BSP has been providing services since 1997 (formally under the BAM Advisor Services and the Loring Ward name). As of March 31, 2024, BSP had $12.03 billion of discretionary regulatory assets under management and $15.19 billion of non-discretionary regulatory assets under management. In addition, BSP provides administrative, back-office and retirement plan services to $14.36 billion of assets managed or advised by the independent firms that hire BSP for its services. In the aggregate, the total number of assets under management or administration was $41.58 billion. Focus Financial Partners BSP is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, BSP is a wholly- owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because BSP is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of BSP. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Overview BSP primarily provides turnkey asset management services to independent registered investment advisors (investment advisors). BSP's services will include, but are not limited to, coordinating with custodians, client billing services and account reconciliation, providing access to certain investment options, various portfolio management tools and other administration and support to investment advisors throughout the country. The services may be performed internally or through affiliated and non-affiliated third parties. In exercising some of these services, BSP may be granted discretion over certain client accounts. The details of that discretionary authority is determined by the client on a client by client basis at the time of an account opening. BSP also provides fixed income sub-advisory services to investment advisors and their clients if requested. BSP provides fixed income investment allocation recommendations and management services to the registered investment advisors for their clients. Through the investment advisor’s investment advisory agreements with their clients, BSP is granted the discretionary authority to select fixed income securities for clients based on the asset allocation provided by the investment advisor and client. Additionally, BSP provides retirement plan services to participant-directed pension and profit-sharing plans. Investors receive this ADV based upon their decision to engage their independent registered investment advisor to manage a portfolio consisting of fixed income securities and their advisor's decision to use BSP as a fixed income sub-advisor, exercising limited investment discretion over the investor's account for fixed income management or as a result of BSP providing 3(38) services for a retirement plan. Investment advisors receive this ADV based upon their or their advisor’s decision to contract with BSP for turnkey asset management and fixed income sub-advisory services for their firms. For advisory services where we are acting as a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. Turnkey Asset Management Services BSP assists independent registered investment advisors who provide portfolio management and employee benefit retirement services to investors. BSP educates investment advisors on the principles and tenets of Modern Portfolio Theory (MPT) as a methodology for structuring investment portfolios with long-term investment goals. BSP also provides investment advisors with model investment portfolios that demonstrate the historical risk and return results of multiple asset class allocations to investors and that investment advisors may use as starting points to manage investment accounts. On an ongoing basis, BSP will recommend to investment advisors investments, including the allocations to various asset classes, for the investment advisor's consideration based on its market research. BSP's advisory services are designed to educate investment advisors on how to offer long-term investment solutions through appropriate asset allocations. BSP primarily recommends that investment advisors use passively managed and/or evidence-based mutual funds and exchange traded funds (ETFs). BSP will also provide advice to investment advisors regarding various other securities, including, but not limited to, equity securities (stocks), certain alternative investment securities, corporate debt securities, certificates of deposit, variable investment company products and municipal/government bonds. In conjunction with BSP’s advisory services, BSP provides comprehensive support to investment advisors, which includes, but is not limited to: a. Acting as operational liaison between advisors and approved custodians; b. Providing a billing platform for advisors with the ultimate responsibility for fee schedules set by the advisors; c. Providing portfolio management and trading as requested by advisors; d. Performing reconciliation and maintenance of certain client account data; e. Providing access to certain investment options and research; f. Providing access to various portfolio management tools and performance reports; and g. Undertaking other administrative actions, agreed to by all parties, necessary to provide requested support to advisors. BSP Retirement Solutions Services BSP has identified certain retirement plan service providers (RPSPs), whose services include recordkeeping, third party administration, custody, plan installation or conversion and investment open architecture with the ability to handle asset allocation models. Plan representatives establish a relationship with their chosen providers. BSP has and will continue to work with RPSPs to offer a package of services that meets an advisor’s needs for qualified retirement plans. BSP will, on an ongoing basis, provide training to investment advisors on using the preferred RPSPs' services, act as the liaison between the investment advisor and RPSPs if needed, facilitate billing when appropriate and provide periodic accounting of assets under advisement in retirement plans set up with RPSPs via the BSP 401k website. BSP provides 3(38) investment management and advisory consulting services to participant-directed defined contribution plans and Cash Balance Plans. BSP constructs and maintains model portfolios for retirement plan participants as a fiduciary to these plans. BSP coordinates these services with other independent investment advisors to which BSP may provide the back-office services described above. However, not being a back- office client of BSP does not preclude a plan from using the BSP Retirement Solutions platform. Defined contribution plan participants can select from the model portfolios, Target Date Funds or construct their own customized portfolio from the funds made available within the plan. BSP will have discretion over the funds to be made available in the plan at any given time. The independent advisors with which BSP coordinates clients’ services will discuss plan investments and fiduciary obligations with the plan sponsor or trustee as a part of this multi-party service. The model portfolios generally include multiple asset categories of mutual funds managed by fund companies. BSP shall select, monitor and change funds or allocations in the model portfolios from time to time as determined by BSP in its discretion. As a best practice, from time to time, BSP directs the recordkeeper to rebalance the models or make changes to them to the extent necessary to comply with the current allocation of BSP’s model portfolios. BSP’s fee for BSP Retirement Solutions does not include any brokerage commissions, custodial, administrative or recordkeeping fees, or other expenses incurred by the plan and/or plan participants. BSP’s fee is also separate and distinct from any fees charged by other investment advisors. BSP is authorized in its agreement with the plan to deduct the fee directly from the plan’s custodial account. BSP Retirement Solutions is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients. BSP Retirement Solutions is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with

respect to investment management services and investment advice provided to ERISA plans. As such, BSP is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”). Sub-Advisory Services BSP may be engaged by investment advisors to act as a sub-advisor for accounts of investment advisor’s clients. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by independent advisors. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but is not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC, iShares, Cliffwater, LLC, BlackRock, Inc. or other providers selected by BSP. Each Portfolio is designed to meet a particular investment goal which the independent investment advisor has determined is suitable to their client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP, if granted, will have the discretionary authority to manage the Portfolio(s), including rebalancing. However, the investment advisor, on behalf of their advisory client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact their independent investment advisor to determine if changes to an account and the allocation of the assets held in the account are necessary. Fixed Income Only Sub-Advisory Services BSP can provide additional specific fixed income sub-advisory services related to fixed income accounts of investment advisor’s clients. If the investment advisor and client agree to include an allocation of fixed income securities, the investment advisor may retain BSP as a fixed-income sub-advisor to their client's account subject to certain account minimums. If the investment advisor and client agree to allocate assets to a fixed income portfolio, the client must grant the investment advisor with discretionary authority to retain BSP as a sub-advisor of such portfolio and grant BSP discretionary authority to manage such portfolio. Upon purchasing of fixed income securities for a client’s account, BSP will provide periodic monitoring of the client’s fixed income investments for any material changes including structure or credit quality. If material changes arise that BSP believes necessitate the selling of securities, BSP will undertake such sale and replacement, if necessary, in accordance with previously agreed to procedures with advisor and/or client spelled out in separate agreements. Additionally, BSP may perform tax loss harvesting as BSP deems appropriate, but only for securities purchased by BSP or for which BSP is provided cost basis and trade date. SA Fund Management BSP is the investment manager, administrator, and shareholder servicing agent of the SA Funds – Investment Trust (“SA Funds”). For further information about the SA Funds, refer to the applicable prospectus at https://buckinghamstrategicpartners.com/sa-funds/documents/. BSP defines the investment objectives of the individual SA Funds, administers the SA Funds, monitors the Sub-Adviser and other service providers to the SA Funds, and is responsible for the servicing of the SA Funds’ shareholders. For its services to the SA Funds, BSP receives management, administration, and shareholder servicing fees from each of the SA Funds (with the exception of the SA Worldwide Moderate Growth Fund) as described in the SA Funds’ prospectuses. All of the officers of the SA Funds are employees or officers of BSP. They do not receive compensation from the SA Funds for this service. BSP is compensated directly from the SA Funds, as described in the SA Funds’ prospectus. BSP does not emphasize one SA Fund over another except as part of an overall portfolio or asset-class allocation strategy. BSP has contracted with Dimensional Fund Advisors LP (“DFA”), an unaffiliated registered investment adviser, to buy and sell securities that fulfill the asset-class investment components of the SA Funds (with the exception of the SA Worldwide Moderate Growth Fund, which is serviced by BSP). DFA uses a committee of investment professionals to manage the assets of these Funds. BSP relies on DFA as the SA Funds’ sub-adviser to obtain best execution for all trading performed on behalf of the SA Funds. BSP may contract with other mutual fund sub-advisers when additional funds are added to the Trust or should BSP determine that the continued use of DFA is not advantageous to the SA Funds or its shareholders. BSP and the Trust have obtained exemptive relief to change sub-advisers for any SA Fund by a vote of the Board of Trustees of the Trust. It may also retain others to perform accounting, administration, and shareholder services. BSP generally pays some or all custodial transaction charges for clients of investment advisors utilizing the SA Funds, subject to certain restrictions and thresholds, as part of its “No Transaction Fee” solution. Strategic and Other Services The Strategic Service program consists of mutual fund and ETF model portfolio construction and strategic advice provided exclusively to investment advisors for implementation to their clients. Mutual fund model portfolios (“Model Portfolios”), are generally constructed utilizing either the DFA Funds, SA Funds, Vanguard Funds or other similar type funds, and services may include the periodic rebalancing of Model Portfolios. ETF model portfolios are generally constructed using DFA ETFs, Vanguard ETFs, Blackrock or other similar ETFs. From time to time, BSP acts as a research provider to other registered investment advisors. BSP makes available to investment advisors and their clients the option of obtaining certain credit and cash management financial solutions from unaffiliated third-party financial institutions with the assistance of BSP’s affiliate, UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. Although the revenue paid to UPTIQ benefits UPTIQ Inc.’s investors, including Focus, our parent company, no Focus affiliate will receive any compensation from UPTIQ or Flourish that is attributable to our clients’ transactions. Investment advisors and their clients who use UPTIQ’s services will receive product-specific disclosure from the unaffiliated third-party financial institutions and other unaffiliated third-party intermediaries that provide such services. BSP makes available to investment advisors and their clients the option of obtaining certain insurance solutions from unaffiliated, third-party insurance brokers (the “Brokers”) with the assistance of BSP’s affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of BSP’s parent company, Focus Financial Partners, LLC. If FRS refers one of these investment advisors’ clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions paid to the Broker by the insurance carrier with which the policy was placed. Investment advisors and their clients who use FRS’s services will receive product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries that provide such services. For certain clients, BSP provides an additional service for client held-away accounts that are maintained at independent third-party custodians where BSP utilizes order management system to implement asset allocation or rebalancing strategies on behalf of the client for those held-away accounts. These are primarily 401(k) accounts, 529 plans and other assets BSP does not directly manage and is maintained by the client. BSP regularly reviews the current holdings and available investment options in these held-away accounts, monitors the held-away accounts, rebalances and implements the client’s investment strategies as necessary. The order management system that we use for held-away accounts is provided by Pontera Solutions, Inc. No Legal or Public Accounting Advice While associates of BSP and affiliated companies may be licensed attorneys or certified public accountants and certain associates of affiliated companies engage in outside public accounting activities, neither affiliated companies or BSP is a law firm or a public accounting firm and does not provide any legal or public accounting advice. Clients should seek the counsel of a qualified certified public accountant and/or attorney when necessary.