Tingey Advisors, Inc. (hereafter “Tingey Advisors” or “TA”), operating as a DBA of Cannon Tingey Investment Advisors, Inc., is a fee-based investment advisor founded in 1996 that manages approximately $421 Million of discretionary assets (as of 12/31/23) for approximately 978 portfolio accounts representing approximately 393 client relationships. TA provides personalized portfolio management service and investment advice according to specific client objectives. Principal owners include Alan B. Tingey, CFA and Jon D. Tingey, CFA - each owning 50% of the firm. TA may, on occasion, furnish Version Date: 31 March 2024 2 advice to clients on matters not involving publicly traded securities; however, such advice does not involve recommendations of private securities offerings and represents less than 5% of total revenues over the past five years. In addition to discretionary assets under management disclosed on this ADV, TA also advises on non-discretionary portfolios that include but are not limited to qualified retirement plans or 401(k) plans. Initial Consultation Tingey Advisors generally offers a free consultation service to accomplish the following: 1) introduce the client to TA, it’s principals, portfolio managers and its services, 2) gather information about the client’s investment objectives, risk tolerance and other factors critical to the investment decision making process, 3) agree to terms of service and compensation, and 4) execute custodial account-opening, management and investment guideline documents. TA will also offer the prospective client, a Client Relationship Summary which provides relevant information in the process of choosing an investment advisor. Additionally, TA provides the firm’s Disclosure Brochure describing TA’s business process, fees, and other information. Portfolio Management Services TA provides portfolio management services to individuals, small businesses, and institutions. TA takes a personal approach to investing. TA evaluates the client’s risk tolerance in order to establish investment objectives which are used to determine portfolio investment guidelines. This process allows TA to tailor its investment advice and portfolio management services to meet client needs. As part of the analysis of client risk and objectives, portfolios are categorized as, one of the following: 1) “Growth”, 2) “Income”, 3) “Balanced”, 4) “Balanced with Growth Bias”, or 5) “Balanced with Income Bias”. Growth portfolios, by objective, hold primarily common stocks. Income portfolios primarily hold bonds. Balanced portfolios hold a combination of stocks and bonds. TA uses a low-turnover, prudently diversified strategy wherein many different stocks and/or bonds will exist in the portfolio at any given time. Unless otherwise stipulated, the clients

give TA full discretion to manage client portfolios in accordance with mutually agreed upon investment guidelines. 401(k) or other Qualified Plan Consulting Services & Selection of Advisors TA provides financial advisory services to qualified retirement plans, including 401(k) and other defined compensation plans for a fee calculated as a percentage of assets under management (AUM fee). As such, TA recommends, for plan trustee approval, certain mutual funds to become part of the asset selection list for participants in a given plan. While the ultimate structure of the plan is the responsibility of the trustees (which is not the role of TA), the trustees may rely upon the advice of TA in developing an appropriate line up of mutual funds for the plan’s participants to select their investments. Educational Seminars As part of its retirement plan service for qualified plans, TA may from time to time engage in seminars to educate qualified plan participants during enrollment meetings. No additional fee is charged beyond the AUM fee referred to above. TA may also engage from time to time in educational sessions for its traditional portfolio management clients, both individually and collectively, as part of its overall service. TA may sponsor an annual “Financial Markets Outlook” luncheon or webcast, where clients are invited to hear analysis of financial markets. Statements and Newsletters TA may provide quarterly statements of account to clients along with the monthly statements they receive from their selected custodian. TA may also deliver a quarterly newsletter containing a summary of the markets and general economic and financial information to the clients with their quarterly statement. TA may, from time to time, provide market commentaries, wherein TA discusses notable issues related to the capital markets. Other investment advisory services TA offers other investment advisory services providing general, non-discretionary financial advice. For example, trustees may hire TA to advise them on defining appropriate mutual funds or other investment options for the participants of a 401(k) plan. In such cases, fees are paid as a percentage of assets under management; however, this type of consulting service does not include investment discretion since the plan participants are responsible to select their own mutual funds or other assets according to their own risk tolerance and objectives. Other General Consulting TA may periodically engage in general consulting services for various firms or individuals in areas including, but not limited to, providing expert witness services, general financial consulting, general management consulting, personal and corporate consulting, or a project requested by a client which may or may not involve investment advice.