Investors Asset Management of Georgia, Inc. (“Investors Asset Management” or “IAM”) and the Investment Advisory Representatives of the firm manage investment accounts on a discretionary basis for a fee. IAM was founded in November 1990, and Timothy Rigby is the principal owner of the Firm. Advisory Services Investors Asset Management provides advisory services, giving continuous advice based on the client’s individual needs. The firm performs an initial review of each client’s investible assets in relation to their objectives, preferences and tolerance for risk. These objectives can range from preservation of capital, growth, growth and income, income and short- or long- term goals. Each advisor creates a specific investment strategy determined for each client and develops a truly individualized portfolio for each client based on individual needs. An allocation among publicly traded securities is then made based on each advisor’s judgments regarding expected returns and variability of returns on those securities. Thereafter, the portfolio will be monitored daily, and adjustments will be made when warranted by changes in estimated returns of specific securities or asset classes or in the client’s personal situation. If requested, clients receive quarterly reviews which outline each holding, date of purchase, cost, market value, gain or loss, as well as performance data. It is necessary for clients to inform their advisor of any changes in their financial situation or investment goals and objectives, and any preferences or restrictions on certain investments. Retirement Plan Programs Advisors of the firm also provide financial and consulting services for assets managed by Investors Asset Management. Such accounts include “Investors Choice” services available to 401(k), 403(b) and 457(b) Plans, collectively (“Retirement Plan(s)”). IAM may act as a fiduciary on a non-discretionary basis, as defined by §3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”); or IAM may act as an investment manager as defined by §3(38) of ERISA. IAM requires each Retirement Plan client to make a selection of services in writing as part of its agreement. As part of the services offered, IAM may consult and advise trustees of each Retirement Plan on overall plan design and implementation. Included in this service is selection and monitoring of the mutual funds offered, including model portfolios, for participants to choose from. IAM typically recommends its own model portfolios to Retirement Plan clients, but will recommend other funds, as directed by the Retirement Plan. IAM also may also give guidance on plan expenses and fiduciary liability and disclosures required under Department of Labor rules. The overriding goal is to create a better outcome for participants at retirement. Advisors will not at any time have access to a client’s funds, securities, or account(s) and therefore will not have authority to rebalance, reallocate or place trades in the participant’s account. All trade implementation under these services is the responsibility of the client through the particular recordkeeper and/or custodian in the program. MidAtlantic Trust Company, a leading custodian for corporate 401(k) programs, has developed a management platform called “ModelxChange” for 401(k) model portfolios. Investors Asset Management enrolled their Investors CHOICE 401(k) portfolios on this platform as a means to provide a single system for the creation, execution, and ongoing management of mutual fund and ETF investment portfolios for the 401(k) marketplace. Incorporation of disclosure data and fact sheets is a key component of the ModelxChange platform.

MidAtlantic satisfies DOL regulations by calculating returns, expense ratios, turnover, benchmark data, and other pertinent data and delivers it to Retirement Plan sponsors and participants via composite and plan specific fact sheets. ERISA and Individual Retirement Accounts Disclosure 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 special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special 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. Financial Planning IAM also offers planning in areas such as estate and retirement planning, financial planning, educational funding, and tax and risk strategies. IAM can provide clients with a written analysis in one or more of these areas detailing strengths and weaknesses of their current financial situation. These written plans can range from brief summaries to complex financial solutions depending on each client’s needs and goals. General Information Each client has the ability to impose reasonable restrictions on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an Investment Advisor Representative believes that the instructions are inappropriate for the client, Investors Asset Management will notify the client that, unless the instructions are modified, it may cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. Investors Asset Management does not offer a wrap fee program. Investors Asset Management’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Investors Asset Management’s fee, and Investors Asset Management shall not receive any portion of these commissions, fees, and costs. As of December 31, 2023, Investors Asset Management had $354.2 million under management on a discretionary basis.