KUTSCHER BENNER BARSNESS & STEVENS, INC. (“KBBS”) has counseled individuals, families and trustees since 1992. From our origins we were an early adopter of integrated financial planning under an exclusively fee‐for‐service arrangement (no commissions). Scott Benner, Cameron Barsness, Ryan Stevens, Gianna Giusti and Kyle O’Connor are the firm shareholders. Professional and educational backgrounds are described in detail in the attached brochure supplement (Form ADV Part 2B). The firm has non‐discretionary regulatory assets under management of $513,175,872 as of December 31, 2023. We emphasize routine financial planning with a distinctively in‐depth review and written report, involving and integrating these important determinants of financial success:  Balance sheet (prepare and updated to include all assets)  Budgeting and cash flow (12‐month forward‐ looking projection)  Tax analysis and issue spotting (12‐month forward‐looking forecast)  Savings analysis, both for retirement and regular assets  Portfolio sustainability analysis and spending targets  Investment policy (establish, review and revise as appropriate)  Asset allocation (integrate across entire balance sheet as appropriate for investment policy)  Selection of subadvisors and investment strategies  Strategies for harvesting employee stock options and dealing with other stock concentration situations  Performance reports, if feasible for entire investment portfolio  Insurance and risk management (identify gaps and suggest improvements)  Estate planning and charitable goals (identify and suggest potential improvements) The advice we provide is customized for each client. The investment advice for each client is integrated with other financial planning considerations (described above) and affects all of a client’s investment assets. For example, recommendations often involve bank accounts, regular brokerage accounts, employer retirement plans, commercial real estate, private equity and/or debt, annuities, mutual funds, legacy stocks and bonds holdings. Special facets of our advice may touch on environmental, social and governance (“ESG”) investments, private placement funds, insider stock with certain investment restrictions, and other investment approaches that might be unique to a client’s wishes or circumstances. We believe the success of clients’ financial planning is enhanced when they understand and are involved in their investment strategies. Therefore, we encourage communication as well as client oversight and review of our investment recommendations we make. Accordingly, we seek approval prior to affecting changes to a client’s investment portfolio. In this way, the client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendations. In our role as financial counsel, we do not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, we do not prepare estate planning documents or tax returns and we do not sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non‐investment implementation purposes (e.g., attorneys, accountants, insurance, etc.), including certain KBBS representatives in their separate capacities as attorneys (for more information see Item 10 below). If the client engages any 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, and the engaged licensed professional will be exclusively responsible for the quality and competency of the services they provided. FIDUCIARY DUTY AND PORTFOLIO ACTIVITY Our firm has a fiduciary duty to provide services consistent with our clients’ best interests. As part of our investment advisory services, we review client portfolios on an ongoing basis to determine if any changes are appropriate based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, and/or a change in the clients’ investment objectives. Based upon these factors, there may be extended periods of time when we determine that changes to a client’s portfolio are neither necessary nor prudent. CLIENT PARTNERSHIP AND ENGAGEMENT In performing our services, we are not required to verify information received from clients or from their other professionals. We rely on our clients to notify us promptly if there is ever any change in their situations or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. We believe that it is important for the client to address financial planning issues on an ongoing basis. Our advisory fees, as set forth in Item 5 below, will remain the same regardless of whether or not the client engages with us on matters that fall within the scope of our relationship. 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 our firm) will be profitable or equal any specific performance level(s). PRIVATE INVESTMENT FUNDS As noted above, we may provide investment advice regarding unaffiliated private investment funds. Our role relative to these funds is limited to the initial and ongoing due diligence and investment monitoring services. These private investment funds will be considered in the investment portfolio base for purposes of our investment advisory fee. Our clients are under absolutely no obligation to consider or make an investment in private investment funds, and in fact, many of our clients are not invested in such funds. We acknowledge and make considerable effort to inform clients that private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, lack of transparency, conflicts and additional fees, including incentive compensation (as laid out in such funds’ 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 themselves as qualified for investment in the fund, and acknowledging and accepting the various risk factors that are associated with such an investment. For valuation purposes, both for client reporting and calculation of our fees, we use the most recent value reported by the fund sponsor. INTERVAL FUNDS As noted above, we may provide investment advice regarding interval funds. An interval fund is a non‐ traditional type of closed‐end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. These investment funds will be considered

in the investment portfolio base for purposes of our investment advisory fee. Our clients are under absolutely no obligation to consider or make an investment in interval funds, and in fact, many of our clients are not invested in such funds. We acknowledge and make considerable effort to inform clients that interval funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints (similar to a private investment) and lack of transparency. SEPARATE ACCOUNT MANAGERS/INDEPENDENT MANAGERS We typically recommend that clients allocate a portion of their investment assets to investment managers—most typically open‐end mutual funds, index funds, closed end funds, and ETFs—who are not affiliated with us and are independent from us, while we render investment supervisory services relative to the ongoing monitoring and review of account performance, asset allocation and clients’ investment objectives. Those managers have separate written agreements with their clients and they have day‐to‐day responsibility for the active discretionary management of assets under their care, including, to the extent applicable, proxy voting responsibility. The investment management fees charged by independent managers are separate from, and in addition to, KBBS’ advisory fee as set forth in the fee schedule at Item 5 below. IMPACT OR “ESG” INVESTING ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., 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 through transparency, accounting standards, diversity and inclusion and shareholder engagement). 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 the 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 us), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. We generally rely on 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. MARGIN We do not recommend the use of margin for investment purposes. A margin account is a brokerage account that allows clients to borrow money to buy securities and/or for other non‐ investment borrowing purposes. The custodian then charges the client interest for the right to borrow money and uses the securities as collateral. The use of margin can magnify both account gains and losses. For fee related calculations, we use the net account value after reducing for margin. For regulatory AUM reporting purposes, we use the gross account value as instructed by the SEC. RETIREMENT 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 we recommend that a client roll over their retirement plan assets into an account to be newly managed by us, such a recommendation could create a conflict of interest if we will earn new (or increased) compensation as a result of the rollover. If we provide 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), we are 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 to an account managed by us, whether it is from an employer’s plan or an existing IRA. CYBERSECURITY RISKS The information technology systems and networks that we and our third‐party service providers (e.g., ShareFile, Tamarac, eMoney) use to provide services to clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in our operations and result in the unauthorized acquisition or use of clients’ confidential or non‐ public personal information. Therefore, we acknowledge that we are subject to the risk of cybersecurity incidents that could ultimately cause our firm and our clients 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 we have established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that we do 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, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. CASH FUNDS Custodians, including Schwab, often place cash proceeds from account transactions and deposits into a cash “sweep” account. At Schwab, this sweep is actually an internal transfer to Schwab Bank, which is then covered up to $250,000 via FDIC insured banks. The yield on the sweep cash is generally lower than what is available via position traded money market funds. We regularly work with clients to manage their cash between sweep and position traded funds, taking into account any yield dispersion between the sweep cash and a money market funds, an indication from the client of an imminent need for such cash, if the client has a demonstrated history of writing checks from the account, and/or whether cash is held for fee billing purposes. Our clients remain responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any unmanaged accounts and away from our primary custodians (i.e., Schwab). a client or prospective client may have regarding our advisory business or related issues.