KAM is owned by KraftCPAs, PLLC (hereinafter KraftCPAs). KAM has been providing advisory services since 2002. As of October 31, 2022, KAM managed $424,166,283 on a discretionary basis and $0 on a non- discretionary basis. As of October 31, 2022, KAM had a total of $20,391,842 of additional Assets Under Advisement. InvestmentManagementServices KAM will work with the client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement (IPS). KAM uses investment and portfolio allocation software to evaluate alternative portfolio designs. KAM evaluates the client's existing investments with respect to the IPS. KAM works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by KAM. KAM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular review meetings with the client regarding the client’s portfolio, as necessary. In summary, KAM's investment management services include the following: A. analyzing a client's financial condition; B. recommending options to achieve the client's financial objectives; C. arranging for the implementation of the approved investment strategies; and D. monitoring the performance of the client's investments. KAM will typically create a portfolio of no-load mutual funds and may use model portfolios if the models match the client's investment policy. KAM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. Client portfolios may also include some individual equity securities. KAM typically manages mutual fund and equity portfolios on a discretionary basis. Clients may impose any reasonable restrictions on KAM’s discretionary authority, including restrictions on the types of securities in which KAM may invest client’s assets and on specific securities that the client may believe to be appropriate. KAM may also recommend fixed income portfolios to advisory clients, which consist of managed accounts of individual bonds. KAM will request discretionary authority from advisory clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. Pursuant to its discretionary authority, KAM will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s IPS. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain KAM’s consent prior to the sale of any client securities. In certain circumstances, KAM will also pursue other investment strategies on behalf of clients. KAM may engage an independent third-party money manager or sub-advisor (collectively, “TPMMs”) to manage your account on a discretionary basis. The TPMMs we select for management of your account will be SEC or state registered investment advisors. You will be provided with a copy of the selected TPMM’s disclosure brochure (Form ADV Part 2A, Form CRS, or the equivalent) at or prior to the time they begin to direct your investment portfolio. Where your assets are allocated to a TPMM, we will act as a “co-advisor,” responsible for the determining the suitability of the selected TPMM’s investment program(s), advising the TPMM(s) of any changes in your investment profile and suitability information, and monitoring the performance of the investments managed by the selected TPMM(s). The TPMM shall be responsible for all trading and portfolio management functions under this arrangement, including monitoring the securities for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that cost basis information is provided). In most TPMM arrangements, clients are not required to enter into a separate investment management agreement with the selected TPMM(s). Clients may be required to execute a limited power of attorney granting such TPMMs the discretionary authority to invest and manage the sub-advised portion of the client’s account at the client’s custodian(s). The TPMM may also request authority to directly debit fees from the client’s account(s). Such fees are separate, distinct, and in addition to KAM’s advisory fees. We will engage and terminate TPMMs and/or reallocate your assets among TPMMs when we believe such termination(s) and/or reallocation(s) are in your best interests. On an ongoing basis, KAM will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. KAM will periodically, and at least annually, review client’s investment policy statement, risk profile and consider the re-balancing of each client’s accounts to the extent appropriate. KAM will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to

provide sub-advisory services. In addition to managing the client’s investment portfolio, KAM may consult with clients on various financial areas including income and estate tax planning, college financing planning, retirement planning, asset protection, insurance analysis, personal cash flow analysis, charitable gifting, and establishment of retirement plans, among other things. These wealth management consultations are provided to clients when the consultations are mutually agreed upon by KAM and the client. These services are offered as an extra benefit to those clients. Additionally, KAM manages Health Savings Accounts (HSAs) on behalf of clients. Based on the client’s investment objective, KAM will affect trades in the client’s HSA account directly with the health savings custodian. FinancialPlanningServices KAM also provides advice in the form of Financial Planning. Clients purchasing this service will typically receive a written financial report, providing the client with a detailed financial report designed to achieve their stated financial goals and objectives. The types of reports provided to client will vary upon the services requested by the client. In general, the financial plan will address any or all of the following areas of concern:  Personal: Family records, budgeting, personal liability, estate information and financial goals.  Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. KAM may illustrate the impact of various investments on a client’s current income tax and future tax liability.  Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.  Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.  Investments: Analysis of investment alternatives and their effect on a client’s portfolio. KAM gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, KAM suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion. NextGenerationFinancialPlanningServices KAM also offers financial planning as a subscription service which will include the following:  Onboarding process to gather information about a client’s current financial situation, discover values and goals and collect relevant data to develop a financial plan.  Establish an account on the financial planning software, MoneyGuideElite® software to provide customized and goal-oriented financial plans.  Develop a financial plan incorporating the investment planning, retirement planning, estate planning, education planning, risk management, cash flow management, income tax planning and insurance planning.  Conduct an in-person meeting to discuss the customized financial plan, establish connections with estate attorneys, accounting professionals and insurance agents (if needed) and provide training on use of MoneyGuideElite®. After creation of the initial financial plan, three video conferences per year, and one annual, in-person plan check-up meeting. EmployeeBenefitRetirementPlanServices KAM also provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. KAM will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. KAM will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. KAM will recommend changes in the plan's investment vehicles as may be appropriate from time to time. KAM generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, KAM works in coordination and support with Buckingham Retirement Solutions. Retirement plan clients will engage both KAM and Buckingham Retirement Solutions. Buckingham Retirement Solutions will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. KAM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.