General Description of Primary Advisory Services A & I Financial Services, LLC, doing business as A & I Wealth Management (“A & I Wealth Management” or “we”) is a registered investment adviser based in Lone Tree, CO. We are organized as a limited liability company under the laws of the State of Colorado. We have been providing investment advisory services since 2009. In 2018, A & I Financial Services LLC ownership structure changed from being owned directly by Karl F. Frank and Stacey K. Frank to full ownership by A & I Holdings, LLC. Karl F. Frank and Stacey K. Frank are our principal owners. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Asset Management Services
• Use of Third Party Money Managers
• Financial Planning Services (Plans and Consultations)
• Retirement Plan Services Asset Management Services We offer investment supervisory services defined as giving continuous investment advice to you (or making investments for you) based on your individual needs, goals and objectives. Through this service, we offer a customized investment program providing you with advice regarding allocation among various asset classes, ongoing assistance with evaluation and selection of investments, and adjustment and balancing of portfolios. We meet with you to conduct a detailed financial analysis and assess your financial situation, financial goals and risk tolerance. Based on this analysis, we select portfolio strategist and investment managers. The portfolio strategist and investment managers may be representatives associated with us, they may be sub-advisors who provide model portfolio recommendations, or they may be registered with outside money managers with whom we have relationships. We manage multiple model portfolios that utilize different asset mixes and trading strategies. A client account may participate in several model portfolios or a single model portfolio. We continuously monitor and review each model portfolio and implement block trades when we determine that investment changes are required. Use of Third Party Money Managers As part of our overall asset management strategy, we may also recommend third party money managers or programs to manage all or a portion of your account. All third party money managers recommended by our firm must either be registered as investment advisers or exempt from registration requirements. We will periodically monitor the third party investment advisor’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. After gathering information about your financial situation and objectives, we will recommend that you engage a specific third-party money manager or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the money manager’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. Where we are appointed as your agent to buy and sell securities or other investments for your account on a discretionary basis, you delegate to A & I Wealth Management the authority to retain one or more third party investment advisor(s) to provide all, or a portion, of the discretionary management services with respect to your account. We shall have the discretion to hire and fire any third party investment advisor. To the extent you participate in a specific program offered by A& I Wealth Management that is provided through a third party investment advisor or platform, the investments that are available to you through that program may be limited to certain types of securities. You may not be able to impose investment restrictions with respect to the securities and other assets that are purchased for, or held in, the account by such third party investment advisor(s). We may also act as solicitor and refer you to unaffiliated third-party investment advisors offering asset management and other investment advisory services. We perform due diligence in selecting the third- party money managers. Each solicitation arrangement is performed pursuant to a written solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules and regulations. In some cases, you may be required to sign an agreement directly with the third party investment advisor(s). In which case, you may terminate your advisory relationship with the third investment advisor(s) according to the terms of your agreement with the third party investment advisor(s). You should review each third party investment advisor’s brochure for specific information on how you may terminate your advisory relationship with the third party investment advisor and how you may receive a refund, if applicable. You should contact the third party investment adviser directly for questions regarding your agreement with the third party investment adviser. Our representatives are available to answer questions regarding your account. Our representatives also act as the communication conduit between you and the third-party investment advisors. Third party managed programs generally have account minimum requirements and these minimum requirements vary from investment advisor to investment advisor. Account minimums are generally higher on fixed income accounts than equity-based accounts. A complete description of the third-party investment advisor’s services, fee schedules and account minimums are disclosed in the third-party investment advisor’s Disclosure Brochure that is provided to clients at the time an agreement for services is executed and an account established. The type and frequency of reports provided to clients will also depend upon the third-party investment advisor selected. Third-party investment advisors may take discretionary authority to determine the securities to be purchased and sold for the client. In some instances, we may be considered a sub-advisor because we are responsible for the initial and on-going suitability review and are also responsible for maintaining your current information. The third-party investment advisor may also use other sub-advisors in providing management and other advisory services to your accounts. Recommendation of Variable Annuities We offer discretionary asset management of variable annuity portfolios through Nationwide Advisory Solutions. The Nationwide platform gives us access to a large range of investment strategies and securities. Investments are determined by the investment adviser representative managing the account and in accordance with the client’s investment objectives. Variable annuities managed through the Nationwide Advisory Solutions platform are fee based and do not incur commission charges. For its services as custodian, Nationwide Advisory Solutions charges a flat monthly insurance charge of $20 without regard to the size of account. Specifics regarding the annuities are found in the annuities’ prospectuses and application documents. Financial Planning Services (Plans and Consultations) A & I Wealth Management offers financial planning services that focus on your specific needs and concerns. The services may be comprehensive in nature (focusing on your overall financial situation, risk, goals, and objectives) or they may be modular in nature (focusing on specific areas of concern that you have.) Financial planning services may include giving advice on investment and non-investment related matters. For example, we also conduct business exit strategy planning on a stand-alone basis. Additionally, we offer consulting services in regard to your specific needs and concerns and this can include both investment and non-investment matters. Consultations can also include specialized business exit planning services. Consultation services can be contracted on a case-by-case basis (limited) or on an on-going basis. You have sole discretion whether or not to implement any recommendation from us. It is your responsibility to notify us if there are any changes in your financial situation or investment objectives that could affect the advice provided by us. We collect a variety of information from you that

is necessary to perform the requested services. We gather the information to review your current financial condition, assist you in determining your attitude toward risk and identify your financial goals, objectives and challenges. Financial data that we gather and review may include statements and account data from banks, broker/dealers and mutual funds, as well as tax returns and insurance policies. Depending on the level and scope of the financial planning engagement, we may also review wills and trusts. We rely on the information provided by you. Therefore, it is important the information you provide is complete and accurate. Neither we nor our investment advisor representatives (“representatives”) are responsible for verifying the information you provide. In addition, if authorized by you, we will gather information or documentation from your other professionals and are expressly authorized to rely on the information provided. We urge you to work closely with your attorney, accountant or other professionals regarding your financial and personal situation. We meet with you to discuss our recommendations and outline steps you must take to implement those recommendations. Although financial planning services are provided with the intention that you will implement the recommendations contained in the plan, you are not obligated to do so. You retain discretion over implementing decisions relating to financial planning services and are free to accept or reject any recommendation from us. It is your responsibility to notify us of any changes in your financial situation or investment objectives. You should notify us of any changes so that we can work with you to determine if the changes will affect the advice provided by us. Together, we will determine if you wish to engage us to review, evaluate and revise previous recommendations. Retirement Plan Services A & I Wealth Management offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. Our services can include, but are not limited to, the following:
• Preparation of Investment Policy Statement. An Investment Policy Statement (“IPS”) is a document drafted for the purpose of determining an investment philosophy for the retirement plan investment program which may exceed the tenure of the various individuals charged with managing it. The IAR assists The Plan in the preparation and implementation of a suitable IPS.
• Non-Discretionary Investment Advice. Advisor provides non-discretionary investment advice regarding assets classes and investment options, consistent with the plan’s investment policy statement.
• Default Investment Alternative Advice. We provide non-discretionary investment advice to assist with development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. The Plan Sponsor retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5).
• Investment Recommendations. IAR recommends, for selection by the Plan, an array of investments to be offered under the Plan consistent with the policies outlined in the IPS.
• Investment Monitoring. IAR monitors the plan investments and determine their suitability pursuant to the criteria set forth in the IPS. When appropriate, IAR will recommend, for selection by the Plan, suitable replacement investments.
• Performance Reports. IAR prepares and presents reports evaluating the performance of plan investments pursuant to the criteria set forth in the IPS.
• Participant Enrollment and Education. IAR conducts retirement plan investment education seminars and individual (one-on-one) meetings with participants for the purpose of providing them with the opportunity to take full advantage of the benefits provided by the retirement plan. A & I Wealth Management acknowledges that in performing the services it is acting as a limited scope “fiduciary” as defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. A & I Wealth Management acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause A & I Wealth Management to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, A & I Wealth Management (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets and (c) is not the “Administrator” of the retirement plan as defined in ERISA. 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 interests ahead of yours. All recommendations are submitted to the client for ultimate approval or rejection. It is the client’s responsibility to evaluate the Advisor’s recommendations and make changes to the plan itself. Limits Advice to Certain Types of Investments We offer advice on equity securities, corporate, municipal and government debt securities, certificates of deposit, investment company securities, options contracts on securities and interest in partnerships investing in real estate, oil and gas interests, and others. We also advise on certain investment products such as variable life insurance and annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, we direct or recommend the allocation of Client assets among the various investment options available with the product. Client assets are generally maintained at either the insurance company or the custodian designated by the product’s provider. Additionally, we may advise you on types of investments that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Tailor Advisor Services to Individual Needs of Clients We provide services based on your specific needs. You are given the ability to impose restrictions on your accounts, including specific investment selections and sectors. However, we will not enter into an investment advisor relationship with a client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Wrap-Fee Program versus Portfolio Management Program In traditional management programs, advisory services are provided for a fee but transaction services are billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction services are provided for one fee. We do not act as a portfolio manager of or sponsor wrap fee programs. Client Assets Managed by Advisor As of December 31, 2023, we manage $369,416,647 in client assets on a discretionary basis, and non- discretionary assets under management of approximately $42,679,215.