Laffer Tengler Investments, Inc. (hereinafter, “LTI,” the “Firm,” “Our,” or “We”) was incorporated in 1999 and started managing discretionary accounts in August of 2000. Dr. Arthur B. Laffer and Arthur B. Laffer, Jr. founded the Firm. Nancy Tengler is the Chief Executive Officer and Chief Investment Officer. Arthur B. Laffer, Jr. is the President and the Senior Portfolio Manager. The Firm is organized as a common stock corporation and is currently domiciled in the state of Tennessee. 100% of the stock is owned by ButcherJoseph Financial Holdings, LLC. Specific ownership interest information is located on Schedule A and Schedule B of Part 1 of the firm’s Form ADV. As of December 31st, 2023, Laffer Tengler Investments managed $462,553,183 in discretionary assets and provided advice on model portfolio assets in the amount of $724,713,891. The Laffer Tengler Wealth Management Wrap Program (“Wrap Fee Program”) is one of the programs Laffer Tengler Investments, Inc. offers. For its wealth management clients, LTI offers an investment program in which the client pays a single fee for asset management and transaction costs in their accounts (“Wrap Fee”). Wrap Fees include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark- downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than our recommended qualified custodian. Because of the nature of a Wrap Fee Program, a client may pay more, or less than if the client had compensated another adviser outside of the Wrap Fee Program. For example, if a client’s account is rarely traded, the transaction fees that the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. LTI receives the Wrap Fee for our services. When transaction fees are charged by our recommended custodian or broker/dealer, we will pay those fees on behalf of our client. The remainder of the Wrap Fee is the net management fee payable to LTI. The amount payable to us varies depending upon the trading activity in a client's account. The more transactions in the account, the greater the amount of transaction fees, and therefore the less compensation to us. Accordingly, we have a financial incentive to avoid trading the account. This can create a conflict of interest between the Firm and its Wrap Fee Program clients. We mitigate this conflict by requiring that the Firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own and through a review of client accounts. Services Clients participating in the Wrap Program shall receive the following services to the extent applicable to their financial needs:
• Access to an investment adviser representative for financial advice and account service;
• Development of a broadly diversified portfolio with asset classes and investment selections designed to meet the liquidity and risk characteristics of your financial goals;
• Recommendations of specific investment strategies used to implement your portfolio;
• Assistance setting financial goals and monitoring progress toward goals;
• Quarterly performance reports provided by LTI. This reporting is in addition to the regular statements you receive from the custodian who holds your assets. An investment adviser representative will assess your current financial circumstances, taking into account your tolerance for risk and your investment objectives. An asset allocation structure will be developed specifically for you to help you toward your long-term financial goals. LTI will help you implement the recommended asset allocation structure using various investment strategies managed by LTI’s portfolio managers that will give you exposure to a diverse mix of equities, fixed income and cash. See ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION for more information on the investment strategies we offer. Limited circumstance may warrant allocating a portion of your portfolio to a third-party manager when LTI does not offer a specific strategy needed to implement the recommended allocation. In this

case, LTI will provide you with the necessary information about the manager, including any additional fees you might incur. Fees The following discussion represents the basic compensation arrangements of Laffer Tengler Investments. However, fees and other compensation are negotiable in certain circumstances and arrangements with any particular client may vary. Each client’s specific fee schedule will be stated in their Investment Management Agreement. Unless specifically stated to the contrary, fees will be calculated based upon the aggregate market value of all assets under management within the client’s account(s), including allocations to cash (unless a specific cash account is designated as unmanaged). Fees that are calculated as a percentage of assets under management are generally charged quarterly in arrears. Laffer Tengler Investments standard fee schedule for this Wrap Fee Program is below. Client’s Aggregate Portfolio Management Assets Annual Fee Rate* (Applies to all household assets once total Client assets reaches the specified range below) Up to $3,000,000 1.15% $3,000,001 - $5,000,000 1.00% $5,00,001 - $10,000,000 0.90% $10,000,001 - $20,000,000 0.75% Over $20,000,000 Negotiable Laffer Tengler Investments reserves the right, in its sole discretion, to negotiate and to charge different fees for certain accounts based on a client’s particular needs or requirements as well as overall financial condition, goals, risk tolerance and other factors unique to the client’s particular circumstances. Clients can elect to have fees owed to Laffer Tengler Investments deducted directly from their account. In instances where a client has authorized direct billing, the client’s “qualified custodian” sends periodic statements, no less frequently than quarterly, showing all transactions and holdings during the period. Clients are urged to review their account statements for accuracy and compare the information to any reports received directly from Laffer Tengler Investments. Clients may also request that billings be made directly to the client or a designated third party if authorized in writing by the client. A wrap fee arrangement typically covers portfolio management, advisory services, custodian fees, brokerage commissions and other costs associated with purchase and sale when transactions are executed through the account custodian. Mark-ups, mark-downs and dealer spreads are costs borne by the client as they are reflected in the price of the transaction. The advisory fee does not include other fees such as trade-away fees, account transfer fees, account maintenance fees, wire fees, interest, or taxes. All fees paid to Laffer Tengler Investments are separate and distinct from the fees and expenses charged by mutual funds or in conjunction with internal expenses associated with exchange-traded funds. The client will be solely responsible, directly or indirectly, for these additional expenses. Depending on the rate of the wrap fee charged, the amount of account activity, the value of custodial and other services provided and other factors, the wrap fee may exceed the aggregate costs of the services provided if they were to be obtained separately and, with respect to brokerage, transaction-based commissions. Investment advisory agreements between Laffer Tengler Investments and its clients are generally terminable at any time by the client or the Firm upon 5-day advance notice by either party to the other. Clients should review their Investment Management Agreement for the terms and conditions specific to their account. Termination typically requires that written notice be given by the terminating party. In the event of termination during a quarterly period, the client will pay only that portion of the fee earned by Laffer Tengler Investments up to the actual date services are terminated. To the extent that fees are paid to the Firm in advance and a client terminates its agreement during the quarterly period, Laffer Tengler Investments will refund to the client a pro rata portion of the fee paid. Compensation Laffer Tengler Investment advisory personnel are not compensated based on your participation in this Wrap Fee Program; therefore, there is no incentive to recommend this program over other advisory services we may offer.