A. Description of the Advisory Firm This firm has been a Registered Investment Advisor since June 17, 1993. The principal founder and owner is Frank Curtis Shepard. B. Types of Advisory Services S&A Financial Services, Inc. (hereinafter “S&A”) offers the following services to advisory clients: Investment Advisory and Management Services S&A offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. S&A creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Advisory and Management Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring • Pension Consulting S&A evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. S&A may request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in a pool of securities. We do not and will not have custody of your funds or securities. We do have limited authority to direct the Custodian to deduct investment advisory fees, but only with the appropriate authorization from you. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that may adversely affect an account’s performance. This could result in capital losses in your account. Financial Planning Services Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt planning. Financial advisory services provided by us may include the analysis of your situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help you meet your specific financial objectives. Such services may include a written financial analysis and specific or general investment and/or planning recommendations. In preparing your financial plan, we may address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards, depending on your specific needs. These include: financial position, protection planning, investment planning, income tax planning, retirement planning, and estate planning. Our specific services in preparing your plan may include:
• Determination of appropriate income planning strategies for both pre- and post- retirement timeframes.
• Review of existing and proposed investment asset mixes to help you meet your overall financial objectives. This would include a review of risk/return issues and a suggested plan of action consistent with your risk tolerance and overall financial objectives.
• Calculation of your pre-retirement savings and investing needs.
• Assessment of your overall financial

position including net worth, cash flow, and debt.
• Comprehensive analysis of IRA-related issues including rollover, distribution, and inheritance planning options.
• Evaluation of strategies designed to maximize the utilization and protection of your IRA assets.
• Review and determination of your life and disability insurance needs.
• Development of investment strategies consistent with your business ownership succession and transition planning, if applicable. These services are based on hourly fees and the final fee structure is documented in the Financial Planning Agreement. Pension Consulting Services S&A offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: o identifying investment objectives and restrictions o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. C. Client Tailored Services and Client Imposed Restrictions S&A offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent S&A from properly servicing the client account, or if the restrictions would require S&A to deviate from its standard suite of services, S&A reserves the right to end the relationship. Because S&A is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. D. Wrap Fee Programs S&A does not participate in any wrap fee programs. E. Amounts Under Management S&A has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $240,798,371 $17,422,157 12/31/2022 In addition to managed, S&A has the following assets under advisement: $11,063,406.