A. Firm Information Well Done, LLC dba CapTrust Financial Advisors (hereinafter “CapTrust” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). CapTrust is organized as a limited liability company (“LLC”) under the laws of the State of Michigan. The Advisor was founded in 1997 and became a registered investment advisor in January 2015. CapTrust is primarily owned by Brian VandenBrink, Shawn Pacanowski, Bryan Linn, Brendon Johnson, and Rhonda Carter , all of whom believe in an employee-ownership structure. While this Disclosure Brochure generally describes the business of CapTrust, certain sections also discuss the activities of its Supervised Persons, which refer to the Advisor’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on CapTrust’s behalf and is subject to the Advisor’s supervision or control. For information regarding this Disclosure Brochure, please contact Rhonda Carter, the Chief Compliance Officer at (616) 392-5332. B. Advisory Services Offered CapTrust offers a variety of advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses and retirement plans (each a “Client”). The Advisor serves as a fiduciary to its Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate conflicts of interest. CapTrust’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics. Wealth Planning and Investment Management Services The Advisor’s Wealth Planning and Investment Management service includes regular and continuous Client interactions integrated with ongoing guidance and planning and portfolio management services. These services are defined below and may be offered on a stand-alone basis. Wealth Planning Services CapTrust offers Clients a broad range of Wealth Planning services as part of its comprehensive wealth management services or pursuant to a Client agreement. Services include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Investment Consulting
• Education Savings
• Retirement Planning
• Risk Management Charitable Giving Tax Planning
• Social Security Planning Generally, such planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. CapTrust may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor might not provide a written summary. Wealth Planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for Investment Management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Investment Management Services CapTrust manages Client investment portfolios on a discretionary or non-discretionary basis. CapTrust primarily allocates Client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, variable annuities and independent investment managers, as described below, in accordance with their stated investment objectives. In addition, CapTrust also recommends that certain eligible Clients invest in privately placed securities, which includes debt, equity and/or interests in collective investment vehicles (e.g., hedge funds, private equity funds, etc.). Where appropriate, the Advisor also provides advice about any type of legacy position or other investment held in Client portfolios. Clients may engage CapTrust to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, CapTrust directs or recommends the allocation of Client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. CapTrust tailors its advisory services to meet the needs of its individual Clients and seeks to ensure, on a continuous basis, that Client portfolios are managed in a manner consistent with those needs and objectives. CapTrust consults with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify CapTrust if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if CapTrust determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Advisor’s management efforts. At no time will CapTrust accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual

retirement accounts (“IRAs”), the Advisor is 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – When deemed to be in the Client’s best interest, CapTrust will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an investment management platform. CapTrust serves as the Client’s primary Advisor and Relationship Manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. CapTrust will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. CapTrust will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. CapTrust does not receive any compensation from these Independent Managers, other than its investment advisory fee as described in Item 5 below. Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to non-purpose loan programs available through the Custodian’s banking partner (“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non- purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose loans, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. Fully Paid Securities Lending – The Custodian allows Clients to enroll in their Fully Paid Securities Lending program (“FPSL”) which enables Clients to lend certain securities to the Custodian in exchange for additional income in their portfolios. Securities lending is when a Client temporarily loans securities to a financial institution. The Client will enter into a separate loan agreement that will cover the terms of the loan. Pershing utilizes the securities to satisfy both internal and external borrowing needs. The Custodian will earn revenue from lending these securities and a portion of that revenue will be shared with the Client. The Advisor does not earn any additional revenue for Clients who choose to enroll in FPSL. Retirement Plan Advisory Services CapTrust provides advisory services on behalf of company retirement plans (each a separate “Plan”) and the company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Vendor Analysis
• Investment Policy Statement (“IPS”) Design and Monitoring Plan Participant Enrollment and Education Tracking
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance These services are provided by CapTrust serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of CapTrust’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to CapTrust rendering any of the aforementioned advisory services, the Client is required to enter into one or more written agreements with CapTrust setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
• Establishing an Investment Strategy – CapTrust, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – CapTrust will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – CapTrust will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – CapTrust will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs CapTrust typically includes the securities transaction fees together with its Investment Management fee. The combination of these fees into a single, “bundled” fee is called a Wrap Fee Program. CapTrust serves as the sponsor and portfolio manager of the CapTrust Wrap Fee Program. In the event the Client is provided Investment Management services under the CapTrust Wrap Fee Program, securities transaction fees for the Advisor’s discretionary trading in the Client’s account[s] will be covered under the Wrap Fee Program. Clients may pay a higher or lower aggregate fee than if investment management and brokerage services are purchased separately, depending on the level of trading in the Client’s account[s]. A complete description of the CapTrust Wrap Fee Program is contained in the Appendix 1 – Wrap Fee Program Brochure, which is included as part of this overall Disclosure Brochure. CapTrust manages wrap fee accounts in substantially the same fashion as non-wrap fee accounts. E. Assets Under Management As of December 31, 2022, CapTrust manages $1,516,340,746 in Client assets, $1,507,734,827 of which are on a discretionary basis and $8,605,919 of which are on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.