As discussed below in this Brochure, IC Advisory provides its clients (i.e., individuals, pension and profit-sharing plans, trusts, and business entities) with financial planning and/or investment management services on both a discretionary and non-discretionary basis. IC Advisory Services, Inc. is a SEC-registered investment adviser with its principal place of business located in Bedminster, NJ. IC Advisory Ownership IC Advisory is a wholly owned subsidiary of IC Financial Services, Inc. (“IC Financial”). IC Financial is principally owned by the Ralph DeVito Family Trust (Ralph J. DeVito trustee). The Investment Center, Inc. is a registered broker-dealer. IC Advisory Description The business of providing sound investment advice has radically changed over the last decade. More than ever, investing requires the need for analysis and investment solutions to help realize an investor’s financial needs. IC Advisory Services has developed a sophisticated platform to help investors address their situation. The platform is flexible, providing investors with the opportunity to first enter into a financial planning relationship or to immediately invest into one of the many investment choices available. By choosing to develop a strategy through a financial planning relationship, typically goal based planning, your designated financial advisor or Investment Advisor Representative (“IAR”) will help map out a financial plan based on needs and lifestyle choices. IARs will then help manage the plan and will typically review on a regular basis to make certain an investor stays on course and keeps goals in sight. Some may choose to begin investing immediately through one of the many investment programs offered through IC Advisory. The choices are abundant, ranging from mutual fund and ETF wrap programs to equity and fixed income managed accounts. Wrap programs place an investor into an asset allocation mix based on risk tolerance whereas managed accounts may be more customized, giving an investor the opportunity to work with the manager to tailor a portfolio. Another option available is an investor may elect to have an Advisor Managed Account, where the IAR personally manages the investor’s portfolio. The IAR utilizes one of many research programs available to help the investor stay on course to meet their investment needs and objectives. Our firm offers services through our network of IARs. It is important to understand that our firm enables its IARs to provide customized advice to their clients. IARs are permitted great latitude in selecting investments, investment strategies, delivering investment advice to our clients, an negotiating their fees, which all remain subject to the supervision of our compliance department. Each of our advisory programs that our IARs may use in servicing their clients are described in detail below. Our firm generally requires that The Investment Center, Inc. (“The Investment Center”), a registered broker-dealer and our affiliate, serve as introducing broker-dealer on client accounts with Pershing, LLC to act as the clearing broker-dealer. In fact, substantially all of our clients’ accounts are maintained at The Investment Center. Please refer to Item 12 for additional information about this arrangement. Advisory Services Offered Financial Planning Financial planning is based on a long-term relationship with a financial advisor and involves a comprehensive on-going approach to managing all aspects of a client’s financial life. IC Advisory is equipped to provide its clients with a broad range of financial planning services. The client is free at all times to accept or reject any financial planning or investment recommendation from IC Advisory. Clients may also obtain legal, accounting and/or brokerage services from professionals of their choosing to implement any of the recommendations of IC Advisory. In general, the financial plan can address any or all of the following areas: PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long- term care, liability, home and automobile. RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. 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 stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a general nature. If requested by the client, IC Advisory may recommend the services of other professionals for implementation purposes. Such services may include IARs acting as registered representatives of IC Advisory’s affiliated broker-dealer, The Investment Center, Inc. and as licensed insurance agents. However, the client is not obligated to engage the services of any recommended professional and retains absolute discretion over all such implementation decisions. Clients are encouraged to renew IC Advisory’s financial planning services on an annual basis for the purpose of reviewing/updating IC Advisory’s previous recommendations and/or services. IC Advisory will charge a fee (fixed fee and/or hourly) for financial planning services, which will address, among other issues, investment recommendations. IC Advisory’s financial planning fees are negotiable, but generally range from a minimum fee of $250.00 to $5,000.00 on a fixed fee basis, and between $100.00 and $500.00 on an hourly basis, depending upon the level and scope of service(s) required and the professional rendering the service(s). In the event the client terminates IC Advisory’s financial planning services, the balance, if any, of IC Advisory’s fee shall be refunded to the client. Prior to engaging IC Advisory to provide financial planning services, the client will be required to enter into a Financial Planning Agreement with IC Advisory setting forth the terms and conditions of the engagement and describing the scope of the services to be provided. Investment Management IC Advisory through its IARs may recommend one or more different types of accounts or arrangements for the management of a client’s assets. Each of these account types and arrangements are described in greater detail below. Advisor Managed Account Programs Advisor managed account programs available through IC Advisory include the firm’s sponsored asset management wrap fee programs, the Independent Asset Management Account (“IAM”) and Choice programs. IAM and Choice program accounts are typically opened with The Investment Center and Pershing, LLC serves as the clearing broker-dealer. Your IAR will recommend or manage your assets in accordance with your stated objectives. The terms and conditions of the IAM and Choice programs are set forth in a separate written agreement between IC Advisory and the Client. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding one or more of the following securities:
• Exchange-listed securities • Mutual fund shares
• Securities traded over-the- counter
• Exchange Traded Funds (ETFs)
• Warrants
• Unit Investment Trusts (UITs)
• Corporate debt securities (other than commercial paper)
• United States governmental securities
• Commercial paper
• Options contracts on securities
• Certificates of deposit • Interests in partnerships investing in real estate
• Municipal securities
• Interests in partnerships investing in oil and gas interests
• Variable life insurance
• Variable and fee-based annuities Because some types of investments involve additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. IAM IC Advisory is able to offer its clients a comprehensive investment program, for a single specified fee, with unlimited trading in individual stocks, bonds, exchange traded funds (ETFs), Unit Investment Trusts (UITs), no-load and select load-waived mutual funds, long options, short puts and covered calls. The client grants IC Advisory and their IAR discretionary authority to buy and/or sell no-load and select load-waived mutual funds, and to liquidate previously purchased load mutual funds. In addition, either with discretion, or upon consultation with and direction from the client, the financial adviser is authorized to buy, sell and trade other securities approved for the IAM Program, including individual stocks, bonds and options. Participation in the IAM Program may cost more or less than purchasing such services separately or engaging the services of a broker-dealer. In addition, the fees charged by IC Advisory for participation in the IAM Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. See available IAM customized non-wrap arrangement discussed below. Choice Choice is a comprehensive mutual fund and exchange traded fund (ETF) investment program that combines the power of professional research with the advantage of professional guidance. Choice offers access to thousands of mutual funds from over one hundred highly regarded investment managers, including no-load fund families and institutional share classes and ETFs. IAM and Choice Custom - Customized Non-Wrap Program (Servicing and Fees) IC Advisory will provide clients with the same services and investment options as with the IAM and Choice Programs, but, rather than paying one specified fee, the client account will be responsible for the payment of brokerage and custodial fees. With respect to the broker-dealer’s brokerage fees, the client’s account will incur charges imposed by the broker-dealer, which include transaction costs and commissions, on a per-trade basis. While IAR’s may recommend a wrap or non-wrap program, clients are ultimately responsible for selecting the program that is most appropriate for them. IC Advisory does not review or monitor the initial or ongoing decision by a client to enter into a wrap or non-wrap program. Clients who are uncertain which relationship is more appropriate should discuss their concerns with their IAR. Independent Managers/Investment Programs In addition to the above asset management services, IC Advisory may also recommend that certain clients authorize the active discretionary management of their assets by and/or among certain independent investment advisory programs. IC Advisory may recommend investment programs, based upon the stated investment objectives of the client, including, but not limited to: o Absolute Capital o AssetMark o Beacon Capital (Dimensional Fund Advisors - DFA) o Brinker Capital o BTS Asset Management o City National Rochdale o Clark Lanza Skalla (CLS) o Dunham & Associates o Envestnet o Flexible Plan Investments o Hanlon Investments o Managers Choice o Manning & Napier o Morningstar o Orion Portfolio Solutions o Saratoga Asset Management o SEI o Symmetry (Dimensional Fund Advisors - DFA) o Toews Corporation o United Capital The terms and conditions under which the client shall engage the Independent Manager[s] shall be set forth in a separate written agreement between the client and the designated Independent Manager[s]. IC Advisory shall continue to render advisory services to the client relative to the ongoing monitoring and renewing of account performance and client investment objectives, for which IC Advisory shall usually receive an annual fee (typically between 1.00% and 3.00%) based upon a percentage of the market value of the assets being managed by the designated Independent Manager[s]. Factors which IC Advisory shall consider in recommending Independent Manager[s] include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager[s] together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets are exclusive of, and in addition to, IC Advisory’s investment advisory fee set forth above. In addition to the fees charged by IC Advisory, the designated Independent Manager[s] and corresponding broker-dealer/custodian, the client, relative to mutual fund and exchange traded fund purchases, shall incur charges imposed at the fund level (i.e., advisory fees and other fund expenses). Prior to engaging IC Advisory to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with IC Advisory setting forth the terms and conditions under which IC Advisory shall manage the client's assets and a custodial/clearing agreement. Both IC Advisory's Investment Advisory Agreement and the custodial/clearing agreement may authorize the account custodian to debit the account for the amount of IC Advisory's investment management fee and to directly remit that management fee to IC Advisory. The investment advisory agreement between IC Advisory and the client will continue in effect until terminated by either party by written notice. IC Advisory's investment management fee shall be pro- rated through the date of termination, and any remaining balance (if any) shall be promptly refunded to the client. IC Advisory may also allocate the investment management assets of its client accounts, on a discretionary basis, among one or more mutual fund asset allocation programs which have been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly managed investment programs, with a non-exclusive safe harbor from the definition of an investment company. With respect to non-discretionary asset management services, IC Advisory generally maintains ongoing responsibility to make recommendations based upon the needs of the client as to the specific mutual funds or other securities the account may purchase or sell. If such recommendation is accepted by the client, IC Advisory is responsible for arranging or effecting the purchase or sale. Mutual funds and/or variable annuity/life products may have been (or may in the future be) purchased by the client through an SEC registered and FINRA member broker-dealer (including, but not limited to, IC Advisory’s affiliated SEC registered and FINRA member broker-dealer, The Investment Center, Inc. – see disclosure below), for which product sales the Client may have paid (or will pay) a separate commission. Clients are under no obligation to purchase any commission products through The Investment Center, Inc. or IC Advisory’s representatives. In certain instances, dependent upon the specific arrangement with the Independent Manager[s], IC Advisory may be compensated for its services directly from the Independent Manager[s] pursuant to a referral fee arrangement in accordance with Rule 206(4)-1 of the Investment Advisers Act of 1940. IC Advantage Portfolios IC Advantage Portfolios is a low cost, low entry third-party managed solution providing access to models from some of the industry's top asset managers. Through IC Advantage Portfolios, clients can be provided with access to model portfolios from managers including Russell, Vanguard and Blackrock. Each manager provides research models which are managed and rebalanced by Pershing Managed Investments on an ongoing basis. IC Advisory shall render advisory services to the client relative to the initial and ongoing allocations among the various investment models, as well as ongoing monitoring of account performance and client investment objectives, for which services IC Advisory shall usually receive an annual fee (typically between 0.50% and 1.00%) based upon a percentage of the market value of the assets being managed. The program fees charged by the various model managers (generally ranging from 0.25% to 0.65% annually), together with the fees charged by the corresponding designated broker- dealer/custodian of the client’s assets are exclusive of, and in addition to, IC Advisory’s investment advisory fee set forth above. In addition to the fees charged by IC Advisory, the designated model managers, and corresponding broker-dealer/custodian, the client, relative to mutual fund and exchange traded fund purchases, shall incur charges imposed at the fund level (i.e., advisory fees and other fund expenses). The model managers made available through the IC Advantage Portfolios program may impose minimum investment

level requirements, generally ranging from $10,000 to $50,000. Clients who have questions regarding minimum investment levels and eligibility for participation in the IC Advantage Portfolios program are advised to consult their IAR. Retirement Plan Consulting IC Advisory also provides non-discretionary pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self- directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, IC Advisory shall also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between IC Advisory and the plan sponsor. Account Minimums & Management Fees IC Advisory generally requires an account minimum of between $10,000.00 and $50,000.00 for investment management services, depending upon the asset management program selected for the client. IC Advisory, in its sole discretion, may charge a lesser investment management fee and/or reduce or waive its account minimum based upon certain criteria (i.e., the representative assigned to the account, the amount of assets to be invested, the complexity of the engagement, the anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated future additional assets, and negotiations with the client, etc.). Unaffiliated Wrap Programs In the event that IC Advisory is engaged to provide investment management services as part of an unaffiliated wrap-fee program, IC Advisory will be unable to negotiate commissions and/or transaction costs. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately or engaging the services of a broker-dealer. In the event that IC Advisory is engaged to provide investment management services as part of an unaffiliated managed account program, IC Advisory will likewise be unable to negotiate commissions and/or transaction costs. If the program is offered on a non-wrap basis, the program sponsor will determine the broker-dealer though which transactions must be effected, and the amount of transaction fees and/or commissions to be charged to the participant investor accounts. Commission Transactions The Investment Center, Inc. is registered as a broker-dealer and most IARs are registered representatives. Clients should review and understand the disclosure under the headings “The Investment Center, Inc.” in Item 10, and Item 12 in its entirety. IC Advisory’s relationship with The Investment Center, Inc. is material to a client’s relationship with IC Advisory. Unaffiliated Private Investment Funds IARs that are registered representatives may recommend that clients investments in unaffiliated private investment funds on a non-discretionary commission basis through The Investment Center. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation: In the event that IC Advisory references private investment funds owned by the client on any supplemental account reports prepared by IC Advisory, the value(s) for all such private investment funds shall reflect either the initial purchase and/or the most recent valuation provided by fund sponsor. If the valuation reflects the initial purchase price (and/or a value as of a pervious date), the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. IC Advisory may also provide investment advice regarding unaffiliated private investment funds. IC Advisory, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in unaffiliated private investment funds. IC Advisory’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of IC Advisory calculating its investment advisory fee. IC Advisory’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Assets Under Management U.S. Dollar Amount Total No. of Accounts Discretionary $1,733,708,933 4,981 Non-Discretionary $407,370,750 1,030 Total $2,141,079,683 6,011 As of 12/31/2024 Important Miscellaneous Information Non-Discretionary Service Limitations: Clients that determine to engage IC Advisory on a non- discretionary investment advisory basis must be willing to accept that IC Advisory cannot effect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Therefore, in the event of a market correction, and the client is unavailable, IC Advisory will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s verbal consent. Variable Investment Products: To the extent that IC Advisory renders investment advisory services relative to the recommended allocation of assets among the various mutual fund sub-classes that comprise a variable annuity product owned by the client, the custodian shall be the specific insurance company that issued the variable annuity. The investment advisory fee to be received by IC Advisory shall be in addition to the commission fee previously charged to purchase the variable investment product, including any commission that may have been paid to a representative of IC Advisory in his/her separate capacity as a registered representative of The Investment Center, Inc. Fee-based Annuities: IC Advisory makes sub-accounts allocation recommendations for various indexed, variable and structured fee-based annuities (collectively, “fee-based annuities”) on a discretionary basis for an advisory fee. The Firm maintains discretionary authority over the selection of the sub-accounts or underlying investment options, which means that IC Advisory is not obligated to consult with you to determine and obtain your approval as to which sub-accounts/investments are to be purchased or sold in your fee-based annuity. Advisory fees charged for the sub- account/investment allocation recommendations provided for the fee-based annuities are in addition to any underlying fees related to the fee-based annuity. Clients may refer to their fee-based annuity’s prospectus for a description of any underlying fees. You should be aware that certain riders purchased with the fee-based annuity may limit the investment options and the ability to reallocate to certain subaccounts. Additionally, the decision to liquidate a fee-based annuity prior to the end of its surrender charge period may result in early withdrawal charges and a complete loss of certain benefits for which fees may have previously been paid to the annuity company. 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 IC Advisory recommends that a client roll over their retirement plan assets into an account to be managed by IC Advisory, such a recommendation creates a conflict of interest if IC Advisory will earn new (or increase its current) compensation as a result of the rollover. If IC Advisory 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), IC Advisory 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 retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by IC Advisory, whether it is from an employer’s plan or an existing IRA. Account Aggregation Service Providers: In conjunction with the services provided by ByAllAccounts, Inc., eMoney Advisor, MoneyGuidePro, RightCapital, and other aggregation service providers, IC Advisory may also provide, for a separate fee, periodic comprehensive account reporting services, which can incorporate all of the client’s investment assets including those investment assets that are not part of the assets managed by IC Advisory (the “Excluded Assets”). Unless stated otherwise, IC Advisory’s service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because IC Advisory does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not IC Advisory, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or their other advisors that maintain trading authority, and not IC Advisory, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, IC Advisory shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that IC Advisory provide investment management services with respect to the Excluded Assets, the client may engage IC Advisory to do so pursuant to the terms and conditions of an advisory agreement between IC Advisory and the client. Additionally, the eMoney platform (and other financial planning tools) also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by IC Advisory. Finally, IC Advisory shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform (or other financial planning tools) without IC Advisory’s assistance or oversight. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: As indicated above, to the extent requested by the client, IC Advisory may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. IC Advisory does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, IC Advisory does not prepare estate planning documents or tax returns. To the extent requested by a client, IC Advisory may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including representatives of IC Advisory in their separate individual capacities as registered representatives The Investment Center, Inc., our affiliated SEC registered and FINRA member broker-dealer and/or as licensed insurance agents, servicing clients through IC Insurance Services, Inc. an affiliated insurance company. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from IC Advisory and/or its representatives. If the client engages any professional (i.e., attorney, accountant, 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), and not IC Advisory, shall be responsible for the quality and competency of the services provided. Conflict of Interest: The recommendation by one of IC Advisory’s representatives that a client purchase a securities or insurance commission product through one of IC Advisory’s representatives in their separate and individual capacity as a registered representative of The Investment Center, Inc. and/or as an insurance agent of IC Insurance Services, Inc., or another third-party insurance agency or insurance company, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment or insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products through such a representative. Clients are reminded that they may purchase securities and insurance products recommended by IC Advisory through other, non- affiliated broker-dealers and/or insurance agencies. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and 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 limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by IC Advisory), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. IC Advisory does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, IC Advisory shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Tradeaway Fees: Relative to its discretionary investment management services, when beneficial to the client, individual equity and/or fixed-income transactions may be effected through broker- dealers with whom IC Advisory and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker-dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “tradeaway” fee charged by the account custodian). Client Obligations: In performing its services, IC Advisory 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. The client is free to accept or reject any recommendation made by IC Advisory. Moreover, each client is advised that it remains their responsibility to promptly notify IC Advisory if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising IC Advisory’s previous recommendations and/or services, or if they wish to impose any reasonable restrictions upon IC Advisory’s management services. Cybersecurity Risk The information technology systems and networks that IC Advisory and its third-party service providers use to provide services to IC Advisory’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in IC Advisory’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and IC Advisory are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although IC Advisory has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that IC Advisory does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Consulting Services Clients can 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.