EM 4 Who We Are Financial Services Advisory (hereinafter referred to as “FSA,” “the Advisor,” “we,” “us” and “our”) is a fee-only registered investment advisor1 incorporated in 1982 as a Maryland corporation. As a fiduciary, we put your interests first as we help you achieve your financial goals. We provide asset management and financial planning services2 for individuals, business owners, foundations, trusts, IRAs and other retirement plans. Owners The following persons control FSA: Name Title CRD# James E. Joseph President and Chief Compliance Officer 2943563 Ronald J. Rough Chief Investment Officer 2083110 Our Mission Our mission is to be an indispensable financial partner with every client we serve. What We Do We assist you in pursuing financial security in an insecure world. As part of our investment advisory services offering, we help you establish and develop realistic goals and implement an active-system of asset management and, when requested, provide limited financial planning as it relates to goal development, retirement planning, investment allocation, education planning and basic tax and estate planning needs. Our asset management services are designed to increase your portfolio value during rising markets and use our exit strategy called FSA Safety Net® to help reduce losses during sustained downward trends (see Item 8, “Managing Risk”). We also offer FSA Next®, which we designed to assist young families and individuals to begin investing and planning for their future. We do not participate in a wrap fee program. Investment Advisory Services We believe that managing your money is more than just buying or selling investments – it’s about understanding your goals and motivations and how your investments support them. So, before we get started actively managing your portfolio, we need to understand your financial picture. 1 The term “registered investment advisor” is not intended to imply that Financial Services Advisory has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission and “Notice Filed” with such other state regulatory agencies that may have limited regulatory jurisdiction over our business practices. 2 Financial Services Advisory is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any asset management and financial planning services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). To accomplish this, we have a four-step process for on-boarding new clients, which we designed to make the transition smooth and stress-free. Step 1 – “Get to Know You Meeting” Our first session gives us the opportunity to get to know each other. We do an assessment of where you are and where you want to be. We want to learn your current financial situation, including your prior investment experience and tolerance for risk. We listen to your concerns, ask lots of questions and begin to formulate a strategy to address your goals and needs. Step 2 – “The Transition” Once we understand where you are and where you want to go, this next step involves a deeper analysis of your retirement goals and finances – including investments. You will complete our Client Profile and Agreement3. Any analysis we provide helps us better assist you in meeting your goals and managing your investment portfolio. We will help determine what (if anything) is needed to prepare for the transition of working together. We will recommend Charles Schwab & Co., Inc. and its affiliated entities (Schwab) for your investment assets. In certain cases when consistent with your investment objectives, we may recommend that you invest a portion of your investment portfolio through Schwab’s Institutional Intelligent Portfolios® program described below. We recommend Schwab because of the benefits we receive servicing your account and Schwab’s ability to accept most securities from other firms. For more information on the benefits we can receive from Schwab, please see Item 12, “Brokerage Practices.” Step 3 – “Moving Forward” After all accounts are opened and assets are in place, we begin management utilizing the FSA Safety Net® system. Throughout the course of the year, expect to receive various communications from us in addition to the monthly account statements from your custodian: v Quarterly Financial Planning Newsletter v Periodic market updates v Periodic reviews of your accounts and planning goals v Webinar invitations to hear and see what we’re thinking and doing Step 4 – “Peace of Mind” The goal of this final step is to hear you confidently say, “I’m glad I don’t have to worry about it anymore.” Working together, your accounts are now actively managed seeking to make money during good cycles and preserving gains when price trends reverse to help achieve your financial goals. During each review meeting, we take the opportunity to review your investment portfolio considering your current needs as well as any additional financial items you may wish to discuss. 3 The Client Profile and Agreement we use is an important tool in gathering information about your investment experience, risk tolerance, income/tax bracket, liquidity, time horizons, etc. If you elect not to answer the questionnaire or choose to respond with limited input, it is possible that we could operate in a handicapped capacity contrary to your investment needs. Therefore, if you desire the most effective and accurate recommendations regarding your managed account(s), you should make every effort to provide us with your detailed personal needs and objectives, along with financial and tax information. FSA Next® As a financial advisor, one of the most difficult conversations is to inform someone at or near retirement that they may need to keep working or scale back their lifestyle. We have found ourselves wishing we had the opportunity to teach principles and provide practical tools at an earlier age that lead to financial success. For this reason, we developed FSA Next® – a service built upon the philosophy: DISCIPLINE = FREEDOM4 We believe, through FSA Next®, that a disciplined approach to spending, saving and investing, combined with well-defined goals and a long-term time horizon, can give you the best chance of achieving financial freedom. We view financial freedom as more than just buying or selling investments – it’s about: v Taking advantage of long-term time horizons – Just like aiming an arrow towards a target, small adjustments at the start can have a dramatic effect on where you land in the future. FSA Next® is designed to make sure you are properly aligned to hit your financial targets. v Being S.M.A.R.T.: Have clearly defined goals – Specific Measurable Achievable Relevant Time-Bound v Leveraging the advice of experts – No one has time to be an expert in everything. Partner with a CERTIFIED FINANCIAL PLANNERä through FSA Next® to develop a strategy that will give you the best chance at achieving your financial goals. We have a 3-step process for FSA Next®. Step 1 – 30 Minute Consultation Our first session gives us the opportunity to get to know each other. We do an assessment of where you are relative to your short- and long-term goals. We ask you to complete our “Client Profile and Agreement” so we can more fully understand your investment objective. We listen to your concerns, ask a lot of questions and try to gain an understanding of how we can add value to your current situation. Step 2 – Personal Financial Analysis (“PFA”) The PFA is an analysis of your financial situation. Together we will review your current spending and savings habits and assess the trajectory towards your financial targets. If we determine that adjustments need to be made, we can assist in developing a strategy to get you on track towards achieving those goals. Areas of focus include: v Budgeting v Cash Flow v Retirement Savings v Debt Management v Investment Allocation v Education Savings 4 Inspired by the book by: Willink, Jocko (2015). Extreme Ownership, New York, NY: St. Martin’s Press. v Basic Tax Planning Step 3 – Ongoing Financial Planning Services and Asset Management Younger individuals generally experience several transitions both personally and professionally. The choices you make during this time may dictate the lifestyle you will be able to live throughout the course of your life. Once you complete the PFA, we hope that it serves as the blueprint for you and your advisor to decide upon the ongoing topics of focus. These topics are to help keep you on track towards achieving your financial goals and may change over time. You may need further assistance from outside professionals (i.e., attorneys, accountants, insurance agents, etc.) to address your financial situation. Should this be the case, we may recommend the services of these outside professionals to help with implementation. FSA Next® provides you with ongoing access to your personal financial advisor who can help you navigate these changes and aid in decision making. That personal financial advisor can also provide asset management services through Schwab’s Institutional Intelligent Portfolios® (SIIP) program described below. Asset Management through Schwab’s Institutional Intelligent Portfolios® Overview When consistent with an investment advisory client’s investment objectives, we may offer asset management services through Schwab’s SIIP program. SIIP is an automated investment program through which you are invested in a range of investment strategies that we constructed and manage, each consisting of a portfolio that can include exchange traded funds (“ETFs”), mutual funds and a cash allocation. You can instruct us to exclude up to three mutual funds or ETFs from your portfolio. Your portfolio is held in a brokerage account opened by you at Schwab. We use the Institutional Intelligent Portfolios® platform (the Platform), offered by Schwab Performance Technologies (SPT), a software provider to independent investment advisors and an affiliate of Schwab, to operate the SIIP program. We are independent of and not owned by, affiliated with or sponsored or supervised by SPT, Schwab and their affiliates. We, and not Schwab, are your investment adviser and primary point of contact with respect to the SIIP program. As between us and Schwab, we are solely responsible, and Schwab is not responsible, for determining the appropriateness of the SIIP for you, choosing a suitable investment strategy and portfolio for your investment needs and goals and managing that portfolio on an ongoing basis. We contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the SIIP. The Platform enables us to make the SIIP available to you online and includes a system that automates certain key parts of its investment process (the System). The System includes an online questionnaire that helps us determine your investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. We will recommend a portfolio via the System in response to your answers to the online questionnaire. You may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information it has about you. The System also includes an automated investment engine through which we manage your portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if you are eligible and elect). We charge clients a fee for our services as described below under Item 5, “Fees and Compensation.” Our fees are not set or supervised by Schwab. We generally recommend to all our clients that investment management accounts be maintained at Schwab. Because of this consideration, Item 12 below describes possible conflicts of interest. Keep in mind, you do not have to accept our recommendation. Clients enrolled in the SIIP program are limited in the universe of investment options available to them. For example, the investment options available are limited to ETFs and mutual funds, whereas we recommend various other types of securities in its other services. You will have access to your accounts and a financial interface online but can also confer with us with respect to your account. Please also refer to Item 8 below with respect to the investment risks associated with the SIIP program, including mutual fund and ETF risk. Rebalancing The System will rebalance your account periodically by generating instructions to Schwab to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep Program,” considering the asset allocation for your investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an asset class varies by a set parameter established by us, (ii) we decide to change the ETFs or your percentage allocations for an investment strategy or (iii) we decide to change your investment strategy, which could occur, for example, when you make changes to your investment profile or impose or modify restrictions on the management of your account. Accounts below $5,000 may deviate farther than the set parameters as well as the target allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes due to the inability to buy or sell at least one share of an ETF or mutual fund. For example, withdrawal requests may require entire asset classes to be liquidated to generate and disburse the requested cash. Sweep Program Each investment strategy involves a cash allocation (Cash Allocation) that will be held in a sweep SIIP program at Charles Schwab Bank (the Sweep Program). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash and may be higher depending on the investment strategy chosen for you. The Cash Allocation will be accomplished through enrollment in the Sweep Program which is sponsored by Schwab. By enrolling in the SIIP program, you consent to having the free credit balances in your brokerage accounts at Schwab swept into deposit accounts (Deposit Accounts) at Charles Schwab Bank (Schwab Bank) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the SIIP program. If the Deposit Account balances exceed the Cash Allocation for your investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If you request cash withdrawals from your accounts, this likely will require the sale of fund positions in your accounts to bring your Cash Allocation in line with the target allocation for your chosen investment strategy. If you have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with Schwab, Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Compensation to Schwab Under the Institutional Intelligent Portfolio® Program You do not pay fees to SPT or brokerage commissions or other fees to Schwab as part of the SIIP program. However, Schwab receives other revenues including, but not specifically limited to, the following which is subject to change: (i) the profit

earned by Charles Schwab Bank on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in your brokerage account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in your brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Stand-Alone Financial Planning and Consulting Services We provide limited financial planning and consulting services as described above. Except as detailed in Item 5, we generally do not charge an additional fee for requested financial planning services unless the services exceed the limited scope of planning identified in our Client Profile and Agreement. Should additional planning needs be evident, we will have you enter into a separate stand-alone Financial Planning and Consulting Agreement outlining the terms, conditions (including termination), scope of services provided and fees that would be due. Miscellaneous Disclosures Financial Planning We have relied upon information provided by you. We do not verify any information obtained from you or your attorney, accountant or other professionals, including information from custodial/investment statements. In the event that any such information provided is inaccurate or incomplete, the corresponding results or recommendations will be inaccurate or incomplete. We are not a law firm, accounting firm or an insurance agency, and no portion of our services should be construed as comprehensive financial planning or legal, insurance or accounting advice. Rather, you should seek the advice of your attorney, insurance agent, accountant or other corresponding professional advisor with respect to those issues. We do not prepare estate planning documents or tax returns, nor do we sell insurance products. Unless we specifically agree in writing, neither we nor our representatives are responsible to implement any financial plans or financial planning advice, provide ongoing financial planning services or provide ongoing monitoring of financial plans or financial planning advice. Any financial planning, consulting and investment recommendations by us are subject to various market, currency, economic, political, tax and business risks and those recommendations/decisions will not always be profitable. You are free at all times to accept or reject any recommendation from us, and you have the sole authority with regard to the implementation, acceptance or rejection of any recommendation or advice and/or services from us and any recommendations (i.e., estate planning, retirement planning, taxes, etc.) should be discussed and/or implemented, at your sole discretion, with the corresponding professional advisors of your choosing. You may require further assistance from outside professionals (i.e., attorneys, accountants, insurance agents, etc.) to address your financial situation when preparing your financial analysis. Should this be the case and you don’t have a professional of your choosing, we may recommend the services of outside professionals we know to help with implementation, but you should understand that our referral of a professional to you could present conflicts of interest because we could have an economic incentive to refer you to a specific professional and the professional could also make referrals to us. To mitigate those conflicts, we remind you that you are not under any obligation to engage any professionals that we recommend to you. If you engage any professional (i.e., attorney, accountant, insurance agent, etc.) recommended by us or otherwise and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not us, shall be responsible for the quality and competency of the services provided. We believe that it is important for you to address financial planning issues on an ongoing basis. Our advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not you determine to address financial planning issues with us. Socially Responsible Investing Limitations Socially Responsible Investing (SRI) involves the incorporation of environmental, social, and governance considerations into the investment due diligence process (ESG). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by us), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Sub-Advisory Engagements We also serve as a sub-adviser to unaffiliated registered investment advisors per the terms and conditions of a written sub-advisory agreement. The unaffiliated investment advisers that engage our sub-advisory services shall maintain both the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client suitability for our designated investment strategies. If the custodian/broker-dealer is determined by the unaffiliated investment adviser, we will be unable to negotiate commissions and/or transaction costs and/or seek better execution. As a result, such clients may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case through alternative clearing arrangements recommended by us. Higher transaction costs adversely impact account performance. Held-Away Assets “Held-Away Assets” are defined as your investment assets or accounts that are: v Not designated by you to be subject to our discretionary management services under the terms and conditions of our Client Profile and Agreement. v Not included in calculating your performance and not subject to fees based upon a computation of your assets under our management, or v Any specific individual securities that are purchased for your account at your direction and not based upon our investment advice or determination to purchase the individual securities as part of our ongoing discretionary management authority. Held-Away Assets can also include investment assets maintained in defined contribution plans (i.e., 401(k) plans, 403(b) plans, 457 deferred compensation plans, 529 education savings plan, participation accounts, annuities, etc.) not custodied at Schwab where we have trading authority. However, at your election, through a third-party agreement with Pontera Solutions, Inc., you can give us access to manage and trade on Held-Away Assets. Pontera Solutions Platform The Pontera Solutions, Inc. (“Pontera”) platform links Held-Away Assets in a single web- based interface offering us a comprehensive view of your contribution plan(s) and the ability for us to implement asset allocation and opportunistic rebalancing strategies that would otherwise be constrained due to regulatory limitations related to federal and state custody laws. How It Works Pontera will provide a secure link for you to gain access to their platform. There you will provide detailed information relating to your Held-Away Assets and establish the login credentials to those accounts. We will never have direct login capability to those Held- Away Assets. You maintain personal autonomy allowing us to only allocate and trade those accounts you linked to the Pontera platform. Once you give us entitlement to manage those Held-Away Assets, we can structure asset allocations strategies and use our account management software to create a seamless management process. Disclosures v Pontera charges an asset-based annual fee of 0.30% for each contribution plan account we manage on their platform. The fee is calculated at the beginning of each calendar quarter (i.e., 0.30% ÷ 4 = 0.075%) and billed to us – you do not pay directly for this service. This will NOT result in you paying a higher management fee above what we have currently disclosed in our above fee schedule. v Our investment advice is limited by the investment choices available within your contribution plan, and we are not responsible for any costs, expenses, transaction fees, redemption fees, penalties or otherwise resulting from any account transactions. v We will not have, nor will we accept, any authority to change beneficiaries or effect account disbursements or to process any transfers of any funds to/from your contribution plan account(s). v We are independent of and not owned by, affiliated with, or sponsored or supervised by Pontera or any of their affiliates. Limitations Working with Held-Away Assets For Held-Away Assets not linked to Pontera, not custodied at Schwab, or investment assets or accounts where we do not have trading authority, we may provide investment advice when specifically requested by you, and as agreed to by us, subject to the terms and conditions of our Client Profile and Agreement which includes the following: v We do not accept responsibility to provide ongoing review, monitoring or performance evaluation of any Held-Away Assets not linked to the Pontera platform. v If requested by you, we may consult or assist you regarding Held-Away Assets in matters that include, but are not limited to, disposition of assets, transferring of non-managed funds to/from the account(s) or assist with trades within the non- managed account(s) but only as directed by you. You remain responsible for all decisions and consequences regarding the Held-Away Assets and agree to release and hold us harmless, and all persons associated with us, from any and all losses and/or other liabilities resulting from the Held-Away Assets(s). v It is your exclusive obligation and sole responsibility to immediately notify us, in writing, if there is a change in your financial situation or investment objective(s) including, but not limited to, personal/financial situation, goals, needs or concerns/views regarding economic/political/financial climate as well as any changes in investment alternatives, restrictions, etc. for the purpose of reviewing, evaluating or revising any of our previous recommendations and/or services, or if you want to impose, add or modify any reasonable restrictions to our investment advisory services. Please Note: Unless you advise, in writing, to the contrary, there are no restrictions on our services, other than to manage the account in accordance with your designated investment objective. v We shall not be responsible for any costs, damages, penalties or otherwise resulting from the failure to notify us. v We can also provide account reporting services which can incorporate client investment assets that are not part of the assets that we manage (the Held-Away Assets). Retirement Account Rollovers When it comes to your retirement account, you have four options to consider when changing employers or retiring: v Leave the account assets in the former employer’s plan if permitted. v Roll over the assets to the new employer’s plan if one is available and rollovers are permitted. v Roll over the account assets to an Individual Retirement Account (an “IRA”). v Cash out the retirement account assets (there may be tax consequences and/or IRS penalties depending on your age). Should you approach us to advise you on which option would be the best for your particular situation, we have an economic incentive to recommend you roll over your retirement account to a managed IRA account with us where we would earn a management fee on those assets. This can present a conflict of interest and render our advice as subjective and a disadvantage to you. Therefore, if we recommend you roll over your retirement account to an individually managed IRA account, you are under no obligation to engage us to manage your assets. You are free to take your account anywhere. Portfolio Trading Activity As part of our investment advisory services, we will review your portfolios on an ongoing basis to determine if any trades are necessary based upon various factors including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, your financial circumstances and changes in your investment objectives. However, based upon these and other factors, there may be extended periods of time when we determine that trades within your portfolio are neither necessary nor prudent. You nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Cash Positions Our clients’ accounts usually contain cash and cash equivalent positions (such as money market funds), generally for defensive and liquidity purposes. Unless otherwise agreed in writing, all cash and cash equivalent positions will be included as part of assets under management for purposes of calculating our investment management fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), we may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, our advisory fee could exceed the interest paid by your money market fund. Inverse / Enhanced Investments We may utilize inverse (short) mutual funds and/or exchange-traded investment/funds (ETFs) that are designed to perform in an inverse (opposite) relationship to certain market indices (at a rate of one or more times the inverse result of the corresponding index). In addition, we may also use leveraged (enhanced) mutual funds or ETFs that provide an enhanced relationship to certain market indices (at a rate of more than one times the actual result of the corresponding index). These strategies involve a higher level of inherent risk, and therefore, you may direct us, in writing, not to employ any or all such investment strategies. See “Risks Associated with using Leveraged and Inverse Mutual Funds and ETFs” of this Disclosure Brochure for a more detailed description of the risks associated with using inverse/enhanced investments. Tailored Advisory Services We tailor our advisory services to the individual needs of our clients as described above. In addition, our clients may impose reasonable restrictions, in writing, about investing in certain securities or types of securities. Assets Under Management As of December 31, 2023, our assets under management totaled: Client Discretionary Managed Accounts ......................... $693,702,744 We do not offer non-discretionary asset management services.