Description of Services and Fees Fiduciary First, LLC (“Adviser”) is a registered investment adviser based in Central Florida. The Adviser is organized as a limited liability company under the laws of the State of Florida and the Adviser provides investment advisory services and Retirement Plan Fiduciary Process services referred to as "Prudent Fiduciary Process". The Fiduciary First consulting platform has been offered through third party intermediaries since 1985. As of October 1, 2018, Fiduciary First LLC was wholly acquired by NFP Retirement Inc. and its affiliated owners. However, Fiduciary First will maintain its separate registration as an investment adviser. NFP Retirement Inc. is owned by NFP Corp. NFPR provides comprehensive qualified and non-qualified retirement plan consulting, investment advice and fiduciary due diligence services, employee plan and investment education, asset allocation services, plan service provider proposal and provider research and analysis, and plan design guidance to individuals, qualified and non-qualified retirement plan sponsors, and business entities. The Adviser also provides asset management and investment and financial consulting services for individuals to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. The Adviser’s retirement plan consulting services are tailored to meet the needs and objectives of the Plan and the Plan sponsor, investment committees, and other fiduciaries responsible for managing the Plan (individually, a "Plan Fiduciary" and collectively, the "Plan Fiduciaries"). Retirement plan consulting services the Adviser provide may include, but are not limited to, one or more of the following:
• Managing the organizational, Plan goals and success objectives of the Plan - interview the Plan Committee and benchmark successful fulfillment of plan objectives.
• Managing a robust and consistent Fiduciary Process on behalf of the Plan -set up a quarterly calendar of fiduciary behaviors and document the process.
• Maintain a server based encrypted "Client Lockbox " - hold all relevant documentation regarding plan fiduciary process and maintain a living record of fiduciary process.
• Developing and implementing a written Investment and Education Policy Statement - submit draft for Plan Committee approval and monitor the Plan's adherence to the Statement.
• Developing, Evaluating and monitoring Plan investments and investment options - use of highly advanced analytical tools to confirm compliance with the policy statement and ERISA, GFOA and other governance bodies.
• Monitoring and managing the Plan's pursuit of Safe Harbor Status and other Risk Management Strategies - assist with processes in place to accomplish various safe harbors including Regulation 404(c).
• Third party investment manager/mutual fund searches and recommendations - via proprietary benchmarking and ranking technology.
• Asset allocation advice - for plan portfolios that are not participant directed; Efficient Frontier modeling and asset allocation guidance.
• Legal and Compliance Research - assist with use of internal and outsourced legal and technical resources.
• Plan Design - in coordination with the plan's designated recordkeeping vendor and in conjunction with Plan Committee goals; develop strategies to implement client objectives.
• Establishment of Benchmarks - assist with comparison

and contrast dozens of plan profile characteristics and information with plan peer group.
• Bonding and Insurance - request and verify current coverage and hold copies in Client Lockbox.
• Vendor relationship management/coordination - assist with routine vendor interaction and coordination of Plan Committee decisions.
• Analysis of investment segmentation - opine on investment styles, overlap and style drift.
• Fiduciary Review and Provider Benchmarking - assist with routine review of internal fiduciary processes and benchmark against peer group.
• Firm, operational and Investment fiduciary advice - serve in the capacity as an ERISA 3(21) investment advisor or ERISA 3(38) investment manager as defined by the service agreement for these services.
• Monitoring and management of plan committee activities -assist with quarterly schedule of plan committee due diligence.
• Executive benefits - if requested; assist with advisory on non-qualified deferred compensation plans.
• ERISA trust merger and acquisition - assist with due diligence and fiduciary process on acquisitions and divestitures of entities sponsoring retirement plans.
• Fiduciary process outsourcing - provide robust and comprehensive process as coordinated with the client.
• Education & Regulation 404(c) Compliance - review existing internal fiduciary process and recommend adjustments to comply with regulation 404(C) or other risk management strategies.
• QDIA Compliance - review existing internal fiduciary process and recommend adjustments to comply with regulation 404(C)5.
• Fee and cost oversight - assist with development of an ERISA or retirement plan budget and monitor routinely. The Adviser will provide retirement plan consulting services to Plans and Plan Fiduciaries as described above. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain the Adviser; (ii) agree to the scope of the services that the Adviser will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that the Adviser may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement plan consulting services are offered individually or as part of a comprehensive suite of services which can be used with any Plan provider, record keeper, or Plan administrator. Types of Investments The Adviser primarily offers advice on 1940 Act registered funds (“mutual funds”). The Adviser may also recommend third party investment managers and may provide advice on annuity contracts or on publicly traded securities. Agreement Termination Agreement may be terminated by any party effective upon receipt of written notice to the other parties. Clients who terminated mid-calendar quarter will incur a pro rata charge for services rendered from the quarter begin date through date of termination. If clients have pre-paid advisory fees they will receive a refund of any unearned fees prorated from termination date through quarter end. Assets Under Management As of December 31, 2023, the Adviser provides management services for $2,363,436,792 in client assets on a discretionary basis and $944,140,348 in client assets on a non-discretionary basis.