Company History PDS Planning, Inc. (PDS) is a corporation founded in 1985 in the State of Ohio and was registered as an Investment Adviser Firm with the Securities & Exchange Commission in 1988. Owners and shareholders of PDS Planning are Rita M. Itsell, Jamie P. Menges, Kurt M. Brown, and James A. Rogers. Services Offered PDS is a fee-only firm, and advisors adhere to a Code of Ethics to act in its clients’ best interests at all times. PDS offers financial planning and investment advisory services. During our initial meetings with the client, information related to the client’s financial standing, goals and objectives, family dynamics, professional circumstances, investment philosophy, and risk tolerance may be discussed. Using this information, PDS will determine how the client can be best served by our firm. This includes assessing the complexity of their financial plan, expected resources required to complete our planning objectives, and a fee estimate for us to engage the client in an advisory relationship. At that time, an agreement is prepared and signed, setting forth the terms and conditions of engagement along with a description of the scope of the services to be provided. Once an agreement has been executed, it remains the client’s responsibility to promptly notify PDS if there is any change in his/her financial situation or investment objectives. Financial Planning Services PDS provides clients with customized financial planning reports and recommendations after analysis of the client’s assets, liabilities, and income, and taking into account the client’s goals and objectives in the following possible areas:
• Personal Financial Statements: Preparation of personal statement of net worth and cash flow requirements.
• Retirement Planning: Review sources of retirement income, possible dates of retirement, and the effect changes in inflation and rates of return might have on realizing retirement goals.
• Investment Planning: General investment planning, not including Investment Advisory Services.
• Tax Planning: Income tax review and planning for current and future years to help clients realize opportunities that may exist for their benefit within the tax code. We can coordinate with your tax preparer when necessary.
• Estate Planning: Review of account titling and beneficiary designations to ensure compliance with estate documents. We can coordinate with your attorney when necessary.
• Planned Giving: When applicable, we will help clients develop a planned giving strategy to charity, family, or other loved ones.
• Insurance Planning: Review of the impact a disability or unexpected death may have on your financial goals, and provide analysis and recommendations on current and future insurance policies you may have, or acquire.
• Education Funding: Project the expected cost of education goals, how to properly fund and determining if any resources are available to assist in funding this objective.
• Executive Compensation: Review and planning related to existing and future stock options in an effort to maximize value.
• Business Planning: When applicable, review of current business structure, tax considerations, retirement issues, and succession issues for closely-held businesses. The report may be written, electronic, and/or oral in nature, and it may include recommendations regarding the aforementioned areas of importance to the client. PDS Planning, Inc. 5 As indicated in Item 5 below, PDS offers its services on an annual flat, fixed fee basis. This fee is determined based upon a combination of various objective and subjective factors including but not limited to: portfolio composition; the scope and complexity of the engagement; the anticipated servicing needs; related accounts; the professional(s) rendering the service(s); competition, and negotiations with the client. Please Note: similarly situated clients could pay different fees, and the services to be provided by PDS to any particular client could be available from other advisors at lower fees. PDS’ Chief Compliance Officer, Kurt M. Brown, remains available to address any questions that a client or prospective client may have regarding the above fee determination. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, PDS will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. inclusive of our Financial Planning fee set forth at Item 5 below (exceptions may occur based upon client decision, advanced planning needs, special projects, etc. for which PDS may charge a mutually agreeable additional fee and/or stand-alone financial planning engagement). Please Note: Neither PDS, nor any of its employees (including Jamie P. Menges, who is a licensed CPA), serves as an attorney, accountant, or insurance agent for any PDS client, and no portion of PDS’ services should be construed as same. Accordingly, PDS does not prepare legal documents, prepare tax returns, or sell insurance products for or to PDS clients. To the extent requested by a client, we may recommend the services of other professionals for non- investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from PDS and/or its representatives. At all times, the engaged unaffiliated professional(s) (i.e. attorney, accountant, insurance agent, etc.) and not PDS, shall be responsible for the quality and competency of the services provided. PDS’ Chief Compliance Officer, Kurt M. Brown, remains available to address any questions that a client or prospective client may have regarding the above financial planning engagements and services. Investment Advisory Services PDS offers Investment Advisory (Investment Management/Portfolio Management) services to clients. PDS may prepare an Investment Policy Statement (IPS) for the client, which will serve as a guide for future investment decisions. The IPS, when applicable, will outline the client’s general goals and preferences for risk, as well as general asset allocation targets for the client’s managed portfolio. PDS, in consultation with the client, will design and monitor a client’s managed investment portfolio. Clients may impose restrictions on investing in certain securities or types of securities. PDS has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, PDS will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when PDS determines changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by PDS will be profitable or equal any specific performance level(s). Please Note: Retirement Rollovers-Potential for Conflict of Interest. 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 PDS recommends a client roll over their retirement plan assets into an account to be managed by PDS, such a recommendation creates a conflict of interest if PDS will earn new (or increase its current) compensation as a result of the rollover. If PDS provided a recommendation as to whether a client should engage in a rollover or not (whether it is from the employer’s plan or an existing IRA), PDS is acting as a fiduciary with the meaning of Title I of the PDS Planning, Inc. 6 Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by PDS, whether it is from an employer’s plan or an existing IRA, or to engage PDS to monitor and/or manage the account while maintained with the client’s employer. PDS’ Chief Compliance Officer, Kurt M. Brown, remains available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. PDS offers the services of Schwab Institutional. Managed advisory accounts are non-commission, fee-only, where mutual funds, exchange-traded-funds,

separately managed accounts, stocks, bonds, CDs, and other individual securities may be held and managed. Client Obligations. In performing our services, PDS shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify PDS if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Portfolio Activity. PDS has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, PDS will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when PDS determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. As indicated below, there can be no assurance investment decisions made by PDS will be profitable or equal any specific performance level(s) Participant Directed Retirement Plans. PDS may also provide investment advisory and consulting services to participant directed retirement plans. For such engagements, PDS shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by PDS), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. Client Retirement Plan Assets. If requested to do so, PDS shall provide investment advisory services relative to the client’s 401(k) plan assets. In such event, PDS shall allocate the retirement account assets among the investment options available on the 401(k) platform. PDS shall be limited to the allocation of the assets among the investment alternatives available through the plan. PDS will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify PDS of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Miscellaneous Custodian Charges-Additional Fees. As discussed below in Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, PDS generally recommends that Schwab serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. Please Note: there can be no assurance that Schwab will not change their transaction fee pricing in the future. PDS Planning, Inc. 7 Socially Responsible Investing Limitations. Socially Responsible Investing 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 qualifying 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 fewer 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 PDS), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. PDS does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, PDS will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, PDS will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: PDS does not recommend or advocate the purchase of, or investment in, cryptocurrencies. PDS considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Cash Positions. PDS continues to treat cash as an asset class. As such, unless determined to the contrary by PDS, all cash positions (money markets, etc.) shall continue to be included as part of assets under management. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee such anticipated market conditions/events will occur), PDS 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, PDS’s advisory fee could exceed the interest paid by the client’s money market fund. Other Assets. To the extent that PDS provides advisory monitoring or review services for client investment assets for which PDS does not maintain custodian access or trading authority (including initial and ongoing consideration of such assets as part of the client’s asset allocation), PDS may determine to include such assets in its advisory fee calculation per Item 5 below. A client may hold securities which were purchased at the request of the client or acquired prior to the client’s engagement with PDS. Generally, with potential exceptions, PDS does not/would not recommend such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please note: If/when liquidated, it should not be assumed the replacement securities purchased by PDS will outperform the liquidated positions. Cybersecurity Risk. The information technology systems and networks that PDS and its third-party service providers use to provide services to PDS’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in PDS’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and PDS 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 PDS 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 PDS 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. PDS Planning, Inc. 8 As of December 31, 2023, PDS had $1,390,058,390 total assets under management.