A. Sterling Financial Planning, Inc. (“Sterling”) is a New Jersey corporation formed on November 20, 1992. Sterling became registered as an investment adviser in February 1993. Nicholas A. Nicolette, President and Chief Compliance Officer, and Matthew Hannum, Corporate Secretary, are Sterling’s principal owners. B. Sterling offers to provide investment advisory services, retirement plan consulting services, and financial planning and related consulting services to its clients, who generally include individuals, high net worth individuals, pension and profit sharing plans, trusts, and estates. INVESTMENT ADVISORY SERVICES Clients can engage Sterling to provide discretionary or non-discretionary investment advisory services according to the terms and conditions of an Investment Advisory Agreement. Sterling’s annual investment advisory fee is based upon a percentage of the market value of the assets placed under Sterling’s management. Sterling’s investment advisory services are specifically tailored to the needs of each client. To begin the process an investment adviser representative will collaborate with the client to develop investment objectives, which are based upon an assessment of factors that typically include: capital preservation; risk tolerance; income production; liquidity requirements; client preferences; asset and liability levels; and investment restrictions. The client’s investment objectives are established, and a compatible investment strategy and plan are then implemented. Clients may, at any time, impose restrictions in writing on investing in certain securities or types of securities. Sterling currently allocates or recommends that clients allocate investment assets among various mutual funds, exchange traded funds (“ETFs”), individual debt, and individual equity securities, in accordance with the client’s designated investment objectives. Once client investment assets are allocated, Sterling provides ongoing monitoring and review of account performance and asset allocation as compared to client-designated investment objectives and may recommend or execute account transactions as a result of those reviews or other triggering events. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Sterling offers financial planning and consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) under the terms and conditions of a Financial Planning and Consulting Agreement. This Agreement sets forth the terms and conditions of the engagement including the scope of services and the portion of the fee that is due from the client to begin the engagement. RETIREMENT PLAN CONSULTING SERVICES Sterling provides retirement plan consulting services under ERISA §3(21). In this capacity, Sterling assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives from which plan participants choose in self-directing the investments for their individual plan retirement accounts. The plan sponsor or administrator ultimately decides whether and how to implement these recommendations. In addition, to the extent requested by the plan sponsor, Sterling will also provide participant education designed to help participants identify the appropriate investment strategy they choose to employ for their retirement plan accounts. The plan participants are responsible for any individual investment selections made under the plan. When providing services under ERISA §3(21), Sterling does not exercise discretionary authority or control of plan assets or administration of the plan. If the plan sponsor engages Sterling in an ERISA §3(38) capacity, Sterling may provide the same services as described above, but may also manage plan assets on a discretionary basis, develop asset allocation models that Sterling manages on a discretionary basis, which plan participants may choose in managing their individual retirement account, or modify the investment options made available to plan participants on a discretionary basis. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Sterling does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Sterling does not prepare estate planning documents or tax returns. Unless specifically agreed in writing, neither Sterling nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with Sterling, if desired. The client retains absolute discretion over all financial planning and related implementation decisions

and is free to accept or reject any recommendation from Sterling and its representatives in that respect. Sterling’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. Upon client request, Sterling may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who are responsible for the quality and competency of the services they provide. Please refer to Item 10.C. below for additional information about Sterling’s President and Chief Compliance Officer, Nicholas Nicolette, serving as a licensed insurance agent. Retirement Plan Rollovers – No Obligation / 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 Sterling recommends that a client roll over their retirement plan assets into an account to be managed by Sterling, such a recommendation creates a conflict of interest if Sterling will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Sterling. ERISA / IRC Fiduciary Acknowledgment. When Sterling provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way Sterling makes money creates some conflicts with client interests, Sterling operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Sterling must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that Sterling gives advice that is in the client’s best interest; charge no more than is reasonable for Sterling’s services; and give the client basic information about conflicts of interest. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, Sterling will review client portfolios on an ongoing basis to determine if any trades 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 Sterling determines that trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, Sterling is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Sterling if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Sterling’s services or previous recommendations. C. Sterling provides investment advisory services tailored to the specific needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with clients to develop their investment objectives. Sterling will then allocate or recommend that clients allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Sterling’s services. D. Sterling does not participate in a wrap fee program. E. As of December 31, 2023, Sterling had $405,007,071 in assets under management on a discretionary basis and $218,202,698 in assets under management on a non-discretionary basis.