A. Financial Decisions, LLC (“Financial Decisions”) is a limited liability company formed on March 1, 2016 in the State of New York. However, Financial Decisions, LLC operated as a corporation known as Financial Decisions, Inc. up until February 29, 2016. Financial Decisions, Inc. and Financial Decisions, LLC have been registered as an Investment Adviser Firm since September 1991. Financial Decisions is principally owned by Kenneth Gutwillig and Florence Dupont. B. As discussed below, Financial Decisions offers to its clients (individuals, high net worth individuals, pension and profit sharing plans, corporations, business entities, and charitable organizations, etc.) investment advisory and/or management services on a discretionary and/or non-discretionary basis and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can engage Financial Decisions to provide discretionary and/or non/discretionary investment advisory and implementation services on a fee basis, generally negotiable to 1%. Before engaging Financial Decisions to provide those services, clients are required to enter into an Investment Advisory Agreement with Financial Decisions setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Financial Decisions will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Financial Decisions provides ongoing monitoring and review of account performance, asset allocation and client investment objectives, and may rebalance and/or may recommend that clients rebalance accounts as necessary based on such reviews. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent specifically requested by a client, Financial Decisions shall generally provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate and additional fee basis. Financial Decisions’ fees, as set forth in Item 5 below, are negotiable and may vary depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s) Before engaging Financial Decisions to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Financial Decisions setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before Financial Decisions commencing services. If requested by the client, Financial Decisions may recommend the services of other professionals for implementation purposes, including Financial Decisions’ representatives in their individual capacities as licensed insurance agents (see disclosure at 10.C.). 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 Financial Decisions. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, etc.), and not Financial Decisions, shall be responsible for the quality and competency of the services provided. Neither Financial Decisions, nor its investment adviser representatives, assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. In addition, Financial Decisions does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with us, if desired. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested by the client, Financial Decisions shall generally provide financial planning and or related consulting services regarding non- investment related matters, such as estate planning, tax planning, insurance, etc. Neither Financial Decisions, nor any of its representatives, serves as an attorney, accountant, and no portion of Financial Decisions’ services should be construed as legal, or accounting, services. Neither Financial Decisions, nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. Accordingly, Financial Decisions does not prepare estate planning documents or tax returns. In addition, Financial Decisions does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the financial plan with Financial Decisions, if desired. To the extent requested by a client, Financial Decisions may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including representatives of Financial Decisions in their separate capacities as licensed insurance agents as discussed in Item 10.C. below. 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 Financial Decisions Please Also Note-Conflict of Interest: The recommendation by a Financial Decisions representative that a client purchase an insurance commission product from a Financial Decisions representative in his/her individual capacity as an insurance agent presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase insurance commission products from a representative of Financial Decisions. Clients are reminded that they may purchase insurance products recommended by Financial Decisions through other insurance agents. Please Note: If the client engages any such recommended unaffiliated 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 licensed professional[s] (i.e. attorney, accountant, etc.), and not Financial Decisions, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify Financial Decisions if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Financial Decisions’ previous recommendations and/or services. Non-Discretionary Service Limitations. Clients that determine to engage Financial Decisions on a non-discretionary investment advisory basis must be willing to accept that Financial Decisions cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Financial Decisions would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Financial Decisions will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Variable Annuity Management. As part of its Investment Advisory services, Financial Decisions may be engaged to provide discretionary and/or non-discretionary management to a client’s variable annuity product(s). In such engagements, Financial Decisions will allocate investment assets among the investment subaccounts of variable annuity products owned by the client. Financial Decisions will typically propose allocations to individual equity and fixed income investments, exchange-traded funds, and mutual funds, consistent with the client’s designated investment objectives. Once allocated, Financial Decisions provides ongoing monitoring and review of subaccount performance, asset allocation, and client investment objectives. Cybersecurity Risk. The information technology systems and networks that Financial Decisions and its third-party service providers use to provide services to Financial Decisions’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Financial Decisions’ operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Financial Decisions 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 Financial Decisions has established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Financial Decisions 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. Cash Sweep Accounts Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, Financial Decisions shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Financial Decisions reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within Financial Decisions’ actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of Financial Decisions’ unmanaged accounts. Independent Managers. Financial Decisions may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to- day responsibility for the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. Financial Decisions will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Financial Decisions generally considers the following factors when recommending Independent Manager(s): the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager(s), together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets, are exclusive of, and in addition to, Financial Decisions’ ongoing investment advisory fee. These fees will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Asset-Based Pricing Arrangements and Limitations. Relative to Independent Manager engagements (see above), Financial Decisions generally recommends that clients enter into an “Asset-Based” pricing agreement with the account broker-dealer/custodian. Under an asset based pricing arrangement, the amount that a client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the account, generally expressed in basis points and/or a percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or 0.01% (0.0001). This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. Under either the asset-based or transaction-based pricing scenario, the fees charged by the respective broker-dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to Financial Decisions per Item 5 below. Financial Decisions does not receive any portion of the asset based transaction fees payable by you to the account custodian. You are under no obligation to enter into an asset- based arrangement, and, if you do, you can request at any time to switch from asset based pricing to transactions based pricing,

However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to transaction based pricing could prove to be economically disadvantageous. Financial Decisions’ Chief Compliance Officer, Kenneth Gutwillig, remains available to address any questions that a client or prospective client may have regarding Asset- Based versus Transaction- Based pricing. Unaffiliated Private Investment Funds. Financial Decisions also provides investment advice regarding private investment funds. Financial Decisions, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. Financial Decisions’ role relative to unaffiliated private investment funds shall be limited to its initial due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Financial Decisions calculating its investment advisory fee. Financial Decisions’ fee shall be in addition to the fund’s fees. Financial Decisions’ clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Financial Decisions references private investment funds owned by the client on any supplemental account reports prepared by Financial Decisions, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. Please Also Note: As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Financial Decisions shall calculate its fee based upon the latest value provided by the fund sponsor. Client Obligations. In performing its services, Financial Decisions 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 the client’s responsibility to promptly notify Financial Decisions if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Financial Decisions’ previous recommendations and/or services. Disclosure Statement. A copy of Financial Decisions’ written disclosure statement as set forth on Part 2 of Form ADV, in addition to its Form CRS, shall be provided to each client before, or contemporaneously with, the execution of the applicable form of client agreement. Retirement Plan 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 Financial Decisions recommends that a client roll over their retirement plan assets into an account to be managed by Financial Decisions, such a recommendation creates a conflict of interest if Financial Decisions will earn new (or additional) compensation as a result of the rollover. If Financial Decisions provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Financial Decisions is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets or existing IRA assets to an account managed by Financial Decisions. Financial Decisions’ Chief Compliance Officer, Kenneth Gutwillig, remains available to address any questions that a client or prospective client may have regarding its prospective engagement and the corresponding conflict of interest presented by such engagement. ESG/Socially Responsible Investing Limitations. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and 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 limited 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 Financial Decisions), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Financial Decisions does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, Financial Decisions shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Use of Mutual Funds or Exchange Traded Funds. While Financial Decisions may recommend allocating investment assets to mutual funds and exchange traded funds that are not available directly to the public, Financial Decisions may also recommend that clients allocate investment assets to publicly-available mutual funds and exchange traded funds that the client could obtain without engaging Financial Decisions as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds or exchange traded funds without engaging Financial Decisions as an investment advisor, the client or prospective client would not receive the benefit of Financial Decisions’ initial and ongoing investment advisory services. Please Note: In addition to Financial Decisions’ 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: Financial Decisions’ Chief Compliance Officer, Kenneth Gutwillig, remains available to address any questions that a client or prospective client may have regarding the above. Tradeaway/Prime Broker Fees. If, in the reasonable determination of Financial Decisions that it would be beneficial for the client, individual equity and/or fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian (i.e., Schwab or Fidelity). ANY QUESTIONS: Our Chief Compliance Officer, Kenneth Gutwillig, remains available to address any questions that a client or prospective client may have regarding tradeaway arrangements. Custodian Charges-Additional Fees: As discussed below at Item 12, when requested to recommend a broker-dealer/custodian for client accounts, Financial Decisions generally recommends that Charles Schwab & Co, Inc. (“Schwab”) or Fidelity Investments (“Fidelity”) serve as the broker-dealer/custodian for client investment management assets.. Broker-dealers such as Schwab and Fidelity 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 and Fidelity, do not currently charge fees on individual equity or ETF transactions, others do). Please Note: there can be no assurance that Schwab and/or Fidelity will not change their transaction fee pricing in the future. Please Also Note: Fidelity and Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. When beneficial to the client, individual fixed‐ income and/or equity transactions may be effected through broker‐dealers with whom Financial Decisions and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab and/or Fidelity). These fees/charges are in addition to Financial Decisions’ investment advisory fee at Item 5 below. Financial Decisions does not receive any portion of these fees/charges. ANY QUESTIONS: Financial Decisions’ Chief Compliance Officer, Kenneth Gutwillig, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: Cash Positions. Financial Decisions continues to treat cash as an asset class. As such, unless determined to the contrary by Financial Decisions, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Financial Decisions’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Financial Decisions 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, Financial Decisions’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Financial Decisions’ Chief Compliance Officer remains available to address any questions that a client or prospective may have regarding the above fee billing practice Portfolio Activity. Financial Decisions has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Financial Decisions 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 Financial Decisions determines that 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 Financial Decisions will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. C. Financial Decisions shall provide investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Financial Decisions shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Financial Decisions’ services. D. Financial Decisions does not offer a wrap fee program for its investment advisory services. E. As of December 31, 2023, Financial Decisions had $302,509,632.00 in assets under management on a discretionary basis and $43,041.00 in assets under management on a non- discretionary basis.