We provide investment management and advisory services to individual clients, as well as trusts, qualified retirement plan sponsors, and business entities. We are a fee-only firm. The firm has been in business since 2006. Advice is provided through consultation with you and may include determination of financial objectives, identification of financial problems, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Our main business, however, is investment management. We provide both discretionary and non-discretionary services. With non-discretionary services, client approval is obtained before entering transactions. When we have discretionary trading authority, we have the authority to determine, without obtaining your specific consent, the securities to be bought or sold. We do not act as a custodian of your assets. You always maintain asset control. We place trades for you under a limited power of attorney. Whenever practical, we generally recommend the mutual fund share class with lowest annual expense ratios that your custodian offers. That sometimes includes institutional share classes. At times we may recommend other low-cost investment solutions, such as ETFs, stocks, individual fixed income securities, and other products. For more on our investment philosophies, and the risks of our strategies and/or specific investments recommended, please refer to Item 8. We actively seek to avoid, or at least minimize, conflicts of interest which may exist between our firm and you. We sell no products. We accept no commissions or other fees. However, all investment advisory firms will likely possess some unavoidable conflicts of interest. In those instances when conflicts of interest arise, we have adopted policies which seek to keep your best interest’s paramount at all times. See Items 5, 11 and 12 of this Brochure, and other items, which explore in further detail how we act to keep your best interests first at all times during the course of relationship with you. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by you on an as-needed basis. Conflicts of interest will be disclosed to you in the unlikely event they should occur. We often know professionals that we can refer you to; we never accept fees for those referrals. The initial meeting with potential clients, which may be in person or by telephone, is free of charge and is considered an exploratory interview to determine the extent to which investment management may be beneficial to you. Our Principal Owners Jerold Tweddell and Steven Goldberg is a members and principal owners of the Firm. Types of Advisory Services Asset Management As of December 31, 2023, we manage $121,320,324 in assets individual clients, high net worth client, and pension and profit sharing plans. The total asset managed consist of $77,151,154 on a discretionary basis, and $44,169,170 is managed on a non-discretionary basis. We provide investment supervisory services, also known as asset management services (discretionary); manage investment advisory accounts not involving investment supervisory services (non-discretionary); and furnish investment advice through consultations. On an occasional basis, we may furnish advice to you on matters not involving securities, such as financial planning matters and taxation issues. Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually through discount brokers or fund companies. Fund companies

charge each fund shareholder annual expenses that are disclosed in the fund prospectus. Discount brokerages charge a transaction fee for the purchase of some funds. We sometimes buy funds with higher expense ratios for you when discount brokerages offer them without charging transaction fees and we are investing a relatively small amount of money in that fund at that time. We always try to act in your best interests in choosing among different share classes of mutual funds. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The brokerage firm may charge a fee for stock and bond trades. We do not receive any compensation, in any form, from fund companies or brokerages. Investments may also include warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, U. S. government securities, and options contracts. Management of Conflicts of Interest between Clients Our relationship with you is non-exclusive; in other words, we provide investment management and advisory services to multiple clients. We seek to avoid situations in which one client’s interest may conflict with the interest of another of our clients. More information about this policy is found in your Client Agreement. Comparable Services We believe that the charges and fees charged by brokers/custodians we use are competitive with alternative programs available through other firms offering a similar range of services; however, lower fees for comparable services may be available from other sources. Management of Conflicts of Interest Relating to the Fees We Receive, and Receipt of Percentage-Based Compensation. The vast majority of our clients pay us fees based upon a percentage of the assets we advise upon. This is a very common form of compensation for registered investment advisory firms and avoids the multiple inherent conflicts of interest associated with commission-based compensation (we do not accept commission-based compensation of any nature, nor do we accept 12b-1 fees). We endeavor at all times to properly manage potential conflicts of interest. Our goal is that our advice to you remains at all times in your best interests, disregarding any impact of the decision upon our firm. Each time such a potential conflict may arise, we will give you notice, usually orally, of the conflict in that given situation if our advice regarding the proposed transaction would impact our compensation. Our Services are Tailored to Meet Your Needs and Investment Restrictions. In general, our advisory services are designed to meet your needs. While model portfolios may be utilized, each investment portfolio is individually tailored. If your circumstances change, it is the client’s responsibility to notify us. During any 12-month period, clients will communicate with us under normal circumstances. If there has been no contact(s), as appropriate, you will confer with us at least annually to review any changes to your financial situation, and your investment portfolio. After consultation with us, you may impose restrictions on investing in certain securities or types of securities. This most often occurs when you request certain social investing needs be addressed, such as through the use of mutual funds which avoid investments in certain companies. Other restrictions may be imposed by you with respect to the (average or longest) maturity or credit quality of fixed income investments. Our Agreement with you may not be assigned without your consent.