SBK Financial, Inc. (“SBK,” or “we”) is a Virginia corporation founded in 2005 and registered as an investment adviser with the United States Securities and Exchange Commission since May 2005. SBK is principally owned by J. Kevin King, President and Andrea L. Broughton, Vice President and Stephanie Stumpf, Director. INVESTMENT MANAGEMENT SERVICES SBK provides customized investment management services to high-net-worth individuals and associated trusts, estates, pension and profit-sharing plans. We primarily invest client assets in mutual funds or exchange traded funds (“ETFs”). We evaluate, select, and oversee other investment managers to manage a portion of the client’s account when appropriate. For clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, we may occasionally recommend private investment funds, which may include debt, equity, or pooled investment vehicles when consistent with the client’s investment objectives. We may also assist in selecting, evaluating, negotiating, closing, oversight and monitoring investments in certain tax credits, including historic rehabilitation, land preservation, education improvement scholarship, and neighborhood assistance tax credits. We engage an investment consulting firm that is independent of SBK (“Due Diligence Provider” or “Provider”) to perform due diligence on the mutual funds, investment managers and private investment funds we recommend. In limited circumstances, this Provider may offer recommendations for funds that have separately engaged the Provider to perform investment advisory services. This arrangement presents a conflict of interest for the Due Diligence Provider, which we mitigate when applicable by notifying the affected client, reminding them that they can limit their investment options, and that they are not obligated to invest in any private investment funds we recommend. SBK tailors its services to the individual needs of its clients. We collaborate with each client to develop an appropriate investment profile and strategy and seek to manage the portfolio accordingly. To the extent specifically requested by the client, the annual investment advisory fee charged for investment management services also compensates for limited financial planning and consulting services such as tax planning, estate planning, non- investment related financial counseling, etc. While we believe it is important for clients to address these issues on an ongoing basis, our investment advisory fee will remain the same regardless of whether clients choose to use those services. In designing an investment portfolio, we consider the client’s age, investment goals, time horizon, financial circumstances, tax situation, investment experience, risk tolerance, investment limitations and trading restrictions. We help clients select from various growth, balanced and conservative strategies. Clients may impose reasonable restrictions on SBK’s management of their accounts. TAX PREPARATION AND PLANNING SERVICES Certain existing clients may also engage SBK under a separate agreement to provide tax preparation and/or planning services through its representatives who are Certified Public Accountants. In these limited circumstances, SBK charges a fixed fee that varies depending upon the scope and complexity of the tax services required. FINANCIAL PLANNING LIMITATIONS As mentioned above, to the extent requested by the client, SBK may also provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, etc. On a very limited basis, SBK may also provide services to a client who is not an investment management client in coordination with that client’s other registered investment advisers. The services SBK may provide could include tax advisory, estate planning, non-investment related financial counseling, etc., and will be separately identified and billed. Fees for these limited engagements may vary, are negotiable, may be charged on a time and materials basis or as a flat fee, and are typically payable in part upon commencement of a project, periodically over the life of the engagement or upon completion of the engagement. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from SBK and its representatives in that respect. ERISA / IRC Fiduciary Acknowledgment. When SBK 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 the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way SBK makes money creates some conflicts with client interests, SBK 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, SBK 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 SBK gives advice that is in the client’s best interest; charge no more than is reasonable for SBK’s services; and give the client basic information about conflicts of interest. Client Obligations. When performing its services, SBK 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. Clients are responsible to promptly notify SBK if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending SBK’s services or previous recommendations. Portfolio Trading Activity

/ Inactivity. As part of its investment advisory services, SBK will manage client portfolios on an ongoing basis to determine if trading is necessary based upon various factors, including but not limited to investment performance, market conditions, 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 SBK through ongoing management, 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. Asset Aggregation / Reporting Services. SBK 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 SBK to manage (the “Excluded Assets”). SBK’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because SBK does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not SBK, will be exclusively responsible for 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 SBK. Accordingly, SBK would not agree to be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third-party reporting platforms without SBK’s participation or oversight. Margin / Securities Based Loans. SBK does not recommend the use of margin for investment purposes. However, if a client determines to take a margin loan that collateralizes a portion of the assets that SBK is managing, SBK’s investment advisory fee will be computed based upon the full value of the assets, without deducting the amount of the margin loan. Without limiting the above, SBK may recommend that a client establish a margin loan or a securities- based loan (collectively, “SBLs”) with the client’s broker-dealer/custodian or their affiliated banks (each, an “SBL Lender”) to access cash flow. Unlike a real estate-backed loan, an SBL has the potential benefit of enabling borrowers to access funds in a shorter period of time, providing greater repayment flexibility, and may also result in the borrower receiving certain tax benefits. Clients interested in learning more about the potential tax benefits of borrowing money on margin should consult with an accountant or tax advisor. The terms and conditions of each SBL are contained in a separate agreement between the client and the SBL Lender selected by the client, which terms and conditions may vary from client to client. Borrowing funds on margin is not suitable for all clients and is subject to certain risks, including but not limited to: increased market risk, increased risk of loss, especially in the event of a significant downturn; liquidity risk; the potential obligation to post collateral or repay the SBL if the SBL Lender determines that the value of collateralized securities is no longer sufficient to support the value of the SBL; the risk that the SBL Lender may liquidate the client’s securities to satisfy its demand for additional collateral or repayment / the risk that the SBL Lender may terminate the SBL at any time. Before agreeing to participate in an SBL program, clients should carefully review the applicable SBL agreement and all risk disclosures provided by the SBL Lender including the initial margin and maintenance requirements for the specific program in which the client enrolls, and the procedures for issuing “margin calls” and liquidating securities and other assets in the client’s accounts. If SBK recommends that a client apply for an SBL instead of selling securities that SBK manages for a fee to meet liquidity needs, the recommendation presents an ongoing conflict of interest because selling those securities (instead of leveraging those securities to access an SBL) would reduce the amount of assets to which SBK’s investment advisory fee percentage is applied, and thereby reduce the amount of investment advisory fees collected by SBK. Likewise, the same ongoing conflict of interest is present if a client determines to apply for an SBL on their own initiative. These ongoing conflicts of interest would persist as long as SBK has an economic disincentive to recommend that the client terminate the use of SBLs. If the client were to invest any portion of the SBL proceeds in an account that SBK manages, SBK will receive an advisory fee on the invested amount, which could compound this conflict of interest. If a client accesses an SBL through its relationship with SBK and the client’s relationship with SBK is terminated, that client may incur higher (retail) interest rates on the outstanding loan balance. Clients are therefore reminded that they are not under any obligation to employ the use of SBLs, and are solely responsible for determining when to use, reduce, and terminate the use of SBLs. Although SBK seeks to disclose all conflicts of interest related to its recommended use of SBLs and related business practices, there may be other conflicts of interest that are not identified above. Clients are therefore reminded to carefully review the applicable SBL agreement, and all risk disclosures provided by the SBL Lender as applicable and contact SBK’s Chief Compliance Officer with any questions regarding the use of SBLs. WRAP PROGRAMS SBK does not offer investment management services on a wrap-fee basis. REGULATORY ASSETS UNDER MANAGEMENT As of December 31, 2023, SBK had $1,134,816,590 in assets under management, all of which was being managed on a discretionary basis.