A. SFG is a California corporation formed on November 12, 1982, which became registered as an investment adviser in January 1983. SFG is owned by the Schultz Family 2005 Trust, for which Russell Schultz and Vicki Schultz are the Trustees. Mr. Schultz is SFG’s President. B. SFG offers to provide wealth management and non-discretionary investment management services to its clients (currently: individuals, high net worth individuals, trusts, estates, small businesses, pension and profit sharing plans, and charitable organizations) as described below. SFG customizes its services for clients based on its “Four Capitals” which include: Financial Matters, Physical Well-Being, Intellectual Engagement, and Psychological Space. FINANCIAL ADVISORY SERVICES Combined Wealth and Non-Discretionary Investment Management. SFG’s primary service offering employs its “Four Capitals” approach to provide wealth management and non-discretionary investment management services tailored to each client’s unique situation. SFG charges a fixed annual retainer for these services, subject to a minimum annual fee for new clients. While the specific scope of services will depend on the client’s situation and requests, SFG’s wealth management services typically focus on risk management, cash flow management, tax planning, trust and estate planning, charitable giving strategies, and business consulting services. For families who have a combined net worth exceeding $20 million, SFG may also provide real estate advisory, philanthropic planning, multi-advisor coordination, and legacy planning and wealth transfer services. Before SFG provides combined wealth and non-discretionary investment management services, clients are required to enter into a Financial Advisory Agreement with SFG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. An adviser will then coordinate with each client to establish the client’s wealth management and investment objectives. Based on that, SFG will prepare a written financial plan and recommend that the client allocate investment assets consistent with the designated financial plan and investment objectives. SFG will then implement or assist the client in implementing the financial plan objectives. Once the plan is agreed upon and implemented, SFG provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may recommend rebalancing and/or account transactions as a result of those reviews or other triggering events. Non-Discretionary Investment Management (Stand-Alone). SFG also offers to provide non- discretionary investment management services for a stand-alone fee. SFG’s annual fee is fixed and based upon a percentage of the market value of the assets placed under SFG’s management. Before SFG provides stand-alone non-discretionary investment management services on a fee-only basis, clients are required to enter into a Financial Advisory Agreement with SFG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. An investment adviser representative will then coordinate with the client to develop their investment objectives and recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, SFG provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may recommend rebalancing and/or account transactions as a result of those reviews or other triggering events. Wealth Management Services (Stand-Alone). Finally, SFG offers to provide wealth management services addressing investment and non-investment related matters, such as estate planning, insurance planning, tax planning, business consulting services, etc.) for a stand-alone separate fee. SFG’s stand- alone wealth management fees depend upon the level and scope of the services required and the professionals rendering the services. Before engaging SFG to provide planning or consulting services, clients are generally required to enter into a Financial Advisory Agreement with SFG setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before SFG will begin to provide those services. MISCELLANEOUS Limitations of Wealth Management and Non-Investment Consulting/Implementation Services. SFG does not serve as a law firm, accounting firm, or insurance agency, and no portion of SFG’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, SFG does not prepare estate planning documents, tax returns, or sell insurance products. Unless specifically agreed in writing, neither SFG nor its representatives are responsible to implement any wealth management / financial plans or financial planning advice; provide ongoing wealth management / financial planning services; or provide ongoing monitoring of wealth management / financial plans or financial planning advice. The client retains absolute discretion over all such implementation decisions

and is free to accept or reject any recommendation from SFG and its representatives. To the extent requested by a client, SFG may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who are responsible for the quality and competency of the services they provide. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If SFG recommends that a client roll over their retirement plan assets into an account to be managed by SFG, such a recommendation creates a conflict of interest if SFG will earn a new (or increase its current) advisory fee as a result of the rollover. ERISA / IRC Fiduciary Acknowledgment. When SFG provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way SFG makes money creates certain conflicts with client interests, SFG operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, SFG must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that SFG gives advice that is in the client’s best interest; charge no more than is reasonable for SFG’s services; and give the client basic information about conflicts of interest. Asset Aggregation / Reporting Services. SFG may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged SFG to manage (the “Excluded Assets”). SFG’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because SFG does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not SFG, will be exclusively responsible for implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by SFG. Accordingly, SFG will not agree to be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without SFG’s participation or oversight. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, SFG will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when SFG determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, SFG is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify SFG if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending SFG’s services or previous recommendations. C. SFG provides investment advisory services specifically tailored to needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with each client to develop investment objectives. SFG allocates each client’s investment assets consistent with their designated investment objectives. Clients may, at any time, impose restrictions, in writing, on SFG’s services. D. SFG does not participate in a wrap fee program. E. As of December 31, 2023, SFG had $193,526,938 in assets under management on a non-discretionary basis.