OJM is an investment adviser providing financial planning, consulting, and investment management services to individuals and their related entities, high net worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations and other business entities. Prior to engaging OJM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with OJM setting forth the terms and conditions under which OJM renders its services (collectively the “Agreement”). In addition, OJM provides advisory services to individuals and their related entities through a website based program titled the OJM Group Intelligent Portfolios (the “Program”). Clients and prospective clients of the Program are provided with a separate disclosure brochure. OJM has been in business as a registered investment adviser since October 27, 2007. The principal owners of OJM are Jason M. O’Dell, David B. Mandell, and Carole C. Foos. OJM has $721,687,543 of assets under management as of December 31, 2023, all of which are managed on a discretionary basis. As of December 31, 2023, the OJM Group Intelligent Portfolios has $1,533,013 in discretionary assets under management, which is included in the total assets listed above. This disclosure brochure describes the business of OJM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of OJM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on OJM’s behalf and is subject to OJM’s supervision or control. Financial Planning and Consulting Services OJM may provide its clients with a broad range of comprehensive financial planning and consulting services. These services seek to address education and retirement planning needs of the client. In performing its services, OJM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. OJM may recommend the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if OJM recommends its own services. The client is under no obligation to act upon any of the recommendations made by OJM under a financial planning or consulting engagement or to engage the services of any such recommended professional, including OJM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of OJM’s recommendations. Clients are advised that it remains their responsibility to promptly notify OJM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising OJM’s previous recommendations and/or services. Investment Management and Wealth Management Services Investment Management Clients can engage OJM to manage all or a portion of their assets on a discretionary basis or non- discretionary basis. OJM’s investment management service include an ongoing and continuous portfolio management and review in the delivery of initial and ongoing services. OJM may include a review of the overall aspects of a client’s current financial situation and consider both long- and short-term objectives. OJM can also tailor its services to focus only on certain portfolio components, depending upon the client’s wishes and/or the nature of the engagement. OJM welcomes the opportunity to provide individualized services. However, where investment management services or information are limited, clients must understand that comprehensive investment needs and/or objectives may not be fully considered due to the client’s direction to receive focus only on certain portfolio components, more comprehensive services, the lack of information provided by the client, and/or other client directives. Clients engaging OJM for investment management services must play an active role. OJM requires the client to participate in the formation of the investment plan, investment advice, and recommendations. Clients may call OJM at any time to inquire about or discuss their portfolio, but OJM recommends that clients initiate a meeting with OJM no less than annually. Wealth Management In addition, OJM may provide clients with wealth management services which may seek to maximize investment options and financial performance, as well as: budget analysis; cash flow and retirement issues and/or projections; financial planning recommendations; wealth protection; and other areas that may be desired, which can be tailored to suit the needs of the client. When wealth management services strictly focus on limited areas of the clients’ interest or needs, clients must recognize that their overall financial and investment needs and objectives may not be considered as a result of service constraints placed on OJM’s services. Clients requiring assistance with issues relating to matters outside of investment advisory topics should consult their personal tax adviser, legal counsel, or other professionals for expert opinions. If requested, OJM can work in conjunction with the client’s selected legal counsel or certified public accountant. OJM primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities and/or options as well as the securities components of variable annuities and variable life insurance contracts in accordance with the investment objectives of the client. OJM also may provide advice about any type of investment held in clients' portfolios. OJM also may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, OJM either directs or recommends the allocation of client assets among the various investment options that are available through that product or retirement plan. Client assets are maintained at the specific insurance company or custodian designated by the product or retirement plan. OJM tailors its advisory services to the individual needs of clients. OJM consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. OJM ensures that clients’ investments are suitable for their investment

needs, goals, objectives and risk tolerance. Clients are advised to promptly notify OJM if there are changes in their financial situation or investment objectives, or if they wish to impose any reasonable restrictions upon OJM’s management services. Retirement Plan Consulting OJM offers advisory services to 401k and other qualified retirement plans (“Plans”) for businesses, which may include, depending on the needs of the Plan client, recommending investment options for Plans to offer to participants, ongoing monitoring of a Plan’s investment options, assisting plan fiduciaries in creating and/or updating the Plan’s written investment policy statements, working with Plan service providers, and providing general investment education to Plan participants. Other Services for Employee Benefit Plans: As part of providing investment services to Plans, OJM may provide certain information and services to the Plan and the Plan sponsor/trustees. These other services are designed to assist the Plan sponsor/trustees in meeting their obligations to the Plan. Retirement Rollovers Conflict of Interest: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts 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). In the event OJM recommends that a client roll over their retirement plan assets into an account to be managed by OJM, such a recommendation creates a conflict of interest if OJM will earn an advisory fee on the rolled over assets. When acting in such capacity, OJM serves as a fiduciary under the Employee Retirement Income Security Act (ERISA). There is a conflict of interest when an OJM representative makes a recommendation that a participant roll over assets from a retirement account into a new or existing account or investment (e.g. rollover IRA) managed by OJM. The conflict of interest exists because OJM will receive compensation (e.g., management fees) if the money is rolled over, but it will not if the recommendation is not accepted. No client is under any obligation to rollover retirement plan assets to an account managed by OJM. OJM's Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Use of Independent Managers As mentioned above, OJM may recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers shall be set forth in a separate written agreement between OJM or the client and the designated Independent Managers. OJM may render services to the client relative to the discretionary selection of Independent Managers. OJM also monitors and reviews the account performance of any designated Independent Manager. OJM receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending an Independent Manager for a client, OJM reviews information about the Independent Manager such as its disclosure statement and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that OJM considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/ custodian of the client’s assets, may be exclusive of, and in addition to, OJM’s investment advisory fees detailed below in Item 5. As discussed above, the client may incur additional fees than those charged by OJM, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to OJM’s written disclosure statement, the client also receives the written disclosure statement of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than OJM. In such instances, OJM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. If OJM refers a client to an Independent Manager where OJM’s compensation is included in the advisory fee charged by such Independent Manager and the client engages the Independent Manager, OJM shall be compensated for its services by receipt of a fee to be paid directly by the Independent Manager to OJM in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended, and any corresponding state securities laws, rules, regulations, or requirements. Any such fee is paid solely from the Independent Manager’s investment management fee and does not result in any additional charge to the client.