A. Description of the Advisory Firm Dale K. Ehrhart, Inc. is a Corporation organized in the state of Florida, effective October 30, 1975. During the month of October 2021, Dale K. Ehrhart, Inc. submitted Florida Domestication and Articles of Incorporation filings with the State of Florida. Prior to October 2021, Dale K. Ehrhart, Inc. was organized in the state of Delaware. The principal owners are Michael Thomas Hartley, Michael Warren Hartley, and Bonnie Brown Hartley. B. Types of Advisory Services Dale K. Ehrhart, Inc. (hereinafter “DKE”) offers the following services to advisory clients: DKE is comprised of three divisions. (I) The Family Office division provides services including but not limited to investment advice to high net worth families with a minimum account size of $50 million. (II) The TAMP division provides back office and investment management services to independent RIAs. Services include all non-client facing activities associated with the preparation of Investment Proposals and ongoing management of client accounts. (III) The Private Client division services direct clients of DKE. Investment Supervisory Services DKE offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DKE 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. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring DKE evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DKE will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Most accounts serviced directly or indirectly by DKE are discretionary in nature; however, DKE does accept non-discretionary accounts on a case by case basis. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Turnkey Asset Management Program (“TAMP”) Services DKE makes available advisory services and programs of third party investment advisors. As a TAMP, DKE provides back office and investment management services to independent RIAs. DKE’s TAMP clients split investment management fees with DKE, which is disclosed in each firm’s investment management agreement. More specifically, the independent registered investment adviser that directs its clients to DKE’s TAMP services will explain the elements of

the DKE’s strategies, the applicable fees and will perform all screening, suitability and compliance processes applicable to such transactions. The adviser also obtains the necessary financial data from the client, assists the client in determining the suitability of the program, assists the client in setting an appropriate investment objective and assists the client in opening an account with the TAMP. DKE also provides model strategy portfolios and other third-party investment platforms for advisors using its TAMP services. These model portfolios may be used by other advisers in managing their clients’ assets. Depending on the type of program, the IAR may assist the client to select a model portfolio of securities designed by the TAMP. It is the third-party investment advisor (and not DKE) that retains client authority to purchase and sell securities on a discretionary or non-discretionary basis pursuant to investment objective chosen by the client. DKE will not have investment discretion over assets of the third-party investment adviser’s clients except as directed by the third-party investment advisor. Services Limited to Specific Types of Investments DKE generally limits its money management to mutual funds, equities, bonds, fixed income, and ETFs. DKE may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions DKE offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent DKE from properly servicing the client account, or if the restrictions would require DKE to deviate from its standard suite of services, DKE reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. DKE does not participate in any wrap fee programs. E. Amounts Under Management DKE classifies client assets it manages as either Assets Under Management (AUM) or Assets Under Advisement (AUA). DKE has the following assets under management: Discretionary AUM: Non-discretionary AUM: Non-discretionary AUA: Date Calculated: $ 497,976,535 $ 38,597,155 $ 312,781,478 December 2023