General Information Covenant Partners, LLC (“Covenant”) was formed in 1997 and provides fiscal counsel, portfolio management, financial planning, and general consulting services to our clients. Todd D. Glisson and J. Banks Link, as principals, own 100% of Covenant. Please see Brochure Supplements, Exhibit A, for more information on the principal owners who formulate investment advice, have direct contact with clients, and have discretionary authority over client accounts. As of December 31, 2023, Covenant managed $698,560,277 on a discretionary basis, and $245,465,765 assets on a non-discretionary basis. Services Provided At the outset of each new relationship, we spend time with the client, asking questions, discussing investment experience and overall financial situation, and reviewing various options that are available. Based on our review, Covenant generally develops with each client:
• a financial outline based on the client’s financial circumstances, goals and risk tolerance level (the “Financial Profile” or “Profile”); and
• appropriate investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to its future goals. The Investment Plan outlines the types of investments we will make on behalf of the client to meet those goals. The Financial Profile and the Investment Plan, which may or may not be in writing, are discussed regularly in phone calls and meetings. Where we provide general consulting services, we will prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The standard method by which we receive compensation by definition creates some conflicts with your interests, so we operate under a special rule that requires

us to act in your best interest and not put our interests ahead of yours. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between the client and Covenant. Fiscal Counsel We are available to provide Fiscal Counsel Services on a retainer basis. The services provided may include, but are not limited to: analysis and management of personal and business income and expenses (including bill-paying services), revenues, consumption, profitability, cash flow, debt service, insurance needs, tax planning, estate planning, retirement planning, and payroll services. While Covenant itself does not serve as a trustee under ERISA, the principals may individually serve as trustee for a client in some situations. However, these trustee services do not include a comprehensive written financial plan. Portfolio Management As described above, at the beginning of a new relationship, we meet with the client, gather information and perform research and analysis as necessary to develop an appropriate Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by us based on updates to the client’s financial or other circumstances. To implement the Investment Plan, we will manage the investment portfolio on a discretionary basis. As a discretionary investment adviser, we will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may prohibit the sale of certain investments held in the account at the commencement of the relationship. However, any restrictions imposed may adversely affect the composition and performance of the investment portfolio. Clients should also note that the investment portfolio is treated individually by giving consideration to each purchase or sale. For these and other reasons, performance of the investment portfolio within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of the investment portfolio would necessarily be consistent with similar clients of Covenant.