A. D’Orazio & Associates is a Virginia corporation formed on June 7, 2004, which became registered as an investment adviser in December 2004. Andrew Eskelsen, Jeremy Meek, David Trenner, and Jennifer VanLandingham are D’Orazio & Associates’ principal owners. B. D’Orazio & Associates offers financial planning, investment and non-investment related consulting discretionary investment management services, and retirement plan consulting services to its clients, who generally include individuals, high net worth individuals, trusts and estates, and related retirement plans. INVESTMENT ADVISORY SERVICES Clients can engage D’Orazio & Associates to provide discretionary investment advisory services on a fee-only annual retainer basis, payable quarterly, subject to the terms and conditions of a Financial Planning and Investment Management Agreement. Before D’Orazio & Associates provides investment advisory services, an investment adviser representative will coordinate with the client to develop investment objectives, based upon an assessment of factors that typically include capital preservation; risk tolerance; income production; liquidity requirements; client preferences; asset and liability levels; and investment restrictions. D’Orazio & Associates will then allocate investment assets consistent with the designated investment objectives, risk tolerance, investment time horizon, withdrawal requirements, and other special circumstances. We suggest strategies to accomplish agreed-upon goals and use a coordinated implementation and monitoring process for which clients are responsible to notify us of any changes in their circumstances or other information that might affect the advice or services they receive. Currently, D’Orazio & Associates primarily allocates investment assets among various mutual funds, exchange traded funds (“ETFs”), individual equities, and individual bonds, on a discretionary basis in accordance with the client’s designated investment objectives. Once assets are allocated, D’Orazio & Associates provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and may execute account transactions on a discretionary basis based on those reviews or other triggering events. For certain clients who generally meet the definition of “High Net Worth Individual,” D’Orazio & Associates may allocate investment assets held in accounts designated for management valued at $250,000 or greater, to a separately managed account program that D’Orazio & Associates manages in conjunction with an independent investment manager (“SMA Program”). D’Orazio & Associates generally considers the following factors when recommending the SMA Program: client investment objectives; management style; performance; reputation; financial strength; reporting; pricing; and research. The SMA Program that D’Orazio & Associates leverages currently invests in individual domestic equities, American Depository Receipts (“ADRs”) for international equities, and ETFs (primarily for fixed income purposes). D’Orazio & Associates uses this SMA Program to create an equity and fixed income allocation, which is customized to the respective client’s investment objectives. Then, the SMA Program is responsible for initial and ongoing trade execution. To help manage that process, D’Orazio & Associates sets an all-allowable drift from the underlying index, which allows for intra-year tax management through the realization of losses on a portion of the underlying index. Also, although the SMA Program will have day-to-day responsibility for the active discretionary management of the allocated assets, D’Orazio & Associates will continue to provide investment supervisory services for those client assets, which includes ongoing monitoring and review of account performance, asset allocation, and comparison to investment objectives. For the fixed income portion of client portfolios, D’Orazio & Associates primarily invests client assets in fixed income-based mutual funds and ETFs. However, for certain clients with fixed income allocations of approximately $250,000 or more per account, we may purchase individual fixed income securities mainly issued by U.S. financial institutions, municipalities, the federal government, or government agencies. These securities are typically laddered with maturities coordinated with a client’s anticipated cash needs and based on our view about the yield curve for that security and economic environment. D’Orazio & Associates’ “Annual Advisor Compensation” as described in Item 5.A. below compensates for investment management services, and ongoing financial planning and consulting services that may include the following: general review of property and liability insurance coverage; income tax planning; cash management; estate planning; planning for children’s education; retirement planning; retirement plan distribution analysis; real estate investment analysis; charitable gifting techniques; planning for special needs (e.g., disabled child, elder care, Medicaid qualification, etc.); divorce counseling; advanced estate planning techniques; practice management; planning for special situations (e.g., a business opportunity, an investment opportunity, buy-sell agreement, employment agreement, etc.). RETIREMENT PLAN CONSULTING SERVICES Upon specific client request, D’Orazio & Associates may agree to provide retirement plan consulting services to sponsors of self-directed retirement plans organized under the Employee Retirement Security Act of 1974 . The terms and conditions of the engagement between D’Orazio & Associates and the plan sponsor will be set forth in a Retirement Plan Services Agreement. When D’Orazio & Associates performs these services in an ERISA Section 3(21) capacity, it will assist the plan sponsor with the development of investment policy statements, and then the selection and monitoring of investment alternatives including qualified default investment alternatives from which plan participants may choose in self-directing the investments for their individual plan retirement accounts. Upon request by the plan sponsor, D’Orazio & Associates may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. MISCELLANEOUS ERISA / IRC Fiduciary Acknowledgment. When D’Orazio & Associates provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way D’Orazio & Associates makes money creates some conflicts with client interests, D’Orazio & Associates operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s.

Under this special rule’s provisions, D’Orazio & Associates must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that D’Orazio & Associates gives advice that is in the client’s best interest; charge no more than is reasonable for D’Orazio & Associates’ services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of interest. A client or prospective client leaving an employer 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 D’Orazio & Associates recommends that a client roll over their retirement plan assets into an account to be managed by D’Orazio & Associates, such a recommendation creates a conflict of interest if D’Orazio & Associates will earn a new (or increase its current) advisory fee as a result of the rollover. We mitigate this conflict by charging an annual fixed fee, which generally contemplates the value of existing retirement plan assets regardless of a rollover recommendation. Clients are not obligated to roll over retirement plan assets to an account managed by D’Orazio & Associates. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, D’Orazio & Associates will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when D’Orazio & Associates determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. D’Orazio & Associates may agree to provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. However, neither D’Orazio & Associates, nor any of its representatives, serves as an attorney, accountant, or as a licensed insurance agent to any D’Orazio & Associates’ clients, and no portion of D’Orazio & Associates’ services should be construed as legal, accounting, or insurance brokerage services. Accordingly, D’Orazio & Associates does not prepare estate planning documents, tax returns, or sell insurance products. Unless specifically agreed in writing, neither D’Orazio & Associates nor its representatives are responsible to implement or provide ongoing monitoring of any financial plans or financial planning advice. D’Orazio & Associates’ consulting services are completed upon communicating its recommendations to the client. Upon client request, D’Orazio & Associates may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are not obligated to engage the services of any recommended professionals, who are responsible for the quality and competency of the services they provide. Although Joseph A. D’Orazio, is licensed as a Certified Public Accountant (CPA) and an attorney in his separate individual capacity, Mr. D’Orazio does not offer or provide accounting or legal services to any of D’Orazio & Associates’ clients, and no corresponding CPA- client or attorney-client relationship is established. Clients retain absolute discretion over all financial planning, consulting, and related implementation decisions, and is free to accept or reject any recommendation from D’Orazio & Associates and its representatives. Client Obligations. When performing its services, D’Orazio & Associates is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. D’Orazio & Associates encourages clients to promptly notify us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending our services or previous recommendations. Asset Aggregation / Reporting Services. D’Orazio & Associates may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged D’Orazio & Associates to manage (the “Excluded Assets”). D’Orazio & Associates’ service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because D’Orazio & Associates does not have trading authority for the Excluded Assets, the client (and/or another investment professional designated by the client), and not D’Orazio & Associates, will be exclusively responsible for directly implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by D’Orazio & Associates. Accordingly, D’Orazio & Associates will not accept responsibility for adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without D’Orazio & Associates’ participation or oversight. C. D’Orazio & Associates provides investment advisory services specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will coordinate with each client to develop their investment objectives. Then, D’Orazio & Associates will allocate or recommend that clients allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on D’Orazio & Associates’ services. D. D’Orazio & Associates does not participate in a wrap fee program. E. As of December 31, 2023, D’Orazio & Associates had $1,190,037,040 in assets under management on a discretionary basis.