ADVISORY BUSINESS A. General Description of Advisory Firm Total Management Group, Inc. d/b/a Heller Wealth Management (“HWM”) is incorporated in the state of New York. HWM became registered as an Investment Adviser Firm with the SEC on January 17th 2003. Larry Heller CFP®, CPA® is the principal of the firm. B. Description of Advisory Services INVESTMENT ADVISORY SERVICES HWM primarily provides discretionary investment advisory services on a fee basis. HWM manages investment portfolios for individuals, pension and profit-sharing plans, trusts, and business entities. HWM primarily recommends investments consisting of no-load, institutional class mutual funds in addition to individual fixed income securities. HWM works with the Client to determine the Clients investment objectives to create their investment strategy. For certain retirement plans or other accounts held by the client HWM will manage the accounts on a non- discretionary basis. HWM, in limited circumstances, may provide non-discretionary investment advisory services for those clients setting up accounts with third-party money managers. When a client engages us to provide services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have your approval (either verbally or in writing), prior to each and every transaction, that our proposed change is acceptable to you. FINANCIAL PLANNING AND CONSULTING SERVICES HWM may provide its clients with a broad range of comprehensive financial planning and consulting services (including non-investment related matters), which may address, among other issues, estate and retirement planning, taxes, insurance, college planning, long term care issues and/or investment recommendations. RETIREMENT PLAN FIDUCIARY SERVICES In certain instances, HWM may provide fiduciary services to retirement plan sponsors. In this

regard, HWM has expertise in advising retirement plans and their participants regarding the proper and effective use of mutual funds for investing. HWM may act as the investment manager for pension plans as such term is defined in Section 3(38) of ERISA. As such, HWM shall have discretion over the establishment of the pension plan’s investment policy, the prudent selection, monitoring, removal, and replacement of the pension plan’s investment options. HWM will be serving as a fiduciary to pension plans under ERISA in performing these functions. Please refer to the Plan Agreement for relative fees and costs associated with this service. SUB-ADVISORY/CUSTODIAL ARRANGEMENTS HWM primarily recommends that investment management accounts be maintained at ~ 7 ~ Schwab Institutional (“Schwab”). HWM, at times may allocate a portion of a client’s investment assets to an unaffiliated independent investment manager through the Managed Account Access and Marketplace programs. In such situations, the Independent Manager shall have active discretionary management of the allocated funds. HWM shall continue to render investment supervisory services to the client relative to the review of account performance, asset allocation and client investment objectives. HWM has agreements with Aspire and PCS Retirement as administrative management companies for 401(k) and 403(b) plans. Participant assets are held at either Schwab or Matrix. C. Availability of Customized Services for Individual Clients HWM shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services HWM will ascertain each client’s investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on HWM’s services. D. Wrap Fee Programs We do not participate in a wrap fee program. E. Assets Under Management As of April 9, 2024, HWM had a total of $404,000,000 in assets under management.