Firm Description ClientFirst is an investment adviser providing investment advisory services to individuals and high net worth individuals. ClientFirst was founded in 2002. Principal Owners ClientFirst is owned by its sole employee, Edward P. Mahaffy, President, Senior Portfolio Manager and Chief Compliance Officer. Types of Advisory Services ClientFirst offers the following types of advisory services: Financial planning services and portfolio management for individuals and/or small business. Investment Advisory Services ClientFirst provides fee-only investment advisory services, providing ongoing investment advice and monitoring of securities holdings based on the individual needs of the client. ClientFirst develops portfolios based upon a client’s goals, objectives, investment time horizon and risk tolerance, as well as their core financial-related values. ClientFirst uses asset allocation or spreading investments among a number of asset classes and sectors (corporate bonds vs. government securities) for most client portfolios. ClientFirst will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Client portfolios include, but are not limited to, mutual funds, ETF’s and Fixed Income securities. The mutual funds, if selected, will be selected on the basis of any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; management style and philosophy; and fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. Financial planning may be offered as a component of the overall investment advisory services and may include a review a client’s current financial situation. A review may include the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. ClientFirst generally does not charge a separate fee for financial planning services. Tailored Relationships ClientFirst tailor’s investment advisory services to the individual needs of the client. The goals and objectives for each client are documented in our client relationship management system. Client Questionnaires are created that reflect the stated goals and objectives. ClientFirst clients are allowed to impose restrictions on the investments in their account. ClientFirst

may accept any reasonable limitation or restriction to discretionary authority on the account placed by the client. All limitations and restrictions placed on accounts must be presented to ClientFirst in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs ClientFirst does not participate in a Wrap Fee Program. Client Assets As of January 23, 2024, ClientFirst manages $221,586,588 in assets all on a discretionary basis.