Advisor Description First National Corporation, (“First National” or the “Advisor”) was founded in 1978. First National provides personalized investment management, financial planning and consulting services to individuals, high net worth individuals, trusts, estates pension and profit-sharing plans, charitable organizations, businesses and other investment advisors (each a “Client”). Advice is provided through consultation with the Client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. First National also provides investment management services through its separately managed account strategies called Chapoquoit Dynamic Portfolios (“Chapoquoit”). All Clients must establish and maintain their account[s] at a qualified custodian. The Client always maintains control over their account[s] and the ability to view or access their assets at any time. The Client will authorize First National to have investment discretion to purchase or sell investments within their established account[s] at the custodian. For certain Clients, First National may also have authority to make payments on behalf of the Client from the Client’s account[s]. Please see the Custody section below. A written evaluation of each Client's initial situation may be provided to the Client, often in the form of an investment policy statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the Client unless immediate changes are recommended. Certain of First National’s Advisory Persons may sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products if such products are appropriate for their Clients. First National may directly or indirectly compensate other professionals for Client referrals. Please see the section Client Referrals and Other Compensation below. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the Client on an as-needed basis. Conflicts of interest will be disclosed to the Client in the unlikely event they should occur. The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see the Code of Ethics, Participation or Interest in Client Transactions and Personal Trading section below. Principal Owners Michael S. Hebert is a 50% stockholder. Jason T. Skolnick is a 50% stockholder. Types of Advisory Services First National provides investment supervisory services, also known as asset management services; manages investment advisory accounts not involving investment supervisory services; furnishes investment advice through consultations; issues periodicals about securities by subscription; issues special reports about securities; and issues, charts, graphs, formulas, or other devices which Clients may use to evaluate securities. On more than an occasional basis, First National furnishes advice to Clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning. The Advisor’s services include, but are not limited to, the following: For individuals: Investment Management Financial Planning Retirement Planning Estate Planning College Planning Insurance (Life, Disability, Long-Term Care) Variable Annuities For other investment advisors: Investment Management For businesses: Estate Planning for Business Owners Retirement Plans Group Benefits Executive Benefits Planning The Principals of the Advisor may also provide educational seminars and workshops to Clients and prospects. These seminars and workshops are provided as a courtesy at no cost to attendees. As of December 31, 2022, First National manages $1,071,506,922 in Client assets, $1,017,421,807 of which is managed on a discretionary basis, and $54,085,115 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Tailored Relationships The Advisor’s financial services are customized to meet the unique needs of each Client. The goals and objectives for each Client are documented in our Client relationship management system. Investment policy statements may be created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities (for example, stocks) or types of securities (for example, stocks of foreign issuers). Clients are advised to promptly notify First National if there are ever any changes in their financial situation or if they wish to impose any reasonable restrictions upon the Advisor’s management services. Agreements may not be assigned without Client consent. Transactions which do not result in an actual change in control or management are not considered an assignment. Investment Management Services Most Clients choose to have First National manage their assets in order to obtain ongoing in-depth advice and life planning. All aspects of the Client’s financial affairs are reviewed.

Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. Assets are invested primarily in no-load or low-load mutual funds and exchange- traded funds (“ETFs”). Mutual funds and ETFs charge each shareholder fund fees, disclosed in the fund prospectus. Such fees include the management fee, operating expenses and other fees. These fees are in addition to the fees paid by you to First National. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Discount brokerages may also charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through the Client’s account[s] when appropriate. The custodian charges a fee for stock and bond trades. First National does not receive any compensation, in any form, from fund companies and does not receive any portion of transaction costs charged by the custodian. Investments may also include: equities (stocks), corporate debt securities, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U.S. government securities, options contracts, Independent Managers and separately managed accounts, ETFs, private placements and interests in partnerships. Clients may also invest in managed accounts strategies sponsored by First National or other unaffiliated investment advisors, if the Client’s investment parameters are appropriate for the strategies and the Client meets the required investment minimums. Initial public offerings (IPOs) are available through First National on a limited basis. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Chapoquoit Dynamic Portfolios First National is the investment manager of Chapoquoit Dynamic Portfolios, a separately managed account. In managing Chapoquoit, the Advisor employs an active asset allocation strategy using a diversified set of equity, commodity and fixed income ETFs. The investment objectives of Chapoquoit are to: strive for portfolio returns with low correlation to the stock market; target attractive long-term investment returns, after fees; seek to outperform the stock market in equity bear markets; seek to minimize the effect of months with negative returns; and attempt to provide returns above the long-term average for equities, but with bond-like risk. Chapoquoit is managed by Philip Nehro and Richard Oberuc, investment advisor representatives of First National. Messers. Nehro and Oberuc are not, however, responsible for the day-to-day management of First National. Financial Planning Services A financial plan is designed to help the Client with all aspects of financial planning without ongoing investment management after the financial plan is completed. The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment account[s], including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the Client. Retirement Plan Advisory Services The Advisor’s retirement plan advisory services are designed to provide independent consulting services to 401(k), 403(b) and other types of retirement and pension plans. We do not sell or have any retirement plan proprietary products. The Advisor’s retirement and pension plan advisory services assist Plan Sponsors with the fiduciary oversight of their retirement plan (the “Plan”). By acting as fiduciary within the meaning of 3(21) or 3(38) of ERISA, the Advisor can either share, or assume full responsibility with respect to the selection of investments, ongoing monitoring and reporting. The Advisor’s documented processes are designed to help Plan Sponsors meet their required fiduciary obligations. The retirement plan advisory services include: develop investment policy statement; investment and allocation selection; ongoing fund monitoring, QDIA selection assistance, electronic fiduciary vault, vendor search and analysis, plan fee benchmarking, and Participant education.