recommend the services of itself, its Advisory Affiliates in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if the Firm recommends its own services. The client is under no obligation to act upon any of the recommendations made by the Firm or engage the services of any such recommended professional, including the Firm itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of the Firm’s recommendations. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Firm if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s previous recommendations and/or services. In the event the client determines to engage the Firm to provide investment management services, the Firm shall do so on a fee basis. If engaged, the Firm shall charge an annual fee based upon a percentage of the market value of the assets being managed by the Firm. As discussed below, the Firm’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. However, the Firm shall not receive any portion of these commissions, fees, and costs. The Firm offers advice on all types of investments. However, the Firm intends to primarily allocate its client’s investment management assets, on a discretionary basis among Independent Managers (as discussed below), mutual funds, exchange traded funds and the securities, components of variable annuities, equity securities, corporate and municipal bonds and variable life insurance contracts in accordance with the investment objectives of the client. As further discussed in response to Item 12. (below), the Firm shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investments and its affiliates (collectively referred to as “Fidelity”) for investment management accounts. The Firm may only implement its investment management recommendations after the client has arranged for and furnished the Firm with all information

and authorization regarding accounts with appropriate financial institutions. Financial institutions shall include, but are not limited to, Fidelity, any other custodian recommended by the Firm, custodian directed by the client, trust companies, banks etc. (collectively referred to herein as the “Financial Institution(s)”). The Firm may also recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment manager(s) either directly based upon the stated investment objectives of the client. The terms and conditions under which the client shall engage the Independent Manager(s) shall be set forth in separate written agreements between (1) the client and the Firm and (2) the Firm and the designated Independent Manager(s). The Firm shall continue to render advisory services to the client relative to the ongoing monitoring and review of account performance, for which the Firm shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager(s). Factors that the Firm shall consider in recommending Independent Manager(s) include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s), may be exclusive of, and in addition to, the Firm’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by the Firm, the designated Independent Manager(s) and corresponding broker-dealer and custodian. In addition to the Firm’s written disclosure statement, the client shall also receive the written disclosure statement of the designated Independent Manager(s). Certain Independent Manager(s) may impose more restrictive account requirements and varying billing practices than the Firm. In such instances, the Firm may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Manager(s). The Firm also may render non-discretionary investment management services to clients. The client may make additions to and withdrawals from the account at any time, subject to the Firm’s right to terminate an account. Clients may withdraw account assets on notice to the Firm, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and assets withdrawals may impair the achievement of a client’s investment objectives. The Agreement between the Firm and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. The Firm’s annual fee shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. The Firm’s clients are advised to promptly notify the Firm if there are ever any changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon the Firm’s management services. Neither the Firm nor the client may assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of the Firm shall not be considered an assignment. A copy of the Firm’s privacy policy notice and a written disclosure statement that meets the requirements of SEC Release No. IA-3060 of the Investment Advisers Act of 1940, as amended (“Advisers Act”), shall be provided to each client prior to or contemporaneously with the execution of the Agreement. Any client who has not received a copy of the Firm’s written disclosure statement at least forty-eight (48) hours prior to executing the Agreement shall have five (5) business days subsequent to executing the agreement to terminate the Firm’s services without penalty.