Firm Description XPYRIA Investment Advisors, Inc. (hereinafter “XPYRIA” or the “Firm”) was founded in 1990. XPYRIA provides investment supervisory services by managing assets on a discretionary basis, and occasionally a nondiscretionary basis, to individuals, non-profit organizations, Taft-Hartley, business, union, and government/public entities. XPYRIA is devoted to developing and maintaining investment strategies that are suited to the unique goals, objectives, and risk tolerances of each of our client relationships. We maintain significant resources, proprietary databases, and modeling capabilities. Our consultative approach to portfolio management and reporting is centered upon the selection and placement of our client assets with independent investment managers (mutual funds or separate accounts) which we have selected based on our intensive and proprietary research of thousands of managed investment options that exist globally. Principal Owners John H. Cummings Jr., Joseph G. Salpietro, Bret J. Stutzman, and Michael B. Giammatteo are the principal owners of XPYRIA Investment Advisors, Inc. Types of Advisory Services Investment Management- XPYRIA develops and maintains investment strategies that are uniquely suited to the specific goals, objectives, and risk tolerances of each of our clients. We maintain significant resources; technologies, proprietary databases, intellectual property and talent. The implementation of our strategies includes a consultative approach to portfolio management utilizing our proprietary research of thousands of actively and passively managed investment options that exist globally and then the ultimate selection and placement of the client assets in those investments deemed most appropriate. We are sensitive to a client’s disposition toward certain securities or asset classes and are open to discussing strategies to adjust exposure in this regard. Financial Planning- This service is included and ongoing for our Investment Management clients. Financial planning includes Items such as the creation of a wealth plan; analysis of investments outside of our Firm; providing ongoing education; providing retirement planning and analysis; analyzing household cash flow; providing education related analysis and planning; providing debt analysis; counseling on refinancing, purchases, and leases; developing, documenting and updating an investment policy. It often includes working with the client’s tax professional and other advisors to maximize efficiency; minimization of tax implications related to investing. Tailored Advisory Services XPYRIA provides investment management and financial planning services on a client-by-client basis. Types of Clients Our clients include individual, non-profit, Taft-Hartley, business, union, and government/public entities. Our target client has $1 million or more in investable assets, exceptions can and have been made based upon existing relationships, future growth prospects, and the

appropriateness of the engagement to the client’s circumstance. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a fiduciary rule that requires us to act in your best interest and not put our interest ahead of yours. Under the fiduciary rule’s provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. Investors considering rolling over assets from a qualified employer-sponsored retirement plan (“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant leaving an employer typically has four options (and can engage in a combination of these options): 1.Leave the money in the former employer’s plan, if permitted; 2.Rollover the assets to a new employer’s plan (if available and rollovers are permitted); 3.Rollover Employer Plan assets to an IRA; or, 4.Cash out the Employer Plan assets and pay the required taxes on the distribution. At a minimum, Investors should consider fees and expenses, investment options, services, penalty-free withdrawals, protection from creditors and legal judgments, required minimum distributions, and employer stock. We encourage you to discuss your options and review the above listed considerations with an accountant, third-party administrator, investment advisor to your Employer Plan (if available), or legal counsel, to the extent you consider necessary. We have an economic incentive to encourage investors to rollover Employer Plan assets into an IRA managed by us, as we will earn additional compensation on the increased assets. Assets Under Management As of December 31, 2023, XPYRIA Investment Advisors, Inc. managed approximately $823,305,244 in assets under management, all of which is managed on a discretionary basis.