Originally founded in January 1991, ACG Advisory Services, LLC dba Wealthspire Advisors (“Wealthspire” or “firm”), (previously ACG Advisory Services, Inc.) an Investment Advisory firm registered with the Securities and Exchange Commission, provides Investment Management Consulting Services to individuals, trustees of trusts, fiduciaries in other capacities, and to institutions such as financial services firms, financial planners, banks, and other Registered Investment Advisors (“Advisors”). The firm is a subsidiary of Wealthspire Advisors LLC. On July 17, 2023, the firm was acquired by Wealthspire Advisors LLC, a SEC-registered investment advisor wholly owned by NFP Corp. (previously known as National Financial Partners Corp.) (“NFP”). NFP was acquired by Aon plc on April 25, 2024. Following the July 17, 2023 acquisition, the firm became a subsidiary of Wealthspire Advisors LLC. The firm intends to maintain a separate client brochure until such time as the operations of Wealthspire Advisors LLC and the firm are sufficiently integrated to merit a combined client brochure. Joseph Saunders Wiggins, (“Sandy”) is a Managing Director; Mike LaMena is the firm’s Chief Executive Officer; Eric Sontag is the firm’s President and Chief Operating Officer; Hoyt Stastney is the firm’s General Counsel; Michael Moriarty is the firm’s Chief Investment Officer; Michael Del Priore is the firm’s Chief Compliance Officer; and Brian Powers is the firm’s Chief Financial Officer. Service Approach Wealthspire believes that its success and integrity depend upon offering objective, impartial advice. Wealthspire is focused on assisting Advisors and/or Clients in achieving established goals by providing unbiased, relevant information and advice about/access to investment strategies offered by professional money managers. Wealthspire provides investment supervisory services and advice to individuals, banks or thrift institutions, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and business entities. Through dialogue and completing an investment questionnaire, potential Clients and their Advisors provide to Wealthspire information relevant to the establishment of their specific goals, objectives, and investment philosophy, all of which are suitable for their own particular circumstances. Upon consideration and review of the dialogue and submission of the investment questionnaire to Wealthspire, a determination is made as to which services are most appropriate to meet the Client’s specific needs. To document Wealthspire Client relationships, a formal agreement is executed by the parties reflecting the services to be performed by Wealthspire, the fees for such, and the relationship of the Client to Wealthspire. Upon acceptance of a relationship with Wealthspire, the Client agrees to open an account with a custodian designated by the Client to provide custody, trades, trade confirmations, and a regular statement of position and account activity. Wealthspire, through its technology links with the selected custodian, provides Clients with periodic performance reports and other detailed information about ongoing activity within their accounts, including information about manager performance. With regard to Investment Management Consulting Services, Wealthspire performs services in any one or more of the following capacities:
• Analysis of Client Objectives
• Interpretation of Client Risk Tolerance
• Portfolio Construction
• Drafting of Investment Policy Statements
• Recommendation of Investment Vehicles
• Selection of Managers
• Ongoing Monitoring of Manager Performance
• Portfolio Rebalancing
• Manager Additions or Replacements
• Periodic Reporting Regarding Client Assets
• Tax Gain or Loss Harvesting, when applicable
• Financial Consulting and/or Wealth Management, when applicable For Clients developed directly by Wealthspire and its employees, direct client contact is provided by employees of Wealthspire. For Clients referred to Wealthspire by an Advisor, direct client contact is provided by an employee, agent, affiliate or other delegated person of the Advisor to whom Wealthspire provides services. All Clients of Advisors will contract with any intermediary Advisors and with Wealthspire for the services to be offered by Wealthspire. Assets are custodied at a custodial institution selected by the Client in each instance. All joint compensation is fully disclosed to the Client. Wealthspire offers its full scope of services to other Advisors who are not employees of the firm. Using Wealthspire infrastructure and services, such Advisors, in turn, will provide to their investment clients (“Clients”) access to Wealthspire and its services, including research, investment consultation, reporting, portfolio design, manager selection, general wealth management, pre- and post- retirement planning, information useful in harvesting gains and/or losses for tax efficiencies, and many other such services. Under this arrangement, non-employed advisors may receive compensation from Wealthspire, such as a referral fee. This compensation is discussed in the investment advisory agreement signed by the applicable client. Referral Fees. If a client is introduced to Wealthspire by either an unaffiliated or an affiliated promoter, Wealthspire may pay that promoter a referral fee in accordance with the requirements of Rule 206(4)- 1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. Any such referral fee shall be paid solely from Wealthspire investment management fee and shall not result in any additional charge to the client. If the client is introduced to Wealthspire by an unaffiliated promoter, the promoter, at the time of the solicitation, shall disclose the nature of their promoter relationship, and shall provide each prospective client with a copy of Wealthspire’s written Brochure with a copy of the written disclosure statement from the promoter to the client disclosing the terms of the solicitation arrangement between Wealthspire and the promoter, including the compensation to be received by promoter from Wealthspire. Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested and separately engaged by a client to do so, Wealthspire can provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Wealthspire does not serve as an attorney or accountant and no portion of Wealthspire’s services should be construed as same. To the extent requested by a client, Wealthspire may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). No client is under 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 Wealthspire and/or its representatives. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Wealthspire, shall be responsible for the quality and competency of the services provided. Wealthspire provides discretionary and non-discretionary investment advisory services. In addition, clients may elect to grant discretion to managers of separately managed accounts recommended by Wealthspire. Non-Discretionary Service Limitations. Clients who determine to engage Wealthspire on a non- discretionary

investment advisory basis must be willing to accept that Wealthspire cannot effect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client with the exception of placing trades when advisory fees are due. Thus, in the event that Wealthspire would like to make a transaction for a client's account, and the client is unavailable, Wealthspire will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing its services, Wealthspire 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, each client is advised that it remains their responsibility to promptly notify Wealthspire if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Wealthspire’s previous recommendations and/or services. Retirement Rollovers- A client or prospective client is under absolutely no obligation to engage Wealthspire as the investment adviser for his/her employer-sponsored retirement account. Rather, a client can continue to self-direct his/her retirement account at his/her employer. If the client determines that he/she would like Wealthspire 's assistance, Wealthspire shall charge a separate and additional advisory fee for its ongoing advisory services. The client will not incur this separate and additional advisory fee if he/she determines to continue to self-direct his/her account. As a result, any recommendation by Wealthspire that a client engage Wealthspire to manage his/her retirement account presents a conflict of interest since Wealthspire shall derive an economic benefit from such engagement. Again, a client is under absolutely no obligation to engage Wealthspire as the investment adviser for his/her retirement account. ANY QUESTIONS: Wealthspire’s Chief Compliance Officer, Michael Del Priore, remains available to address any questions that a client may have regarding its prospective engagement and the corresponding conflict of interest presented by such engagement. He can be reached at (414) 509-1330 or at compliance@wealthspire.com. Use of Mutual Funds. Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Wealthspire independent of engaging Wealthspire as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Wealthspire initial and ongoing investment advisory services. Please Note: Use of DFA Mutual Funds. The firm utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Please Also Note: In addition to Wealthspire investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). ANY QUESTIONS: Wealthspire’s Chief Compliance Officer, Michael Del Priore, remains available to address any questions that a client or prospective client may have regarding the above, including DFA. He can be reached at (414) 509-1330 or at compliance@wealthspire.com. Portfolio Activity. Wealthspire has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Wealthspire 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 Wealthspire 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. Use of Interval Funds. When consistent with a client’s investment objectives, Wealthspire may allocate investment assets to Interval Funds. Investment companies structured as interval funds are generally designed for long-term investors who do not require daily liquidity. Shares in interval funds typically do not trade on the secondary market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds recommended by Wealthspire offers a two to three-week period, on a quarterly basis, during which the client may seek the redemption of previously purchased interval funds. Thus, if we determined that the fund is no longer performing or if a client ever wished to close or transfer their account, the Interval Fund could not be sold or transferred immediately. Rather, sale or transfer would need to await the quarterly permitted sale date. Moreover, the eventual net asset value for the Interval Fund could be substantially different (positive or negative) than the Interval Fund value on the date the sale was requested. There can be no assurance that any such strategy will prove profitable or successful. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Wealthspire) will be profitable or equal any specific performance level(s). Depending on the client's aggregate assets under the management of Wealthspire, Wealthspire may prepare periodic reports showing the Client's account activity. These reports will be provided either electronically or in bound copy form. The firm serves as the sub-adviser for DP Grow, LLC, for the management of client assets. The firm’s fee for these sub-advisory services are paid for by DP Grow from DP Grow’s investment advisory fee. Clients do not pay additional fees for sub-advisory services. The firm provides 3(38) investment management and advisory consulting services to participant- directed pension and profit-sharing plans. As an investment fiduciary, the firm constructs and maintains mutual fund menus for participant-directed retirement plans on behalf of the firm’s plan sponsor clients. The firm coordinates these services with other independent investment advisors to whom the firm provides the service described above. The firm’s fee for the 3(38) investment advisory services does not include any brokerage commissions, custodial, administrative or recordkeeping fees, or other expenses incurred by the plan and/or plan participants. The firm’s fee is also separate and distinct from any fees charged by the other investment advisor(s). The firm’s fee for 3(38) investment advisory services will be billed to the plan by the Recordkeeper and then paid directly to the firm. The firm’s total assets under management as of 12/31/2023 was $518,106,982. The discretionary portion of this total was $343,588,577 and the non-discretionary portion of this total was $174,518,405.