This Disclosure document is being offered to you by Wakefield Asset Management, LLLP (“Wakefield”, “WAM” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Wakefield Asset Management, LLLP is a registered investment adviser with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940 (Advisers Act). Wakefield was founded in 2003 and is 100% employee owned. G. Todd Gervasini is the principal owner, Managing Partner, and Chief Investment Officer of Wakefield. We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that help clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and WAM execute an Investment Management Agreement. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES WAM furnishes discretionary and non-discretionary investment advisory services to individual and institutional investors. In a discretionary relationship, WAM makes investment decisions for its clients based on a highly disciplined and technologically advanced process for research, security selection, implementation, and monitoring. Investors are permitted to impose restrictions on investing in certain securities or types of securities. During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background. Based on client needs, we develop a client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. Once we have determined the types of investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment review and management services. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client financial objectives. We trade these portfolios based on the combination of our market views and client objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from clients. Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). To the extent requested by the client, WAM may recommend the services of other professionals for advice and implementation of non-investment related matters such as estate planning, tax planning, banking matters, insurance, etc. The client is under no obligation to engage the services of any recommended professional and retains absolute discretion over the selection of professionals and the implementation of products they recommend. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. NON-DISCRETIONARY CONSULTING SERVICES WAM also furnishes non-discretionary financial consulting services to individual and institutional investors. We evaluate each investor’s financial circumstances, investment objectives and investable assets and recommend investment strategies for implementation. The investor determines whether to implement such recommendations and, if implemented, which service providers

will be used. THIRD PARTY INVESTMENT & SUB-ADVISER SERVICES WAM provides portfolio specific separate account management for accounts referred by Wakefield Wealth Management, LLLP (WWM), or third-party investment advisers, brokers, and/or broker-dealers. Under these programs, participating clients (generally with the assistance from the third-party investment adviser) may select WAM to provide selected investment advisory services for their account. This may be only a portion of the client’s overall investment portfolio. These accounts are managed according to the investment strategies described in Item 8. WAM provides sub-advisory services to clients of WWM, an affiliated investment adviser. The Assets under Management reported below includes $342 million of discretionary assets and $479 million of assets under advisement attributed to this sub-advisory relationship. These assets are also reported on WWM’s Form ADV Part 2A. WRAP FEE PROGRAMS Our Firm does not sponsor a Wrap Fee Program. WAM has agreements with various financial services firms (“Program Sponsors”) to provide investment advisory services to managed accounts in programs sponsored or administered by these firms. These programs are commonly referred to as Managed Account Programs or UMA or SMA programs. Under these programs, participating clients (generally with assistance from the Program Sponsor) may select WAM to provide selected investment advisory services for their account (or a portion thereof). The services WAM provides to Managed Accounts may differ among the Managed Account Programs and may differ from the services provided to clients who do not participate in Managed Account Programs. WAM generally receives a portion of the wrap fee charged on these accounts for the services we provide. Please see further discussion of management fees under Item 5 – Fees and Compensation. For Managed Accounts, WAM is appointed to act as an investment adviser through a process administered by the Program Sponsor. WAM will generally make its representatives available for communications as reasonably requested by clients and or Program Sponsors. In the course of providing services to Managed Account Programs, WAM may reasonably rely on information or directions communicated by the Program Sponsor acting with apparent authority on behalf of its client. WAM reserves the right to decline to manage any account. Clients should review all materials related to their Managed Account Program (including the wrap fee program brochure of the Program Sponsor) including materials related to the terms, conditions, and fees. Each client should evaluate the potential advantages, disadvantages, and overall appropriateness of the program in light of the client’s particular circumstances. Clients are encouraged to consult their own financial advisers and legal and tax professionals in connection with selecting and engaging the services of an investment adviser in a particular strategy and participating in a Managed Account Program. ASSETS As of December 31, 2023 Market Value (U.S. Dollars) Discretionary Assets $342,823,141 Non-Discretionary Assets $271,802 Total Regulatory Asset Under Management $343,094,943 Assets Under Advisement $479,031,250 Total Assets Managed $822,126,193 “Discretionary Assets” are those accounts where the client has granted WAM authority, without any further approval except as otherwise required by law, (a) to make all investment decisions for the account; (b) to buy, sell and otherwise deal with the assets of the account; and (c) in furtherance of the foregoing, to do anything which WAM deems requisite, appropriate or advisable, including, without limitation, the submission of instructions to the custodian, if any, of the account. “Non-Discretionary Assets” are those accounts where the client retains authority for approving the final investment decisions. WAM provides advice to clients regarding these accounts but does not make independent investment decisions. “Assets Under Advisement” (AUA) include assets in Managed Account Programs where WAM provides model investment portfolios. The program sponsor retains final discretion to implement the model strategy and performs all trading and account administration. Also included in AUA are assets in qualified plans (retirement plans) where WAM provides continuous and regular advice to the trustees of the plans regarding the selection of their vendors including the selection of investment options available under the plan.