Paradigm Consulting, Inc. (“we”, “our”, “us”, “Firm”), has applied to be an Independent Registered Investment Adviser with the State of New York. Our business focuses on pension consulting services. Laurie A. Schoen and Amy L. Mielnicki are the principal owners of Paradigm Consulting, Inc. We are pending registration as an Investment Adviser with the State of New York, CRD #144990, in order to offer investment advisory products and services to our advisory clients (“you”). Such services are offered through our Financial Advisers (“FAs”) who have registered as our Investment Adviser Representatives (“Advisory Representatives”). The registration of our firm and its advisers does not imply a certain level of skill or training. Separate and apart from their registration as Advisory Representatives of the Adviser, the Advisory Representatives are also Registered Representatives of Osaic Wealth, Inc., a Financial Industry Regulatory Authority (“FINRA”) broker/dealer and a SEC registered investment adviser. Such registration of the Registered Representatives or Osaic Wealth, Inc. does not imply a certain level of skill or training. Osaic Wealth, Inc. is also a member of various other regulatory bodies. Osaic Wealth, Inc. does not provide any investment advisory services in conjunction with or as part of the investment advisory services provided by Paradigm Consulting, Inc. or its Advisory Representatives. Types of Advisory Programs We Offer RETIREMENT PLAN CONSULTING SERVICES We also offer retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (hereafter the “Company”) in meeting their management and fiduciary obligations to the plan under ERISA. Retirement consulting services will consist of general or specific advice, and may include any one or all of the following: 1. Strategic Planning and Investment Policy Development/Review. Meet with the Company and/or the Named Fiduciary or their fiduciary delegate to assist them in developing an investment policy statement (hereafter the “IPS”). Alternatively, if the Plan has an existing investment policy statement, we will review the existing IPS and assist the Company, Named Fiduciary and/or their fiduciary delegate to determine whether the Plan is performing consistent with the IPS and/or whether the IPS needs to be revised, based on an analysis of the Plan’s liquidity requirements, performance goals and risk tolerance levels of the Plan using information provided by the Company. 2. Plan Review. Conduct a review of the Plan design and advise the Named Fiduciary whether the Plan is operating in accordance with Plan documents and applicable provisions of ERISA; and review Named Fiduciary's compliance with fiduciary responsibilities, including compliance with requirements for self-directed plans (if applicable) under ERISA Section 404(c); 3. Plan Fee and Cost Review. Conduct an annual review fees and costs charged to Plan by other service providers to assist Named Fiduciary to determine reasonableness of fees and costs paid by Plan; 4. Third-Party Service Provider Liaison. Act as liaison for the Plan and the Named Fiduciary when dealing with the trustee, custodian, plan actuary and other third-party service providers to Plan; 5. Assessment of Investments. Conduct a periodic review of fund expenses, investment performance, and style drift for mutual funds offered by the Plan to participants, comparing them with other funds in the same asset category using Morningstar data from Principia and MPI Stylus; provide suggestions to the Named Fiduciary from time to time as deemed warranted by the IAR for alternative mutual fund options for the Plan to make available to its participants (which decision shall remain the sole and exclusive decision of the Named Fiduciary and/or their fiduciary delegate); 6. Participant Education and Communication. Coordinate and/or conduct investment education

and enrollment meetings for plan participants as determined by the Company.
In certain circumstances, the Company may also engage us to provide the following additional services, for separate compensation: 1. Executive Benefits. Review, design and implementation for nonqualified plans/deferred compensation. 2. Plan Conversion. Assist with conversion to alternate vendors, including preparation of Request for Proposal (RFP) from prospective new vendors, and review and comparison of responses to RFP. 3. Merger and Acquisition Assistance. Perform merger and acquisition due diligence review of pension plan documents and investments for possible merger or termination of duplicate plans. 4. Compliance Correction. Assist with corrective actions as necessary to comply with applicable laws and regulations. 5. Coordination with Other Advisers. Interact with outside advisors, or tax, legal and accounting counsel, as necessary. We will determine with the Company, in advance, the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee paying arrangements. In performing the contracted services, we shall not be required to verify the accuracy or consistency of any information received from the Company. The fee for the services may be charged either at a pre-determined fixed fee or based upon a percentage of the Plan assets. On-site participant educational sessions are also available and are charged at a per day rate as requested by the Company. The exact fee will be negotiated in advance of services rendered and shall be clearly set forth in the executed agreement for services between us and the Company. Fees may be billed quarterly or monthly (in arrears or in advance). In special circumstances other fee paying arrangements may be negotiated. The above referenced terms will be disclosed in the client agreement we sign with the Company. In special circumstances other fee-paying arrangements may be negotiated. There is no minimum account size requirement for our Retirement Plan Consulting Services. All client accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). We will provide pension consulting services to the Company as described above. In providing pension consulting services, we and the Company agree that we will serve in a fiduciary capacity with respect to certain of the services provided, and as referenced in the executed agreement for services. However, the Company is free to seek independent advice about the appropriateness of any recommendations made by us, or our IARs. We do not provide legal, tax, or actuarial advice and we will not be responsible for ensuring that the IPS and asset allocation choices comply with any legal, actuarial or other requirements that apply to the Plan. We will serve in a Non-Discretionary ERISA fiduciary capacity with respect to the services that we provide, which will be further explained in the written agreement we sign with the Company. A Non-Discretionary investment advisory account is an account where buy and sell decisions are made by the client. This means that the you must direct all transactions to be completed on an account. We do not have the ability to complete transactions without first getting permission from the you. The Company is always free to seek independent advice about the appropriateness of any recommendations made by us. Management of Client Assets Paradigm Consulting, Inc.’s investment advisory accounts are managed on a non-discretionary basis, determined at the time the account is opened based on our client’s written authorization. February 29, 2024 Paradigm Consulting, Inc. had the following client assets under management (AUM):  $5,900,000 AUM for non-discretionary accounts