A. Description of the Advisory Firm BCO Wealth Management, LLC (hereinafter “BCO Wealth”) is a Limited Liability Company organized in the State of New Mexico. The firm was formed in May 2022, and the principal owners are John Milo Overstreet and Lyle Harley Cole. B. Types of Advisory Services Portfolio Management Services BCO Wealth offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BCO Wealth creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring BCO Wealth evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. BCO Wealth will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. BCO Wealth seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of BCO Wealth’s economic, investment or other financial interests. To meet its fiduciary obligations, BCO Wealth attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, BCO Wealth’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is BCO Wealth’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. As part of its Portfolio Management Services, BCO Wealth will sometimes manage client portfolios using SEI’s Asset Allocation Program, sponsored by SEI Investment Management Corp ("SIMC"). In this program, SIMC provides advisory services to Adviser (but not to the client) involving the structure and design of asset allocation portfolios comprised solely of mutual funds advised by SIMC. SIMC also advises Adviser with respect to reallocation and rebalancing of investments within such asset allocation programs. BCO Wealth determines the client's investment objectives, investment time horizon, and risk profile by means of an interview process and the completion of a questionnaire. This process will help BCO Wealth review the client's situation and enable BCO Wealth to recommend an initial asset allocation. The client may place reasonable restrictions on the nature of the funds held in the portfolio or the allocation among the various classes, and BCO Wealth will assist the client in understanding and evaluating the potential impact of these restrictions on the model portfolios. SEI Private Trust Company (a subsidiary of SEI Investments Company) acts as the transfer agent and custodian for the client's account. BCO Wealth may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, BCO Wealth will always ensure those other advisers are properly licensed or registered as an investment adviser. BCO Wealth conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. BCO Wealth

then makes investments with a third-party investment adviser by referring the client to the third-party adviser. BCO Wealth will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Specifically, BCO Wealth generally recommends the three third-party arrangements detailed in Item 5 under Selection of Other Advisers Fees. Pension Consulting Services BCO Wealth offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments BCO Wealth generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non- U.S. securities. BCO Wealth may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status 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. C. Client Tailored Services and Client Imposed Restrictions BCO Wealth will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by BCO Wealth on behalf of the client. BCO Wealth may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. BCO Wealth does not participate in wrap fee programs. E. Assets Under Management BCO Wealth has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $240,717,249.00 $ 0.00 December 2022