SCF Investment Advisors, Inc. (“SCFIA,” “we,” or “us”) was formed in 2003, is an Arizona corporation, and is a wholly owned subsidiary of SCF Holdings, Inc., a Delaware corporation. SCF Holdings, Inc. is wholly owned by AWS 9, Inc., a Delaware corporation, which is wholly owned by Atria Wealth Solutions, Inc., a Delaware corporation, which is in turn wholly owned by Atria Wealth Solutions Holdings LLC, a Delaware limited liability company, which is privately owned. SCFIA is registered as an investment adviser with the Securities and Exchange Commission. SCFIA is affiliated with SCF Securities, Inc. (“SCFS”), a registered securities broker-dealer and insurance agency. As of December 31, 2023, SCFIA had regulatory assets under management of $2,554,158,376. Of that amount, $588,384,559 was managed on a non-discretionary basis and $1,965,773,817 was managed on a discretionary basis. Our investment advisory services (“Advisory Services”) are made available to clients through individuals associated with SCFIA as investment adviser representatives (“IARs”). Many IARs are dually licensed (i.e., they are licensed both as IARs and as registered representatives of SCFS and offer both investment advisory and brokerage services), which, in addition to Advisory Services, allows them to offer commission-based products. Your IAR will disclose to you whether he or she is dually licensed and if there are any limitations on services offered due to registrations and qualifications. IARs are independent contractors of SCFIA. IARs and SCFIA offices often use marketing or business names other than SCFIA. The purpose of using a name other than SCFIA is for an IAR to create a brand that is specific to the IAR or office but separate from SCFIA. IARs who use names other than SCFIA must disclose in their advertising and correspondence materials that securities and advisory services are offered through SCFIA. IARs offer services individually to clients. Each client will work directly with IAR. The IAR will assist the client in selecting the service appropriate for the client’s personal situation. SCFIA offers various types of services including, but not limited to, providing advisory services and financial planning and consulting services. A description of the types of services offered is outlined below. SCFIA offers advisory services to its clients in various programs through IARs. The IAR tailors advisory services to the individual needs of Clients. Clients may impose restrictions on investing in certain securities or types of securities. Restrictions may include various types of indices and/or specific bonds, stocks, funds, or alternative investments, etc. The goals and objectives for each Client are obtained by the IAR to assist in determining the appropriate program and are documented in our client relationship management system. IARs are responsible for gathering necessary financial information from the Client and recommending a product or service offered by SCFIA, described herein. Please be advised that each IAR has an inherent fiduciary obligation to serve in the Client’s best interest with respect to the financial advice and services rendered. Advisory Services An Advisory Services Agreement allows the Client to engage the IAR to act as their investment advisor to perform portfolio management and investment advisory services for the account covered by the agreement. In providing portfolio management and investment advisory services, IAR will rely on personal financial and investment profile information while rendering services. Client agrees to promptly notify IAR if/when this information changes. The scope of work and fee for portfolio management and investment advisory services is provided to the Client in writing prior to the start of the relationship. Clients may choose to have the IAR manage their assets to obtain ongoing in-depth financial advice and planning. Many aspects of the Client’s financial affairs are reviewed. Realistic and measurable goals are set and the objectives to pursue those goals are defined. As goals and objectives change over time, suggestions are made to the Client for acceptance and implementation on an ongoing basis. Assets are invested in traded and/or non-traded securities and may also include no-load or low-load mutual funds, exchange- traded funds, equities (stocks), corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, mutual funds shares), U.S. government securities, alternative investments, options contracts, and interests in partnerships. Investments may be purchased through SCFIA’s affiliated broker-dealer, fund companies, insurance companies, or qualified custodians. IAR will place trades through the qualified custodian. Qualified custodians utilized by the IAR include National Financial Services (“NFS”), Pershing Advisor Solutions (“PAS”), Schwab Advisor Services (“Schwab”), and Fidelity Institutional Wealth Services (“IWS”). Qualified custodians may include insurance companies, mutual funds, or other financial institutions. The qualified custodian(s) will maintain physical custody of all funds and securities of the Account, and Client will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. (See Item 15 Custody below) Client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the qualified custodian(s), but rather represents a direct and beneficial interest in the securities which compose the client’s account. At least quarterly, Client will receive an account statement from the qualified custodian of the Account detailing transactions in the Account. Any checks drawn on Client’s account will be at the Client’s instructions only. All transactions will be confirmed by receiving customary statements from Account’s qualified custodian. 5 Third Party Investment Adviser (TPIA) Programs SCFIA provides its IARs and clients with access to a number of TPIA programs and platforms for use by IARs that provide clients the opportunity to receive the investment management expertise of a diverse set of advisers that specialize in different asset classes and investment styles and use different portfolio management techniques including asset allocation strategies, mutual fund and ETF models, separately managed account (SMA) programs, unified managed account (UMA) programs, wrap fee services, and other types of managed portfolios such as tax harvesting and tax efficiency strategies, risk management strategies, and dynamic and tactical portfolios. Some programs are more or less aggressive as compared to other programs. Some programs also have higher or lower fees and expenses than other programs. These programs are sponsored by the TPIAs and are offered through co-adviser agreements, solicitor/referral/promoter arrangements, and other types of agreements between SCFIA and a TPIA. Many TPIAs sponsor a broad range of investment programs. TPIAs typically maintain their own custodial relationships and do not leverage a custodial relationship contracted through SCFIA except for certain TPIAs as detailed further below. When acting in a co-advisory capacity, SCFIA and TPIA are jointly responsible for the ongoing management of your account. Depending on the agreement between SCFIA and a TPIA and based on the information provided by a client, an IAR will refer a client to or assist the client in selecting a TPIA who offers products and services that demonstrate an investment philosophy and style that appear to align with the needs of the client. A client is asked to provide detailed financial and other pertinent data to IAR. An IAR helps a client determine the client’s risk tolerance, investment goals, and other relevant guidelines. Factors we consider in the selection of a particular TPIA include (a) our assessment of a TPIA, (b) your investment experience, risk tolerance, goals, objectives, and restrictions, and (c) the assets you have available to invest. There is no guarantee that a client’s goals or investment objectives will be achieved by any specific program. After an IAR assists a client in selecting a suitable TPIA program, client assets are then either invested in the strategy or model or the TPIA begins to allocate the client’s assets in the investment portfolio. The IAR provides initial and continuing education and information regarding the program selected. The IAR will also explain rebalancing guidelines utilized within the program and meet with a client periodically to discuss changes to the client’s financial circumstances. In certain circumstances an IAR acts purely in a solicitor/promoter or referral capacity when referring you to a TPIA. Under these arrangements, an IAR assists a client in identifying the client’s objectives and refers the client to a TPIA according to the client’s stated objectives. The client typically enters into an agreement directly with the TPIA and the client’s funds are invested by the TPIA. The IAR monitors the performance of the TPIA and coordinates communication between the client and TPIA. An IAR does not actively participate in the execution of any securities transactions for a client’s TPIA account and does not have authority to determine, without obtaining specific client consent, the securities to be bought or sold, the amount of the securities to be bought or sold, or the broker-dealer to be used for the purchase or sale of securities in the client’s TPIA account. SCFIA and your

IAR is compensated for referring you to the TPIA program. This compensation generally takes the form of the TPIA sharing a portion of the advisory fee you pay to the TPIA. When SCFIA acts as a solicitor/promoter for a TPIA program, you will receive a written solicitor/promoter disclosure statement describing the nature of our relationship with the TPIA program, if any; and the terms of our compensation arrangement with the TPIA program, including a description of the compensation that your IAR and SCFIA will receive for referring you to the TPIA program. Please consult the applicable TPIA’s agreement for further information, including information on the capacity in which SCFIA acts for a particular program. Clients should refer to TPIA’s Form ADV Part 2A, or equivalent brochure, for a full description of the terms and conditions of their services and fees. TPIAs are subject to our due diligence process for inclusion as a TPIA and are subject to future change from time to time. Please consult your IAR for information regarding available TPIAs. The services of a number of SMA Managers, Sub-Managers, and Model Providers we make available can be accessed through different platforms and programs. Your advisory fee will vary depending on the platform or program selected to access the SMA Manager, Sub-Manager, or Model Provider. We have a financial incentive to recommend programs that generate more fees to us. Some TPIA programs are considered “wrap fee” programs. A wrap fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee programs, you will pay our firm a single fee, which includes money management fees, certain transaction costs, and certain custodial and administrative costs. Clients should refer to the client agreement, fee schedule, and TPIA brochure for their program for details on what the wrap fee covers. The total fees you pay to access a particular SMA Manager, Sub-Manager, or Model Provider can be more or less than the combined fees charged by the TPIA, SCFIA, and your IAR for a TPIA program that offers the same SMA Manager, Sub- Manager, or Model Provider through a co-advisory or other type of relationship. You should consider the aggregate fees charged on a particular platform and the services available when choosing a platform and investment manager and discuss with your IAR the platform and program pricing relative to a specific TPIA, SMA Manager, Sub-Manager, or Model Provider for additional details. TPIAs have differing minimum account requirements and a variety of fee ranges. All securities are selected, and transactions are executed by the third-party money manager. Your IAR will contact you periodically to review your financial situation, objectives, and restrictions and communicate information to the TPIA; and assist you in understanding and evaluating the services provided by the money manager. SCFIA and IAR share in a portion of the fee paid to the TPIA for its services. Since the TPIA services provided by each sponsor are unique, clients should request and carefully review the applicable 6 disclosure brochure, client agreement, and other account paperwork for each TPIA for more detailed information about the services provided by a TPIA, including without limitation, a description of the TPIA’s background, investment strategies, fees, custody arrangements, conflicts of interest, and other relevant information regarding the TPIA’s services and business practices. A complete list of TPIAs available through SCFIA is available upon request. SCFIA has entered into co-advisory or other types of relationships with a number of TPIAs such as AssetMark Inc, (“AssetMark”), Envestnet, SMArtX, Axxcess Wealth Management (“Axxcess), and Ashton Thomas Private Wealth, LLC (“Amplify”). SMArtX, Axxcess, and Amplify leverage the SCFIA custodial platform. IARs may delegate certain investment advisory responsibilities or discretionary authority to TPIAs and their related program managers. SCFIA and your IAR utilize multiple broker-dealer custodians for brokerage and clearing services. Refer to Item 12: Brokerage Practices for more details. Additional information is available via the TPIAs and any program manager’s Form ADV 2A. Clients may obtain a copy the Form ADV 2A from their IAR or by visiting www.adviserinfo.sec.gov. Amplify Platform SCFIA has an agreement with Amplify that allows its IARs to offer advisory services to Clients by selecting the Amplify Platform. The Amplify Platform provides back-office operational support services such as administrative, trading, reporting services and access to independent third-party managers (“Program Managers”). The Amplify Platform allows you to establish an account where Amplify acts as the Program sponsor and provides, through a sub-advisory agreement with SCFIA, administrative and trading services (including overlay account management) by directing the investment, reinvestment, and rebalancing of Program Assets in accordance with the information and instructions provided by Adviser, Program Managers, and Client. SCFIA and its IARs will assist you in determining which investments and/or Program Managers are best suited for you, gather information from you about your financial situation, investment objectives, and other information you need to open your account. Per the terms in the Advisory Agreement, you grant to SCFIA discretion to buy, sell, trade, and allocate in and among stocks, bonds, mutual funds, exchange traded funds, investment subdivisions within variable annuity products, and/or Program Managers available within the Amplify Program. Financial Planning and Consulting Services Financial planning and consulting services allow IARs to furnish recommendations as to the allocation of Client’s present financial resources among different types of assets to correlate with the Client’s financial planning objectives; and/or prepare a plan and/or provide consulting services. Financial planning may include, but is not limited to, furnishing recommendations as to the allocation of present financial resources among different types of assets including investments, savings, and insurance with a view toward better correlating the assets with the Client’s financial planning objectives. If Client engages IAR for financial planning services, IAR will prepare a financial plan to assist the Client in defining personal financial planning goals and objectives that may encompass areas of business and personal financial planning, education planning, retirement planning, disability protection, estate planning, tax planning, charitable giving, and investments, and to supply analyses and recommendations as to the actions and investment strategies necessary to pursue these goals and objectives. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of any recommendations is at the discretion of the Client. The Client is under no obligation to execute any investment transactions through IAR or SCFIA. The value and usefulness of the financial planning services will be dependent upon the information that the Client produces, the Client’s active participation in the formulation of financial planning objectives, and the implementation of the plan to attain those objectives. Consulting services may include, but are not limited to, the IAR assisting the Client with ongoing advice regarding the management of their financial resources based upon an analysis of Client’s current situation, goals, and objectives. Areas of consulting include but are not limited to retirement planning, education planning, business planning, charitable giving, cash flow/budget analysis, divorce planning, life insurance review, disability insurance review, investment planning, estate planning, debt management, long term care insurance review, and asset monitoring services. Investment advice and recommendations may be implemented at the discretion of the Client. Neither SCFIA nor its IARs provide legal or tax advice. Clients should consult with an appropriately licensed attorney or tax professional. Since financial planning is a discovery process, situations may occur wherein the Client is unaware of certain financial exposures or predicaments. IRA Rollover Considerations If you decide to roll assets out of a retirement plan into a SCFIA advisory individual retirement account (“IRA”), SCFIA and your IAR have a financial incentive to recommend that you invest those assets in one of our programs, because SCFIA and your IAR will be paid on those assets, for example, through advisory fees. You should be aware that such fees likely will be higher 7 than those you pay through your plan, and there can be custodial and other maintenance fees. The following fiduciary acknowledgement applies only when our IAR (i) provides investment advice to participants in or the fiduciaries of ERISA-covered retirement plans and to owners of IRAs, and (ii) recommends to participants in ERISA-covered retirement plans or owners of IRAs to make a rollover to an IRA. When we provide investment advice to you regarding your retirement plan account or IRA, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean we are acting as fiduciaries for purposes of other applicable laws. This acknowledgement of fiduciary status does not confer contractual rights or obligations on you, SCFIA, or your IAR.