P.J. Roland, Ltd. d/b/a Canon Capital Investment Advisory, (CCIA), was incorporated on January 12, 1989 with the purpose of serving the investment management needs of clients. The firm was initially registered with the Pennsylvania Securities Commission. As a result of the assets under management growth, it is currently registered with the federal Securities and Exchange Commission (SEC). As of December 31, 2022, the firm managed approximately $172,616,630 on a discretionary basis and $7,152,438 on a non-discretionary basis. The principal owner of the firm is Peter J. Roland. CCIA is responsible for managing clients’ overall investment strategy, which may include deciding on the client’s asset allocation, developing the client’s investment strategy, implementing the strategy with appropriate investment managers, and monitoring the strategy on a one-time or ongoing basis. The firm’s investment management services are tailored to clients’ unique needs and any restrictions communicated by clients. CCIA’s investment advisory services are based on a Fiduciary Quality Management System which contains steps that are consistent with the global ISO 9000 Quality Management System standard. The firm has been certified by the Center for Fiduciary Excellence (CEFEX) for adherence and conformity to investment fiduciary best practices. In addition, all management employees meet the requirements of the Employee Retirement Income Security Act of 1974 to serve in a fiduciary capacity. Canon Capital Investment Advisory (CCIA) also provides an automated investing solution referred to as CCIA Wealth Innovation Services. This service is provided through a relationship

with its affiliated company IM Investing which also includes utilization of the Charles Schwab and Co., Inc.’s Institutional Intelligence Portfolios Platform. This platform is provided by Schwab for use by independent investment advisors and is sponsored by Schwab Wealth Investment Advisory, Inc. (“SWIA”), which is an affiliate of Charles Schwab & Co., Inc. (“Schwab”). In addition to providing the Schwab Institutional Intelligent Portfolios technology platform, SWIA’s role is limited to delivering the appropriate disclosures and administering the described services per those disclosures. In addition, the CCIA Wealth Innovation Services are communicated and marketed through the IM_Investing web platform, which is owned by IMobile Invest, LLC, an affiliated company of CCIA. The purpose of the IM_Investing web platform is to assist in bringing both educational and a more personal experience to clients as well as provide marketing services. CCIA is the client’s formal investment advisor for all CCIA Wealth Innovation Services. CCIA pays IMobile Invest, LLC, a marketing, education and web platform, a service fee in conjunction with offering the Wealth Innovation Services. CCIA charges clients a fee for our Wealth Innovation Services as described under item 5, Fees and Compensation. Clients do not pay any brokerage commissions or other fees to Charles Schwab & Co., Inc. Schwab does receive other revenues in connection with the CCIA Wealth Innovation Services. As a result of Canon Capital Investment Advisory (CCIA) having over $100 Million in client assets in accounts at Charles Schwab & Co., Inc., there is no licensing fee charges to CCIA.