Description of Advisory Firm William Howard & Co. Financial Advisors, Inc.’s registration was granted by the U.S. Securities and Exchange Commission on January 28, 1988. William Barker Howard, Jr. (CRD Number 1040874) is President and Chief Executive Officer of the firm. Mr. Howard is the principal owner of the firm. The firm is not publicly owned or traded. There are no indirect owners of the firm or intermediaries who have any ownership interest in the firm. The firm manages each Client’s portfolio on an individualized basis. Clients may impose restrictions on their accounts. The firm does not participate in wrap programs. As of December 31, 2023, the firm managed assets on a discretionary basis in the amount of $275,882,881 on a nondiscretionary basis in the amount of $14,369,550. Types of Advisory Services William Howard & Co. Financial Advisors, Inc. provides investment advisory services. The fees for investment advisory services are based on the market value of assets under management at the end of each calendar quarter and are payable at the end of each calendar quarter. William Howard & Co. Financial Advisors, Inc. receives approximately 90 percent of total advisory billings from this service. William Howard & Co. Financial Advisors, Inc. investment advisory services are implemented by following a six- step process described below. Step 1: Develop a written investment policy: This policy includes quantifying investment objectives, setting investment parameters and constraints, establishing procedures for selecting investments, defining appropriate asset classes, i.e., cash, bonds, and stocks, and establishing acceptable procedures for comparing and evaluating investments. This policy will be used to measure future performance and consistency of the portfolio meeting the investment philosophy, risk tolerance, and long-term goals of our clients. Step2: Analyze current investment portfolio: This entails an analysis of current investment activities and a review of current investment policies and strategies. Step 3: Design an optimal portfolio: We design efficient portfolios that diversify across broad categories of investments considering the relationships (or correlation) of these investments, standard deviation, potential returns, and tax impact of asset classes. The result is an individually designed portfolio that reflects the Clients’ priorities. Step 4: Implement investment policy. We follow the parameters and constraints defined in the investment policy and design an investment portfolio whose risk level and

performance in a given asset class is consistent with the Client’s investment policy. Custody and discount brokerage services are coordinated with Charles Schwab. Step 5: Monitor and Supervise: We provide ongoing supervision of investment policy and investment strategies and prepare quarterly performance reports. Step 6: Rebalance the portfolio: Fine tuning or rebalancing the portfolio is an essential function. Changes in the financial markets increase or decrease the overall mix of investments and adjustments are required to retain the desired asset allocation and meet the investment policy standards. William Howard & Co. Financial Advisors, Inc. furnishes advice to Clients on matters not involving securities. The services provided are Financial Advisory Services. William Howard & Co. Financial Advisors Inc. may employ sub-advisers to provide investment management services to clients. Financial Advisory Services fall under one of the following categories: Comprehensive Financial Planning—an in-depth analysis which reviews, evaluates, and recommends alternatives to accomplishing Client goals and objectives in the areas of insurance planning, education planning, investment planning, tax planning, retirement planning, estate planning and business planning. Single Purpose Planning—an in-depth analysis which reviews, evaluates, and recommends alternatives to accomplishing Client goals and objectives regarding one or more areas of special concern, i.e., investment planning, retirement planning, estate planning, etc. Consultation Planning—includes written or verbal recommendations on financial planning or business planning issues. Annual Retainer—includes plan monitoring, revisions, Client meetings and reports, e.g., financial statements, investment, income, insurance, ownership, performance schedules, etc. Since financial goals, resources, tax laws, investment philosophy, etc., change, it is necessary to make planning a continuing process, so modification can be implemented as warranted. This continuing process also allows us the ability of monitoring the progress of our actions. We feel the described service is essential to any successful financial planning. The reports used in providing these services include Financial Statements, Financial Summaries, Schedules of Assets, Schedules of Asset Ownership, Schedules of Insurance, Cash Flow Analysis, Insurance Needs Analysis, Income Tax Projections, Portfolio Analysis, Education Funding Analysis, Retirement Capital Projections, Analysis for Retirement Plan Distributions and Estate Tax Analysis.