Advisory Business and Ownership Freedom Investment Management, Inc (“Freedom”) is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser. Freedom provides a full suite of institutional and retail programs and services, ranging from investment portfolios to a state-of-the-art turnkey asset management platform (TAMP) for advisory firms and their associated financial advisors to ERISA retirement plan investment management services. As of December 31, 2023, Freedom managed approximately $2.1 billion in discretionary regulatory assets under management and provided advisory services to approximately $172 million in participant-directed defined contribution plans, third-party platforms, and consulting arrangements. Types of Services Offered Freedom provides discretionary investment advisory services to separately managed accounts and pooled investment vehicles and through sub-advisory relationships. Freedom provides non-discretionary investment advisory services to registered investment advisers, corporations, institutions, individuals and other legal entities. Freedom also offers administrative services to other financial intermediaries. This suite of services is branded as the “Freedom Advisors platform.” The services include, but are not limited to, custodial account set up, asset transfer, account administration, Client and advisor reporting, trading for Freedom-managed strategies as well as those provided by sub-advisers and model providers, customer billing and payment, Client and advisor online portal administration, consulting, marketing support, and other back and middle office services. Investment advisory services include advice with respect to a broad range of U.S. and non-U.S. securities, no- load mutual funds and/or exchange traded funds or exchange traded notes (herein after collectively, "ETFs"), certificates of deposits, bonds, interval funds, group annuity accounts providing a stable value solution to IRA owners and other assets, as discussed below, as well as model portfolios which are based on the Client’s investment objectives. Freedom will allocate the Client's assets among various investments taking into consideration the overall management style selected by the Client. Freedom manages portfolios designed by its investment team and also manages portfolios designed by the investment teams within other model-providers or sub-advisers contracted to provide those model portfolios. Freedom offers its services directly to institutions and through registered financial service intermediaries. These services are also offered on a sub-advisory or model-provider basis on the Freedom Advisors platform, as well as on SMArtX Advisory Solutions, LPL, Morgan Stanley and the Envestnet™ platform and several intermediary- specific managed account platforms. Additionally, Freedom offers its portfolio modeling and other services to retirement plan sponsors through several custodians and on several retirement plan platforms including, but not limited to, Vestwell, Empower, Ascensus, MidAtlantic Trust’s ModelxChange, Professional Capital Services (PCS), and others. INVESTMENT MANAGEMENT SERVICES Discretionary investment advisory services are provided to Clients in accordance with the terms and restrictions of such Client’s investment management agreement, investment plan, partnership agreement, and agreements and documents governing investment products in which Clients are invested (collectively, the “Governing Documents”). These investment advisory services include advice with respect to a broad range of U.S. and non- U.S. securities and instruments and other assets, as discussed below, as well as model portfolios which are based on the Client’s investment objectives. With respect to non-discretionary accounts, Freedom provides model portfolios to registered investment advisers and other entities which are not customized to the circumstances of the end Client. This also includes Freedom’s due diligence and advisory services covering specialty investments such as interval funds and stable value contracts. Institutional Investment Advisory Business We offer our services directly to defined benefit, municipal, Taft Hartley, and other retirement plan Clients in both a full-service investment advisory capacity and as an investment-only offering. The investment strategies employed to fill the needs of these institutional investors are typically designed specifically for each institution and may or may not employ Freedom’s model-based investment implementation methodology. Freedom will meet with institutional Clients on a periodic basis, as requested, and will also meet with Client’s consultant or advisor if they utilize one. Freedom also provides discretionary investment management services to institutional investors through a collective investment trust for ERISA and non-ERISA qualified retirement plans. Advisory Services through Promoters and Referral Arrangements Investment advisory firms that introduce Clients to Freedom in return for a portion of the fee charged by Freedom under a Promoter agreement are referred to as “Promoters.” Financial advisors associated with Promoters are independent contractors and are not employees of Freedom. The introductory services provided by the Promoters will include, but are not limited to, assisting the Client or prospective Client in understanding the services provided by Freedom, assisting the Client in understanding the investment management strategies offered by Freedom or a sub-adviser or model provider, assisting the Client in determining the custodian that will be used for a particular account, assisting the Client in the suitability assessment process by helping prepare an Investment Plan, assisting the Client in the completion of all new account paperwork, introducing the Client to Freedom, maintaining ongoing contact with the Client so as to maintain current information regarding the Client's financial situation and investment objectives, conveying any changes in the Client’s information, financial status, and/or financial objectives to Freedom, communicating any concerns of the Client to Freedom, and serving as the Client’s primary liaison with Freedom. The Financial Advisor must consult the Clients at least annually to confirm the appropriateness of the Investment Plan. The Financial Advisor is responsible for communicating to Freedom any changes to the Client’s situation, profile, or Investment Plan. Under a referral agreement, Freedom will engage third parties to serve as co-adviser, marketing agent, promoter, or referral source for the purpose of introducing and referring prospective Clients to Freedom for investment advisory services. Upon signing an investment management agreement, Freedom will provide promoter/referral Clients ongoing discretionary investment management services. Freedom will periodically revise the utilized investment products, adjust the strategic asset allocation, and/or rebalance the investment portfolio as deemed appropriate, within the parameters of the Client’s Investment Plan and in accordance with any restrictions specified by the Client. Freedom will respond to inquiries directly from each Client; however, in most circumstances the promoting/referring advisory firms will be the primary liaison between the Client and Freedom. Advisory Services Available Through a Separate Account Management Arrangement: Freedom also acts as a Separate Account Manager on the Managed Account Marketplace Program sponsored by Charles Schwab & Company, Inc. (“Schwab MAM”) Under this arrangement, the Client is a Client of both the introducing advisory firm and Freedom under a “Dual Contract” arrangement. Freedom provides the introducing advisory firm sufficient information and documentation to evaluate Freedom's services and recommend a particular strategy to the Client. When Freedom is contracted for management by the Client/introducing advisory firm, Freedom manages the account based on the terms of the contract and direction from the introducing advisory firm. Freedom only bills the Client account for Freedom’s investment management fee and does not share any of its fees with the introducing advisory firm. Advisory Services Available Through a Direct Arrangement: Freedom will take on Clients through a direct arrangement where the Client contracts with Freedom directly (“Direct Arrangement”). Freedom also has a small group of Investment Adviser Representatives (“IARs”) who exclusively use the investment management and administrative services of Freedom and the sub-advisers and model managers available through Freedom Advisers. Direct Clients and Clients of Freedom through these IARs are provided with the same portfolio models and services as Clients introduced under the separate account management arrangements. In certain circumstances, IARs associated with Freedom directly have their own legal business entities with trade names and logos used for marketing purposes which may appear on marketing materials or Client statements. The Client should understand that the businesses are legal entities of the IARs and not of Freedom. The IARs are under the supervision of Freedom, and the advisory services of the IARs are provided through Freedom. The above arrangements are part of Freedom's retail investment management business. Under the Promoter, Referral and Direct arrangements, the Client works with the soliciting/referring advisory firm or Freedom IAR to determine which portfolio or portfolio(s) is/are appropriate for their particular investment account. Based upon information supplied by the prospective Client, the Promoter, referring advisory firm, or IAR will produce an Investment Plan using tools provided by Freedom, typically through an online application. The Investment Plan will assist in defining the criteria and in outlining the appropriate investment guidelines upon which Freedom will base investment account or model portfolio recommendations. Additionally, Freedom will construct an asset allocation and make specific investment recommendations or use a portfolio model provided by a sub-adviser or model-provider, if selected, that we seek to align with the Client's Investment Plan. Under the Co-Adviser arrangement, the introducing advisory firm selects the appropriate Freedom model based on its knowledge of the Client's objectives and risk tolerances. The introducing advisory firm, as a fiduciary working on the Client's behalf, is authorized to instruct Freedom to change models on behalf of the Client. For retail investment management Client accounts, Freedom will seek to ensure that the following conditions are met and maintained: 1. Freedom will manage each Client's account on the basis of the parameters defined in the Investment Plan and any reasonable investment restrictions the Client may impose; 2. For Direct Clients, Freedom will obtain sufficient Client information to be able to provide individualized investment advice to the Client. For Schwab Managed Account Marketplace (“MAM”) and Morgan Stanley, Freedom will manage to the objectives specified by the Client's Investment Advisor. At least annually, Freedom, the Client's Promoter or the Client's IAR will contact the Client to determine whether there have been any changes in the Client's financial situation or investment objectives and whether the Client wishes to impose investment restrictions or modify existing restrictions. For Direct and introduced Clients, Freedom will request on a quarterly basis that Clients notify them in writing if there have been material changes in the Client's financial situation or investment objectives and/or if the Client wishes to impose investment restrictions or modify existing restrictions; 3. Each Client is able to impose reasonable investment restrictions on the management of their account (See disclosure

in Item 12 pertaining to the trading of accounts with restrictions); 4. Each Client will receive custodial statements, at least quarterly, with a description of all account activity. Client retains control and all rights of beneficial ownership of account assets including, but not limited to, voting power, if desired, and other rights typically granted to the owner of securities. Platform Advisory Services (Sub-Advisory Services): Freedom offers its investment strategy and portfolio modeling services through other investment advisory firms on a sub-advisory or model-provider basis. In these cases, the Client contracts with the other advisory firm for investment management services and uses Freedom's investment models, asset allocation strategies and buy/sell signals to manage the Client accounts. As a sub- advisor or model-provider, Freedom's role is limited to providing proprietary investment strategies, training on those strategies, any updates to the strategies and marketing support to promote the use of the strategies by advisory firms using the investment managers suite of services. Such investment managers and service providers include Envestnet Asset Management, Inc. (“Envestnet”), LPL, SMArtX, and others. Additionally, Envestnet can offer Freedom’s strategies to other investment advisory firms. Freedom retains the right to approve or decline being included on any additional platforms through Envestnet. Group Trust Advisory Services (Sub-Advisory Services): Reliance Trust Company (“Reliance Trust”) has selected and retained Freedom to provide investment advisory services with respect to Series Four of the Group Trust designated as the “Reliance Trust Company Advisors Portfolios Programs Collective Investment Trust” (herein referred to as the “Collective Trust”) to be offered exclusively to plan sponsors of tax-qualified employee retirement plans held in employee benefit trust and agency accounts by Reliance Trust. Freedom monitors and makes recommendations regarding the purchase and sales of securities within the 3D Global Portfolios Fund account managed by Reliance Trust. The Collective Trust is designed primarily for defined contribution plans, including 401(k), money purchase and traditional profit-sharing plans. Acting as a non-discretionary sub-adviser, Freedom periodically makes recommendations for investment changes in the portfolios when such changes are deemed advisable. Freedom proposes such specific investment recommendations to Reliance Trust; however, Reliance Trust makes the final decision as to the specific securities, funds or assets and mix that will comprise the Collective Trust. Clients should refer to the Collective Trust’s Offering Statement for further details and the terms of this investment product. Full Service Retirement Plan Services: Freedom offers investment advisory services to defined contribution (“DC”) retirement plan sponsors directly and through other investment advisory firms. Freedom provides two types of advisory services to DC plan sponsors as outlined below. ERISA Section 3(38) Investment Management Services: For Promoter Introduced Plans: For DC Plans introduced to Freedom by Promoters, Freedom coordinates the efforts of a record keeper, custodian and third-party administrator, if needed, (collectively “Service Providers”) and helps the Promoter introduce the various parties and roles to the plan sponsor Client. Freedom acts as an ERISA Section 3(38) fiduciary and selects the investment options for the plan, produces an IPS for the plan and assists the Service Providers with coordinating a plan conversion. On an ongoing basis, Freedom manages the risk- based or target-date model portfolios within the plan and monitors the additional investment options (“Stand- alone”) selected for inclusion within the plan. The monitoring of the Stand-alone investments is managed in part through the use of the Fiduciary Investment Reporting Manager (FiRM) system which uses an investment screening and evaluation process developed especially for fiduciary retirement plan investors. The fee charged to the plan, or directly to the plan sponsor if requested, is typically billed quarterly, in arrears and is based on total assets within the plan. Part of the fee is paid to the Promoter based on the details specified in the Promoter Disclosure document approved and signed by the plan sponsor. For Adviser Introduced Plans: The same suite of services is provided to the plan sponsor as described in the preceding paragraph except that Freedom does not share its fee with the introducing advisory firm. Under this scenario, the introducing advisory firm bills the plan or plan sponsor directly and typically acts as an ERISA Section 3(21) fiduciary. A sub-set of adviser-introduced plans are plans introduced by advisors associated with Cambridge Investment Research Advisors, Inc. (“CIR”) and administered by Cambridge Retirement Plan Services (“RPS”). Freedom will act as 3(38) fiduciary on these plans, if contracted by the plan sponsor; however, Freedom’s model portfolios will be managed by CIR with Freedom acting as sub-adviser to CIR. Fiduciary Investment Management for Open Architecture Tax Exempt Employers Freedom has been engaged by National Life Group (“NLG”) to provide fiduciary investment management services for retirement plan Clients using NLG’s Balanced Opportunities Platform, a retirement platform for non-profits, government entities and other eligible employers using 403(b), 457 and certain other tax advantaged retirement plans. Freedom reviews the mutual fund options available on the Platform and maintains a recommended list of no-load mutual funds that are offered to plan sponsors if the plan sponsor chooses to use the fiduciary oversight feature available through the Balanced Opportunities Platform. The fee for this service is charged at the plan level. Freedom also structures globally diversified balanced portfolios using the mutual funds available through the Balanced Opportunities Platform. These model portfolios are offered as investment choices to plan participants if the plan sponsor chooses this service from the Balanced Opportunities Platform. The fee for this service is charged at the account holder or participant level and is only charged to those who use the service. Defined Contribution Investment Only (“DCIO”) DCIO Managed Models: These services include Freedom’s construction and management of portfolio models that are then made available to retirement plans either through the management of the model portfolios in a retirement plan record keeping system or through a unitization system such as Mid Atlantic Trust’s ModelxChange® system. In both cases Freedom acts as a 3(38) fiduciary for the management of the model portfolios only. Freedom is paid a fee only on the assets within the model portfolios. The model portfolios may be risk-based, target-date or both. As mentioned above, Freedom provides services through advisors associated with CIR. Freedom will offer portfolio models through CIR and RPS on an investment-only basis as well. In this case Freedom will act as sub- adviser to CIR who will act as investment manager for the portfolio models. DCIO through Collective Investment Trusts (“CIT’s”): Freedom’s risk-based models are also available to retirement plan sponsors through the use of CIT’s sub-advised by Freedom and managed and distributed by Reliance Trust. These CITs are priced daily, trade in full and fractional shares and are available to retirement plans whose service providers trade and settle through NSCC. In all cases above, except with the CIT’s, written agreements are executed between Freedom and plan sponsors for the above services which spell out the level of service provided by Freedom. Freedom's investment advisory services are provided to the plan sponsor only and not to individual plan participants. Financial Planning Services Freedom also offers financial planning services through its IARs, primarily to individuals. Financial planning typically involves providing a variety of analyses based on a multiple step process regarding the management of financial resources designed to meet an individual Client’s financial needs and goals. Each financial plan is tailored to the circumstances of the Client based on information obtained from the Client. The IAR will typically meet with the Client to identify and prioritize goals and future needs, and gather information necessary to perform analyses, conduct evaluation, and formulate recommendations. The information gathered would normally cover income, expenses, current and anticipated assets and liabilities; including, but not limited to, savings, investments, retirement and employee benefits, current expenses, planned expenses, and debt. Based upon the IAR’s analyses and evaluation, a written financial plan will be developed using approved financial planning software, currently eMoney Advisor® and Income Conductor® that proposes recommendations for a general course of action and/or specific steps to be taken by the Client. These recommendations are designed to help the Client attain the goals established, however, the written financial plan will not contain recommendations with respect to the advisability of purchasing any specific investment, insurance contract or other property. Freedom offers the following Financial Planning Services:  Investment Planning – analyzing the current cash flow, risk tolerance, time horizon and goals of a Client in an effort to design asset allocation strategies that will optimize portfolio composition to achieve objectives.  Education Planning – estimating education costs and explaining strategies that will help fund the education of children, grandchildren, or others. This could involve information pertaining to the post- secondary financial aid process.  Retirement Planning – estimating retirement income and expenses and applying strategies focused on both the accumulation of assets and the distribution of such during retirement to identify the adequacy of funding.  Budget/Cash Flow Planning – compiling information of assets, debt, current inflows and outflows and analyzing it to determine how the cash flows will affect goals and objectives. A Client can engage Freedom to perform one or more of the planning services described above. The analyses and recommendations provided through these planning services are based upon the information provided by the Client and their advisory firm, economic and tax considerations, and the Financial Advisor’s judgment. The Financial Advisor is prohibited from providing legal or tax advice, and Freedom strongly encourages its Clients to work with their legal and tax advisors prior to implementing any recommendations listed in the written financial plan. The delivery of the written financial plan and the execution of the acknowledgement letter by the Client signify the end of the Financial Planning Services engagement and Freedom has no responsibility to keep the plan current. The Client is under no obligation to purchase any investment or insurance product from Freedom in connection with the delivery of the written financial plan. If a Client reengages Freedom to update or revise a previously delivered written financial plan, it will be deemed a new Financial Planning relationship, and the Client will be required to execute a new Financial Planning Services Agreement. The Client can choose to implement the recommendations of the written financial plan with an investment professional of their choice. Freedom does not offer legal advice or tax advice. Wrap Fee Programs We offer a wrap fee program as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed similarly and are offered separately to provide investment advisory firms a choice of pricing structures. Please refer to our Wrap Fee Program Brochure for a full description of these services.