A. FIRM DESCRIPTION Odyssey is a Georgia Limited Liability Company, located in Roswell, Georgia, originally founded in 2007, and approved as a registered investment advisor with the Securities and Exchange Commission on August 27, 2022. Odyssey will begin providing investment advisory and financial planning services in September 2022. The Firm is wholly owned by Robert F. Fezza and Stephen A. Siders. Mr. Siders also acts as the Firm’s Chief Compliance Officer. B. ADVISORY SERVICES Odyssey dedicates itself to understanding the intricacies of each client. For all investment advisory and related services described below, we tailor our products in accordance with the client-specific needs obtained from documented discussions, a financial plan and/or risk assessment. Before providing investment advisory services, Odyssey takes multiple factors into consideration, including but not limited to, investment objectives, investment time horizon, risk tolerance, and the client’s financial circumstances. Investment Advisory Services We offer discretionary investment advisory services through one or more third-party Sub- Advisors (“Sub-Advisor”). We reserve the right to decline to offer our services to a client or prospective client if we deem it to be in the best interest of the client, prospective client, or Firm. If a client engages us for investment advisory services, we require an executed Investment Advisory Agreement (“IAA”) between the client and the Firm prior to the Firm providing our services to the client. The IAA outlines the services and fees the client will incur for the Firm’s services. Upon execution of the IAA, the Firm will work closely with the client to identify their specific needs and objectives and the suitability of the products and/or model portfolios (the “Portfolios”) offered by the Sub-Advisor. As part of our discretionary authority, we retain the ability to hire and fire any Sub-Advisor as necessary to best service our clients’ accounts. We review several factors when determining which Sub-Advisor is most suitable for our Firm and its clients. Please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for additional information on how we select a third-party service provider or Sub-Advisor. Odyssey has engaged Forum Financial Management, LP (“Forum”) as a third-party Sub-Advisor to provide back-office services for the benefit of our client’s accounts. These services include, but are not limited to, account administration, technology, and trading. As such, clients understand and expressly permit Odyssey to share relevant client information with Forum. Forum maintains a privacy policy whereby Forum does not disclose non-public information obtained from Odyssey to any non-affiliated third parties, except as required to process transactions on client’s behalf (03-2024) Page 5 of 26 or if required by law or regulation. Odyssey pays Forum a fee for its services. Clients are not charged any other additional fees by Odyssey for Forum’s services. Clients will only have a direct relationship with the Firm and the Firm will serve as the communication conduit between the client and Forum (or any other Sub-Advisor). In third-party managed accounts, the Sub-Advisor will retain discretionary authority to formulate, monitor, and revise the investments held in the Portfolios. Clients must authorize the Sub-Advisor to direct trades for clients’ accounts with the custodian. However, this discretionary authority is limited to implementing transactions necessary to allocate the client’s assets among the Portfolios as directed by the Firm. The Sub-Advisor will be responsible for providing ongoing rebalancing of the Portfolios to ensure they continue to align with the stated investment objective and risk tolerance of the Portfolio. The Sub-Advisor will not have the authority to provide the client with any investment advice, determine the suitability of its portfolios for the client, or change the Portfolio in which the Client’s assets are invested in. The Sub-Advisor will not have possession or custody of cash and/or securities in any accounts, nor any responsibility or liability for custody, which will remain solely with custodian. The Sub-Advisor utilized by the Firm may not achieve the best rate of returns or charge the lowest fees in comparison to other third-party investment advisors and managers. The Firm may utilize additional independent third parties to assist it in recommending and monitoring the Sub-Advisor as necessary under appropriate circumstances. Investments Held Away Odyssey occasionally advises clients with respect to investment accounts not directly supervised and managed by Odyssey. The accounts include, but are not limited to, 401(k), 403(b), and 529 accounts. The fees for such services will be deducted from the accounts managed by Odyssey. This advice will generally include asset allocation and fund selection. The fee for assets held away is the same fee for assets under direct management, which will be evidenced in the client’s advisory agreement. Funds selected will be primarily chosen on their asset class description and fees in a manner consistent with portfolios directed by the Firm. Financial Planning and Consulting Services If a client engages the Firm to provide financial planning and consulting services, we require a written Financial Planning Agreement (“FPA”) executed by the client prior to the engagement of services. We provide our clients

with an in-depth analysis of their current financial situation, as well as detailed recommendations related to the client’s financial goals. The financial plan may include one or more of the following:
• Personal Financial Planning
• Investment Analysis/Asset Allocation (03-2024) Page 6 of 26
• Risk Management and Analysis
• Analysis of Cash Flow and Debt
• Employee Benefits and Compensation
• Education Planning
• Business Planning
• Retirement Accumulation and Income Planning
• Insurance Needs/Planning
• Tax Return Review and Planning
• Wealth accumulation and Preservation Strategies
• Estate Planning
• Charitable Giving Solutions
• Financial Considerations of Divorce Planning
• Multi-Generational Planning If an inherent conflict of interest exists between the interests of the Firm and the interests of the client, the client is under no obligation to act upon our recommendations. Should the client elect to act on any recommendation made by the Firm, the client is under no obligation to affect the transactions through the Firm. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. The Firm cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. Qualified Plan Consulting Services Our retirement plan consulting services are available to sponsors of qualified plans (“Plan(s)”). The Firm may be engaged to provide investment advisory services to Plans, whereby the Firm assists a business in ensuring its investment offerings in the Plan are consistent with the investment objective designed by the Plan. This includes recommending investments to the Plan Sponsor and/or Investment Advisor, assist the Plan Sponsor in ensuring the investments follow the firm’s Investment Policy Statement, complete suitability analysis for Plan Participants, provide non-discretionary portfolio recommendations to Participants based on the suitability analysis, and consult with Plan Participants. In such engagements, the Firm will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). The Firm will generally provide services on an “assets under management” fee basis per the terms and conditions of a Retirement Plan Consulting Agreement between the Plan and the Firm. Subscription Fee Service Odyssey offers a subscription service, personal planning and ongoing financial advice, which may or not include investment management for a minimum annual fee. Subscription clients sign an (03-2024) Page 7 of 26 agreement for 12 months of financial advice to be provided monthly on various topics and via various formats. We create a plan to guide our clients towards achieving specific financial goals or for analysis of specific client financial issues. These services are provided on a non- discretionary basis. These services do not require active management of a client account but focus on the client's overall financial situation. Subscription clients do have the option for Odyssey to manage their investments and custody their assets at Schwab or elect to keep their assets outside of Odyssey's management. C. TAILORED RELATIONSHIPS At Odyssey, we offer the same suite of services to all of our clients. The advisory services and recommendations offered by the Firm are based on the individual needs of our clients and the suitability of products and services. Recommendations presented to clients and the implementation of such recommendations are dependent upon the information provided by the client to build the client’s financial profile which outlines each client’s current situation (goals, income, objectives, and risk tolerance levels) and used to construct a client specific action plan to aid in the selection of a portfolio through the sub-advisor. We will make every effort to comply with the wishes of the client but cannot guarantee absolute adherence due to our use of the Sub-Advisor. However, it is incumbent upon the client to disclose any restrictions and preferences in writing to the Firm prior to the implementation of our recommendations. If the restrictions prevent the Firm from properly servicing the client account Odyssey reserves the right to terminate the relationship. D. WRAP FEE PROGRAMS Our Firm does not participate in and is not a sponsor of wrap fee programs; however, we may recommend third-party wrap fee programs to clients. Wrap Fee Programs are arrangements between broker-dealers, investment advisors, banks and other financial institutions, and affiliated and unaffiliated investment advisors through which the clients of such firms receive discretionary investment advisory, execution, clearing, and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all- inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. E. ASSETS UNDER MANAGEMENT When calculating regulatory assets under management, an investment advisor must include the value of any advisory account over which it exercises continuous and regular advisory or management services. Our assets under management as of 12/31/2023 are $263,970,000. (03-2024) Page 8 of 26