FocusPoint Solutions, Inc. (“FPS”) is a SEC registered investment advisory firm located in Portland, Oregon. We provide turnkey management services and business solutions to both non-affiliated and affiliated registered investment advisory firms (collectively “RIA Firms”). FPS also provides asset allocation and asset model implementation as directed by our RIA Firm clients. We provide services to both existing RIA Firms as well as to RIA Firms who wish to transition their business from a commission-based model to a fee-based model. In either circumstance, FPS primarily operates transparently behind the scenes to support the RIA Firms in building and operating an efficient business. The firm has been in business since 2004 and registered with the SEC since 2004. The principal owner and Chief Compliance Officer of the firm is Christopher K. Hicks. FPS offers the following services as a part of the turnkey business solution: Asset allocation and model implementation – As directed by RIA Firms, we provide numerous asset allocation model portfolios based upon Modern Portfolio Theory. Our approach uses broadly diversified portfolios and a systematic strategy to manage investments. The Asset Allocation Portfolios primarily include mutual funds. However, other investments such as exchange-traded funds, exchange-listed equity securities, certificates of deposit, municipal securities, U.S. government securities and money market funds may be utilized when suitable and appropriate to meet the guidelines provided us by the RIA firms. Additionally, we support RIA Firms with research, due diligence, reporting and portfolio analysis. See Item 8 for a description of the investment strategy. These models are designed with varying risk return characteristics using multiple asset classes. The RIA Firms utilize these models to manage their clients’ (an “End Client”) accounts. We provide detailed research and analysis on the model portfolios and communicate on a systematic daily, weekly, monthly, and quarterly basis with RIA Firms. In connection with the implementation of investment models, we make periodic recommendations regarding changes in the models for the RIA Firm’s consideration and approval. We do not directly provide advisory services to, or have any direct relationship with the RIA Firm’s End Clients. We do not have discretionary authority over and do not manage the accounts on behalf of any End Clients. FPS, upon instructions from the RIA Firm, will transmit appropriate instructions of changes to the custodian. Through their RIA Firm, End Clients may impose reasonable restrictions on investing

in certain securities or types of securities. Individual advice and services are tailored by RIA Firms to the stated objectives of their End Client. The RIA Firm discusses with an End Client in detail critically important information such as their risk tolerance, time horizon, and projected future needs, to formulate an investment policy. The RIA Firm sends instructions to us in accordance with this policy which objectively and suitably guides the management of the End Client’s account. RIA Firms meet with End Clients as needed to review portfolio performance, discuss current issues, and re-assess goals and plans. Fully outsourced virtual back office - We handle all initial account setup including tracking and follow- up of incoming transfers. On an ongoing basis, we handle all distributions, downloading, reconciliation, along with RIA Firm directed trading and approved rebalancing. The RIA Firm has access to all End Client investment account information, including reporting capability, through this web-based system. Part 2A - 5 End Clients of RIA Firms authorize them to use us to service their account, including billing and the deduction of fees. Those End Clients agree to allow the RIA Firm to share non-public, personal information with us for the purpose of administering and managing their account. RIA Firms require us to execute a confidentiality agreement and not share their End Clients’ information with any unauthorized person or entity. The use of FPS will not cause End Clients to incur any additional fees. We deduct our fee from the total advisory fee charged to an End Client by the RIA Firm. RIA Firms’ fee schedules are disclosed to their End Clients in their Brochures. Training and presentation materials– We provide the RIA Firm with training on Modern Portfolio Theory and on presentation materials to use with End Clients to teach this concept. The RIA Firm has access to run customized client presentations including an Investment Policy Statement. Business consulting – We work with the RIA Firm to help them develop an efficient business strategy. Areas of focus include improving time management and productivity, leveraging technology, increasing profitably, and creating more free time. Strategic alliances – Through exclusive arrangements with various experts, we make available a support network to RIA Firms for marketing, compliance, and financial planning case writing. We do not manage Wrap Fee programs. We manage approximately $5,001,681,150 of assets on a non-discretionary basis and $0 of assets on a discretionary basis. These amounts were calculated as of December 31, 2023.