Cornell Pochily is a registered investment advisory firm founded by principals Ezra Cornell and Robert Pochily in January 2008 to more efficiently address the investment needs of their clients. The Firm is principally owned by Ezra Cornell, Nelson B. Mead, and Shane P. O’Neill. Cornell Pochily provides financial planning, consulting, investment management services and tax preparation services. Prior to engaging Cornell Pochily to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Cornell Pochily setting forth the terms and conditions under which Cornell Pochily renders its services (collectively the “Agreement”). As of December 31, 2023, Cornell Pochily had $492,150,125 in regulatory assets under management, all of which were managed on a discretionary basis. Cornell Pochily had an additional $142,149,232 which the Firm considered “assets under advisement,” for which it provided more limited non-discretionary consulting services. This disclosure brochure describes the business of Cornell Pochily. Certain sections will also describe the activities of the Firm and its personnel who are all subject to Cornell Pochily’s supervision or control. Financial Planning and Consulting Services Cornell Pochily provides clients with a broad range of comprehensive financial planning and consulting services (which may include non-investment related matters). These services generally include investment and asset allocation planning, retirement planning, personal budget planning, long-term financial planning, basic estate planning and tax preparation. In addition, Cornell Pochily provides consulting services to individual participants in self-directed pension and profit sharing plans as well as other clients who do not want the regular supervision and management provided in an investment management relationship described below. When the Firm agrees to provide financial planning services for a client(s), the scope of the engagement, and any limitations, the period during which the services will be provided and the client’s responsibilities will be reviewed and set forth in the Agreement. Unless specifically included in the Agreement, implementing, monitoring and updating the financial planning recommendations are excluded from the scope of the engagement. In performing its services, Cornell Pochily is not required to verify any information received from the client or from the client’s other professionals (i.e., attorney, accountant, etc.) and is expressly authorized to rely on such information. Cornell Pochily will recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Cornell Pochily recommends its own services.

The client is under no obligation to act upon any of the recommendations made by Cornell Pochily under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Cornell Pochily itself. The client retains absolute Page 5 © MarketCounsel 2024 discretion over all such implementation decisions and is free to accept or reject any of Cornell Pochily’s recommendations. Clients are advised that it remains their responsibility to promptly notify Cornell Pochily if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Cornell Pochily’s previous recommendations and/or services. Investment Management Services Clients can engage Cornell Pochily to manage all or a portion of their assets on a discretionary or non- discretionary basis. When managing on a discretionary basis, Cornell Pochily primarily allocates clients’ investment management assets among mutual funds, exchange-traded funds (“ETFs”), and/or individual debt and equity securities in accordance with the investment objectives and risk tolerance of the client. While the Firm generally does not invest client assets in initial public offerings (“IPOs”) of equity, it may invest in such offerings upon a client’s request. The Firm may also provide advice about any type of investment held in clients' portfolios as required based on a client’s needs. Clients may choose to hold positions that are excluded from management or are not continuously monitored or otherwise advised upon by the Firm. Cornell Pochily also renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, Cornell Pochily either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Cornell Pochily tailors its advisory services to the individual needs of clients. Cornell Pochily 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. Cornell Pochily strives to ensure that clients’ investments are appropriate for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify Cornell Pochily if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Cornell Pochily’s management services. Page 6 © MarketCounsel 2024