Soltis Investment Advisors, LLC (“Soltis”) is owned by eight partners. Soltis provides its Clients2 with the following Advisory Services which we refer to as The Investment Management Discipline: 1. Review of Client’s Investment Goals and Objectives. Each Client is provided an Investment Policy Statement as a result of this review which details the Client’s investment guiding principles, risk tolerance, portfolio asset allocation, investment selection, and performance expectations. 2. Recommend an Appropriate Asset Allocation and Investment Selection. Based on the Client’s Investment Policy Statement, Soltis recommends a Portfolio strategy, which includes a general allocation by Asset Class (i.e. stock, bonds, cash, ETFs, mutual funds, and private alternative investment vehicles) in combination with risk characteristics and return expectations. Soltis’ portfolios are developed (based on Modern Portfolio Theory Principles and other methods and techniques) to provide diversification by both Asset Class and Style to maximize the risk-adjusted return based on the Client’s risk return profile. Securities are selected based on a continuous qualitative and quantitative review of their valuations, performance relative to appropriate market indices, and their respective peer group and expected performance. Securities are either retained or replaced based on performance as defined by Soltis’ investment selection criteria. Soltis has conducted due diligence on certain independent registered investment advisors and enters into written sub-advisory agreements to provide Investment Advisory Services to a selected portion of Soltis’ Client portfolios, as appropriate. Soltis may also enter into additional written sub-advisory agreements with other third-party registered investment advisors, from time to time, as it deems appropriate and in the best interests of our Clients. Soltis will monitor the selected sub- advisor(s) and may, from time to time and in its sole discretion, hire and/or replace any sub-advisor as part of our engagement to manage the Client’s portfolio(s) consistent with the Client’s objectives. Soltis will ensure that, as appropriate, the Client receives a copy of the disclosure document (Form ADV, Part 2, or other disclosure document in lieu of Part 2) of any sub-advisor selected to manage all, or a portion of, a Client’s account assets. 3. Financial Planning and Consulting Services: Soltis may provide its Clients with a broad range of comprehensive financial planning and consulting services, which may include non-investment related matters. These services generally address a multitude of retirement related matters, including retirement plan analysis, retirement income analysis, estate preservation, charitable giving and asset protection strategies. For Clients who only require advice on a single aspect of their financial resources, Soltis’ consulting services are generally more appropriate. 2 That meet the minimum account threshold of $750,000.00 or greater In performing its services, Soltis is not required to verify any information received from the Client or from the Client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Soltis may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Soltis recommends its own services. The Client is under no obligation to act upon any of the recommendations made by Soltis under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Soltis itself. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Soltis’ recommendations. Clients are advised that it remains their responsibility to promptly notify Soltis if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Soltis’ previous recommendations and/or services. Soltis, in its sole discretion, may agree to provide advisory services to Clients that do not meet its minimum account size threshold. In these circumstances, not all of the above-referenced services may be available or provided in the same manner. Specific advisory services will be set forth in the Client Investment Advisory Agreement. 4. Pension/401(k) Consulting Advisory Services Soltis also provides investment planning, implementation advice, and portfolio management assistance to 401(k) retirement and pension plans. As part of its services, Soltis works with its Clients to develop Investment Policy Statements which include asset allocation and investment recommendations. Soltis delivers written reports for review and discussion, on a quarterly basis, which include performance evaluations of each investment option and each portfolio, comparative performance for established benchmarks and for peer institutions, and assessment of asset allocation and if needed, for rebalancing. Additionally, Soltis’ relationship managers present reports to Clients or to its Clients’ Investment Committees on at least an annual basis. The Soltis relationship manager will also assist Client and/or the Client’s Investment Committee with regular review and updates of Investment Policy Statements including asset allocation, fund manager selection, and selection of appropriate benchmarks. Other services provided may include custodian review and analysis, ongoing research and education, and portfolio manager searches, including non-traditional asset classes. In 2019, Soltis began to provide discretionary management services to its Pension and 401(k) Clients through the use of Collective Investment Trusts / Funds

(“CIT / CIF”) established through the Alta Trust Company. CIT / CIFs look and act very much like mutual funds. However, CIT / CIFs are issued by a bank and are not registered with the Securities and Exchange Commission. The CIT / CIF units are not registered under the Investment Company Act of 1940, as amended, (“1940 Act”) or other applicable law and are not securities registered under the Securities Act of 1933, as amended or applicable securities laws. CIT / CIFs are regulated by federal banking regulators, such as the OCC (Office of the Comptroller of the Currency) and state banking regulators. CIT / CIF’s are only available to qualified retirement trusts such as 401k, Profit Sharing, Defined Benefit and government retirement plans. CIT / CIFs offer the same kind of diversification as a mutual fund but also add an additional layer of fiduciary protection. CIT / CIFs generally provide a retirement vehicle that is much lower in cost than the typical mutual fund. In certain situations, in retirement plans, a conflict of interest may arise when Soltis makes recommendations about plan distributions and rollovers (“rollover recommendations”), if it results in Soltis receiving compensation that it would not have received absent the recommendation. These include, for example, fees for advising a participant in a retirement plan on a rollover IRA or an individual investor on the transfer of an IRA from another firm. Soltis will manage this conflict through a process designed to develop an informed recommendation in the best interest of the Client. No Client is under an obligation to roll over ERISA plan or IRA assets to an account advised by Soltis. The rollover recommendations occur in several scenarios. The first is where Soltis is serving as a fiduciary adviser to a private sector retirement plan, for example, a 401(k) plan. In that case, the rollover recommendation is fiduciary advice under both the Investment Advisers Act of 1940 (Advisers Act) and the Employee Retirement Income Security Act (ERISA). In addition to being a conflict of interest as described above, it is also a prohibited transaction under ERISA where Soltis receives compensation from the rollover IRA that is greater than the compensation, if any, being received from the participant’s account in the plan. In that circumstance, Soltis will comply with the conditions of exceptions to the prohibited transaction rules (e.g., a prohibited transaction exemption or non-enforcement policy). Another scenario is where Soltis is not providing ERISA fiduciary advisory services to the plan. In that case, a rollover recommendation is not a prohibited transaction under ERISA, but it is a conflict of interest under the Advisers Act because of the compensation received by Soltis from the rollover IRA. 5. Soltis Automated Portfolio Management Services Soltis offers an automated investment service (the “Service”) through which Clients are invested in a range of investment strategies that Soltis has constructed and manage, each consisting of a portfolio that may include exchange-traded or mutual funds (“Funds”) and a cash allocation. The Client may instruct us to exclude up to three 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”). Soltis uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Service. Soltis is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). Soltis, and not Schwab, are the Client’s investment advisor and primary point of contact with respect to the Service. Soltis is solely responsible for determining the appropriateness of the Service 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. Soltis has contracted with SPT to provide the Platform, which consists of technology and related trading and account management services. The Platform enables Soltis to make the Service 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 can help determine the Client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that, if Soltis uses the online questionnaire, Soltis 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, however Soltis will make the final decision and select a portfolio based on all the information Soltis has about the Client. The System also includes an automated investment engine through which Soltis manages the Client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the Client is eligible and elects). Soltis charges Clients a fee for services as described below under Item 5 Fees and Compensation. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Service. Schwab does receive other revenues in connection with the Service. As of December 2023, Soltis provides advisory services on more than $8.47 billion dollars which is comprised of $6.82 billion in Assets Under Management (“AUM”) and more than $1.65 billion of Assets Under Advisement (“AUA”). One of the reasons behind Soltis’ increase in AUM was due to the continued rollout of its CIT / CIF discretionary program for its pension and 401(k) Clients.