General Information Secrest Blakey & Associates, LLC d/b/a Southeast Financial Group (“SEFG”) was formed in 2009 (and registered as an investment adviser in 2012. SEFG provides financial planning and investment portfolio management services to its clients. Edward B. Secrest is the principal owner of Southeast Financial Group, Inc., As of December 31, 2023, SEFG manages $131,377,481 of assets on a discretionary basis, and $46,444,104 of assets on a non-discretionary basis. SERVICES PROVIDED At the outset of each client relationship, SEFG spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Clients may elect to retain SEFG to prepare a full financial plan. This written report is presented to the client for consideration. In most cases, clients subsequently retain SEFG to manage the investment portfolio on an ongoing basis. For those financial planning clients making this election, and for other clients who do not need financial planning but retain SEFG for portfolio management services, based on all the information initially gathered, SEFG generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments SEFG will make on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. Finally, where SEFG provides only limited financial planning or general consulting services, SEFG will work with the client to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances. Financial Planning This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. Depending on a client’s particular situation, financial planning may include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning;
• Assessing risk and reviewing basic health, life and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have SEFG implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by SEFG under a financial planning engagement and/or engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, SEFG meets with the client, asks questions, gathers information and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by SEFG based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, SEFG will manage the client’s investment portfolio on a discretionary basis or a non-discretionary basis. As a discretionary investment adviser, SEFG will have the authority to supervise and direct the portfolio without prior consultation with the client. Under a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able

to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on SEFG in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of SEFG. Alternative investment strategies may be implemented to complement core holdings to create a holistic approach to asset management and assist in meeting longer-term financial planning goals. SEFG assists clients with the implementation of alternative investment strategies when Accredited Investor, Qualified Client and/or Qualified Purchaser definitions are met. These strategies include, but are not limited to investments in hedge funds, private equity, private markets including diversified real estate, infrastructure, private credit, real estate, structured notes and certificates of deposit, opportunity zones, 1031 exchanges, exchange funds, and interval funds. These strategies are applied to a portion of the portfolio managed toward longer-term trends and economic views where all factors of the client’s suitability and liquidity have been met. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. SEFG will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we 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 may be offered individually or as part of a comprehensive suite of services. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, SEFG will be considered a fiduciary under ERISA. For example, SEFG will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among which Plan Participants may select. With respect to any account for which SEFG meets the definition of a fiduciary under Department of Labor rules, SEFG acknowledges that both SEFG and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between SEFG and Client. Fiduciary Consulting Services
• Investment Selection Services SEFG will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice SEFG provides Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding asset classes and investments.
• Investment Monitoring SEFG will assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and SEFG will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties.