Founded in 2002 with contributing business originating in 2000, CTB Financial Services, ltd. (“CTB Financial”) is a federally-registered advisory firm offering full-service portfolio investment services, cross-disciplinary planning and coordination of allied professionals directly to investing clients. Asset Management CTB Financial manages each client’s portfolio in light of the client’s stated goals. Clients may specify preferences and restrictions upon establishing an advisory relationship and at any time thereafter. Clients who establish accounts with CTB Financial must agree that the risks of such accounts are borne solely by the client. CTB Financial generally will recommend and rebalance accounts when its regular portfolio monitoring reveals opportunities to rebalance. These rebalancing opportunities are defined by degrees of “out-of-balance-ness” measured against “tolerance bands,” which are set at the asset class level of each portfolio. Tolerance bands are set depending on the type and size of each asset class, as well as up versus down variances. But in general, tolerance bands are set at around a 5%-7% variance of each asset class allocation target. Once a rebalancing opportunity is identified, CTB Financial makes the appropriate trades to bring the portfolio back into balance. CTB Financial carries out the rebalancing only after all other relevant objectives are considered and factored in, including the potential tax impacts of such trading actions, as well as the trading costs imposed by the custodian. As further discussed in Item 16 below, CTB Financial’s clients authorize CTB Financial to carry out rebalancing in their accounts on a discretionary basis within certain target allocation bands,

without obtaining specific client consent for each transaction, unless otherwise instructed. CTB Financial invites clients to meet, at least annually, to review their goals, financial planning needs, portfolio and investment results, as well as any changes in the client’s financial situation, investment objectives, and the ongoing suitability of their asset allocation. Strategic Services and Planning. Some clients engage CTB Financial to act as a “Personal Chief Financial Officer,” or “Personal CFO,” to coordinate a team of cross- disciplinary financial professionals, which may include a CPA, an estate attorney, mortgage experts, and insurance specialists of various types, as identified by the client. These strategic services aim to assist clients in developing and implementing a fully integrated and synergistic financial plan that takes personal financial objectives into account. In addition, CTB Financial engages in a wide variety of planning services for its clients, including financial advice not pertaining to investments only. Financial planning may include income tax planning, financial goal planning (retirement, college, etc.), estate planning, insurance planning, business planning, and charitable giving, as well as assistance with planning for large purchases. This list is not exhaustive. CTB Financial does not provide legal advice. CTB Financial Services, ltd. is a Minnesota corporation based in Minneapolis, Minnesota. CTB Financial has two principal shareholders: Jonathan Liang holds a majority interest and O. Charles Brown maintains a minority interest. As of December 31, 2022, CTB Financial managed total assets of $$218,319,178 on a discretionary basis for its clients. 4