FOCUS FINANCIAL PARTNERS, LLC SPIA, registered with the SEC since 1992, is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, SPIA is a wholly-owned subsidiary of FI Services Holdings, LLC., which is a wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus, LLC. Ultimate governance of Focus LLC is conducted though the board of directors at Ferdinand FFP Ultimate Holdings, L.P. Focus LLC is the majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of SPIA. Focus, LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other financial service firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. SPIA is managed by Richard Anzelone, Derek Amey and Betsey Purinton (“SPIA Principals”), pursuant to a management agreement between SPM Management Company, FI Services Holdings and Focus. The SPIA Principals serve as leaders and officers of SPIA and are responsible for the management, supervision, and oversight of SPIA. INVESTMENT MANAGEMENT SERVICES (“IMS”) We provide proactive investment management services that include asset allocation, security selection, broker- dealer and custodial recommendations and ongoing portfolio management for clients’ retirement and non- retirement accounts. We create personalized portfolios geared to our client's stated goals, along with proactive account management and monitoring on an ongoing basis with rebalancing whenever economic, market and geopolitical conditions deem it advisable. As part of our investment management services, we offer unlimited access to a SPIA financial advisor, general financial planning and a customized web portal for investment performance and account reporting. We generally begin by evaluating the risk-assessment questionnaire completed by the client, which helps the advisor determine the client's overall investment experience, financial goals, targeted retirement date and tolerance for market risk. Based on this information, we recommend a model investment portfolio for our client’s account. After reviewing the financial information provided by the client and based on the client's long- term goals, risk tolerance and time horizons, we will develop an investment strategy for each account that the client maintains. An account typically consists of, but is not limited to, equity mutual funds, exchange traded funds, commodities, alternatives and/or bond mutual funds, which hold only the client's securities and allows the client to have his/her own cost basis in each of the securities in the account. SPIA generally offers six portfolio models, each with a range of investment risk. As a SPIA client, you are placed in a portfolio model based on measurements of your risk tolerance. Before selecting a portfolio model, we talk to you about your understanding of, and ability to accept, risk. The goal is to select a portfolio model where you can feel comfortable in both good times and bad. The portfolios are generally built around the following major strategies: Capital Preservation, Income, Conservative, Balanced, Growth and Aggressive Growth. We also offer sustainable investing portfolios (an approach that considers environmental, social and governance (“ESG”) factors and their impact) which add a layer of ESG integration to our existing asset allocation methodology. SPIA actively monitors each strategy and shifts assets and sector rotations within a specified range, based on our market and economic analyses. As the investment manager, SPIA will invest/reinvest client assets in accordance with the Investment Policy Statement ("IPS") created by SPIA for each client. Clients may change portfolio models at any time by signing a new IPS. However, we encourage those changes only after careful discussion between client and client’s advisor to ensure that life events are driving the request and not emotional reactions to temporary market conditions. SPIA will rebalance the portfolio's investments as necessary, to remain consistent with the client's stated financial goals and objectives. If SPIA is managing a client’s variable annuity, SPIA will be limited by the fund options available by the variable annuity product. Variable annuities will be managed under similar policies and procedures as we manage participants’ employer-sponsored retirement plans (e.g., 401(k), 403(b) or 457 plans) as explained below. These held-away accounts are maintained at independent third-party custodians and are not held at our primary custodian Fidelity, unless Fidelity has entered into a separate agreement with a Plan. SPIA offers investment management services to participants in employer-sponsored retirement plans (e.g., 401(k), 403(b) or 457) plans. Investment management of an employer-sponsored retirement plan (“Plan”) account is incorporated into a client's overall financial plan. If the client is a participant in a Plan that permits participants to direct investments into one or more investment alternatives, SPIA will assist the client in selecting among these investment options. If the client chooses and the Plan permits, SPIA will exercise direct control and discretion in managing the client's Plan account. If SPIA is managing an employer-sponsored retirement plan account with full discretion, we will access the client’s Plan account and evaluate the current investments and/or allocations to make sure they are aligned correctly with the client’s portfolio model (e.g., Growth or Balanced) based on the risk level the client has specified. We strive wherever possible to match a client’s holdings in their retirement plans to the allocation of our portfolio models but must work within the constraints of the Plan offerings. We review the accounts at least quarterly and will rebalance the account when our review determines that rebalancing is needed to remain consistent with the client’s stated financial goals and objectives. We also change the allocation of future salary deductions when warranted to maintain or obtain the appropriate asset allocation for the client’s portfolio. SPIA's ability to manage a Plan account pursuant to a client's investment objectives, as compared to the management of accounts held at Fidelity, is limited due to Plan rules, restrictions, investment choices, and the labor-intensive nature of managing a client’s Plan account. Typically, a client opens an account with a custodian (i.e., SPIA recommends Fidelity as broker-dealer and custodian), allowing SPIA greater flexibility in rebalancing an account along with a greater number of investment choices as opposed to what is usually offered by an employer-sponsored retirement plan. Our services include providing our clients with annual updates to their investment strategy as needed by meeting with clients in person, virtual meeting, or conference call. In addition, clients will have daily access to portfolio reports through a web-based portfolio management and technology platform offered through Orion Technology Services, LLC (“Orion”) by accessing SPIA’s website. Except for certain web-based Plan restrictions, most clients will also receive web-based portfolio reports from SPIA offered through Orion with respect to their employer-sponsored retirement plan. However, clients should always make sure that they receive at least quarterly statements from the custodian of their Plan account (e.g., 401(k) or 403(b)) along with the custodian of any other account. Accounts under IMS are managed on a discretionary basis, which means that SPIA has the authority to make ongoing investment decisions within accounts without prior consent for individual transactions, unless mutually agreed to otherwise by SPIA and client. SPIA actively discourages client-directed trading within a managed account; however, clients will have the opportunity to place reasonable restrictions on SPIA management authority. As mentioned previously, clients may change their portfolio model at any time by signing a new IPS. However, we encourage those changes only after careful discussion between client and client’s advisor to ensure that life events are driving the request and not emotional reactions to temporary market conditions. Under limited circumstances, as mutually agreed to by SPIA and client, SPIA may advise clients on a non- discretionary basis or an investment consulting/advisory basis. In certain cases, under SPIA’s IMS, SPIA utilizes separately managed accounts available on the Fidelity Managed Account Xchange (“FMAX”) platform to aid in the investment management of a client’s account. FMAX allows clients and SPIA access to one or more

separately managed accounts offered on the platform. FMAX is a comprehensive wealth advisory platform that integrates planning, managed accounts, clearing and custody capabilities, and other third-party products and services into one technology-supported solution. FMAX is sponsored by Fidelity Institutional Wealth Advisors (“FIWA”), an unaffiliated Investment Adviser. FIWA is responsible for the due diligence of the separately managed accounts available on FMAX. SPIA is responsible for determining the appropriate separately managed accounts based on the client’s investment risk profile and will have the discretion to hire and fire separately managed account managers within certain parameters. The separately managed accounts provide SPIA with access to a universe of investment style-specific professionally managed portfolios composed of individual securities. SPIA may combine the separately managed account with mutual funds or ETFs in order to meet a client's personal asset allocation requirements. Clients who decide to use a separately managed account will be subject to the Fidelity Managed Account Xchange Program Terms and Conditions and Statement of Investment Selection (“SIS”), which along with FIWA’s Form ADV Part 2A brochure, explain the program in greater detail. FINANCIAL PLANNING SERVICES (Stand Alone) SPIA offers financial planning services to clients. The financial plan may include, without limitations, an analysis of the following financial planning topics as applicable to the client’s current situation:
• a balance sheet, retirement projections
• a review of life/disability and long-term care insurance coverage
• college funding/savings
• a risk tolerance assessment The financial plan will cover those areas of financial planning that SPIA determines are applicable to the client based solely on the information provided to SPIA by the client. SPIA’s financial planning agreement is a one-time service that does not include implementation or monitoring. Clients who desire us to implement the plan and monitor their investments must hire SPIA in an ongoing arrangement. Any implementation of recommendations or day-to-day management of client funds, securities or other assets will require the signing of a Discretionary Investment Management Services Agreement. Financial consulting not covered under the financial planning agreement is available to all clients and prospective clients at an hourly rate. RETIREMENT PLAN ADVISOR SERVICES (“REPAS”) SPIA provides advisory services to retirement plans (“REPAS”) subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), including participant-directed defined contribution plans, such as 401(k) plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory or investment management agreement with SPIA describing the services that SPIA will perform for the ERISA plan and its participants. SPIA provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. Fiduciary Services: SPIA provides REPAS fiduciary services either as a discretionary investment manager or a non-discretionary investment adviser. SPIA provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA § 3(38) and in that capacity, SPIA’s investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. Each ERISA Plan Client who engages SPIA to perform investment management services is required to enter into an investment management agreement. SPIA’s investment management services include developing and implementing an investment policy statement, selecting a broad range of investment options consistent with ERISA § 404(c), making decisions about the selection, retention, removal and addition of investment options and if the ERISA Plan Client has determined that the Plan should have a qualified default investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting the investment that will serve as a QDIA. The investment options and/or QDIA selected by SPIA may include managed portfolios developed by SPIA that use the Plan’s investment options. SPIA’s managed portfolios consist of but are not limited to: Conservative, Balanced, Growth, and Aggressive Growth. SPIA has full discretionary authority over investment management of the Plan assets invested in the SPIA managed portfolios including, but not limited to, determination of the asset class allocations and selection of the underlying investments for each portfolio, adjustment of the asset class allocations, and the addition, removal, or modification of the underlying investments. However, ERISA Plan Clients will have the opportunity to place reasonable restrictions on SPIA management authority. If SPIA managed portfolios are offered as Plan investment options and/or a QDIA, it will not result in additional compensation to SPIA. The managed portfolios are made available to retirement plans by the record-keeper through Mid-Atlantic Trust Company’s (“MATC”) ModelxChange® platform. SPIA also provides investment advisory services to ERISA plans on a non-discretionary basis and in that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and responsibility for the implementation (or rejection) of SPIA’s recommendations or advice. Each ERISA Plan Client who engages SPIA to perform non-discretionary investment advisory services is required to enter into an investment advisory agreement. SPIA’s non-discretionary investment advisory services include assisting the ERISA Plan Client in developing and implementing an investment policy statement, assisting the ERISA Plan Client in selecting a broad range of investment options consistent with ERISA § 404(c), assisting the ERISA Plan Client in making decisions about the selection, retention, removal and addition of investment options, and if the ERISA Client has determined that the Plan should have a QDIA for participants who fail to make an investment election, assisting in the selection of the investment that will serve as a QDIA. SPIA also provides asset allocation services that enable participants to allocate the money in their Plan account among the Plan’s designated investment alternatives. The asset allocation service is not an investment itself, but instead a service to help participants to decide how to invest their Plan account. Non-Fiduciary Services: SPIA’s non-fiduciary services to ERISA Plan Clients include assisting in educating plan participants about general investment principles and the investment alternatives under the plan and educating the ERISA Plan Client as to its fiduciary responsibilities. SPIA’s non-fiduciary services also include assisting the ERISA Plan Client in monitoring, selecting and supervising service vendors. In carrying out this service, SPIA will introduce Sentinel Benefits & Financial Group (“Sentinel”) as a potential third-party administrator and/or record-keeper. Recommending Sentinel creates a conflict of interest due to the fact that Sentinel and SPIA are both owned by Focus LLC. However, SPIA and Sentinel do not share in any fees and SPIA does not earn any additional revenue if Sentinel is used as the third-party administrator and/or record-keeper. The ERISA Plan Client is not obligated to use Sentinel as the third-party administrator and/or record-keeper. For a more detailed description of SPIA’s fiduciary and non-fiduciary services, the ERISA Plan Client should refer to the investment advisory agreement or investment management agreement. SPIA is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan participants. SPIA is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants (collectively, “Retirement Account Clients”). As such, SPIA is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid the conflict or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). As a fiduciary, we have duties of care and loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. As of December 31, 2023, we managed client assets totaling approximately $717,000,000 on a discretionary basis.