Abacus Planning Group, Inc. (Abacus), founded in 1998, is a SEC-registered investment adviser headquartered in Columbia, South Carolina. The investment advice provided by Abacus focuses solely on the individual needs of the client. Through conversations, collection of financial information and assessment questionnaires, Abacus documents a client’s personal circumstances, individual objectives, risk tolerance, time horizons, liquidity needs, growth and income expectations, as well as income and estate tax considerations. When appropriate, Abacus also reviews a client's prior investment history. Information gathered in this process guides the creation and management of the client’s portfolio. After establishing written investment policy guidelines and implementing the investment recommendations approved by the client, the Abacus investment team consistently reviews the portfolio using both manual and automated methods. The portfolio is rebalanced on an ongoing basis to consistently reflect the client's established guidelines. Our investment recommendations are not limited to any specific product or service and will generally include advice regarding the following securities: | Exchange-listed securities | Exchange-traded funds | Securities traded over-the-counter | Foreign issuers | Corporate debt securities [other than commercial paper] | Hedge funds | Limited partnership interests | Municipal bonds | Mutual fund shares | United States governmental securities | Money market funds | Certificates of deposit financial planning Our financial planning services begin with a comprehensive financial plan. The financial plan will typically address the following areas: goal setting | Abacus documents a set of personalized financial objectives for each client through a series of open-ended questions and assessment tools. investment philosophy | Abacus educates each client as to its basic tenets of portfolio management. Abacus also presents each client with an initial analysis of his or her current portfolio. financial independence | Abacus creates long-term cash-flow projections, in order for each client to understand how much to save at the pre-retirement stage or how much can be spent each year if he or she is already financially independent. Abacus creates multiple “what-if” scenarios to make clients aware of how changes in the assumptions can impact their future financial security. education funding | Abacus projects the cost of educating children or grandchildren and suggests the most effective ways to fund these upcoming expenses. investment policy guidelines and recommendations | Abacus dovetails a client’s investment plan with the client’s goals through written investment policy guidelines and specific investment recommendations unique to each client. risk management review | Abacus evaluates a client’s various insurance policies – from automobile to long- term care and life insurance. Abacus will comment on the quality and cost of the existing coverage as well, and where necessary, make recommendations for termination or additional coverage in conjunction with your insurance agent. income tax review | Abacus will review each client’s income tax return and, in conjunction with the client’s CPA, make income tax planning recommendations. estate planning review | Abacus examines each client’s current estate plan to confirm it meets stated goals and family objectives. If changes are needed, we will work closely with the client’s estate planning attorney and accountant to implement these changes. If a client needs to engage an attorney or accountant, we will assist in selecting the appropriate professional. portfolio reports | Clients are “walked through” the format of the Abacus portfolio report. This ensures each client is familiar with the presentation of the information and has a chance to ask questions to fully understand the regular reports. Typically, the initial financial plan is completed and presented over the course of the first year of the advisory contract date. The Abacus team continually updates each client’s planning component, to reflect changes within the client’s financial life or external to the client such as changes to income or estate tax laws. important disclosures limitations of financial planning and non-investment consulting / implementation services | As indicated above, to the extent requested by a client, Abacus may provide financial planning and related consulting services. Abacus and its investment adviser representatives will assist clients with the implementation of a financial plan. Unless engaged to do so, Abacus does not monitor a client’s financial plan. It is the client’s responsibility to revisit their financial plan with Abacus, if and when desired. Furthermore, although Abacus may provide recommendations regarding non-investment related matters, such as estate planning, tax planning and insurance, Abacus does not serve as a law firm, accounting firm, or insurance agency, and no portion of Abacus’ services should be construed as legal, accounting, or insurance implementation services. Accordingly, Abacus does not prepare estate planning documents, tax returns or sell insurance products except when specifically requested by a client. To the extent requested by a client, Abacus may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are 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 made by Abacus or its representatives. If the client engages any unaffiliated 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 licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Abacus, shall be responsible for the quality and competency of the services provided. 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 Abacus recommends that a client roll over their retirement plan assets into an account to be managed by Abacus, such a recommendation creates a conflict of interest if Abacus will earn new (or increase its current) compensation as a result of the rollover. If Abacus 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), Abacus 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 to an account managed by Abacus, whether it is from an employer’s plan or an existing IRA. use of mutual and exchange traded funds and dimensional fund advisors mutual funds | Abacus utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Abacus’ investment advisory fee described below, and transaction and/or custodial fees discussed above, 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). The mutual funds and exchange traded funds utilized by the Abacus are generally available directly to the public. Thus, a client can generally obtain the funds recommended and/or utilized by Abacus independent of engaging Abacus as an investment advisor. However, if a prospective client does so, then they will not receive Abacus' initial and ongoing investment advisory services. Others mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”) are generally only available through registered investment advisers. Abacus may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of Abacus’s services to such a client, restrictions regarding transferability, additional purchases of, or reallocation among DFA funds will apply. Please Note: In addition to Abacus’ 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). affiliated private funds | Abacus is the managing partner of Terrum Real Estate Partnership I, LP, Terrum Royalty Fund, LP, Terrum Royalty Fund II, LP, Terrum Royalty Fund III, LP, Tyche Opportunity Fund I, LP, Periculum, LP, Series A, Periculum, LP, Series B, and Periculum, LP, Series C (together the “Affiliated Funds”), the complete description of which is set forth in the each of the Affiliated Fund’s offering documents. Abacus, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to one or more of the Affiliated Funds. Abacus’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). 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 they are qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. In the event that we reference Affiliated Funds owned by the client on any supplemental account reports, the values for all Affiliated Funds will generally reflect the most recent value. The current value of any Affiliated Fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. If an Affiliated Funds has invested in a third-party fund, the investment manager of that fund is responsible for determining the value of interests in that fund. Abacus will rely on values provided by the third-party fund’s manager. portfolio activity | Abacus has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, we 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, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when we determine that changes to a client’s portfolio are neither necessary nor prudent. Clients

nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. cash positions | Abacus continues to treat cash as an asset class. As such, unless determined to the contrary by Abacus, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Abacus’s 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), Abacus 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, Abacus’s advisory fee could exceed the interest paid by the client’s money market fund. cash sweep accounts | Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Abacus shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Abacus 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 Abacus’ 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 Abacus unmanaged accounts. ANY QUESTIONS: Abacus’ Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above. other assets | To the extent that Abacus provides advisory monitoring or review services for client investment assets for which the Abacus does not maintain custodian access or trading authority (including initial and ongoing consideration of such assets as part of the client’s asset allocation), Abacus may determine to include such assets in its advisory fee calculation per Item 5 below. cybersecurity risk | The information technology systems and networks that Abacus and its third-party service providers use to provide services to Abacus’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Abacus’ operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Abacus 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 Abacus has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Abacus 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. 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 Abacus), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Abacus 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, Abacus 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. cryptocurrency | For clients who want exposure to cryptocurrencies, including Bitcoin, Abacus, will advise the client to consider a potential investment in corresponding exchange traded securities or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, and uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Abacus will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Abacus does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Abacus considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. ByAllAccounts | Abacus, in conjunction with the services provided by ByAllAccounts, Inc., may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Abacus (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not Abacus, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Abacus’ service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Abacus is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Abacus does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If Abacus is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Abacus shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Abacus provide investment management services for the Excluded Assets, the client may engage Abacus to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Abacus and the client. cross transactions | In limited circumstances, when determined to be in the best interest of its clients, Abacus may engage in a cross-transaction pursuant to which Abacus may effect transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when Abacus believes that such transactions [generally, thinly traded bonds] are beneficial to its clients). For all such transactions, neither Abacus nor any affiliate will be acting as a broker. Abacus will not receive any commission or transaction-based compensation, although Abacus has an interest in the price at which the cross trades are conducted since Abacus' asset-based fees will be negatively impacted by lower bond values. This may present a conflict of interest. These transactions will be generally effected through Schwab, the account custodian, or a prime broker. The client may revoke Abacus’ cross-transaction authority at any time upon written notice to Abacus. custodian charges – additional fees | Broker-dealers such as Schwab 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, generally (with the potential exception for large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There can be no assurance that Schwab will not change their transaction fee pricing in the future. Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. client obligations | In performing our services, Abacus 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 us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous recommendations or services. amount of managed assets As of December 31, 2023, we were actively managing $1,652,513,077 of clients' assets on a discretionary basis and $29,117,380 on a non-discretionary basis for a total of $1,681,630,457 in assets under management.