A. Description of the Advisory Firm Precept Advisory Group LLC is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”) and has been in business in California since January 2010. The owner of Precept Advisory Group is McGriff Insurance Services, LLC. B. Types of Advisory Services Precept Advisory Group LLC (hereinafter “PAG,” “we,” or “us”) offers the following services to advisory clients: Investment Advisory Services Overview PAG offers investment advisory services to corporations or other entities regarding their pension plans, profit sharing plans, or other retirement plans, as well as, to the plan sponsors, related trusts, and other plan fiduciaries regarding such plans. For clients seeking to establish a pension, profit sharing, or other retirement plan, PAG will provide retirement consulting services to the plan sponsor and other plan fiduciaries regarding plan design, investment options, selection of the plan administrator and record keeper, enrollment and educational services for plan participants, and other services based upon an analysis of the particular needs of the plan. Thereafter, PAG shall periodically conduct a review of the plan, the investment options offered by the plan to its participants, and any other items agreed to. For clients with an established pension, profit sharing, or other retirement plan, PAG will initially perform a plan review and then provide the plan sponsor and other fiduciaries with a plan efficiency assessment and recommendations for plan enhancements, remediation of deficiencies, or changes that may be beneficial to the plan. Thereafter, PAG will provide services similar to those described above for newly established plans. Fees for these services will be based on a percentage of Assets Under Management, Hourly fees, or Fixed fees. 3(21) and 3(38) Fiduciary Services The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries (e.g., plan sponsor) may retain investment advisers for various types of services with respect to plan assets. For certain services, PAG will be considered a fiduciary under ERISA. For example, PAG will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the plan sponsor by recommending a suite of investments as choices among which plan participants may select. Also, to the extent that the plan sponsors

retain PAG to act as an investment manager within the meaning of ERISA § 3(38), PAG will provide discretionary investment management services to the plan. 3(21) Services When serving as an ERISA 3(21) investment advisor, the plan sponsor and PAG share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Agreement between PAG and the plan sponsor. 3(38) Services When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of fiduciary responsibility for the investment decisions made by PAG. PAG is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Agreement between PAG and the plan sponsor. PAG’s investment management is limited in that it has the discretion solely to add, remove, or replace funds in plan fund lineups and initiate the transfer of existing balances to the replacements without prior approval from the plan sponsor. PAG can provide the services identified in this Brochure on either a discretionary (3(38)) or non-discretionary (3(21)) basis. The particular services and level of authority provided will be detailed in the Agreement with the client. Services Limited to Specific Types of Investments PAG limits its investment management to registered investment companies (e.g., mutual funds and exchange-traded funds (ETFs)), separate accounts, stable value products, and collective trusts. In addition, PAG uses other securities to help diversify a portfolio, when applicable. C. Client Tailored Services and Client Imposed Restrictions PAG offers the same suite of services to all its clients. However, specific client financial plans and their implementation are dependent upon the client’s Investment Policy Statement which outlines each client’s current situation and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients cannot impose restrictions on investing in certain securities or types of securities. D. Wrap Fee Programs PAG does not participate in any wrap fee programs. E. Amounts Under Management PAG has the following assets under management (“AUM”): Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 287,629,677 $ 3,980,502,830 12/31/2023