A. TandemGrowth Financial Advisors, LLC (“TandemGrowth”) is a Georgia limited liability company formed on November 13, 2000, which became registered as an investment adviser in May 2003. TandemGrowth is owned by Jeffrey Bernier. Mr. Bernier is TandemGrowth’s Managing Member and Chief Compliance Officer. B. As discussed below, TandemGrowth offers financial planning and investment advisory services to its clients (generally, individuals, high net worth individuals, trusts and estates, etc.) on a fee basis. WEALTH MANAGEMENT SERVICES Clients may choose to engage TandemGrowth to provide “Wealth Management Services,” which include initial and ongoing financial planning services in addition to discretionary or non- discretionary investment advisory services. Before engaging TandemGrowth to provide Wealth Management Services, the client is required to sign a Wealth Management Agreement with TandemGrowth setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that are due from the client. The financial planning aspect of the Wealth Management Services addresses investment and non- investment related matters, which generally include, but are not necessarily limited to investment and retirement planning, education planning, legacy/estate planning, cash flow planning, income tax planning, goals-based investment planning, risk management planning, and stock option planning. The specific financial planning services generally include: ongoing review and communications regarding financial planning concepts, a discovery meeting, preparation and delivery of a “Financial Map” document that confirms the client’s financial goals and includes: a balance sheet, a summary cash flow schedule, a retirement analysis, an insurance summary, a needs analysis in the event of disability, an estate plan analysis, a survivor needs analysis, an education funding analysis and planning recommendations (as applicable). The financial planning services also include: an annual review, a semi-annual review, a year-end tax planning meeting with the client’s designated certified public accountant or other tax planning professional, joint meetings with the client’s other designated professionals, attendance at an annual market update luncheon, access to an online financial planning portal and access to account holdings (please see “Asset Aggregation / Reporting Services” disclosure below), receipt of a “TandemGrowth Perspectives Blog” and participation in client education workshops. The discretionary or non-discretionary investment advisory component of the Wealth Management Services addresses ongoing management of the client’s investment assets. To commence this part of the process, an investment adviser representative will confirm each client’s investment objectives based on the Financial Map and assist the client in selecting an appropriate strategy for managing their assets. TandemGrowth will then allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. TandemGrowth generally allocates or recommends that a client allocate client assets among various mutual funds and exchange traded funds (“ETFs”) consistent with one or more of the investment strategies described in Item 8 below. To a much lesser extent, TandemGrowth may make an exception to manage client assets on a non-discretionary basis and/or allocate investment assets among unaffiliated independent investment managers (“Independent Managers”) in accordance with the client’s designated investment objectives. In those situations, the Independent Managers will have day-to-day responsibility for the active discretionary management of the allocated assets. TandemGrowth will continue to provide investment supervisory services to the client through the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. When recommending Independent Managers, TandemGrowth generally considers the client’s designated investment objectives as compared to the Independent Manager’s management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers are exclusive of, and in addition to, TandemGrowth’s ongoing investment advisory fee, subject to the terms and conditions of a separate agreement between the client and the Independent Managers. Once TandemGrowth allocates client assets, it provides ongoing monitoring and review of portfolio performance and asset allocation as compared to client investment objectives and may periodically execute or recommend execution of transactions for the portfolio based upon those reviews or upon other triggering events. Except as confirmed in writing to the client, TandemGrowth assumes that there are no restrictions on its services, other than to manage the account in accordance with the client’s designated investment objectives. Clients who own variable annuities can also engage TandemGrowth to manage their variable annuity subaccounts as part of their overall investment portfolio. A variable annuity is a deferred annuity that provides investment returns based on the performance of its “subaccounts.” Those subaccounts contain investment assets. Unless otherwise agreed in writing, the value of the subaccounts that clients engage TandemGrowth to manage would be included as part of TandemGrowth’s calculation of its advisory fee described in Item 5. TandemGrowth’s investment selection for the variable annuity subaccounts is limited to those made available by the variable annuity sponsor. Neither TandemGrowth, nor any of its employees: offer to sell variable annuity products to its clients; or are registered as, or associated with, a broker-dealer. Clients seeking to purchase or exchange variable annuities may seek a referral from TandemGrowth to an unaffiliated broker-dealer/insurance agency. However, neither TandemGrowth, nor any of its employees, will receive any portion of the fees or commissions earned by the unaffiliated broker- dealer/insurance agency. TandemGrowth’s only compensation related to variable annuities will be limited to the management of the investment subaccounts it is engaged to manage. Clients are not under any obligation to engage TandemGrowth to provide those services. The fact that TandemGrowth could earn an advisory fee on the variable annuity subaccounts presents a conflict of interest if TandemGrowth were to recommend that clients evaluate variable annuity products with unaffiliated broker-dealers/insurance agencies. TandemGrowth mitigates that conflict of interest by reminding clients that they are not under any obligation to purchase variable annuities or engage TandemGrowth to manage variable annuity subaccounts. NEXTGEN SERVICES In limited circumstances as a courtesy to existing clients, TandemGrowth offers its “NextGen Services” (“NextGen”) to adult children of TandemGrowth’s existing clients. Those clients can choose to engage TandemGrowth to provide initial and ongoing financial planning and/or investment advisory services as further described below. NEXTGEN FINANCIAL PLANNING SERVICES Clients who qualify for the NextGen Services may choose to engage TandemGrowth to provide initial and ongoing financial planning services for an initial fee and a recurring monthly fee. These financial planning services address investment and non-investment related matters, which may include, but are not limited to investment and retirement planning, education planning, legacy/estate planning, cash flow planning, goals-based investment planning, and risk management planning (as applicable). The specific financial planning services include ongoing review and communications regarding financial planning concepts, a discovery meeting, preparation and delivery of a “Financial Map” document that confirms the client’s financial goals and includes: a balance sheet, a summary cash flow schedule, a retirement analysis, an insurance summary, a needs analysis in the event of disability, an estate plan analysis, a survivor needs analysis, an education funding analysis and planning recommendations (as applicable). The NextGen ongoing financial planning services also include an annual review, attendance at an annual market update luncheon, access to an online financial planning portal and access to portfolio holdings, receipt of a monthly “TandemGrowth Perspectives Blog” and participation in client education workshops. Before engaging TandemGrowth to provide such initial and ongoing financial planning services, clients are required to enter into a NextGen Financial Planning and Consulting Agreement with TandemGrowth setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fees that are due from the client. NEXTGEN INVESTMENT ADVISORY SERVICES Clients who qualify for NextGen Services may also choose to engage TandemGrowth to provide discretionary investment advisory services under the terms and conditions of a NextGen Investment Advisory Agreement. To commence the NextGen investment advisory process, an investment adviser representative will coordinate with the client to develop their

investment objectives, and then allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. TandemGrowth generally allocates or recommends that a client allocate client assets among various mutual funds and ETFs consistent with one or more investment strategies described in Item 8 below. To a much lesser extent, TandemGrowth may make an exception to manage client assets on a non-discretionary basis and/or allocate investment assets among independent managers. Once allocated, TandemGrowth provides ongoing monitoring and review of portfolio performance and asset allocation as compared to client investment objectives, and TandemGrowth may periodically execute or recommend execution of transactions for the portfolio based upon those reviews or upon other triggering events. Except as confirmed in writing to the client, TandemGrowth assumes that there are no restrictions on its services, other than to manage the account in accordance with the client’s designated investment objective. MISCELLANEOUS ERISA / IRC Fiduciary Acknowledgment. When TandemGrowth provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way TandemGrowth makes money creates some conflicts with client interests, TandemGrowth operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, TandemGrowth must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that TandemGrowth gives advice that is in the client’s best interest; charge no more than is reasonable for TandemGrowth’s services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If TandemGrowth recommends that a client roll over their retirement plan assets into an account to be managed by TandemGrowth, such a recommendation creates a conflict of interest if TandemGrowth will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by TandemGrowth. Order Management System. As part of its investment advisory services, TandemGrowth may manage clients’ retirement plan accounts (generally 401(k), 403(b) or profit-sharing plans) on a discretionary basis using an “Order Management System.” The Order Management System allows TandemGrowth to access and manage the client’s designated retirement plan account maintained on platforms where TandemGrowth would otherwise need to collect the client’s personal login credentials to manage the account and therefore potentially trigger additional custody obligations. However, when clients engage TandemGrowth in this capacity, they are responsible to keep the Order Management System link / TandemGrowth’s login credentials active, so that TandemGrowth will be able to access and manage the respective account without delay. If TandemGrowth determines that an Order Management System link has become inactive, TandemGrowth will use its best efforts to notify the client to resolve the issue. However, clients will remain subject to TandemGrowth’s fees described in Item 5 even when TandemGrowth is not capable of executing trades because of the inactive link. Limitations of Financial Planning and Consulting/Implementation Services. TandemGrowth does not serve as a law firm, licensed insurance agency, or accounting firm, and no portion of its services should be construed as legal, insurance implementation or accounting services. Accordingly, TandemGrowth does not prepare estate planning documents, sell insurance products or prepare tax returns. Unless specifically agreed in writing, neither TandemGrowth nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. The client is solely responsible to revisit the financial plan or financial planning advice with TandemGrowth, if desired. The client retains absolute discretion over all financial planning and related implementation decisions and is free to accept or reject any recommendation from TandemGrowth and its representatives in that respect. TandemGrowth’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. To the extent requested by a client, TandemGrowth may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are under no obligation to engage the services of any recommended professional, who are responsible for the quality and competency of the services they provide. Client Obligations. When performing its services, TandemGrowth is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify TandemGrowth if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending TandemGrowth’s services or previous recommendations. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, TandemGrowth will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when TandemGrowth determines that trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Asset Aggregation / Reporting Services. TandemGrowth may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged TandemGrowth to manage (the “Excluded Assets”). TandemGrowth’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because TandemGrowth does not have trading authority for the Excluded Assets, the client (and/or another investment professional designated by the client), and not TandemGrowth, will be exclusively responsible for directly implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by TandemGrowth. Accordingly, TandemGrowth will not accept responsibility for adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without TandemGrowth’s participation or oversight. C. TandemGrowth provides investment advisory services specifically tailored to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. If engaged to do so, TandemGrowth will then allocate or recommend that the client allocate investment assets consistent with their designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on TandemGrowth’s services. D. TandemGrowth does not participate in a wrap fee program by providing portfolio management services. E. As of December 31, 2023, TandemGrowth had $234,120,097 in regulatory assets under management on a discretionary basis and $982,190 in regulatory assets under management on a non-discretionary basis.