Our Advisory Business Novus Advisors is a registered investment adviser with the Securities and Exchange Commission (“SEC”). The Adviser has been in business since 2011. The principal owners of Novus are Jennifer M. Belshe, Member and Christopher G. Connelly, Member. Services Novus provides its clients with investment advisory services consisting of discretionary and non- discretionary asset management through the use of equity, fixed income and balanced portfolios and Financial and Retirement Planning. Novus does not provide legal, tax or accounting advice or services and clients should not assume that Novus is providing such services at any time. Also, clients should understand that, generally speaking, securities or other investments for which Novus provides advice to clients are not deposits or obligations of any bank, are not endorsed or guaranteed by any bank and are not insured by the Federal Deposit Insurance Corporation, the Federal Reserve Board or any other governmental agency and that neither Novus nor any of its affiliated companies is a trust or banking institution. Active Asset Management Asset Management service will involve the use of mutual fund and exchange-traded fund portfolios and/or the purchase and sale of individual securities which Novus may implement for clients directly. In addition, where deemed appropriate, Novus may provide access to particular investment products such as fixed-indexed annuities or other insurance products through an affiliated company. Novus’ services and processes are designed to determine and address each client’s specific investment needs through formulation of an asset allocation strategy tailored to meet the client’s financial situation, objectives, time horizon, income needs and risk tolerance. Clients may also impose restrictions on Novus’ ability to implement particular types of investments on his or her behalf. * Please note that pursuant to the investment advisory agreement you are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. * Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. Additionally, trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Periodically, your account may need to be rebalanced or reallocated in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur as required or pursuant to the schedule we have determined together. You will be responsible for all tax consequences resulting from the sale of any security, rebalancing or reallocation of the account. You are responsible for any taxable events in these instances. We are not Novus Advisors ADV Part 2A Page 5 of 22 tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. Outside Money Managers We may determine that opening an account with a professional third-party money manager is in your best interests. We have contracts with several third-party money managers. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may:
• Assist in the identification of investment objectives
• Recommend specific investment style and asset allocation strategies
• Assist in the selection of appropriate money managers and review performance and progress
• Recommend reallocation among managers or styles within the program
• Recommend the hiring and firing of money managers utilized by you. You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur. Financial and Retirement Planning Through this process we explore areas such as cash flow analysis, retirement planning, investment management, risk management, tax management, education planning and estate planning. We approach each situation with creativity, commitment and expertise to put a plan in place that best suits your individual needs and goals. As you work towards your goals, we will work with you to monitor your progress, and make adjustments as needed. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. Novus Advisors ADV Part 2A Page 6 of 22 It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. ERISA Novus offers various levels of advisory and consulting services to employee benefit plans (“Plans”) and to the participants of such plans (“Participants”). The services are designed to assist plan sponsors (“Plan Sponsors”) in meeting their management and fiduciary obligations to the Participants under the Employee Retirement Income Securities Act (“ERISA”) and the Pension Protection Act of 2006 (“PPA”). Novus will provide services to Plan Sponsors and their Participants in the form of education services to Plan committees, Participant education services, developing an investment policy statement, providing investment recommendations and performance monitoring, selection of Qualified Default Investment Alternative (“QDIA”), and providing general information about the Plan to Plan Sponsors and Participants. Plan Sponsors must make the ultimate decision to retain Novus for pension consulting and other advisory services including, but not limited to, services at the Participant level. The Plan Sponsor is free to seek independent advice about the appropriateness of any recommended services for the plan. Both parties acknowledge that if the Account is subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA), the following provisions will apply:
• The Adviser acknowledges that it is a “fiduciary” with respect to the Client as that term is defined under Section 3(21)(A) of ERISA.
• The person signing this Agreement on behalf of the Client acknowledges its status as a “named fiduciary” with respect to the control and

management of the assets held in the Account, and agrees to notify the Adviser promptly of any change in the identity of the named fiduciary with respect to the Account;
• The Adviser agrees to obtain and maintain an ERISA bond satisfying the requirements of Section 412 of ERISA and include The Adviser and its members, agents and employees among those insured under that bond unless provided by the Plan. When delivering ERISA fiduciary services, we will perform those services for the retirement plan as a fiduciary and will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. In our capacity as a 3(21) plan fiduciary, we will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the plan sponsor in determining the appropriate model(s)investment(s) for the retirement plan. Novus Advisors ADV Part 2A Page 7 of 22 Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Adviser will not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. The Adviser will/will not communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. The Adviser will provide the Plan Sponsor with a sample investment policy statement. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the Adviser’s investment advisory services. The Adviser offers the following 3(21) services:
• Plan design and asset selection consultation
• Develop and annually review Investment Policy Statement (“IPS”)
• Develop investment menu according to the IPS
• Review plan sponsor’s stated financial criteria for each investment option
• Monitor each investment option according to the IPS
• Quarterly portfolio statements, rate of return reports, asset allocation statements
• Provide investment research and performance information on investment options
• Investment option replacement guidance
• Personal consultations with the plan sponsor as necessary
• Develop Plan Investment Committee Charter, as needed
• Fiduciary due diligence assistance
• Attendance at Plan Committee and other meetings
• Annual Fiduciary Plan Review
• Fiduciary education services to Plan Committee
• Participant education, guidance, and enrollment
• Vendor coordination assistance
• Benchmarking services The Adviser will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors Novus Advisors ADV Part 2A Page 8 of 22 including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. The Client confirms that any instructions that have been given to the Adviser with regard to the Account are consistent with the governing plan documents and investment policy statements of the plan. Except as otherwise provided under ERISA the Adviser shall not be liable for any error of judgment or mistake of law or for any loss suffered by the Client in connection with the matters to which this Agreement relates except a loss resulting from the Adviser’s breach of its fiduciary duty, negligence, misconduct or bad faith. The Adviser is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended (the “Code”); The Adviser is neither a law firm nor a public accounting firm and Adviser will not provide legal or accounting advice; The Client acknowledges that the services covered by this Agreement are consultative, and give no investment authority (“discretion”) or responsibility to the Adviser over any assets of the Plan or Participant regardless of how and where the assets are held. Throughout the term of this Agreement, the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held with any affiliated or unaffiliated third-party. The Adviser encourages plan sponsors to consult with other professional advisors since we do not provide tax or legal advice that may affect asset classes or allocations. The Adviser will apply any guidelines the client supplies, as directed, however, compliance with these restrictions or guidelines, is the client’s responsibility. Non-Discretionary 3(21) Fiduciary Services When the Adviser performs “3(21) Fiduciary Services,” the Adviser will act as a co-fiduciary “investment adviser” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Adviser will not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. The Adviser will/will not communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. Novus Advisors ADV Part 2A Page 9 of 22 Discretionary 3(38) Fiduciary Services When a client engages the Adviser to perform “3(38) Fiduciary Services”, the Adviser acts as an “investment manager” (as defined in Section 3(38) of ERISA) with respect to the performance of discretionary fiduciary investment services. Under this arrangement the Adviser is appointed by the Plan Sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions related to the plan assets. Wrap Fee The Adviser does not sponsor or participate in a third-party sponsored wrap fee program. Assets Under Management As of December 31, 2023, we had a total of $ 211,796,328; $132,265,226 in discretionary assets under management and $79,531,102 in non-discretionary assets under management.