FFAS is a private corporation that provides investment advisory services to individual investors, families, and small businesses. FFAS was established in 1974 by William B. Mason, who served as the principal owner until his retirement in early 2012. At that time, Geraldine B. Cunningham, who joined the company in 1981, became the sole owner. Mrs. Cunningham also serves in the capacity as President and Treasurer of FFAS. The term “Advisor” in this Brochure is used in reference to any representative who provides investment advice on behalf of FFAS. Such individuals are properly registered in all required jurisdictions. Please note the term ‘registered’ does not imply a certain level of skill or training. Each Advisor’s qualifications are discussed in detail in Part 2B of this brochure. FFAS uses the term “investment advisory services” in this brochure to describe our activities, which are personalized to each individual Client’s self-disclosed needs, and include a range of activities generally associated with: a) portfolio management, which we define as the practice of making decisions about investment mix in accord with policy, matching investments to objectives, allocating assets among security types, and weighing risk against performance; and b) financial planning, which is defined by the Certified Financial Planner Board of Standards, Inc. (CFP Board) as a collaborative process that helps maximize a Client’s potential for meeting life goals through Financial Advice that integrates relevant elements of the Client’s personal and financial circumstances. Clients may engage FFAS to provide portfolio management services, financial planning services, or a combination of both. FFAS Advisors work with each Client during the preliminary consultation phase to a) identify and prioritize their financial objectives, and b) examine and assess their individual tolerance for financial risk within the context of their unique financial situation and given the complexity of our global economy. FFAS does not participate in wrap fee programs, nor does it publish research reports or sell newsletters. FFAS does work collaboratively with our Clients’ accountants and attorneys, when appropriate, to discuss and manage estate planning, generation skipping, and tax efficiency. 4.1. PORTFOLIO MANAGEMENT SERVICES As of December 31, 2023, the total value of our Clients’ regulated assets under FFAS management was $224,998,015. FFAS offers portfolio management services strictly on a non-discretionary basis, which means that an Advisor must obtain Client consent to a recommended trade before making any transaction in that Client’s account. Our investment philosophy focuses on “value” investing, with an eye toward long-term growth. Clients are encouraged to fully complete a set of financial questionnaires to help the Advisor establish the parameters by which the account will be managed, including the investment objectives of the account, the tolerable amount of risk or loss, if a Client has any particular investment restrictions or preferences, and how performance will be measured against a particular benchmark index. FFAS may recommend that a Client roll over their retirement plan assets into an account to be managed by FFAS. 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 we recommend that a Client roll over their retirement plan assets into an account to be managed by FFAS, such a recommendation creates a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the Client. No Client is under any obligation to roll over retirement plan assets to an account managed by us. 4.2. FINANCIAL PLANNING AND CONSULTATION SERVICES FFAS offers a variety of customizable financial planning services to Clients interested in: planning for education and retirement funding; trying to improve tax efficiency; and strategies to address needs regarding long-term health care, liability protection, charitable inclinations, and estate transfer upon death. Other financial services provided by FFAS include fiscal wellness coaching, navigating interactions with third-parties (e.g., financial institutions, insurance companies, and government agencies), and assisting Clients with the management of household economies, financial data, and debt. FFAS also provides consultation services that may not constitute financial planning. The scope of services to be provided will be described in an agreement between FFAS and the Client. FFAS will not provide financial planning or consulting services to Client with respect to the Accounts or any other Client assets unless a separate written financial planning agreement has been signed by Client and Advisor. The recommendations and solutions FFAS provides relative to financial planning objectives are designed to achieve the Client’s desired goals, but often require input from the Client for success, and also may require revisions to meet changing circumstances. Any financial plan created by an FFAS Advisor is based on a Client’s financial situation as reported to FFAS at the time of the plan creation; the import of such a plan tends to diminish when changes in circumstance are not disclosed. Therefore, FFAS urges Clients to relate significant life changes when (or even before) they occur so that our financial planning services can be adjusted accordingly. If Client decides to implement the advice of FFAS, Client is not obligated to do so through the FFAS or any of its Advisors. 4.3. EDUCATIONAL SEMINARS FFAS occasionally provides educational seminars covering a variety of topics, including information about required minimum distributions, qualified charitable distributions and TSP investment workshops. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. 5.0 FEES & COMPENSATION FFAS receives compensation from its Clients in consideration for services provided based on one or more of the following fee structures: fee-based (based on a percentage of the Client’s assets under FFAS management); transaction-based commissions and 12b-1 fees; an hourly rate; or a fixed fee. We do not receive third party referral fees for our investment advisory services. FFAS does not charge fees for educational seminars to attendees. 5.1. FEE-BASED PORTFOLIO MANAGEMENT SERVICES FFAS receives a fee as compensation for investment advisory services (the “Advisory Fee”). The Advisory Fee is calculated and assessed as agreed to by Advisor and Client and will depend on the service selected. For portfolio management services, the Advisory Fee, including the method of calculating and manner of payment, may be amended as provided in the Amendment section of the Investment Management Agreement. Advisory Fees will be billed quarterly, in advance, based upon the agreed annual percentage rate. Fees will be based on the fair market value of the assets in Client’s Accounts at close of business as of the last day of the quarter. One-quarter of the annual rate is assessed each quarter. The quarterly fee is determined by multiplying the fee-based account values as of the market close on March 31st, June 30th, September 30th, and December 31st by the annual fee rate, and then calculating a quarterly amount based on the number of days in the quarter. There is an example of this fee calculation in Item 5. FFAS does not have discretion to select a broker-dealer for the client. FFAS recommends the client’s broker- dealer, and the client signs an agreement directly with the custodian involved. FFAS does not have discretion to decide commission rates, except that it sometimes voluntarily reduces any standard commission to be received by a representative with respect to a client’s brokerage account. For example, the representative may elect to receive only 80 percent of a standard commission for any client that has an advisory account. For new Accounts, the amount of the initial Advisory Fee charged for the quarter in which the Agreement is established will be based upon the initial value of the assets transferred or deposited into the Accounts, pro- rated based upon the number of days remaining in the quarter and will be billed in the month following the establishment of the Account. For any quarter in which any interim deposit or withdrawal in excess of $10,000 in a single transaction is made, the qualifying deposit or withdrawal will be billed or credited, respectively, on a pro-rata basis based on the number of days remaining in the quarter. Adjustments for deposits or withdrawals will occur in the month following the qualifying transaction. Unless otherwise specified, the Advisory Fee shall be automatically deducted from Client’s Accounts by the Custodian by the fifteenth (15th) day of each calendar quarter. However, upon request, the client can arrange to pay fees with a personal check, or to have the payment come from another designated account. The annual Advisory Fee charged by Advisor is 1.5% of the Account value(s) per year if the value of the Account(s) is $500,000 or less. Reductions in the annual Advisory Fee to 1.25% and 1.0% are scheduled to occur if a specific Account’s value exceeds $500,000 or $1,000,000, respectively. The annual Advisory Fee is negotiable for an Account worth $2,000,000 or more. Advisory fees for accounts whose value is less than $2,000,000 may also be negotiated based on factors such as the amount of assets under management, the range of investment types, and the relative complexity of financial circumstances, among others. Since this fee is negotiable, the exact fee to be paid will be clearly stated (as a percentage of account assets) in the Investment Management Agreement between FFAS and Client. Upon termination of the Investment Management Agreement, the Client shall be entitled to a pro-rata refund of unearned fees for the quarter. Transaction charges, handling fees, custodial fees, service charges, ticket charges, asset-based custodial fees, and other similar charges incurred in connection with transactions for the Accounts or other services rendered by a custodian are in addition to any fee-based Advisory Fee paid to FFAS and must be paid by the Client. Client agrees to be responsible for all additional fees and charges for which Client becomes obligated under any separate agreement with the Custodian. These charges are separate from FFAS quarterly fees, and FFAS does not typically receive any portion of these costs. Mutual funds and similar investment vehicles pay managers to manage the assets of the fund, and the expenses of the fund, including said management fees, are deducted from all of the fund assets, are chargeable against the net asset value of fund shares owned by Client, and are therefore borne separately by Client. Rule 12b-1 shareholder servicing and/or distribution fees are fees charged by mutual fund sponsors or their affiliates in connection with certain investments in mutual funds. The Client, like other shareholders of mutual funds, will bear a proportionate share of such fund's advisory, administrative, and Rule 12b-1 fees, as well as the account fees on account assets invested in these fund shares. FFAS’s Advisors sometimes receive portions of 12b-1 fees, as discussed below. Unrelated parties may also receive Rule 12b-1 shareholder servicing and/or distribution fees, as well as other marketing payments from mutual fund sponsors or their affiliates in connection with the investments in the account. Information on specific 12b-1 fees paid by Clients is presented in every mutual fund prospectus. Other fees and expenses that Client may pay outside of this Agreement include retirement plan fees, mutual fund sales loads, contingent deferred sales charges, annuity fees including mortality and expense charges, and surrender charges. A description of the types of fees and expenses actually charged by a particular investment are described in the prospectus or contract, as applicable, of the particular investment. The transaction fees (a.k.a., ticket charges) listed below for fee-based accounts are transaction costs charged by the account custodian and are not commissions. The custodian may amend these fees in the future. In all advisory Accounts that are fee-based, the Client is also responsible for paying all charges related to securities transactions. These charges are in addition to our Advisory Fee, and neither FFAS nor our Advisors receive any part of the related charges. For fee-based accounts, an amount equal to the portion of any charges,

fees, or commissions discussed above (including 12b-1 fees) that inure to the benefit of FFAS or any of FFAS’s Advisors, shall either be refunded to Client’s Account, or netted against the Advisory Fees charged under the Client’s Investment Management Agreement, at FFAS’s election. However, as described in Section 5.2 below, some of our historical advisory arrangements call for FFAS to receive commissions as compensation for advisory services we provide with respect to the Accounts. In those situations, we do not charge an additional Advisory Fee, and the commissions we receive constitute the entire compensation to us in managing the accounts. FFAS reduces Advisory Fees to zero in these cases in recognition that the receipt of commissions constitutes adequate compensation. In these types of Accounts, we do not refund any commissions, including 12b-1 fees, received by FFAS or any of our Advisors. Regardless of the type of advisory fee arrangement FFAS has with any particular Client, all of our Advisors [acting in their separate capacity as registered representatives of Cetera Advisors, LLC, doing business as First Allied Securities (FA), a broker/dealer and a member of FINRA/SIPC] receive commissions, including 12b-1 fees, TRANSACTION TYPE FEE-BASED ACCOUNT CHARGE Equity Trade $14.00 per trade Option Trade $14.00 + $1.65/contract per trade Corporate Bond Trade (listed on the NYSE) $30.00 + $1.00/bond per trade Corporate Bond Trade (not listed on the NYSE, a.k.a. OTC) $30.00 per trade Municipal Bond Trade $30.00 per trade Treasury Security Trade $35.00 per trade Agency, Zero, CMO Security Trade $35.00 per trade Money Market Instrument (e.g., CDs, Commercial Paper, etc.) Trade $35.00 per trade Unit Investment Trust Trade $25.00 per trade “No-Load” Mutual Fund Trade $20.00 per trade “Load” Mutual Fund Trade at Net Asset Value (NAV) $20.00 per trade “Load” Mutual Fund Exchanges within Fund Family $12.50 round trip Systematic Contributions & Withdrawals $7.50 per event Custodian Handling Charge $7.50 electronic (+$1.50 for paper) with respect to securities transactions in non-advisory brokerage accounts and in accounts held directly with an insurance or investment company. This creates a conflict of interest in that they have an incentive to recommend such brokerage transactions based upon their receipt of compensation. FFAS minimizes the impact of these conflicts by: (a) disclosing the conflict of interest to our Clients in this Brochure so they can make an informed decision and ask questions relevant to the fees to be received and other factors; and (b) considering whether a particular product or investment may be available in an advisory account as well as a brokerage account; (c) considering all relevant factors, including those not relevant to costs, relating to a proposed brokerage transaction; and (d) taking all factors into account, ensuring the recommendation to choose FA as the broker-dealer or to purchase the recommended security is in the best interest of the Client. Additionally, in order to further mitigate the conflict, FFAS will generally discount commissions on non-advisory account transactions below the level recommended by the broker- dealer/custodian in cases where the Client has at least one fee-based account and at least one non-fee-based account under FFAS management. In some instances, the Advisor may reduce the amount of a commission he or she would otherwise receive for a particular client, account, or transaction. In that sense, the commissions our Advisors receive are also negotiable. The firm does not have discretion to decide commission rates, except that it sometimes voluntarily reduces any standard commission to be received by a representative with respect to a client’s brokerage account. For example, a representative may elect to reduce commission to 80% of a standard commission on a brokerage transaction for a client that also has an advisory account. This type of commission reduction does not apply to all clients, but rather is something an Advisor may do for certain clients, taking into considerations factors such as the longevity of the client relationship, account size, the existence of other accounts, the complexity of the services generally provided to the client, and similar factors. In determining whether to recommend that the Client open and maintain either a brokerage account or a fee- based advisory account, we evaluate among other things the anticipated costs to the Client and will offer or recommend the type of account that is in the Client’s best interest. In a situation in which transactions are not likely to be frequent, a commission-based account may be more appropriate if the amount of anticipated commission is below the amount of asset-based fees for the same period. Similarly, if an Account is anticipated to have frequent trades, a fee-based account may be more appropriate. Strictly based on compensation, these situations present conflicts of interests because the option with lowest anticipated cost to the Client may not be the option that maximizes the fees to FFAS or our Advisors. We mitigate these conflicts using factors similar to those discussed above, namely: (a) disclosing the conflict of interest to our Clients in this Brochure so they can make an informed decision and ask questions relevant to the fees to be received in the different type of accounts and other factors; and (b) considering whether a particular product or investment may be available in an advisory account as well as a brokerage account; (c) considering all relevant factors, including those not relevant to costs, relating to the benefits or disadvantages of the different types of accounts; and (d) taking all factors into account, ensuring the recommendation to open either a brokerage account or an advisory account is in the best interest of the Client. FFAS Advisors are also licensed insurance agents. They offer various insurance products for which they earn a sales commission. This presents a conflict of interest in that receiving these commissions give Advisors an incentive to recommend insurance products based on the compensation received, rather than on the Client’s needs. However, all FFAS Advisors act in a fiduciary capacity, and make the Client’s needs paramount in their advisory recommendations. Insurance products may be available through other channels and as a Client you are not obligated to purchase insurance products recommended by our Advisors. More details regarding the above-described conflicts of interest, related conflicts regarding our relationship with FA, and other conflicts of interests are described in Item 10 of this Brochure. Additional information about brokerage services is presented in Section 12.0 of this Brochure. As a fiduciary, each FFAS Advisor is committed to holding the Client’s best interest above all else and consequently must disregard any consideration of personal enrichment when developing suggestions. Be that as it may, accepting compensation for the sale of investment products presents a conflict of interest, as it gives an incentive to make recommendations based on compensation received rather than Client needs. This conflict of interest exists particularly whenever a significant difference in compensation results from implementing a specific investment over other investment choices, and/or in determining the account in which to implement a given suggestion. Our receipt of an asset-based fee presents a conflict of interest. This is because the more assets there are in the client’s account, the more the client will pay in fees. Therefore, we have an incentive to encourage clients to increase the assets in their accounts. We address this conflict of interest by ensuring any such recommendations are in the client’s best interest. Client is not obliged under any circumstance to accept any suggestion or engage FFAS to act on a given suggestion, if accepted. Any decision by the Client to act directly or indirectly on any suggestion made by FFAS shall be made fully and solely by Client. Clients also have the option to purchase investment products that we recommend through other brokers or agents that are not affiliated with FFAS. Account fees and transactions charges may be higher or lower at FA than at other broker/dealers offering similar services. 5.2. COMMISSION-BASED FEES In the past, FFAS has permitted Clients to elect a commission-based, or transactional, fee structure for accounts advised by FFAS. FFAS does not charge any fee-based Advisory Fee for these Accounts. We are no longer offering that alternative, but we still have Clients for whom we provide service under this arrangement. Commissions are charged only when transactions are effected. The commissions have a minimum per- transaction fee of $65.00. Commissions are paid directly to Advisors. Clients who have at least one fee-based account will receive discounted commission fees on transactions in any non-fee-based accounts. Transactions in commission-based accounts are subject to the Custodian Handling Charge of $7.50 per transaction, plus $1.50 per transaction if a paper confirmation is requested. These fees are in addition to commission charges, and are paid directly to the custodian for services rendered. The firm does not have discretion to decide commission rates, except that it sometimes voluntarily reduces any standard commission to be received by a representative with respect to a client’s brokerage account. For example, a representative may elect to reduce commission to 80% of a standard commission on a brokerage transaction for a client that also has an advisory account. This type of commission reduction does not apply to all clients, but rather is something an Advisor may do for certain clients, taking into considerations factors such as the longevity of the client relationship, account size, the existence of other accounts, the complexity of the services generally provided to the client, and similar factors. 5.3. FINANCIAL PLANNING SERVICES FFAS provides financial planning services to many of its Clients. The amount and method that FFAS charges Clients receiving financial planning services is negotiable. In most cases, FFAS Advisors will eliminate financial planning service fees for Clients with whom FFAS has a concurrent or pre-existing agreement to provide portfolio management services for assets under FFAS management. The specific fees charged by FFAS to other Clients in need of financial planning services depend largely on the type, complexity, and duration of the specific services requested, and are calculated using the following fee schedules: a) Fixed Fees: FFAS will charge a fixed fee of up to $5,000.00 annually for broad-based financial planning services. In limited circumstances, the total cost could potentially exceed $5,000.00. In these cases, we will notify Client in advance and may request that Client pay an additional fee. b) Hourly Fees: FFAS charges an hourly fee, typically at the rate of $150 per hour, for Clients who request specific services (such as a modular plan or hourly consulting services) and do not desire a broad-based financial plan. c) Monthly Fees: In certain situations, FFAS will charge a monthly fee, payable monthly. The amount of the fee is negotiable and there is no standard or customary fee. d) Annual Fees: In certain situations, FFAS will charge an annual fee, which will be paid in monthly or quarterly installments. The amount of the fee is negotiable and there is no standard or customary fee. Prior to engaging FFAS to provide financial planning services, the Client will be required to enter into a written Investment Management Agreement with our firm. The Agreement will set forth the terms and conditions of the engagement and describe the scope of the services to be provided and the portion of the fee that is due from the Client. For fixed fees, FFAS generally requires a prepayment of 50% of the fee with the remaining balance due upon completion of the agreed upon services. At FFAS’s discretion, FFAS may require prepayment of all or a portion of a fee for financial planning, but at no time will FFAS require prepayment of $1,200 or more, six months or more in advance. Other fee payment arrangements may be negotiated with the Client on a case-by-case basis, particularly for Clients with an ongoing need for financial services. All such arrangements will be clearly set forth in the Investment Management Agreement signed by Client and the firm. Either party may terminate the Investment Management Agreement by written notice to the other. In the event the Client terminates FFAS’ financial planning services, the balance of FFAS’ unearned fees (if any) for such services will be refunded to the Client. 6.0 PERFORMANCE-BASED FEES We do not engage in charging performance-based fees, and FFAS does not have any arrangements for compensation to its Advisors on the basis of a share of the capital gains upon, or the capital appreciation of, the assets, or any portion of the assets, in a Client account.