A. History of the firm; ownership of the firm. Laura Tarbox began her career in the advisory business in 1980 with a boutique investment firm in Tustin, California, which was affiliated with a large independent broker/dealer. Although she found the world of investments to be very compelling, the industry culture of day trading stocks, pitching the latest investments and cold calling for new clients quickly lost its appeal. Laura discovered the CERTIFIED FINANCIAL PLANNER™ courses, where she found she could use her investment knowledge in conjunction with the practice of holistic planning and became one of the early pioneers of the financial planning profession. Laura completed the CFP® program in 1983, and founded The Tarbox Group, Inc. on January 1, 1985 in California. Laura Tarbox is the owner and principal of Tarbox Family Office, Inc., and founded the firm as an SEC- registered investment adviser. Never comfortable with the conflicts inherent in selling products, Laura made the decision to drop her securities and insurance licenses in 1990, becoming one of the first truly fee-only financial advisors in the U.S. The firm is not affiliated with any bank, brokerage firm, insurance, or trust company, and is privately held. Tarbox Family Office, Inc. does not sell any products, or take any commissions, trails, or referral fees. Our allegiance is to our client, and our incentive is to serve our clients` best interest. During the 1990s, Laura built the firm and its reputation, and has developed a team approach to providing financial planning and investment advisory services. She has added talented, multi-disciplined professionals with expertise in tax, investments, retirement, and estate planning. B. Types of Services Financial Planning, Tax Preparation and Consulting Services Tarbox Family Office, Inc.’s approach starts with the evaluation and review of its clients’ financial concerns, risks, and objectives. We suggest strategies to accomplish agreed-upon goals and use a coordinated implementation and follow-through process once decisions are made. Results and progress are evaluated on an ongoing basis. Financial planning services may include:
• Coordination of multi-generational estate planning and wealth transfer
• Assistance in establishing goals and development of overall family financial plan
• Advice on philanthropic giving and management
• Help with maximizing employee benefits
• Assistance with complex financial transactions
• Work with and/or coordination with other close family members
• Cash-flow analysis and management
• Review and management of insurance coverage
• Ongoing tax planning, consulting, and coordination
• Preparation of income tax returns under the terms of a separate agreement Investment Advisory Services Investment management is implemented as part of the client’s overall plan and involves the management and oversight of all assets on an ongoing basis. We provide disciplined and customized institutional-grade investment management for both taxable and tax-deferred clients. Tarbox Family Office, Inc. uses an asset class investing approach, with a variety of asset types to build portfolios, and a strong preference for liquidity, where possible. Tarbox Family Office, Inc. looks at the performance of various asset classes over long periods of time to determine its sector allocations for its models, then chooses the most appropriate vehicle to obtain the appropriate exposure to those asset classes. Equities Tarbox Family Office, Inc.’s core investment portfolios include equity exposure to Global, Domestic (U.S.), Developed International and Emerging Markets. We diversify across equity markets, making small shifts into equity exposures that look most attractive to use for the next one to three years. For example, we may overweight U.S. stocks and underweight developed international stocks. Within the broader equity market, we invest across market capitalizations (large, mid, small and microcap) and styles (value and growth). The focus is not on individual companies or marketing timing maneuvers. Typically, the firm indexes the core of each of our equity portfolios. Tarbox Family Office, Inc. believes traditional index funds have significant benefits that include an easily understandable discipline, transparency, reduced costs, tax efficiency, and lack of subjectivity, all of which have been shown to add significantly to investment returns. For example, we use S&P 500 index funds to provide primary exposure to large-cap U.S. stocks. We will often use Exchange Traded Funds (“ETFs”) to implement index strategies. When consistent with a client’s investment objectives, we may allocate to “interval funds.” Investment companies structured as “interval funds” are generally designed for long-term investors that do not require daily liquidity. Shares in interval funds typically do not trade on the secondary market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds we use offer a two to three week period, on a quarterly basis, during which the client may seek the redemption of the previously purchased interval funds. We may include actively managed mutual funds in client portfolios, which seek to add value by:
• Providing specific exposure to portfolios to more inefficient asset classes such as small-cap or emerging markets
• Allowing great stock pickers to identify attractive companies
• Protecting portfolios in down markets Important factors that we consider to help identify superior active managers include:
• An investment approach that is consistent and repeatable
• Reasonable expenses
• Mindfulness of the importance of maximizing pre-tax and after-tax performance
• Risk and return analysis
• Managers who invest their own money in the funds they manage
• Portfolio concentration – conviction, keeping risk in mind Fixed Income Tarbox Family Office, Inc. includes bond and cash investments in client portfolios to provide stable cash flow. We participate across a full spectrum of fixed income assets, allowing us to invest where we find the greatest potential value, i.e., corporates, agencies, municipals, etc. Individual fixed income portfolio construction involves:
• Controlling portfolio duration to protect form interest rate fluctuations
• Managing the impact of callable bonds
• Cash flow-liability matching, if appropriate
• Building of national and state-specific portfolios The factors under consideration when constructing the fixed income portfolio include:
• Controlling costs by working with multiple bond sources and technology sources (i.e., Bloomberg) to obtain the highest bond yields
• Minimizing tax impact: Utilization of federal and state tax-free bonds for clients in higher tax brackets
• Asset location: Placement of tax-inefficient holding in tax-deferred accounts when possible Investments in these assets may cause a client to miss upswings in the equity markets. A client can advise Tarbox Family Office, Inc. not to maintain (or to limit the amount of) cash or cash equivalent positions in their account. Alternatives Tarbox Family Office, Inc. client portfolios have an allocation to alternatives, which are typically comprised of mutual funds. We feel that alternatives can potentially reduce portfolio risk and enhance returns because this asset class does not always move in sync with the stock or bond markets. These holdings may include:
• Single-strategy hedge funds
• Hedge fund-of-funds
• Long-short funds
• Arbitrage strategies
• Managed futures
• Value-added real estate partnerships
• Real estate investment trusts (“REITs”)
• Commodities
• Hedged mutual funds
• Private equity MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services We may provide services regarding non-investment related matters, such as: estate planning, tax planning, tax preparation, insurance consulting, etc. Tarbox Family Office, Inc. does not serve as a law firm, or insurance agency, and our services should be construed as legal services or insurance sales. Tarbox Family Office, Inc. does not prepare estate planning documents, or sell insurance products. Unless specifically agreed in writing, neither Tarbox Family Office, Inc. nor its 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. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from Tarbox Family Office, Inc., and its representatives in that respect. Tarbox Family Office, Inc.’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. Upon specific client request, Tarbox Family Office, Inc. may recommend other professionals to provide services (such as attorneys, accountants, and insurance agents). 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. Independent Managers When consistent with investment objectives, Tarbox Family Office, Inc. may also recommend that certain clients authorize Tarbox Family Office, Inc. to allocate the active discretionary management of a portion of their assets among certain independent investment managers or platforms that Tarbox Family Office, Inc. selects to provide specialized investment services (the “Independent Managers”). Tarbox Family Office, Inc. considers the following factors before recommending allocations to Independent Managers: portfolio investment objectives, account management style, historical performance, reputation, financial strength, reporting, pricing, and research. The terms and conditions of the relationship are detailed in a separate agreement executed between the client and the Independent Manager. Tarbox Family Office, Inc. will monitor those accounts with a focus on client investment objectives, and asset allocation. Tarbox Family Office, Inc. may determine that the allocation to an Independent Manager is no longer appropriate and reallocate client investment assets elsewhere. The value of assets allocated to the Independent Managers is included in the calculation of the client’s investment advisory fee paid to Tarbox Family Office, Inc. as described in Item 5. The investment management fees charged by the designated Independent Managers are exclusive of, and in addition to, Tarbox Family Office, Inc.’s ongoing investment advisory fee. Fees charged by the Independent Managers (which may include fees collected by Tarbox Family Office that it remits to the Independent Managers) may be either in advance or arrears depending upon the specific Independent Manager relationship, which will be disclosed to the client at the point of entering into the Independent Manager relationship. Unaffiliated Private Investment Funds Tarbox Family Office, Inc. may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. Tarbox Family Office, Inc.’s role in this respect is limited to initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the funds are included in the calculation of Tarbox Family Office, Inc. investment advisory fee. Tarbox Family Office, Inc.’s clients are under absolutely no obligation to consider or make an investment in a private investment funds. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that they are qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. If Tarbox Family Office, Inc. bills an investment advisory fee

based upon the value of private investment funds or otherwise references private investment funds owned by the client on any supplemental account reports prepared by Tarbox Family Office, Inc., the value for all private investment funds owned by the client will reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. Retirement Plan Rollovers-No Obligation/Conflict of Interest A client or prospective client leaving an employer 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 Tarbox Family Office, Inc. recommends that a client roll over their retirement plan assets into an account to be managed by Tarbox Family Office, Inc., such a recommendation creates a conflict of interest if Tarbox Family Office, Inc. will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Tarbox Family Office, Inc. ERISA / IRC Fiduciary Acknowledgment When Tarbox Family Office, Inc. 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 Tarbox Family Office, Inc. makes money creates some conflicts with client interests, Tarbox Family Office, Inc. 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, Tarbox Family Office, Inc. 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 Tarbox Family Office, Inc. gives advice that is in the client’s best interest; charge no more than is reasonable for Tarbox Family Office, Inc.’s services; and give the client basic information about conflicts of interest. Client Obligations When performing its services, Tarbox Family Office, Inc. 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 Tarbox Family Office, Inc. if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Tarbox Family Office, Inc.’s services or previous recommendations. Margin / Securities Based Loans Tarbox Family Office, Inc. does not recommend the use of margin for investment purposes. However, if a client determines to take a margin loan that collateralizes a portion of the assets that Tarbox Family Office, Inc. is managing, Tarbox Family Office, Inc.’s investment advisory fee will be computed based upon the full value of the assets, without deducting the amount of the margin loan. Without limiting the above, upon specific client request and generally in a financial planning context, Tarbox Family Office, Inc. may help clients evaluate and establish a margin or securities based loan (“SBL”) with the client’s broker- dealer/custodian or their affiliated banks (each, an “SBL Lender”) to access cash flow. Compared to real estate-backed loans, an SBL could provide access to funds in a shorter time, provide greater repayment flexibility, and may also result in the borrower receiving certain tax benefits. Clients interested in learning more about the potential tax benefits of SBLs should consult with an accountant or tax advisor. The terms and conditions of each SBL are contained in a separate agreement between the client and the SBL Lender selected by the client, which terms and conditions may vary from client to client. SBLs are not suitable for all clients and are subject to certain risks, including but not limited to: increased market risk, increased risk of loss, especially in the event of a significant downturn; liquidity risk; the potential obligation to post collateral or repay the SBL if the SBL Lender determines that the value of collateralized securities is no longer sufficient to support the value of the SBL; the risk that the SBL Lender may liquidate the client’s securities to satisfy its demand for additional collateral or repayment / the risk that the SBL Lender may terminate the SBL at any time. Before agreeing to participate in SBL programs, clients should carefully review the applicable SBL agreement and all risk disclosures provided by the SBL Lender including the initial margin and maintenance requirements for the specific program in which the client enrolls, and the procedures for issuing “margin calls” and liquidating securities and other assets in the client’s accounts. If Tarbox Family Office, Inc. recommends that a client apply for a SBL instead of selling securities that Tarbox Family Office, Inc. manages for a fee to meet liquidity needs, the recommendation presents an ongoing conflict of interest because selling those securities (instead of leveraging those securities to access an SBL) would reduce the amount of assets to which Tarbox Family Office, Inc.’s investment advisory fee percentage is applied, and thereby reduce the amount of investment advisory fees collected by Tarbox Family Office, Inc.. Likewise, the same ongoing conflict of interest is present if a client determines to apply for a SBL on their own initiative. These ongoing conflicts of interest would persist as long as Tarbox Family Office, Inc. has an economic disincentive to recommend that the client terminate the use of SBLs. If the client were to invest any portion of the SBL proceeds in an account that Tarbox Family Office, Inc. manages, Tarbox Family Office, Inc. will receive an advisory fee on the invested amount, which could compound this conflict of interest. If a client accesses an SBL through its relationship with Tarbox Family Office, Inc. and the client’s relationship with Tarbox Family Office, Inc. is terminated, clients may incur higher (retail) interest rates on the outstanding loan balance. Clients are not under any obligation to employ the use of SBLs, and are solely responsible for determining when to use, reduce, and terminate the use of SBLs. Although Tarbox Family Office, Inc. seeks to disclose all conflicts of interest related to its recommended use of SBLs and related business practices, there may be other conflicts of interest that are not identified above. Clients are therefore reminded to carefully review the applicable SBL agreement, and all risk disclosures provided by the SBL Lender as applicable and contact Tarbox Family Office, Inc.’s Chief Compliance Officer with any questions about the use of SBLs. Third Party Reporting Services Tarbox Family Office, Inc. 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 Tarbox Family Office, Inc. to manage (the “Excluded Assets”). Tarbox Family Office, Inc.’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because Tarbox Family Office, Inc. does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not Tarbox Family Office, Inc., will be exclusively responsible for directly 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 Tarbox Family Office, Inc. Accordingly, Tarbox Family Office, Inc. 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 Tarbox Family Office, Inc.’s participation or oversight. Portfolio Trading Activity and Inactivity As part of its investment advisory services, Tarbox Family Office, Inc. 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, 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 Tarbox Family Office, Inc. 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. Cybersecurity Risk The information technology systems and networks that Tarbox Family Office, Inc. and its third-party service providers use to provide services to Tarbox Family Office, Inc.’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Tarbox Family Office, Inc.’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Tarbox Family Office, Inc. are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost, and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Tarbox Family Office, Inc. has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Tarbox Family Office, Inc. does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. C. Advisory Services Tailored to Individual Clients Tarbox Family Office, Inc.’s goal is not to beat a particular index – it is to meet or exceed our clients’ specific required or targeted rate of return. No two clients have the same situation, so no two clients have the same investment portfolio. In all cases, the firm’s clients appreciate the focus and attention given to their unique situation. We work with the client to establish a unique Investment Policy Statement (“IPS”), the purpose of which is to agree on a set of general parameters and select an allocation to one of Tarbox Family Office, Inc.’s four model strategies: Stable Growth, Conservative Growth, Moderate Growth and Growth. The appropriate model strategy is based on the appropriate target volatility/return portfolio, given the client’s risk tolerance. Once the strategy is selected, Tarbox Family Office, Inc. individually manages each client portfolio in conformity with the IPS. To build a client customized portfolio, we use the following investment process:
• For individuals and families, we start with a review of the client’s current investments, tax situation, income needs, family dynamics, and short- and long-term goals.
• For foundations and endowments, we review the entity’s current policy and investment profile in relation to its spending needs. This provides a risk/reward profile that leads toward the selection of a targeted asset allocation. The client may, at any time, impose reasonable restrictions, in writing, on Tarbox Family Office, Inc.’s services. D. Wrap-Fee Programs Tarbox Family Office, Inc. does not participate in a wrap fee program. E. Assets Under Management As of December 31, 2023, Tarbox Family Office, Inc. had $873,623,926 in assets under management on a discretionary basis.