401K Generation, Inc. (“401KG”) was established in June of 2010 and is owned by partners Eddie Rojas and Kelli D. Rojas. Each partner owns a 50% share of the Firm. 401KG offers retirement plan consulting services to plan sponsors and other plan fiduciaries as well as individual managed accounts and investment advisory services. Retirement plan consulting services are tailored to the needs of the plan through analysis and discovery meetings. Individual managed account and investment advisory services are tailored to the specific needs of individuals, businesses, and trust account clients. Clients may restrict the range of investments used in their portfolios via notation on their Consulting or Investment Advisory Agreement. We do not offer a wrap fee program. As of 12/31/23, we managed approximately $29,964,009 in client assets on a non-discretionary basis and approximately $109,521,268 in client assets on a discretionary basis. In addition, we provide 3(21) pension consulting services to approximately 6,238 plans holding approximately $625,482,537 in plan assets. Retirement Plan Consulting Services Retirement plan consulting services primarily consist of evaluation of existing plans as well as assistance in implementing new plans for employer sponsored plans including some or all of the following: advising on plan fund offerings, cost and fee ratios, allocation strategies, maximization of plan value through employee education and participation. We currently model these consultative services to mutual funds and ETFs only. 401KG provides retirement plan advisory services to sponsors of participant account directed Plans covered by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). There is no plan size minimum. Open architecture retirement plan services are provided in conjunction with an administration and recordkeeping service provider and generally a broker- dealer or investment advisory firm. The plan sponsor enters into both (i) an Investment Advisory Agreement with 401KG and (ii) separate services agreement(s) with each service provider, e.g., administrative, recordkeeping, third-party money manager. ERISA Section 3(16), 3(21) and 3(38) Services 401KG provides comprehensive qualified retirement plan consulting services which including fiduciary services that would otherwise be the responsibility of the employer under ERISA Section 3(16) as the sponsor of a retirement savings plan; and/or acting as a “fiduciary” to certain plan sponsor clients consistent with Section 3(21) and/or 3 (38) of ERISA. Specific services and the related fiduciary capacities of 401KG will be detailed in a written agreement to be executed by all clients. We provide investment advice and fiduciary due diligence services; employee plan and participant investment education; asset allocation services; and 401(k) proposal and vendor research and analysis to qualified retirement plan sponsors and business entities. These services may include the identifications and recommendation of a third-party money manager, monitoring investment manager performance and reporting of plan investment assets. Plan sponsors authorize 401KG to recommend the selection, addition, removal and/or replacement of funds available for purchase by plan participants. Recommendations must be consistent with any written investment policy approved by the plan sponsor and provided to 401KG along with any requirements under ERISA. Based upon the evaluation of each fund’s performance the plan sponsor will determine the appropriateness and continued suitability of available investment options. At least annually, 401KG will meet with plan sponsors and review the plan’s investment options to determine ongoing appropriateness. If an existing fund is no longer suitable as an investment option, we will assist in the transition to the replacement option if requested by the plan sponsor. 401KG will monitor the relevant data on the performance of each investment option and provide the plan sponsor, through the record keeper or administrator, with services described in the advisory agreement. In order to fulfill expanded transparency requirements as set forth under Section 408(b)(2) of ERISA, 401KG discloses detailed information regarding fees, services, and fiduciary status to plan sponsors within the Investment Advisory Agreement which is executed by all plan sponsors. 401KG will not be acting as the “plan administrator” or the “named plan fiduciary” as defined by ERISA. Unless 401k Generation and the plan sponsor agree to otherwise in writing, 401k Generation is only a fiduciary to the plan for purposes of the fiduciary services specified in the Investment Advisory Agreement executed by 401KG and the plan sponsor and is not a fiduciary to the plan when performing any other services for the Plan. 401k Generation will distribute to plan participants, beneficiaries, and alternative payees, as applicable (collectively, “participants”), via a mailing or electronic delivery in accordance with electronic delivery methods permitted by the DOL and/or IRS, those notices, communication materials

and Plan distribution forms/information (collectively, the “materials”), for which 401k Generation has responsibility as indicated below. To the extent 401k Generation distributes materials to a participant electronically but 401k Generation has actual knowledge that the delivery attempt to the participant failed, 401k Generation will redistribute the materials to such participants via a mailing. ERISA Section 3(16) Services o Participant Notification Services to include Sub-QDIA, Participant Fee Disclosure, Summary Plan Description, Safe Harbor Notice, and Auto Enrollment Notification. o Hardship Approval o Qualified Domestic Relations Order Services o Delivery of Enrollment Materials to Participants o 5500 Submission Participant Notification Services Required Notices. Beginning on or before 30 days of the Addendum Effective Date, 401k Generation will create and distribute to Plan participants the following required notices to the extent applicable to the design of the Plan: Annual Fee Disclosure Notice (required by ERISA Section 404(a)(5)) QDIA Notices (required by ERISA Section 404(c)(5)) Summary Plan Description (required by ERISA Section 101(a)(1)) Fee Disclosure Change Notices (required by ERISA Section 404(a)(5)) Blackout Notices (required by ERISA Section 101(i)) Summary of Material Modifications (required by ERISA Section 104(b)(1)) Summary Annual Report (required by ERISA Section 103(a)) Safe Harbor Notices (required by Code Section 401(k)) ACA, EACA, QACA Notices (required by Code Sections 401(k)(13), 414(w) Transaction Processing Services For distribution events occurring on or after the Addendum Effective Date, 401k Generation will provide the following transaction processing services: Distribution Processing Services. 401k Generation will: (1) accept and review a plan participant’s request for a Plan distribution, including termination, hardship, and in‐service (as applicable to the Plan); (2) communicate to participants, as necessary, about their distribution requests; and (3) oversee and authorize Plan distributions in accordance with the Plan through the assigned TPA. Qualified Domestic Relations Order Services 401k Generation will process qualified domestic relations orders under Code Section 414(p) (“QDRO”). 401k Generation will: (1) adopt reasonable QDRO procedures on behalf of the Plan; (2) accept and review any domestic relations order that purports to divide a participant’s benefit under the Plan to determine whether the order is a QDRO in accordance with the Plan, the law and the Plan’s QDRO procedures; (3) communicate to Plan participants and other necessary parties about the qualified status of a domestic relations order; (4) notify TPA to oversee and authorize any action necessary to freeze or otherwise handle a participant’s account as a result of a domestic relations order or a possible or pending domestic relations order that Employer or a third party communicates in writing to 401k Generation; (5) notify TPA to oversee and authorize the creation of the alternate payee’s account upon determination of a domestic relations order as a QDRO; and (6) notify TPA to oversee and authorize Plan distributions, if applicable, under a QDRO or by the alternate payee in accordance with the Plan. If a dispute arises between the Plan and a participant subject to a domestic relations order, 401k Generation will direct that dispute to the Employer to handle. Employer agrees to immediately notify 401k Generation of any possible or pending domestic relations order of which it becomes aware. Delivery of Enrollment Materials to Participants 401k Generation will distribute to participants via electronic delivery an enrollment booklet to enable the participants to enroll in the Plan. A hardcopy of the enrollment materials can be sent via a mailing upon request. Individual Managed Accounts Our individual managed accounts and investment advisory services consist of investment advice and portfolio model allocations as well as financial planning when requested. We have registered a DBA in Florida, Winter Park Wealth Management, primarily for use with such individual asset management accounts. Our advisory is capable of transacting business in most types of securities; however, our business model generally utilizes equities, fixed income, mutual funds, and ETFs. 401KG will manage assets on either a discretionary or non-discretionary basis on behalf of our client’s a specified in the Investment Advisory Agreement. Third-Party Money Managers We may also identify and monitor appropriate unaffiliated Third-Party Money Managers who will implement trading strategies for our clients. Any Third-Party Money Manager utilized will be party to an executed Agreement with 401K Generation; subject to a due diligence review; licensed as an investment advisor with the SEC and/or the appropriate state; and will provide its own ADV Part 2A disclosure document and client agreement to each client describing its services, compensation arrangements and any potential conflicts of interest.