A. Comprehensive Financial Planning, Inc. (the “Registrant” or “CFPI”) is a corporation formed on February 28, 1984, in the Commonwealth of Pennsylvania. The Registrant became registered as an Investment Adviser Firm in 1986. The Registrant is owned by Richard J. Walters, (the “Principal”), CFP®, AIF® - Mr. Walters is also the Registrant’s President. B. As discussed below, the Registrant offers to its clients (pension and profit-sharing plans, individuals, business entities, trusts, estates and charitable organizations, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine whether to engage the Registrant to provide discretionary and/or non-discretionary investment advisory services on a fee basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management between 1.75 % and 0.20% for Equity investments and 0.26% for cash and cash equivalent investments. In certain circumstances, if pension, profit sharing, or 401k plans have over 500 employees and assets in excess of $50 million dollars in plan assets, Registrant will consider an annual “flat fee” usually between $155 to $200 per participant, based on the number of plan participants at the beginning of the plan year. THE MANAGED PORTFOLIO PROGRAM The Registrant offers investment advisory service to its clients under its Managed Portfolio Program. The Managed Portfolio Program is an intermediate to long-term proposition, designed for clients seeking to participate in intermediate to long-term bull markets, while avoiding the potential severe declines of intermediate to long-term bear markets. The investment services under The Managed Portfolio Program are managed on a regular and continuous basis. The Managed Portfolio Program attempts to coordinate and monitor the client’s investment portfolio based on the client’s designated investment objectives, risk tolerance, and goals. The services offered within the Managed Portfolio Program include: continual asset management and implementation services, summarized portfolio reports, semi-annual account reports to clients detailing with account holdings, and a newsletter reviewing the markets, the economy and the Registrant’s current investment outlook. RETIREMENT CONSULTING The Registrant also provides non-discretionary pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans as well as trustee directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts if it is a self-directed retirement plan. In addition, to the extent requested by the plan sponsor, the Registrant shall also provide participant level education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. Also, the Registrant provides participant enrollment meetings to provide education on how the plan sponsor plan document functions. The terms and conditions of the engagement shall generally be set forth in a separate agreement between the Registrant and the plan sponsor. Comprehensive Financial Planning, Inc. shall serve as a “fiduciary” within the meaning of Section 3(21) under the Employee Retirement Income Security Act of 1974 (ERISA) with respect to retirement accounts for the plan sponsor. Such advisers provide advice to retirement plans – they do not take control of the plan assets, so the plan sponsor has the final decisions regarding implementation of the investment options. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent specifically requested by a client, the Registrant may determine to 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 fee basis. The Registrant uses a two-fold approach when providing financial planning and consulting services to its clients. First, the Registrant takes a broad view of the client’s financial picture. Second, the Registrant attempts to coordinate and formulate an interrelated plan by working closely with each client’s other professional advisers. The Registrant begins each client relationship with a background interview, learning the client’s current financial positions, income stream, expenditures, retirement position, and investment portfolio. Thereafter, the client’s individual planner analyzes taxable income statements, cash flow statements, income tax returns, insurance policies, investment portfolio, retirement plan, balance sheets, and the client’s investment objectives. After gathering this information, the individual planner is able, with the cooperation of the client’s other professionals (attorney, accountant, investment adviser, insurance adviser), to form a strategic plan of action. A formal plan is delivered to the client for comments and adjustments, followed by execution. If changes in a client’s financial circumstances warrant it, the planner may, on an hourly basis, revise and update the client’s financial plan. The Registrant’s planning and consulting fees are generally rendered at a rate of $250.00 per hour, but in certain limited circumstances may be negotiable (depending upon the level and scope of the services required and the professional rendering the services). Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant 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 prior to Registrant commencing services. Subsequent to the completion of a client’s initial financial plan and analysis, the client may terminate the Registrant’s on-going financial planning agreement upon ten (10) day’s written notice to the Registrant. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes, including the Registrant’s representatives in their individual capacities as registered representatives of a broker-dealer and/or in their individual capacities as licensed insurance agents. (See disclosure at Items 10 B and 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 the Registrant. 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. Please Also Note: It remains

the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. MISCELLANEOUS Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Registrant may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, retirement planning, etc. Neither the Registrant, nor any of its representatives, serves as an attorney or accountant, and no portion of the Registrant’s services should be construed as same. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including representatives of the Registrant in their separate licensed/registered capacities as discussed 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 the Registrant. 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. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous recommendations and/or services. Retirement Rollovers - No Obligation/Conflict of Interest: A client leaving an employer typically has four options (and may engage in a combination of these options): 1.) leave the money in his former employer’s plan, if permitted, 2.) roll over the assets to his new employer’s plan, if one is available and rollovers are permitted, 3.) rollover to an IRA, or 4.) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). The Registrant may recommend an investor roll over plan assets to an Individual Retirement Account (IRA) managed by the Registrant. As a result, the Registrant and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave his or her plan assets with his or her old employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to the Registrant (unless you engage the Registrant to monitor and/or manage the account while maintained at your employer). The Registrant has an economic incentive to encourage an investor to roll plan assets into an IRA that the Registrant will manage or to engage the Registrant to monitor and/or manage the account while maintained at your employer. There are various factors that the Registrant may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA; ii) fees and expenses in the plan versus the fees and expenses in an IRA; iii) the services and responsiveness of the plan’s investment professionals versus the Registrant’s; iv) protection of assets from creditors and legal judgments; v) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to rollover plan assets to an IRA managed by the Registrant or to engage the Registrant to monitor and/or manage the account while maintained at your employer. The Registrant follows the guidelines of Department of Labor (DOL) Prohibited Transaction Exemption 2020-02 (PTE 2020-02). Please Note: Cash Positions. 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), the Registrant may maintain cash positions for defensive purposes. All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating the Registrant’s advisory fee. The Registrant’s Chief Compliance Officer, Richard J. Walters, CFP®, AIF®, remains available to address any questions that a client or prospective client may have regarding the above fee billing practice. Please Note-Use of Mutual Funds and/or ETFs (Exchange-Traded Funds): Many mutual funds and/or ETFs are available directly to the public. Thus, a prospective client can obtain many of the mutual funds and/or ETFs that may be recommended and/or utilized by the Registrant independent of engaging the Registrant as an investment advisor. However, if a prospective client determines to do so, he/she will not receive the Registrant's initial and ongoing investment advisory services. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non-discretionary investment advisory basis must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable or unavailable timely, the Registrant will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing its services, the Registrant 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 his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Managed Portfolio Program Agreement, Advisory Agreement for Defined Contribution Plans or Financial Planning and Consulting Agreement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant 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 the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of February 29, 2024, the Registrant had $330,172,083 in assets under management on a discretionary basis and $32,978,414 in assets under management on a non-discretionary basis.