LVM, founded in July 1988, furnishes wealth management services, integrating investment management and financial planning. Craig A. Vander Molen, CFA, is the majority owner. Investment supervisory services include continuous advice as to the investment of funds based on the individual needs of a client. Financial planning includes collecting, organizing, and analyzing a client’s financial data to provide optimal wealth design through appropriate account structure (including taxable and non-taxable accounts and strategies used within each) and income tax and estate tax strategies on the basis of the individual needs of a client. LVM considers such factors as the size and source of the account, client’s identity and background, the client’s income and growth objectives, cash flow needs, income tax bracket, potential federal and state estate taxes, and the client’s relative risk aversion. The individual needs and situation of each client dictate whether or not both investment supervisory and financial planning services are utilized. Clients may impose investment restrictions on individual securities or security types. LVM does not provide investment advice on all possible investments. In two client relationships, LVM is retained under a wrap-fee program. In a wrap fee program a broker/dealer recommends LVM to manage a client’s assets, pays LVM’s investment management fees on behalf of the client, executes the client’s securities transactions without commission charges, monitors portfolio performance and acts as custodian, or provides some combination of these or other services, all for a single fee. LVM’s investment advisory fee in a wrap-fee arrangement may vary from that charged to wealth management clients. In evaluating such a program, a client should understand that LVM cannot negotiate brokerage commissions. Transactions are effected “net” and a portion of the wrap fee is generally considered in lieu of explicit brokerage commissions. Trades will be generally executed with the referring broker/dealer to avoid incurring the incremental brokerage costs from incurred using other broker/dealers. In evaluating a wrap fee arrangement, the client should consider whether, depending on the amount of the wrap fee, the amount of portfolio activity and the value attributed to monitoring, custodial, and any other services provided, the wrap fee would exceed the cost of such services if they were separately provided and LVM were free to chose broker/dealers to execute portfolio transactions. In limited cases, LVM is retained for investment management only for clients who receive financial planning from a broker/dealer's registered representative. At the broker/dealer's

specific request, LVM invoices these joint clients for both its investment management fee and the broker/dealer's registered representative fees, remitting to the broker/dealer its portion of the fee. LVM’s business continuity plan addresses pandemics and health crises. While the global COVID-19 pandemic did not impede LVM’s ability to serve its clients and manage its business, future health crises could negatively affect LVM’s ability to serve its clients. Fiduciary Status Pursuant to the Employee Retirement Income Security Act of 1974 (“ERISA”), and regulations under the Internal Revenue Code of 1986 (“Code”), LVM and its individuals providing wealth management advice on our behalf (“Fiduciary Advisers” or “FAs”) will be deemed investment advice fiduciaries (“ERISA Fiduciaries”) when LVM renders individualized investment advice to a plan, plan fiduciary, plan participant or beneficiary, IRA, or IRA owner, Health Savings Accounts (“HSAs”), Archer Medical Savings Accounts and Coverdell Education Savings Accounts (together, “Retirement Accounts”) for a fee or other compensation, whether direct or indirect. While LVM is already a fiduciary for all of its advised accounts under the Investment Advisers Act of 1940, LVM is required to acknowledge this ERISA Fiduciary status. Acknowledgement of Fiduciary Status Pursuant to the recommendations LVM provides to retirement account(s) and client acceptance thereof, LVM acknowledges that together with its FAs that it is acting as Fiduciaries under ERISA with respect to recommended transactions. As ERISA Fiduciaries to clients, LVM and its FAs have an affirmative duty of undivided loyalty to always serve clients’ best interests and act in utmost good faith, placing clients’ interests first and foremost without regard to the financial interests of its employees, related entities, or other parties. Further, as Fiduciaries LVM and its FAs are required to act prudently on its clients’ behalf, exercising care, skill and diligence when providing wealth management services. As ERISA Fiduciaries, LVM and its FAs are committed to these Impartial Conduct Standards: (i) providing prudent advice that is, at the time of the recommendation, in the best interest of a client, (ii) receiving no more than reasonable compensation, and (iii) statements made regarding the recommended transaction, fees and compensation, material conflicts of interest and other matters relevant to the retirement investor’s investment decisions, will not be materially misleading at the time they are made. At June 30, 2023, LVM managed $946,985,015 discretionary assets and $27,607,154 non discretionary assets.