A. Description of Advisory Firm Pinkerton Retirement Specialists, LLC (“PRS”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”). PRS is a limited liability company formed under the laws of the State of Idaho. PRS is ultimately owned and controlled by Dan Pinkerton, Managing Member, and his wife, Kathryn Pinkerton. The company was founded in 1987, incorporated in 1996, and PRS has been registered with the SEC as an investment advisor since June 15, 2010. B. Description of Advisory Services Offered Asset Management Services PRS offers investment advisory services for individual clients, high net worth families, foundations, endowments, pension and profit sharing plans, corporations, and institutional investors. These services involve providing a client with constant management of their investment funds. PRS watches a client’s advisory accounts and executes trades. PRS has discretionary and non-discretionary authority of clients’ advisory accounts. Discretionary authority allows us to decide what securities to buy or sell without needing client approval, whereas non-discretionary authority requires client approval before initiating the buying or selling of securities. See Item 15 of this Brochure. PRS offers a customized and individualized investment program for clients. A specific asset allocation strategy is crafted to focus on the specific client’s goals and objectives. PRS offers the following strategies: ▪ Active Portfolios (A20-A100) – Portfolios of high quality actively managed non-transaction-fee (NTF) funds requiring a score of at least 8 out of 12 on our proprietary scoring methodology. Portfolios range from 100% equity to 20% equity/80% fixed income allocations. ▪ Passive Portfolios (P20-P100) – Portfolios of high quality passive (index focused) funds requiring a score of at least 8 out of 12 on our proprietary scoring methodology. Portfolios range from 100%/0% fixed income equity to 20% equity/80% fixed income allocations. ▪ GTS – Index focused ETF portfolio based on our Global Indexed Trend Tracking Strategy (GITTS), which utilizes proprietary moving averages to determine best opportunities to be invested in the market or in cash/short-term bonds. ▪ MGT (Momentum Growth TrendTracker) – Momentum-based tactical model with a focus on wide moat companies trading at a discount. Utilizes cash and short-term bonds during bear markets. ▪ HDT (High Dividend TrendTracker) – Growth & Income model by investing in high-dividend paying, primarily blue-chip stocks, and can include dividend paying mid-cap, international and real estate stocks with a 10-year history of stable or growing dividends. Utilizes cash and short-term bonds during bear markets. ▪ IGP (Income & Growth Portfolio) – Tactical portfolio consisting of high-quality mutual funds when fully invested, and moves to cash/short-term bonds when long-term market momentum turns negative. ▪ TGP (Tactical Growth Portfolio) – The TGP invests 57% in the PRS Bull/Seasonal Strategy and 43% in the PRS Speedometer Strategy. Both of these strategies are fully invested in equities as the markets are advancing, and are fully invested in bonds, cash, and limited strategic equity exposure when in protection mode. ▪ TDP (Tactical Defensive Portfolio) – The TDP portfolio invests defensively for income and growth as well as capital preservation. The TDP is diversified potentially in bonds, gold, equities, and cash. ▪ Tactical Bond Strategy – When both the long-term and short-term trend indicators are positive (Risk On), the Tactical Bond Portfolio is 100% invested in Corporate Bonds. When either the long-term or short- term indicator is negative (Risk Off), the Tactical Bond Portfolio is 100% invested in 7-10year US Treasury Bonds. ▪ GEM (Gold/Equity Momentum Portfolio) – The GEM has a goal of identifying and investing in uptrends in gold ETF’s versus equity ETF’s. PRS will typically construct each client’s account holdings using, but not necessarily limited to, no-load mutual funds, funds at NAV, equity positions, fixed income positions, alternative investments, municipal securities and U.S. government securities. PRS shall obtain from clients information to determine each individual client’s financial situation and investment objectives. Accounts are managed on the basis of each client’s financial situation and investment objectives. At least quarterly, clients are instructed to notify PRS whether the client’s financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts. At least annually, PRS shall contact individual clients to determine whether their financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts managed. PRS shall be reasonably available to consult with individual clients relative to the status of their accounts. Clients shall have the ability to impose reasonable restrictions on the management of their accounts, including the ability to instruct PRS not to purchase certain securities. Client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account. A separate account is maintained for each client with the custodian and clients retain right of ownership of the account (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). Institutional Intelligent Portfolios® (“$ymphony”) We offer an automated investment program (“$ymphony”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”), mutual funds, and a cash allocation. The client may instruct us to exclude up to three ETFs or mutual funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“the Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate $ymphony. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to $ymphony. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of $ymphony for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for $ymphony. The Platform enables us to make $ymphony available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). Before enrolling in $ymphony, clients should carefully review $ymphony’s disclosure brochure to understand the limitations and risks of $ymphony. For example, the efficacy of the System’s recommendations is dependent upon the information the client gives the System, and since the System is an automated information processor, it can only process information within its capabilities. Additionally, $ymphony does not make the entire universe of all ETFs or mutual funds available for us to select, and therefore our ability to build portfolios is limited in this regard. Clients should understand that $ymphony is operated by Schwab, and its effectiveness for a particular client will depend significantly on the System’s capabilities. Any malfunction by $ymphony could result in loss outside of PRS’s control. We charge clients a fee for our services as described below under Item 5: Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of $ymphony. Schwab does receive other revenues in connection with $ymphony. Financial Planning Services PRS provides financial planning services in the form of written financial plans and financial planning consultations. Services may be provided on a one-time basis or on a continuous basis. The client selects these services in the financial planning agreement. Financial planning services may be specific or modular in their preparation (unique to each client in their depth of preparation). Financial planning services may take into consideration factors such as the client's objectives, risks that they are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions, social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for retirement. They may include tax planning or investment planning. They may also include retirement planning, estate or business needs, education planning, life and disability insurance needs, long-term care needs and cash flow/budget planning. The services consider information collected from the client. Information may include financial status, investment objectives and tax status, among other data. The IAR delivers a written financial plan to

the client. While financial planning services are prepared with the intention of the client implementing recommendations made within the plan through PRS, clients are not obligated to do so. Clients may select any investment advisor, broker/dealer, or financial institution to implement PRS recommendations. Financial planning fees are negotiable. In addition, PRS may waive, reduce or credit the amount of the financial planning fee charged to a client when additional advisory fees or commissions are earned. The decision to waive or reduce an advisory fee is at the sole discretion of the firm. Clients receive a written financial plan from the IAR reflecting the planning services selected on the financial planning agreement. Clients will have planning-related consultations with the IAR to evaluate the financial plan and all recommendations. Clients either receive consulting services in person or by telephone from the planning categories selected for the respective period. Pension Consulting Services PRS provides services to pension and profit sharing plans which includes establishing plans and related documents through data gathering, assessment of participant’s goals, meeting with plan participants, fund selection and conducting education and enrollment meetings. The services may include a quarterly review of fund performance and an annual fund review meeting. Qualified and ERISA Plan Consulting Services In addition to the services described above, we also provide qualified and ERISA retirement plan consulting services. These services may involve: ▪ Fiduciary Management Services ▪ Fiduciary Consulting Services ▪ Non-Fiduciary Consulting Services Fiduciary Management Services ▪ Discretionary Investment Management Services by which we monitor the investment options of the Plan in order to add or remove investment options for the Plan and actively manage all assets for participants enrolled in the Plan. Pinkerton Retirement Specialists, LLC will be granted discretionary authority to make all decisions regarding the investment options held in the Plan for Plan participants. ▪ Discretionary Investment Selection Services. Monitoring the investment options of the Plan and add or remove investment options for the Plan. ▪ Default Investment Alternative Management. Develop and actively manage qualified investment alternative(s) (“QDIA”), as defined in DOL Re. 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. Pinkerton Retirement Specialists, LLC acknowledges that it is performing Fiduciary Management Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(38) of Employee Retirement Income Security Act of 1974 (“ERISA”). When providing Fiduciary Management Services, Pinkerton Retirement Specialists’ services include discretionary authority to make investment decision over assets of a retirement plan. Pinkerton Retirement Specialists acknowledges that it is a fiduciary with respect to its exercise of investment decisions over these assets of retirement plan. A client can elect that Pinkerton Retirement Specialists serve as a 3(21) fiduciary. Fiduciary Consulting Services ▪ Recommendations regarding investment selection consistent with ERISA section 404(c). ▪ Ability to consult on a one-on-one basis with Plan Participants Pinkerton Retirement Specialists acknowledges that it is performing Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Pinkerton Retirement Specialists will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Pinkerton Retirement Specialists to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Pinkerton Retirement Specialists (a) has no responsibility and will 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 the client’s retirement plan documents, and (b) is not the “Administrator” of the client’s retirement plan as defined in ERISA. Non-Fiduciary Consulting Services Pinkerton Retirement Specialists provides clients with the following Non-Fiduciary Retirement Plan Consulting Services: ▪ Investment Education. The following services will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts. ▪ Educational presentations for Plan participants. Presentations to Plan participants are informational in nature and intended to provide an overview of the Plan and the Plan’s investment selections. ▪ Asset Allocation Models. ▪ Interactive Investment Materials. The exact suite of services provided to a client will be listed and detailed in the agreement for services. Clients that elect to engage our firm for this service are required to also work with Pinkerton Retirement Specialists to be a service provider to the plan. As a service provider, we will be responsible for all aspects of the management of the 401(k) plan. Specifically, we provide the following non-investment related services; annual plan review, Plan Demographic Review, Legislative Review and Impact, 404(c) Policy Statement, Plan Vendor Contract Service and Pricing Negotiation, Plan Design Review, Education Meetings, Employer Newsletters, Periodic Sample Employee Memos, ERISA Legal Support & Compliance Assistance, 401(k) Help E-Mail & Toll-Free 800 Number for Employees, Vendor Analysis/Selection/Monitoring, and Plan Conversion Management. To help control for the potential conflict of interest of using Pinkerton Retirement Specialists as both a service provider and investment advisor, we conduct periodic reviews of fees charged by other firms providing similar pension consulting services as Pinkerton Retirement Specialists. This is done to demonstrate that fees charged by Pinkerton Retirement Specialists are reasonable compared to other companies. If you, or your company sign up for this service, please understand that you will be ultimately responsible for implementing all recommendations provided by Pinkerton Retirement Specialists. Client funds and assets will be held with a third-party broker/dealer that will serve as the client’s qualified custodian. Pinkerton Retirement Specialists will NOT have a limited power of attorney to execute transactions on behalf of the client. Therefore, we will NOT submit trade instructions to the designated third-party administrator. All changes to Plan holdings and investment selections are the client’s responsibility. If you decide to pick the service option for one-on-one consulting services between Pinkerton Retirement Specialists and Plan Participants, such services are consulting in nature and do not involve Pinkerton Retirement Specialists implementing recommendations in individual participant accounts. It will be the responsibility of each Participant to implement changes in their individual accounts. The Participant can implement recommendations provided by Pinkerton Retirement Specialists or direct the Pinkerton Retirement Specialists representative to do so on their behalf. Pinkerton Retirement Specialists will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Investment Advisory Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. C. Client-Tailored Services and Client-Imposed Restrictions PRS provides asset management services based on the specific needs of the individual client. The client has the ability to impose reasonable limits on investment selections and sectors. PRS may manage a client’s account in accordance with one or more investment models. When client accounts are managed using models, investment selections are based on the underlying model and PRS does not typically develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. D. Wrap Fee Programs PRS does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of March 31, 2024, PRS managed $937,026,774 of client advisory assets on a discretionary basis and $84,874,255 on a non-discretionary basis, for a total of $1,021,901,029 client assets under management.