ML&R WM is directly owned by the accounting firm Maxwell Locke & Ritter LLP. Steven Knebel and the other partners of the accounting firm therefore indirectly own ML&R WM, which has been providing advisory services since 1997. ML&R WM operated as a predecessor company under common ownership from 1997 to 2000. As of December 31, 2022, ML&R WM managed $1,528,214,757 of regulatory assets under management on a discretionary basis, $9,886,975 of regulatory assets under management on a non-discretionary basis, along with an additional $430,338,775 in assets under advisement. Investment Management Services Through personal discussions in which goals and objectives based on a client's particular circumstances are established, ML&R WM develops a client's personal investment policy and creates and manages a portfolio based on that policy. ML&R WM will continuously and regularly manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). ML&R WM will typically create a portfolio of no-load mutual funds and may use model portfolios if the models match the client’s investment policy. ML&R WM will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. ML&R WM primarily recommends portfolios consisting of mutual funds offered by Dimensional Fund Advisors (DFA). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities. Clients may impose any reasonable restrictions on ML&R WM’s discretionary authority, including restrictions on the types of securities in which ML&R WM may invest client’s assets and on specific securities that the client may believe to be appropriate. Independent Managers ML&R can select certain Independent Managers to actively manage a portion of its clients’ assets. Pursuant to the terms of the investment advisory agreement, ML&R shall have discretion to appoint and terminate these third-party managers. Disclosure of the use of an Independent Manager and their fees will be provided to clients. ML&R can utilize Dimensional Fund Advisors, LP (‘Sub-Adviser) for sub-advisory services to separately managed portfolios. Sub-Adviser shall be responsible for the investment and reinvestment of those assets in the client’s accounts. The Sub-Adviser shall manage the assets in accordance with the investment strategy and any customization selected by the Adviser for each Client Account. Use of Independent Managers can result in additional fees to the client. ML&R WM can recommend fixed income portfolios to advisory clients, which consist of managed accounts of individual bonds. ML&R WM will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. ML&R WM will prepare an Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, ML&R WM will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain ML&R WM’s consent prior to the sale of any client securities. On an ongoing basis, ML&R WM will answer clients’ inquiries regarding

their accounts and review periodically with clients the performance of their accounts. ML&R WM will at least annually review client’s investment policy and risk profile. ML&R WM will re-balance clients’ accounts as necessary. ML&R WM will provide to the third-party investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub- advisory services. Pension Consulting Services: ML&R WM's Pension Consulting Services is comprised of two distinct components, which will typically be offered in conjunction with each other, but may be offered separately: 1. Portfolio Composition Consulting 2. Retirement Plan Consulting While the primary clients for these services will be participant-directed pension, profit sharing and 401(k) plans, ML&R WM will also offer these services, where appropriate, to individuals and trusts, estates, charitable organizations or other types of retirement plans. 1. Portfolio Composition Consulting: Within this component, ML&R WM will recommend investments and model portfolios to plan sponsors, who in turn will provide the recommendations to employees and participants. ML&R WM will review various investments, consisting of mutual funds (both index and managed), individual equities, and bonds determined appropriate. The number of investments to be recommended will be determined by the client, based on the plan’s Investment Policy Statement. 2. Retirement Plan Consulting: ML&R WM provides different advisory services (as detailed below) separately or in combination for Retirement Plan Consulting clients. Clients may choose to engage ML&R WM for any combination of the services below. a) Investment Policy Statement ("IPS") Preparation: ML&R WM will meet with the client (in person or over the telephone) to determine the client's investment needs and goals. ML&R WM will then prepare a written IPS stating those needs and goals and encompassing a policy under which these goals are to be achieved. The IPS will also list the criteria for selection of investment vehicles and the procedures and timing interval for monitoring of investment performance. b) Investment Performance Monitoring: Client investments will be monitored based on the procedures and timing intervals delineated in the Investment Policy Statement. For nondiscretionary clients, ML&R WM will supervise the client’s portfolio and will make recommendations to the client as market factors and the client’s needs dictate. For discretionary clients, ML&R WM may rebalance model portfolios or substitute investment options available to plan participants by directly instructing the administrator or custodian to effect such changes. c) Employee Communications: For pension, profit sharing and 401(k) plan clients wherein there are individual accounts with participants exercising control over assets in their own account (''self-directed plans''), ML&R WM also provides periodic educational support and investment workshops designed for the Plan participants. The nature of the topics to be covered will be determined by ML&R WM and the client. Consulting: ML&R WM also provides advice in the form of financial consultations. This hourly service consists of consultations based on specific investment and financial concerns of the client. Consulting services may include, for example, assistance with establishing and implementing a simplified employee pension plan, preparation or review of an investment policy statement, the compilation of reports on various investment accounts, and asset allocation recommendations. The scope and depth of the consultation varies depending on the client's particular circumstances and needs.