Investment Management of Virginia, LLC (“IMVA”) was originally established as Scott & Stringfellow Capital Management, Inc., in 1982 with the sole objective of providing professional money management to both institutional and individual investors. In March 1999, the firm became a wholly owned subsidiary of Branch Banking and Trust Company (BB&T). Investment Management of Virginia, LLC became an independent investment adviser in July 2000 when the former principals of Scott & Stringfellow Capital Management, Inc., purchased the firm from BB&T. John H. Bocock, one of the principal owners of the firm, has a greater than 50% ownership in Investment Management of Virginia, LLC. He assumed the role of Chairman of the Board as of January 1, 2012. IMVA’s main business is providing investment supervisory services to our clients with investment fees charged according to supervised assets under management. There are some relationships in which we provide investment advice to clients but do not actively manage the assets. Most client accounts are managed with discretionary authority, but others are non- discretionary, and their transactions are subject to client approval. In cases of discretionary authority in a relationship, IMVA engages in security transactions on behalf of the client without prior consultation. In a non-discretionary relationship, the client approves all investment transactions in advance. IMVA offers the following Portfolios to our clients: Large Capitalization Core Equity Large Capitalization Balanced Small Capitalization Select Equity Income Opportunity Special Customized Accounts To the extent possible, IMVA portfolio managers shall attempt to ensure that a client’s investment choices at IMVA are appropriate and suitable for that client’s investment needs. The primary means of ensuring that a client’s investments are appropriate include: initial discussions between the client and a portfolio manager at IMVA (when possible), the IMVA Investment Management Agreement, IMVA’s Client Questionnaire, communications with clients, and the provision of the Disclosure Brochure at the start of the relationship as well as the sending of the Summary of Material Changes to the Disclosure Brochure and the offer to send the entire brochure on an annual basis. With respect to ongoing communication with clients, IMVA’s quarterly advisory letters request that clients notify IMVA if their financial circumstances or investment objectives have changed. Additionally, at least once per year, in the context of an annual request letter, clients who have been offered a questionnaire in the past are reminded what information IMVA requested, and they are prompted to contact IMVA (“take the time now”) to make sure that IMVA has current and accurate information. Clients are able to impose restrictions on certain securities or types of securities. Clients are also able to direct trading preferences although they can lose some important advantages if IMVA were able to consolidate all orders in a group with one broker. (see Brokerage Practices section) IMVA may acquire equity mutual funds as part of a client’s account but these positions are not billed upon and are considered unsupervised positions by IMVA. IMVA may aid in choosing a fund most appropriate for the client’s needs if requested. IMVA also participates in model programs, wrap programs, and sub-advisory relationships. Model Programs Model programs are defined as professionally managed private investment accounts that are rebalanced regularly by a sponsor generally in accordance with instructions from an outside portfolio manager (in this case, IMVA) or managers. IMVA supplies the sponsor with a model portfolio and notifies the sponsor when changes to the model are made. It is the sponsor’s decision whether or not to implement the changes provided by IMVA. For example, if the IMVA portfolio manager for a given style purchases a new security with a 2% position, this change is communicated to the sponsor, who theoretically, makes a similar purchase in the investor’s portfolio. The sponsor has the actual relationship with the client and the ultimate fiduciary duty to the client, including the discretion to make and implement changes in client accounts (not IMVA). The placement and execution of security transactions are not done by IMVA, nor does IMVA assume any fiduciary duties associated with these tasks. Model Programs allow the end user to maintain a single account registration at a broker-dealer and

invest in one or several different strategies offered by the sponsor, either in the context of separately managed accounts (“SMA”, e.g., client has a separate account for each strategy chosen) or a single unified managed account (“UMA”, e.g., client has a single separate account that holds securities from a variety of different strategies that the client has chosen). The majority of model programs in which IMVA participates are UMA programs. In the context of model-based UMA programs, the sponsor pays IMVA a fee for the amount of assets managed within the program. The following model-based UMA programs are currently in place (with the respective strategies offered): FDx Advisors Inc. – Small Capitalization and Large Capitalization Core Equity Portfolios Envestnet Asset Management Inc. – Opportunity and Small Capitalization Portfolios SMArtX Advisory Solutions – Small Capitalization and Select Equity Income Portfolios Adhesion Wealth – Small Capitalization Portfolio In the context of model-based SMA programs the sponsor pays IMVA a fee for the amount of assets managed within the program. The following SMA program is currently in place (with the respective strategies offered): Envestnet Asset Management, Inc. – Opportunity and Small Capitalization Portfolios Wrap Programs IMVA also participates in wrap fee programs but is not a sponsor of any program. A wrap fee program is defined to be a program under which any client is charged a specified fee or fees not directly based on transactions in a client’s account for investment advisory services and execution of client transactions. Clients in wrap programs generally have separately managed accounts (“SMA”). These accounts are either structured as a single or dual contract; that is to say, clients sign separate contracts with the wrap plan sponsor and the investment advisor (dual) or only the wrap plan sponsor (single). In the case of most wrap fee programs, the investor is charged one fee which will encompass the management, brokerage, custody, and other services (including commission charges) provided under the program. The fee is generally paid directly to the wrap program sponsor, and a portion is designated for the investment advisor (in this case, IMVA) for its investment advisory services. Generally, wrap program clients have lower minimum account balances to maintain than if they were in a non-wrap or stand-alone investment agreement. Wrap program clients’ trades are generally placed with the plan sponsor, barring a best execution issue, since the wrap fees cover all transaction costs. Wrap program clients may find that if trading is low, they may be better off in a non-wrap program. Wrap program clients are treated the same as IMVA’s separately managed accounts for trading purposes. Wrap program sponsors participate in the firm’s trade randomizer program which seeks to insure that no client is systematically favored over another. This trade randomizer program is explained in greater detail under the ‘Code of Ethics, Participation or Interest in Client Transactions and Personal Trading section of this document. The following wrap programs are currently in place (with the respective sponsors): AMC Advantage Program sponsored by Truist Investment Services, Inc. Managed Account Access Program sponsored by Charles Schwab and Company Private Advisor Network Program sponsored by Wells Fargo Advisors, LLC Managed Account Consulting Program sponsored by D. A. Davidson IMVA’s Small Capitalization, Select Equity Income, Opportunity, Large Capitalization Core Equity, and Large Capitalization Balanced Portfolios are all represented in one or more of these wrap programs. Many of the programs do not have a minimum account size; some programs require a minimum of $100,000 to $500,000. IMVA also has sub-advisory relationships with Mount Yale and TD Ameritrade. A sub-advisory program is defined as one in which another firm hires an outside firm to provide investment advisory services for their clients. These programs primarily utilize IMVA’s Small Capitalization, Customized, and Special Portfolios for their clients and have minimum account size requirements for participation. As of December 31, 2022, IMVA managed: Discretionary Assets of $568,440,478 in 468 accounts Non-Discretionary Assets of $3,006,816 in 1 account Total Assets under management at 12/31/2022: $571,447,294 Total Accounts under management at 12/31/2022: 469 Total assets and accounts displayed above do not include model-based assets.