Proctor was founded in 1994, and is owned by Tony Proctor and Stephen Doucette. The firm has been providing advisory services since 1997. Investment Management Services Proctor provides a full-service investment management solution, specializing in working with clients at or near retirement. We comprehensively gather important facts, goals, and plans of our clients and build completely customized investment allocation plans. Once the plans are completed, we review the plans with our clients, get approvals, and then actively select, monitor, and modify as needed the specific investments in accounts that are established in our clients’ names at nationally-known independent custodians. Periodically we also rebalance our clients’ investment accounts as they move closer to their goals, or as market conditions dictate. All aspects of the client’s financial affairs are reviewed, including, in some cases, those of their children. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for Investment Management Services is provided to the client in writing prior to the start of the relationship. An Investment Management engagement includes (as needed): cash flow management; insurance review; investment management (including performance reporting); education planning; retirement planning; estate planning, as well as the implementation of recommendations within each area. Client assets are often invested in no-load mutual funds, usually through discount brokers. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. Proctor does not receive any compensation, in any form, from fund companies, and does not receive any portion of the fee charged by discount brokers to execute trades in client accounts. In addition, at times when Proctor feels conditions are favorable for such actions, the firm negotiates with large investment banks to create customized bonds, commonly known as Structured Notes or Enhanced Investment Notes (Notes), to use in client portfolios. Typically, these Notes provide some type of advantage over investing directly in equity indexes, while still participating to some extent in equity returns. The advantages often consist of partial to full principal protection; leveraged upside return without corresponding leveraged downside return; access to hard-to-access indexes; 2 absolute return characteristics where the Notes return a positive return regardless of market direction; and high interest coupons relative to current rates. A particular risk associated with these Notes is creditor risk, which we monitor closely.

Liquidity is another unique risk for these Notes, as the only market for these securities is provided by the investment banks that issue them, and they do not guarantee that they will maintain a market for them before they mature. Despite the lack of guaranteed liquidity, issuers may be willing or may intend to redeem these Notes before maturity upon request at current market values, though most Notes are meant to be held to maturity. Typical maturity for the Notes we buy in client portfolios ranges from 6 months to 3 ½ years. Tailored Investment Solutions For each of our clients, Proctor creates a completely customized asset allocation plan that is based on their specific cash-flow needs in and before retirement. Utilizing our proprietary Time-weighted Cash-flow Methodology (TCM), we calculate the net present value of the cash-flow needed by a client every year for at least the next 40 years. With this information, we build an asset allocation plan designed to manage short-term risk against the goal of long- term returns. After building the asset allocation plan, we select the specific investments that go in client accounts, and monitor and make changes to those investments as necessary. While it is possible for clients to request restrictions on investing in specific types of securities, Proctor generally feels that clients are best served when relying on Proctor to determine the types and amounts of securities to be purchased and sold. As of December 31, 2023, Proctor managed approximately $332,822,197 on a discretionary basis. Incidental Financial Planning Services For nearly all of our clients, Proctor also furnishes advice on matters not directly involving investments, such as financial planning matters, taxation issues, college funding issues, insurance planning, and estate planning. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Typically, no separate fee is charged for this service. Tax Preparation Work Tax preparation work is offered as an additional service for investment management clients only. This work is billed based on the time spent preparing the returns, with an hourly rate of up to $150 per hour. For clients with managed assets of at least $2 million as of the end 3 of a year, tax preparation for that year is offered with no additional cost. Eligible federal and applicable state returns are filed electronically without an additional fee. Retirement Planning Course Proctor occasionally teaches a four-part, 10-hour course on retirement planning. This course typically costs between $44 and $69, and is open to the public, including current clients. Clients are allowed to attend the course at no cost.