Firm Description Branson, Fowlkes/Russell, Inc., (“BF/R”) was formed in 1991. BF/R was formed specifically to enter into a contractual agreement with Frank Russell Company now called Russell Investments (“Russell”). Russell is a diversified financial services company which sponsors the Russell Indexes (Russell 1000, 2000, 2500, 3000, etc.) does investment manager research on over 12,000 money management firms, and sponsors a series of private and public investment funds. The purpose of the agreement between Russell and BF/R, amongst other things, was to allow clients of BF/R to have access to certain Private Mutual Funds, Private Trust Funds, Private Investment Partnerships often referred to as Hedge Funds and other Private Investment products. Russell Investments revised its business strategy and has made several of their funds publicly available and also now allows a variety of investment advisory firms to access their products including the co-mingling of Russell and non-Russell investment products in the same account. BF/R consolidated its client accounts holding Russell funds into its affiliate Branson, Fowlkes & Company, Inc. (“BFCO”) allowing the assets to be held in custody at Fidelity Investments. BF/R has continued to be registered as an Investment Adviser with the ability to invest in a global variety of, Russell and non-Russell sponsored, investment products on behalf of its clients. BF/R provides personalized investment advisory services to high-net-worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations and medium sized businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, establishing risk volatility parameters, cash flow management, and tax planning. This information is used to develop various investment strategies which include asset allocations and the selection and monitoring of securities (including open and closed end funds, mutual funds, and publicly - 2 - traded stocks and bonds). BF/R uses a variety of investment strategies including a multi-level approach to investment diversification called D 3 The Power of DiversificationTM . The initial meeting, which may be by telephone, is free of charge and is considered an exploratory consultation to determine the extent to which investment management may be beneficial to the client. Principal Owners BF/R is owned by its founders Jay Branson and Maco Fowlkes. They are each 50% shareholders. Types of Advisory Services BF/R provides investment advisory services, also known as asset management services and furnishes investment advice through consultations. On an occasional basis, BF/R furnishes advice to clients on matters not involving securities, such as taxation issues, and trust services that often include estate planning. As of December 31st, 2022, BF/R has one client and approximately $788,301 assets under management. It expects to continue to add more clients in the future based on implementing several new investment strategies which will be offered exclusively by BF/R. BF/R’s affiliate BFCO manages approximately $308,792,000 in assets for approximately 179 clients. Approximately $262,816,652 is managed on a discretionary basis, and $45,975,348 is managed on a non-discretionary basis. Tailored Relationships The goals, objectives, and investment suitability for each client are documented in our client files. For example, in some cases we may use a questionnaire to explore a client’s tolerance for risk. For some portfolios we may create a written Investment policy statement which reflects the clients stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Types of Agreements The following agreements define the typical

client relationships. Investment Advisory Agreement The services to be provided and fee for an Investment Advisory Agreement are provided to the client in writing when the account(s) to be managed are established. An Investment Advisory Agreement includes, but is not limited to the following services: a. Assisting clients in: (1) establishing, reviewing and changing the investment objectives of the Account, and (2) developing and/or selecting performance standards to measure short-, intermediate-, and long-term Account returns. b. Determining, reviewing, and changing the allocation and diversification of assets in the Account and executing asset allocation software models using variables suitable to the Account. c. Purchasing securities consistent with the Account's investment objectives and asset allocation needs. d. Reporting account investment results quarterly and reviewing the reports and accompanying graphics with you to assist you in understanding their contents. e. Conducting annual meetings at BF/R’s offices to discuss Account performance. The annual Investment Advisory Agreement fee is based on a percentage of the investable assets according to the following schedules: Balanced & Equity Accounts 1.00% on the first $1,000,000; .75% on the next $2,000,000 (from 1,000,001 to 3,000,000); and .50% on the next $2,000,000 (from $3,000,001 to $5,000,000) .50% or as agreed thereafter Fixed Income (Bond) Accounts .30% on the first $ 5,000,000; .25% on the next $ 5,000,000 (from $5,000,001 to $10,000,000); and .25% or as agreed thereafter Separate Account Hedge Fund Strategies* 2.00% on the first $5,000,000; 1.00% on the next $5,000,000 (from 5,000,001 to 10,000,000); and .50% thereafter Plus 20% of profits in excess of a 5% annual return “high water” mark. *This fee schedule is sometimes referred to as a 2 and 20 arrangement and the “high water” mark is cumulative. The minimum annual fee will vary based on the type of account to be managed and is negotiable in some cases. Some current client relationships may exist where the fees are higher or lower than the fee schedule above. In some cases BF/R will provide investment management services for the account of a 401(k) plan participant and not for the entire 401(k) plan. In these cases the advisory fee is determined by the complexity of the plan, operational restrictions, and the size of the participant's account. Fees can range from the normal fee schedule referenced above to as low as .25% annually. BF/R may, under special circumstances, negotiate fees and/or offer services on a gratis basis. The circumstances may include, but not be limited to, members of an employee or client’s extended family, certain non-profit organizations, and non-managed accounts. Although the Advisory Service Agreement is an ongoing agreement and may require periodic adjustments, the length of service to the client is at the client’s discretion. The client or BF/R may terminate an Agreement by written notice to the other party. At termination, fees will be adjusted based on the terms specified in the individual agreement (generally a refund or amount due will be calculated based on the date of the written notice terminating the agreement). Termination of Agreement A Client may terminate any of the aforementioned agreements at any time based on the individual terms specified in their respective agreements. Generally a 30 day written notice is required notifying BF/R at the legal address indicated in their agreement. If there is a balance due, or refund due for advance payment of advisory fees the payment or refund will be calculated based on the terms described in their agreement. BF/R may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, BF/R will refund any unearned portion of the advance payment.