Firm Description City Center Advisors, LLC (“City Center Advisors”) formerly Keystone Financial Partners, Inc. was founded in April of 2015 and became registered as an investment advisor in May of 2015. Frank Endris owns 7% of the firm and David Joel Hardin II, and David Joel Hardin each own 46.5% of the firm. City Center Advisors is a fee based advisory firm. The firm’s owners also sell insurance products for a commission through City Center Financial, an affiliated company. These practices represent conflicts of interest because they give an incentive to recommend products based on the commission and/or fee amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the best interest of their clients and will act in accordance with those responsibilities. Clients have the right to purchase these products and services through another insurance agent of their choosing. Types of Advisory Services ASSET MANAGEMENT City Center Advisors offers discretionary asset management services to advisory Clients. City Center Advisors will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize City Center Advisors discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. When deemed appropriate for the Client, City Center Advisors may hire Sub-Advisors to manage all or a portion of the assets in the Client account. City Center Advisors has full discretion to hire and fire Sub-Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and City Center Advisors. Sub-Advisors execute all trades on behalf of City Center Advisors in Client accounts. City Center Advisors will be responsible for the overall direct relationship with the Client. City Center Advisors retains the authority to terminate the Sub-Advisor relationship at City Center Advisors’ discretion. UNIFIED MANAGED ACCOUNT PROGRAM We offer discretionary investment management services in a managed account program through Overlay Portfolio Management (the “OPM Program”). This OPM Program may consist of using model portfolio advisers, model portfolios or other investment options such as mutual funds and/or exchange-traded funds (“ETFs”) to represent different investment strategies for managing your account. Each of these investment strategies is designed to meet a specific goal. Prior to investing in the OPM Program, you will execute a discretionary investment management agreement with us setting forth the terms and conditions of our management of your investments within the OPM Program. Depending on the management services the client selects, the client will grant us limited discretionary authority to manage the client account through selection of an overlay manager (“Overlay Manager”), third party strategist (“Strategist”) and/or third party managers (“Managers”; collectively, “Third-Party Service Providers”). In addition, the client will authorize the custodian to follow our instructions as well as instructions given by Overlay Manager to effect transactions, deliver securities, deduct fees and take other actions with respect to the client account. The client will not have a direct contractual relationship with the Overlay Manager or any other Third-Party Service Provider. The timing of trades in the client account will primarily depend upon the model or changes in the model and, generally, will not take into consideration how long a client may have held the position indicated by the model. We will retain the right to replace any Strategist or Manager on a discretionary basis. Depending on the service a client has selected, we will separately provide the client with the firm brochure (Part 2 of Form ADV) for the applicable Third-Party Service Provider(s) which includes information about their services, model portfolios, and investment strategies at or before the execution of our discretionary investment management agreement. ERISA PLAN SERVICES City Center Advisors provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance

plans, and deferred compensation plans. City Center Advisors may act as 3(38) advisor an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. City Center Advisors would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• City Center Advisors has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the City Center Advisors’ assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the City Center Advisors is not providing fiduciary advice as defined by ERISA to the Plan participants. City Center Advisors will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. City Center Advisors may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between City Center Advisors and Client. 3. City Center Advisors has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. SEMINARS City Center Advisors holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. City Center Advisors does not charge a fee for attendance to these seminars. FINANCIAL PLANNING City Center Advisors offers limited scope financial planning services to all clients. The services to be performed will be outlined in the financial planning agreement. City Center Advisors reserves the right to waive the fee should the Client implement the plan through City Center Advisors. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without prior written client consent. Wrap Fee Programs City Center Advisors does not sponsor any wrap fee programs. Client Assets Under Management City Center Advisors has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $112,949,720 $0 August 31, 2023