A. Description of Advisory Firm Thoroughbred Financial Services, LLC (TFS), was formed in 1999 and has its main office in Brentwood, TN. It has other offices in Jackson, Knoxville and Columbia, TN. The Parker Family Trust is the principal owner of TFS, holding 50.5% of the membership interests. The Parker Family Trust holds its interests for the benefit of the children of Thomas Jenkins Parker, the president of TFS. Susan S. Parker, the wife of Thomas Jenkins Parker, trustees the Parker Family Trust. TFS is registered as both an investment adviser and a broker-dealer with the Securities and Exchange Commission. Please note, however, that being registered does not imply a certain level of skill or training. B. Types of Services Offered TFS provides clients with investment supervisory services on both a discretionary and nondiscretionary basis. TFS can design an investment management program using mutual funds, exchange traded funds (ETFs), individual stock and bond issues, money market investments, and certificates of deposit, as well as specially structured investments. TFS offers the discretionary and nondiscretionary programs through both the Thoroughbred account and the Cambridge account. TFS can also make advisory recommendations for a portfolio of mutual funds held directly by an investment company, accounts held at a custodian other than its clearing broker-dealer (National Financial Services, LLC), and variable annuity investments (the Identified Portfolio account under Item 5, below). Also, the Bond-Timing account invests in high-yield bond securities (mutual funds or ETFs), government securities (mutual funds or ETFs) or money markets according to the timing signals of BTS Asset Management, Inc. Further, TFS will evaluate the performance of outside money managers selected by the client (The Identified Manager account under Item 5, below). In such a case, the outside money manager will select on a discretionary basis the assets held in the client’s account and TFS will only evaluate the performance of the manager. TFS will base its evaluation upon results achieved and adherence to the investment style for which the client selected the manager. On an occasional basis, TFS will prepare a comprehensive financial plan for

the client for a fee. The plan will address income tax, estate tax, investment planning and retirement planning considerations. Additionally, TFS can offer access to money management services through Envestnet Asset Management, Inc., and their Managed Account Solution Program. Envestnet is a comprehensive program that provides independent portfolio managers, brokerage and custodial services, and quarterly reporting all through their platform. Finally, under the TFS Investment Advisory Retirement Option Plan (e.g., Vanguard/Ascensus), TFS provides retirement plans services regarding plan design selection, plan investment option selection, participant education, and periodic reviews. C. Meeting the Individual Needs of Clients TFS tailors its advisory services to the individual needs of the clients. TFS will use client data forms and personal meetings with the clients to determine the particular client’s investment objectives and risk tolerances. TFS then designs an investment portfolio to meet the specific objectives of the client while assuming a level of risk with which the client is comfortable. The client is always able to impose restrictions on investing in certain securities or types of securities in the client’s account. D. Wrap Fee Programs TFS sponsors certain wrap-fee programs which provide discretionary investment advisory services to clients through outside money managers. For these wrap accounts, TFS charges an asset-based fee that includes charges for the services of both TFS and the outside money manager, as well as the cost of executing trades for the account. TFS manages these accounts in a manner similar to other accounts managed by outside money managers which are not wrap accounts. For both types of accounts, TFS evaluates the performance of the outside managers for the client. The only real difference between the wrap-fee program and a non- wrap account using an outside money manager is the method of charging for trades. Depending upon the frequency of trading by the money manager, a client may or may not be better off by paying a combined (wrap) fee for management and transactions. E. Amount of Assets Under Management As of December 31, 2023, TFS managed $322 million on a nondiscretionary basis and $2.59 billion on a discretionary basis.