A. HBC Financial Services, PLLC began business in January of 2001 to offer additional services to our CPA firm (Harrison Berkman Claypool & Guard, PLLC) clients and others. Our principal owners are: James B. Claypool, CPA, PFS James D. Guard III, CPA, PFS Janon L. Niess, CPA, PFS B. We offer financial, retirement, and estate planning, comprehensive investment and non-investment related consulting, and discretionary investment advisory services using modern portfolio theory primarily through various managed and passive mu- tual funds and exchange traded funds. C. We tailor our advisory services to the individual needs of our clients. Our services are generally based upon the client’s designated investment objective and risk toler- ance, and the results of any corresponding financial, retirement and estate planning analysis that may be provided to the client. By so doing, we are able to allocate the client’s designated investment assets between more aggressive and more risk averse portfolios. Our clients may impose restrictions on investing in certain securities or types of se- curities. D. We do not participate in wrap fee programs. E. As of January 1, 2024, we managed $433 million of client assets on a discretionary basis. We managed $14 million of client assets on a non-discretionary basis. Overview of Services Offering: HBCFS provides discretionary investment advisory services on a fee basis as discussed at Item 5 below. Before engaging HBCFS to provide investment advisory services, clients are required to enter into an Investment Advi- sory Agreement with HBCFS 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, HBCFS will ascertain each client’s investment objective(s) and then allocate the client’s as- sets consistent with the client’s designated investment objective(s). Once allocated, HBCFS provides ongoing supervision of the account(s). Upon the commencement of an engagement, a client (excluding an ERISA plan or en- tity client) will engage HBCFS for initial financial planning services per the terms and conditions of a separate Financial Planning and Consulting Agreement-see below. Thereafter, HBCFS’ annual investment advisory fee shall generally (exceptions can occur-see below) include investment management services, and, to the extent specif- ically requested by the client, subsequent ongoing financial planning and consulting services. In the event that the client requires extraordinary planning and/or consul- tation services (to be determined in the sole discretion of HBCFS), HBCFS may deter- mine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. A client can choose to engage HBCFS without the initial planning engagement, If a client determines to do so, HBCFS’ advi- sory fee shall not include financial planning services. Should the client subsequently desire financial planning services, HBCFS will make them available for a separate fee per the terms and conditions of a separate Financial Planning and Consulting Agree- ment. Initial and/or Stand-Alone Financial Planning Services. As indicated above, com- mencement of an engagement, HBCFS offers to provide financial planning and related consulting services regarding matters such as tax and estate planning, insurance, etc. on a stand-alone basis per the terms and conditions of a separate written agreement and fee, the fee for which shall generally be based upon the individual providing the service and the scope of the services to be provided. Prior to engaging HBCFS to pro- vide planning or consulting services, clients are generally required to enter into a Fi- nancial Planning and Consulting Agreement with HBCFS setting forth the terms and conditions of the engagement (including termination), describing the scope of the ser- vices to be provided, and the portion of the fee that is due from the client prior to HBCFS commencing services. Exceptions: As indicated above, a client can choose to engage HBCFS without the initial planning engagement, If a client determines to do so, HBCFS’ advisory fee shall not include financial planning services. Should the client subsequently desire financial planning services, HBCFS will make them available for a separate fee per the terms and conditions of a separate Financial Planning and Con- sulting Agreement. Ongoing Financial Planning and Non-Investment Consulting/Implementation Services. As discussed above, if the client initially engages HBCFS for financial plan- ning services, HBCFS’ ongoing advisory services will generally include subsequent ongoing financial planning and related consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon extraordinary matters, special projects, for which Firm may charge a separate or additional fee). Please Note. HBCFS believes that it is important for the client to address financial planning issues on an ongoing basis. HBCFS’ advisory fee, as set forth at Item 5 below, will re- main the same regardless of whether or not the client determines to address financial planning issues with HBCFS. Please Also Note: HBCFS does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, HBCFS does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. at- torneys, accountants, insurance, etc.), including HBCFS’ affiliated CPA firm Harrison Berkman Claypool & Guard, PLLC per the terms and conditions of a sperate engage- ment and fee-see Item 10 below. Please Further Note: HBCFS and Harrison Berk- man Claypool & Guard, PLLC are separate entities offering different services, and each of their respective service offerings is subject to the terms and condi- tions of a separate written agreement and fee. The client is not under any obliga- tion to engage any such professional(s). No client is under any obligation to engage the services of a recommend professional, including Harrison Berkman Claypool & Guard, PLLC. HBCFS will work with the CPA and other professionals of the cli- ent’s choosing. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from HBCFS and/or its representatives. If the client engages any unaffiliated professional (i.e. attorney, ac- countant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not HBCFS, shall be responsible for the quality and competency of the services provided. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically

has four options regarding an exist- ing 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 HBCFS recommends that a client roll over their retirement plan assets into an account to be managed by HBCFS, such a recommendation creates a conflict of interest if HBCFS will earn new (or increase its current) compensation as a result of the rollover. If HBCFS provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), HBCFS is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retire- ment accounts. No client is under any obligation to roll over retirement plan as- sets to an account managed by HBCFS, whether it is from an employer’s plan or an existing IRA. HBCFS’ Chief Compliance Officer, James Guard, remains availa- ble to address any questions that a client or prospective client may have regard- ing the potential for conflict of interest presented by such rollover recommen- dation. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, HBCFS gen- erally recommends that Fidelity serve as the broker-dealer/custodian for client in- vestment management assets. Broker-dealers such as Fidelity charge brokerage com- missions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Fidelity, do not currently charge fees on individ- ual equity transactions, including ETFs, others do. Please Note: there can be no as- surance that Fidelity will not change its transaction fee pricing in the future). These fees/charges are in addition to HBCFS’ investment advisory fee at Item 5 below. HBCFS does not receive any portion of these fees/charges. ANY QUESTIONS: HBCFS’ Chief Compliance Officer, James D. Guard III, CPA, PFS, remains available to ad- dress any questions that a client or prospective client may have regarding the above. Portfolio Activity. HBCFS has a fiduciary duty to provide services consistent with the client’s best interest. HBCFS will review client portfolios on an ongoing basis to de- termine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment ob- jective. Based upon these factors, there may be extended periods of time when HBCFS determines that changes to a client’s portfolio are neither necessary, nor prudent. Cli- ents remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Socially Responsible Investing Limitations. Socially Responsible In- vesting involves the incorporation of Environmental, Social and Governance con- siderations into the investment due diligence process (“ESG). There are potential lim- itations associated with allocating a portion of an investment portfolio in ESG securi- ties (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (includ- ing any investment and/or investment strategies recommended and/or undertaken by HBCFS), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. ERISA Plan Engagements: HBCFS may be engaged to provide discretionary invest- ment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, HBCFS will serve as an investment fiduciary as that term is de- fined under The Employee Retirement Income Security Act of 1974 (“ERISA”). HBCFS will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm. Client Retirement Plan Assets. If requested to do so, HBCFS shall provide invest- ment advisory services relative to 401(k) plan assets maintained by the client in con- junction with the retirement plan established by the client’s employer. In such event, HBCFS shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. HBCFS’ ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. HBCFS will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify HBCFS of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the HBCFS to the contrary, in writ- ing, the client’s 401(k) plan assets shall be included as assets under management for purposes of HBCFS calculating its advisory fee. HBCFS does not maintain possession of client retirement account passwords. Please Note: Cash Positions. HBCFS continues to treat cash as an asset class. As such, unless determined to the contrary by HBCFS, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating HBCFS’ advisory fee. At any specific point in time, depending upon per- ceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), HBCFS may maintain cash posi- tions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, HBCFS’ advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: HBCFS’ Chief Compliance Officer, James D. Guard III, CPA, PFS, remains available to address any questions that a client or prospective may have regarding the above fee billing practice.