Frisch Financial Group, Inc. (“Frisch Financial”) is a corporation formed on June 25, 1999 in the State of New York. Frisch Financial became registered as an Investment Adviser Firm in June 2001. Frisch Financial is principally owned by David A. Frisch, who is also Frisch Financial’s President. As discussed below, Frisch Financial offers to its clients investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. Frisch Financial is a fiduciary. This means that Frisch Financial is required to put the interests of its clients first at all times. INVESTMENT ADVISORY SERVICES The client can determine to engage Frisch Financial to provide discretionary and/or non-discretionary investment advisory services on a fee-only basis. Frisch Financial’s annual investment advisory fee may include both discretionary and/or non-discretionary investment advisory services and financial planning services. In the event that the client requires planning services (to be determined in the sole discretion of Frisch Financial), Frisch Financial may determine to charge for such services, the dollar amount of which shall be set forth in a separate written notice to client. Before engaging Frisch Financial to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Frisch Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. To commence the investment advisory process, an investment adviser representative will first ascertain each client’s investment objectives and then allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. Once allocated, Frisch Financial provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, and may rebalance and/or may recommend rebalancing accounts as necessary based on such reviews. Some clients may receive financial planning services as part of their engagement with Frisch Financial for investment management services. If requested by the client, Frisch Financial may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Frisch Financial. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify Frisch Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Frisch Financial’s previous recommendations and/or services. MISCELLANEOUS Fee Differentials. As indicated below, Frisch Financial shall price its services based upon various objective and subjective factors. As a result, Frisch Financial’s clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, and the level and scope of the overall investment advisory and/or consulting services to be rendered. As a result of these factors, the services to be provided by Frisch Financial to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, Frisch Financial can provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, retirement planning, executive compensation strategies, insurance, etc. Frisch Financial’s representatives do not serve as attorneys or insurance agents, and no portion of Frisch Financial’s services should be construed as legal or insurance implementation services. Accordingly, Frisch Financial does not prepare estate planning documents or sell insurance products. To the extent requested by a client, Frisch Financial may recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Frisch Financial or its representatives. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively

from and against the engaged professional. It remains the client’s responsibility to promptly notify Frisch Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Frisch Financial’s previous recommendations and/or services. Trustee Compensation. In very limited circumstances, upon request of a client, Frisch Financial may agree to provide trustee services to clients. In such cases, Frisch Financial may receive additional compensation as described in the trust documents and permitted by statute. ByAllAccounts. Frisch Financial, in conjunction with the services provided by ByAllAccounts, Inc., may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by Frisch Financial (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not Frisch Financial, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Frisch Financial’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Frisch Financial is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Frisch Financial does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If Frisch Financial were asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and Frisch Financial shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Frisch Financial provide investment management services for the Excluded Assets, the client may engage Frisch Financial to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Frisch Financial and the client. Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Frisch Financial recommends that a client roll over their retirement plan assets into an account to be managed by Frisch Financial, such a recommendation creates a conflict of interest if Frisch Financial will earn an advisory fee on the rolled over assets. No client is under any obligation to roll over retirement plan assets to an account managed by Frisch Financial. Non-Discretionary Service Limitations. Clients that determine to engage Frisch Financial on a non-discretionary investment advisory basis must be willing to accept that Frisch Financial cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Frisch Financial would like to make a transaction for a client’s account (including an individual holding or in the event of general market correction), and the client is unavailable, Frisch Financial will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing its services, Frisch Financial shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Frisch Financial if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Frisch Financial’s previous recommendations and/or services. Disclosure Statement. A copy of Frisch Financial’s written disclosure statement as set forth on Part 2 of Form ADV and Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the applicable form of client agreement. Frisch Financial does not participate in a wrap fee program. As of December 31, 2023, Frisch Financial managed a total of $720,848,515. This includes $683,631,801 in assets under management on a discretionary basis, and $37,216,714 in assets under management on a non-discretionary basis.