Ifrah Financial Services, Inc. is a SEC-registered investment adviser with its principal place of business located in Arkansas. We began conducting business in 2006. Listed below are the firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company): Patrick Ifrah, President & CEO Stephen DeSalvo, Chairman of the Board Micah Brown We offer investment supervisory services, individual portfolio management, and model portfolio management services to Clients. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. We offer advice on a broad range of securities such as:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• Exchange Traded Funds (“ETF”)
• United States governmental securities
• Interests in partnerships (for example: real estate, oil and gas, among others)
• Structured Notes Because some types of investments involve certain additional degrees of risk, they will only be utilized when consistent with the Client’s stated investment objectives, tolerance for risk, liquidity and suitability. Please refer to Item 8 for a discussion of our methods of analysis, investment strategies, and risk. Our firm provides investment supervisory and management services to Clients that may use model asset allocation portfolios. Model asset allocation portfolios are offered through either Goldman Sachs Custody Solutions (“GSCS”), formerly known as FOLIOfn and hereinafter referenced as “GSCS” or Charles Schwab. Our available model portfolios are listed below. Each is designed to meet a particular investment goal. Our firm can also provide discretionary management of accounts outside of the model managed programs in certain circumstances. FolioAdvantage Models FolioAdvantage is a multi-strategy for money management. It attempts to diversify among types of equities as well as the types of strategies used. It is based on the premise that there are various times when certain types of securities and management styles go in and out of favor during the economic cycles. FolioAdvantage models are managed at “GSCS”. See Item 12 (Brokerage Practices) below for information related to “GSCS”. Based on the planning process, the Planner may allocate among several sub-portfolios (“Folios”) described below. Folios may be passive or actively managed (or a combination of both) and may use multiple strategies and styles. Folios are used as part of the following allocations: Standard Allocations:
• Ultra Conservative 40/60: 40% Equities - 60% Fixed Income & Cash
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash Folios may also be created for Small Account Models (using ETFs only)
• Small Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Small Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Small Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash
• Ultra-Small Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Ultra-Small Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Ultra-Small Aggressive 90/10: 90% Equities – 10% Fixed Income & Cash The following Folios may be used in any of the Standard and Small Account Models: FOUNDATION FIXED INCOME This Folio uses fixed income ETFs to create a core diversified portfolio of taxable fixed income with the objective of matching or outperforming the Barclays Aggregate Bond Index on a risk- adjusted basis. It is passive in nature however it is reviewed at least annually to consider changes in the yield curve and to reallocate between short, intermediate, and long maturities if appropriate. It may include corporate general and high yield bonds as well as inflation protected treasury bonds as appropriate. Allocations are made in consideration of the trade-offs on the yield curve between yield and maturities as well as quality spreads between Treasuries, Corporates and other credit type securities made available through ETFs. FOUNDATION EQUITY US This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature. The ETFs used are in various asset class categories attempting to cover the US market and are allocated in a manner that is based on distributing the holdings among the following style boxes:
• Small Cap Growth
• Small Cap Value
• Mid Cap Growth
• Mid Cap Value
• Large Cap Growth
• Large Cap Value This Folio may also include a Real Estate Investment Trust (“REIT”) component. The allocations will shift over time and given the passive nature of this Folio it could be a year or more before any changes are made. ADVANTAGE TRADING This Folio is an actively managed portfolio of primarily US Equities; however it can contain some foreign securities if they are traded on a US exchange (typically in the form of an American Deposit Receipt (“ADR”)). This Folio Places additional consideration on the technical characteristics of a stock to select and determine when to purchase and sell stocks from a pre- screened list of securities with quantitative criteria which fall into an acceptable range. This strategy looks for a wide range of opportunities and does not necessarily limit itself to fundamental data. ADVANTAGE LEADERS This Folio is an actively managed portfolio of primarily US Equities; however it can contain some foreign securities if they are traded on a US exchange (typically in the form of an American Deposit Receipt (“ADR”)). This Folio uses an investment screen in search of companies with strong margins and consensus in earnings estimates along with acceptable measures of profitability. Selection of securities will take into consideration valuation, momentum and other quantitative criteria falling into an acceptable range. STRATEGIC EQUITY US This Folio is an actively managed portfolio of primarily US Equities; however it can contain some foreign securities if they are traded on a US exchange (typically in the form of an American Deposit Receipt (“ADR”)). This Folio is invested using a quantitative ranking process and will attempt to limit excessive concentrations in any given sector as deemed appropriate by Advisor. This Folio will include the use of valuation and momentum factors. Valuation factors will include both company intrinsic and relative valuation considerations. Momentum factors will incorporate analyst earning revisions as well as a price momentum model. Momentum is used in addition to valuation because certain securities could remain undervalued for extended periods of time and adding momentum can assist with timing of selections. The valuation and momentum-based models have historically reflected lower correlation to each other over time and thereby the ability to reduce volatility. FOCUS LEADERS This Folio uses domestic ETFs to focus in certain sectors, and stock types and styles based on momentum and technical indicators. This Folio will focus on selected areas of the market and may also invest in ETFs focusing in commodities, currencies as well as target outcome (among others). Allocations also consider volatility and potential risks as well in the current market environment. FOUNDATION EQUITY INTERNATIONAL This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature. The ETFs covers the various markets around the world and will include exposure to developed as well as emerging countries. STRATEGIC EQUITY INTERNATIONAL This Folio uses foreign ETFs to focus in certain geographical areas of the world based primarily on momentum and technical considerations. It may invest in individual country ETFs, or broader geographical areas. Allocations also consider volatility and potential risks as well in the current market environment. ULTRA-SMALL AGGRESSIVE The Ultra- Small Aggressive Portfolio uses three broad ETFs to provide US and International Equity exposure as well as fixed income exposure. This portfolio is used for smaller accounts as deemed appropriate by advisor. ULTRA-SMALL MODERATE The Ultra-Small Moderate Portfolio uses three broad ETFs to provide US and International Equity exposure as well as fixed income exposure. This portfolio is used for smaller accounts as deemed appropriate by advisor. ULTRA-SMALL CONSERVATIVE The Ultra-Small Conservative Portfolio uses three broad ETFs to provide US and International Equity exposure as well as fixed income exposure. This portfolio is used for smaller accounts as deemed appropriate by advisor. A security may be held in multiple Folios and may be bought/sold at different times in those Folios based on considerations for the overall portfolio. Although our FolioAdvantage strategies incorporate the use of quantitative rankings and technical considerations to assist in the selection of securities, investment manager judgment may be used in conjunction with the use of external research to refine the investment selections and the timing on executing specific buy and sell trades. iFocus Models iFocus is a multi-strategy and is based on screening concepts of known successful market professionals and our own quantitative rankings overlaid for a portion of the portfolio that uses individual stocks and a core and passive component made up of exchange traded funds for diversification. iFocus models are managed at “GSCS”. Like the FolioAdvantage Models, the Planner may allocate among several Folios as part of an allocation described below. Standard iFocus Model allocations include:
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash Folios used in iFocus Model allocations include: iFocus Fixed Income This Folio uses fixed income ETFs to create a core diversified portfolio of taxable fixed income. The objective is to match or outperform the Barclays Aggregate Bond Index on a risk adjusted basis. This portfolio is passive in nature; however it is reviewed at least annually to consider changes in the yield curve and reallocate between short, intermediate and long maturities when appropriate. It also may include corporate general and high yield bonds as well as inflation protected treasury bonds, when appropriate. iFocus US Equities This Folio uses ETFs to construct a core portfolio that is diversified and passive in nature. The ETFs used are in various categories attempting to cover the US market and are allocated in a manner based on distributing the holdings among the following style boxes:
• Small Cap Growth
• Small Cap Value
• Mid Cap Growth
• Mid Cap Value
• Large Cap Growth
• Large Cap Value The allocations will shift over time and given the passive nature of this Folio it could be a year or more before any changes are made. iFocus International This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature. The ETFs cover the various markets around the world and will include exposure to developed as well as emerging countries. iFocus Market Pros This Folio uses individual equities based on screening concepts from well-known market professionals and third-party research. From this initial screening, we apply our own set of additional criteria and rankings to select the securities to be used in this Folio. A Multi-Strategy Allocation is also available and uses a blend of FolioAdvantage folio components as well as the iFocus Market Pro folio strategy. The aggressive allocation under the Multi- Strategy uses 95% equities and 5% fixed income. Although our iFocus strategies utilize quantitative rankings and technical considerations to select securities, investment advisor judgment may apply along with the use of external or other research to refine the investment selections and the timing on executing specific buy and sell trades. Schwab Management Models The Standard Management Models include:
• Strategic Model
• Tactical Model
• Tactical + Quant Model Standard Allocations:
• Ultra Conservative 40/60: 40% Equities - 60% Fixed Income & Cash
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash The Strategic Model Uses ETFs for core diversification among fixed income, small/mid/large cap stocks, and international equities. The models are long-term strategic in nature and have very low turnover. They can remain static for extended periods of time except for rebalancing that may occur as determined by the specific needs of the client and the tax implications for the account. The Tactical Model Uses ETFs with diversification across fixed income, small/mid/large cap stocks and international equities. The model will be allocated over time in different ETFs to gain varying exposures to various areas of the markets by emphasizing factors such as value or growth primarily using technical and momentum considerations. The objective is to emphasize areas that are considered to be performing well in a given market environment and attempt to reduce risks when warranted by using lower volatility ETFs as an example. Tactical + Quant Management Model Uses both ETFs and individual equities in areas of Small Cap, Mid Cap and Large Cap as an actively managed component. It incorporates the Tactical Model in addition to using individual equities. The model uses quantitative rankings to select stocks. Valuation and momentum considerations are part of the quantitative rankings. Stock selections are periodically reviewed and substitutions are made when necessary. Value judgment may apply along with the use of external or other research to refine the investment selections and the timing on executing specific buy and sell trades. The Strategic, Tactical and Tactical + Quant Management Models are managed at Charles Schwab (“Schwab”). See Item 12 (Brokerage Practices) below for information related to Schwab. For taxable accounts, we may at our discretion defer or limit trading and we may temporarily assign these accounts to models that have the potential to limit the tax impact of trades in these accounts. Schwab Institutional Intelligent Portfolio Platform IFS occasionally uses the platform and tools made available by Schwab under their Institutional Intelligent Portfolio Platform for the creation and management of custom portfolio models. Charles Schwab makes this platform available at no additional cost except a requirement that 4% of the portfolio be allocated in cash. Managed Funds Portfolio Managed Funds Portfolio Models use mutual fund selections in up to thirteen categories to allocate a Client portfolio. Custom allocations are created by IFS relative to the Client’s investment objectives and risk tolerances. At the discretion of IFS, rebalancing is performed to bring allocations back into balance when suitable and appropriate for a particular Client. During rebalancing, mutual fund substitutions may be performed in some of the mutual fund categories. Mutual fund selections are based on reviewing performance data over various time frames, price momentum, return consistency, risk characteristics, ratings, fund rankings and expenses. Categories are defined based on Morningstar classification of mutual fund objectives. The following categories are available:
• Aggressive Growth
• Growth
•

Growth and Income
• International Equity
• Government Bonds - Short Term (Duration 0-3 years)
• Government Bonds - Intermediate Term (Duration 3-7 years)
• Government Bonds - Long Term (Duration 7+ years)
• Municipal Bonds - Short Term (Duration 0-3 years)
• Municipal Bonds - Intermediate Term (Duration 3-7 years)
• Municipal Bonds - Long Term (Duration 7+ years)
• Corporate Bonds - Investment Grade (Duration - Varied)
• Corporate Bonds - High Yield (Duration - Varied)
• International Bonds (Duration - Varied)
• Cash/Money Market Communications and updating of information To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the Client’s financial circumstances, we will: Send quarterly written reminders to each Client requesting any updated information regarding changes in the Client’s financial situation and investment objectives; Contact each participating Client annually to determine whether there have been any changes in the Client’s financial situation or investment objectives, and whether the Client wishes to impose investment restrictions or modify existing restrictions and always be available to consult with the client when requested. FINANCIAL PLANNING We also provide financial planning services. Financial planning is an evaluation of a Client’s current and future financial situation by using currently known variables to analyze future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the Client. Clients purchasing this service receive a report which provides the Client with a general financial overview designed to assist the Client achieve his or her financial goals and objectives. In general, the financial plan may address any or all of the following areas: Personal: The review of family records, budgeting, personal liability, estate information and financial goals where applicable. Tax and Cash Flow: The analysis of the Client’s income tax and spending and planning for past, current and future years. Investments: The analysis of investment alternatives in the Client’s portfolio. Insurance: The generic review of existing policies and possible recommendation that the Client discuss additional coverage options for life, health, disability, long-term care, liability, home and automobile with a licensed insurance agent. Retirement: The analysis of current strategies and investment plans to help the Client achieve his or her retirement goals. Death and Disability: The review of the Client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. Estate: Assist the Client and may recommend third party professionals to help assess and develop long-term strategies, including as appropriate, living trusts, wills, estate tax, powers of attorney, asset protection plans, long term care, Medicaid, and elder law. The gathering of necessary information through personal interviews. Information gathered includes the Client’s current financial status, tax status, future goals, return objectives and attitudes towards risk. We carefully review documents supplied by the Client and advise accordingly. Should the Client choose to implement the recommendations contained in the plan, we suggest the Client work closely with his/her attorney, accountant, insurance agent, and/or financial planner. Implementation of financial plan recommendations is entirely at the Client’s discretion. We may also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. PUBLICATION OF PERIODICALS We publish a market commentary providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. No specific investment recommendations are provided in these commentaries and the information provided does not purport to meet the objectives or needs of any individual. This is distributed free of charge to our advisory Clients and published on our website. CONSULTING SERVICES Clients may also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the Client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. RETIREMENT PLAN SERVICES IFS offers participant directed 401(k) plans with Vanguard Retirement Services. We provide advisory services and participant education services. Our advisory services are tailored to the needs of the client organization and include assistance with the selection of investment options for the plan as well as making ourselves available to participants for guidance on their account, investment selection and asset allocation decisions and other financial planning related matters. Compensation for our services are through a fully disclosed advisory fee negotiated at the onset of the relationship. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: To the extent specifically requested, Ifrah will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. inclusive of its advisory fee set forth at Item 5 below (limited exceptions may occur based upon assets under management, advanced planning needs, special projects, etc. for which Firm may charge a mutually agreeable additional fee and/or require a stand-alone financial planning engagement). Please Note: Ifrah does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, Ifrah does not prepare estate planning or any other legal documents, 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. attorneys, accountants, insurance, etc.). Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Client Obligations: In performing its services, Ifrah 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 his/her/its responsibility to promptly notify Ifrah if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Ifrah’s previous recommendations and/or services. Retirement Rollovers-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 Ifrah recommends that a client roll over their retirement plan assets into an account to be managed by Ifrah, such a recommendation creates a conflict of interest if Ifrah will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Ifrah serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Ifrah. Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Clients can place reasonable restrictions on the types of investments to be held in their account. Restrictions must be provided to us in writing. Separate Account Managers: Ifrah may allocate a portion of a client’s investment assets among unaffiliated independent investment managers (per the terms of a sub-advisory agreement between Ifrah and the manager) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. Ifrah shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that Ifrah shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note: The investment management fee charged by the separate account manager is separate from, and in addition to, Ifrah’s advisory fee as set forth in the fee schedule at Item 5 below. Custodian Charges-Additional Fees: As discussed below at 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Ifrah generally recommends that Schwab and/or “GSCS” serve as the broker- dealer/custodian for client investment management assets. Broker-dealers charge transaction fees for effecting securities transactions. In addition to Ifrah’s investment advisory fee referenced in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds, exchange traded funds, and individual equity and fixed income securities, including those purchased by an underlying Independent Manager discussed above. See discussion below regarding transaction based vs. asset-based pricing. ANY QUESTIONS: Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a client or prospective client may have regarding the above. Asset-Based Pricing Arrangements and Limitations: Ifrah generally recommends that clients enter into an “Asset-Based” pricing agreement with the account broker-dealer/custodian. Under an asset-based pricing arrangement, the amount that a client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the account, generally expressed in basis points and/or a percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or 0.01% (0.0001). Generally, the applicable fixed percentage fee decreases as the account value increases. This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. Under either the asset- based or transaction-based pricing scenario, the fees charged by the respective broker- dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to Ifrah per Item 5 below. Ifrah does not receive any portion of the asset-based transaction fees payable by you to the account custodian. We continue to believe that our clients can benefit from an asset-based pricing arrangement. You are under no obligation to enter into an asset – based arrangement, and, if you do, you can request at any time to switch from asset-based pricing to transactions-based pricing, However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by you to switch to transaction-based pricing could prove to be economically disadvantageous. Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a client or prospective client may have regarding Asset-Based versus Transaction- Based pricing. Please Note-Use of Mutual and Exchange Traded Funds: In addition to Ifrah’s investment advisory fee described below at Item 5, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). ANY QUESTIONS: Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a client or prospective client may have regarding the above. ERISA Plan and 401(k) Individual Engagements: Trustee Directed Plans. Ifrah may be engaged to provide investment 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, Ifrah will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Ifrah 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. Participant Directed Retirement Plans: Ifrah may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Ifrah and the plan. For such engagements, Ifrah shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Ifrah), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision-making process. Client Retirement Plan Assets: If requested to do so, Ifrah shall provide investment advisory services relative to the client’s 401(k) plan assets. In such event, Ifrah shall recommend that the client allocate the retirement account assets among the investment options available on the 401(k) platform. Ifrah shall be limited to making recommendations regarding the allocation of the assets among the investment alternatives available through the plan. Ifrah will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Ifrah of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Portfolio Activity: Ifrah has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Ifrah will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Ifrah determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Ifrah will be profitable or equal any specific performance level(s). Investment Risk: Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Ifrah) will be profitable or equal any specific performance level(s). We do not manage Wrap Fee programs. As of 12/31/2023, we were actively managing approximately $403,648,623 of client assets broken down per the following: Discretionary basis: $360,688,138 and on a non-discretionary basis $42,960,485. ANY QUESTIONS: Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a client may have regarding its prospective engagement and the corresponding conflict of interest presented by such engagement.