5 Although we offer comprehensive wealth management advice, our advice is neither legal nor accounting advice. We encourage you to coordinate and discuss the impact of our advice with your attorney and accountant. We also rely on you to inform us promptly anytime there are significant changes in your financial situation, goals, or objectives. Although we offer comprehensive wealth management advice, we rely on clients to engage actively in the process. Failure to participate actively in the process may result in our recommendations failing to meet your needs. For 403(b) client accounts, we make available a strategy which selects, allocates, monitors, and rebalance when necessary, institutionally approved mutual funds. If it is determined by us that adjustments need to be made to the portfolio, non-discretionary clients will be contacted for authorization. On an annual basis and/or as needed basis, we will communicate with you to reevaluate financial status, needs, objectives and other pertinent information. We may also offer investment advice concerning investments in cable TV, equipment leasing, mortgages, other partnerships, Real Estate Investment Trusts (REITS) and Unit Investment Trusts (UITs). MDK manages clients’ assets primarily utilizing load waived mutual funds and no‐load mutual funds, taking into consideration the overall management style selected by the client. The mutual funds are selected on the basis of any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. Portfolio weighting between funds and market sectors is determined by each client’s individual needs and circumstances. Custody of Investment Management Service client accounts for both securities and funds will be maintained at Fidelity Investments, Inc. (“Fidelity”). Neither MDK nor its advisory agents are affiliates of Fidelity Investments. MODEL USAGE MDK creates all 403B portfolio models in the office utilizing the funds approved by each institution. Fund selection for each portfolio and allocation percentage is completed following months of consulting with economists and speaking with portfolio managers in regard to the economy and the markets. Additionally, through readings and webinars we research fund managers, fund histories and cost along with reviewing fund prospectuses. MDK’s policy is to always use the share class with the lowest cost available by institution. Model portfolios and funds are reviewed as part of our on-going due diligence on a daily basis. Each morning model portfolio and fund reports are created by the operations team and turned into the advisor for review. These reports reflect overnight performance along with all the trades that occurred overnight in every account. Note, there is a conflict identified: The same funds are not available at all institutions; thus, some clients may have a similar fund chosen. A client with the same investment objectives, goals and/or risk tolerance may differ. PORTFOLIO MONITORING AND PERFORMANCE APPRAISAL Once we complete our analysis of your situation, we will work with you to determine which of our programs is best suited to your needs. We will determine an asset allocation customized to your financial goals, objectives and risk tolerance. Your portfolio allocation will take into consideration your limitations or restrictions, the market and economy at the time and your financial situation, goals and objectives. We will schedule a meeting with you and present the recommended portfolio allocation. Upon your approval, we will implement the initial portfolio allocation. After we implement the initial portfolio allocation, we will provide monitoring services (your account is not actively managed on a continuous basis). We emphasize personal contact and interaction with you rather than continuous and regular account supervision. We will determine the securities to be purchased and sold in the account and will alter the securities holdings from time to time. No changes will be made to the allocation of non- discretionary accounts without prior consultation with you and your expressed agreement for each transaction. Depending on your specific goals and objectives, most accounts will be actively managed although a buy and hold strategy will generally be used. We primarily use open-ended mutual funds, including no-load and load waived, or mutual funds purchased at net asset value (NAV), and Exchange Traded Funds (ETFs). However, managed accounts are not exclusively limited to mutual funds and ETFs and may include stocks, bonds, annuities and other products as are suitable based on your goals and objectives. Transactions in the account, account reallocations and rebalancing may trigger a taxable event, with the exception of IRA accounts, 403(b) accounts and other qualified retirement accounts. Advisory representatives of MDK are registered with Geneos Wealth Management, Inc. (“Geneos”) as Registered Representatives. Geneos is a registered full-service general securities broker-dealer with the Securities and Exchange Commission ("SEC"), a member of the Financial Industry Regulatory Authority. ("FINRA"), and various other regulatory bodies. Our Advisory Representatives are able to recommend the purchase of securities offered by Geneos. If you purchase these products through Geneos, our Advisory Representatives will receive customary commissions from these products. Thus, a conflict of interest exists between the interests of our Advisory Representatives and those of our advisory Clients, as the representative would be incentivized to recommend products that carry a commission. While our Advisory Representatives’ security sales are reviewed for suitability by an appointed supervisor, you should be aware of the incentives they have to sell certain securities products and are encouraged to ask them about any conflict presented. Please be aware that you are under no obligation to purchase products or services recommended by our Advisory Representatives in connection with providing you with any advisory service that we offer. FINANCIAL PLANNING SERVICES We provide a variety of financial planning services to you regarding the management of your financial resources, based upon an analysis of your needs. Generally, such financial planning services will involve preparing a financial program for you based on your financial circumstances and objectives. This information typically covers present and anticipated assets and liabilities, including insurance, savings, investments and anticipated retirement or other employee benefits. Our financial planning typically includes general recommendations for a course of activity or specific actions that you should take. For example, recommendations may be made that the Clients obtain insurance or revise existing coverage,

establish an individual retirement account, increase or decrease funds held in savings accounts or invest funds in certain securities. Other financial planning services that we may provide include ongoing financial counseling, account review, securities research and other advisory services related to investments. Financial planning services to be provided to you will be outlined on the client agreement that you signed with us. RETIREMENT PLAN CONSULTING SERVICES We offer retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting their management and fiduciary obligations to the plan under ERISA. Retirement consulting services will consist of general or specific advice, and may include any one or all of the following: 1. Strategic Planning and Investment Policy Development/Review. 2. Plan Review. 3. Plan Fee and Cost Review. 4. Acting as Third-Party Service Provider Liaison. 5. Assessment of Plan Investments and Investment Options. 6. Plan Participant Education and Communication. The Company may also engage us to provide the following additional services, for separate compensation: 1. Review of Executive Benefits. 2. Assist with Plan Conversion. 3. Merger and Acquisition Assistance. 4. Assist with Corrective Actions to Comply with Applicable Regulations. 5. Coordination with Other Advisers. We will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. When we perform our agreed upon services, we will not be required to verify the accuracy or consistency of any information received from the Company. We will serve in a fiduciary capacity with respect to some of the services that we provide, which will be further explained in the written agreement we sign with the Company. The Company is always free to seek independent advice about the appropriateness of any recommendations made by us. CONSULTING / ASSET ALLOCATION SERVICES MDK also offers various consultation services to clients that have not engaged MDK for portfolio management services. MDK provides this more targeted service to address specific investment and financial concerns of the client, which may include advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. MDK will gather information on a client’s current financial status, future goals and attitudes towards risk. Based upon these personal consultations and the client’s goals and objectives, MDK will analyze and make recommendations to a client about an appropriate allocation of available investments which may include, but are not limited to, stocks, bonds, and mutual funds. Once MDK has determined an asset allocation that is appropriate, based on the client’s investment goals and strategies suitable for a particular client, MDK may suggest the use of an independent investment adviser to manage the client’s portfolio to attain those particular goals. MDK may or may not manage these client portfolios. Consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Please note that any advice given verbally, or any advice provided in a written deliverable involving an Adviser's judgment cannot be guaranteed for accuracy. There are no express or implied guarantees of performance for securities-related recommendations. All recommendations are of a generic nature. SEMINARS / EDUCATIONAL TRAINING MDK may hold investment-related seminars and/or educational events to existing clients, prospective clients, and the general investing public. The seminars feature general investment-related advice for educational purposes and may include both securities and non-securities topics. No specific individualized investment advice regarding investment objectives or investment related needs of the attendees, listeners, or audience is rendered during seminars. However, participants are free to schedule meetings with the Adviser(s) in an effort to obtain personalized investment advice. WRAP FEE PROGRAMS MDK Financial Group, Inc. does not participate in or sponsor any wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2022, MDK Financial Group, Inc. has approximately $135,656,113 in discretionary assets under management and $10,502,032 of non-discretionary assets under management. INVESTMENT MANAGEMENT PROGRAM FEE SCHEDULE: We are compensated for the ongoing quarterly management of the client’s account through a quarterly fee based on an annual percentage of the assets managed by us, charged at the end of each quarter. The fee is assessed on the market value of the account on the last calendar day of the preceding quarter, in arrears. Monies added during the quarter including contributions thru payroll reduction, dividends, interest, capital gains, all sources of income regardless of timing will be included in the fee computation at the end of the quarter as if invested during the entire period. Rollovers and transfers directly from Fund Company to Fund Company that are added during the quarter will be prorated from the date of deposit to the end of that quarter. Fees charged by us are negotiable. There is no minimum account size for opening an investment managed account with us. Advisory clients are subject to MDK’s advisory fee Agreement A, B or C in effect at the time the client entered into the advisory relationship. Pre-existing advisory clients maybe engaged in agreements A, or C; MDK created and renovated the Agreements dependent on the client’s asset size, currently MDK utilizes Agreement B as the primary Agreement. Clients that have obtained $1,000,000 or more in total account value under Agreement C will be converted to Agreement B. However, all advisory client accounts are managed under the same Code of Ethics. The range of Investment Management Advisory Fees is as follows: Investment Management Fee Schedule A First 1.00% of assets up to $500,000 Next .75% of assets over $500,001 to $1 million Next .50% of assets over $1 million Investment Management Fee Schedule B First 1.00% of assets up to $2 million Next 0.80% of assets up to $2 million to $3 million Next 0.60% of assets up to $3 million to $4 million Investment Management Fee Schedule C First 1.50% of assets up to $ 250,000 Next .80% of assets up to $3,000,000 Next 1.25% of assets up to $ 500,000 Next .60% of assets up to $4,000,000 Next 1.00% of assets up to $2,000,000 Next Negotiable thereafter Fees will range according to size and account, complexity, services rendered, etc. and are negotiable upon request.