Liberty Financial Group, Inc.: investment adviser

Cash flow management Employee benefit options College funding planning Risk management and contingency plan reviews Estate planning Financial analysis of assisted living arrangements and other long-term care needs Retirement planning Tax planning A review of your present investment direction; Development of an investment policy statement; Implementation and monitoring to include regular internal portfolio reviews; Quarterly performance reporting; Annual tax loss review; Annual realized gains and loss reporting; Periodic assessment of your volatility tolerance, liquidity needs and time horizons; Client meetings offered at least annually in person or by phone; and Ongoing availability and accessibility as needs arise.

Investment management services are provided on a discretionary and non-discretionary basis. When granted discretion by the client, it means that Liberty Representatives has the authority to purchase and sell securities of their choice in the amounts and at the times they believe it is suitable for a client's account to do so. Services provided to you vary, depending on the nature of your client Agreement and the services you determine you desire at the time of Agreement. We review your portfolio assets on a periodic basis, depending on the types of investments and market conditions, or at your specific request. We strongly encourage clients to maintain contact with us, and we request that client reviews occur no less than annually.

General Information. You have the ability to leave standing instructions with us to refrain from investing in particular companies, to invest in limited amounts of securities, and to request third-party checks on your behalf (sent from the custodian and only mailed directly to you). All clients will have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We do not have custody of client funds or securities. A third-party firm provides execution and custodial services. Mutual Funds and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Therefore, a client or prospective client can obtain many of the funds that may be utilized by Liberty independent of engaging Liberty as an investment advisor. If a client or prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. We do not assure or guarantee the results of our investment advisory services, thus losses can occur from following Liberty's advice pertaining to any investment or investment approach, including using conservative investment strategies. We do not participate in wrap fee programs. Liberty provides tax preparation services to existing clients and on an hourly basis to clients that have engaged us on a consulting basis. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must:

Meet a professional standard of care when making investment recommendations; Never put our financial interests ahead of yours when making recommendations; Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest.

For more information about our conflicts of interest, please review items 5, 10, 11 and 14 or reach out to us using the contact information on the cover page of this brochure. As of December 31, 2025, Liberty has assets of $192,878,837 under discretionary management and $1,438,484 under non-discretionary management.

Cash is considered an asset class and cash balances held in your account are included in the calculation of the advisory fee charged to your account. We have no minimum account size requirement to open an account. Our minimum annual engagement fee is $4500. Investment Management and Financial Planning Service fees are negotiable at our discretion, and may be modified based on individual circumstances, the complexity of services and/or additional resources required. We manage certain of our current clients under a prior fee and services schedule. A one-time fixed fee of up to $1,500 is charged at the outset of the engagement for additional services provided during the first year as prioritized by the client. The one-time fixed fee may be reduced or waived at the discretion of Liberty. Fees payable to Liberty for Investment Management and Financial Planning Services are, with the client's prior permission, automatically deducted from the client's account when due. The client will receive an invoice from Liberty, as well as reports from the account's custodian. Authorization for deduction of fees from the managed account is contained in the Agreement. The client may terminate the authorization for automatic deduction at any time by notifying us in writing. Fees are payable by check at our discretion. Consulting Service Fees for Existing Clients. Fees for existing clients’ hourly Investment Consulting Services range between $250 to $500 per hour, depending upon the complexity and nature of the services. Hourly Consulting fees are negotiable and due at the end of each meeting. As noted above, Liberty provides tax preparation services to investment management and financial planning clients. The fees for such services are based on an hourly rate between $250 and $300 per hour. Tax preparation fees are waived at our discretion. Fees paid to Liberty are for Liberty advisory services only. The fees do not include, for example, the fees charged by third party managers, or accountants and attorney's assisting

with providing the client with accounting and legal advice. Commission on transactions and other account fees will also be charged by and paid to brokerage firms in accordance with the account's brokerage firm's normal commission schedule. See Item 12, Brokerage Practices. In addition to our advisory fees, each mutual fund in which client's assets are invested also incurs its own advisory fees and other internal expenses which already have been deducted from the fund's reported performance. Depending on the fund, a client may be able to invest directly in the shares issued by the fund with or without incurring any sales or thirdparty management fees. Account maintenance fees may also be deducted by the custodian of the client account.

small cap stocks; corporate bonds vs. government securities) is generally in the forefront of our strategies. We primarily use mutual funds (open and closed-end) for tax deferred accounts, and individual securities or Exchange Traded Funds (ETFs) in taxable accounts. We generally use a mixture of active and passive investment approaches to implement an asset allocation policy. Since we believe that risk reduction is a key element to long-term investment success, we use strategic asset allocation principles that are in line with your

investment goals. An Investment Policy Statement and/or Financial Plan are a key part of our overall approach in preparing advice for you. We recommend asset allocation strategies that achieve a diversification of your assets and help lessen your risk, while not undermining the effectiveness of your portfolio’s need to achieve your goals. We emphasize an asset allocation approach using a broadly diversified, low cost and low turnover, style-constant investment strategy for asset classes that we believe tend to be highly efficient. For our active investment approach, we typically seek managers that use a concentrated approach, especially when we feel that a money manager or strategy has the ability to outperform the benchmark of a particular asset class. We may use a preferred list of mutual funds and equities that we have researched and monitored throughout the year. However, the concentrated core investment portfolio generally remains constant. We use our own investment process that balances the size of your portfolio with your individual needs, time horizon, and risk tolerance, while also taking into account your goals, objectives and tax consequences. We consider the individual needs of each client when preparing recommendations. We may select individual securities on a value basis, primarily but not exclusively in taxable accounts. The value strategy we employ uses the following measures: price/earnings multiples, price/cash flow multiples, debt/capitalization ratio, and price earnings to expected growth rate multiples that are below sector, industry or historic averages. We also look for a return on equity (ROE) and free cash flow per share that is greater than sector, industry, or historic averages. The intended holding period for these securities is a minimum of three years. Extreme company or market conditions may cause us to sell prior to this time frame. We may also purchase individual bonds as an alternative to fixed income funds, to lower the annual expenses to the portfolio. In the case of short to intermediate maturity bonds, our intent would be to hold these until they mature. We may also buy longer-term bonds to take advantage of anticipated market changes due to rates, structure and/or quality differences that could add potential capital gains. In developing our investment strategies and advice, we use many sources of public information, including regulatory filings, annual reports, financial news, and perhaps research materials from providers of financial services. We may also use specialized software products supplied by public sources. In providing Financial Life Planning™ services, we look to the long-term. After we evaluate your financial needs, we design investment and insurance strategies to help you achieve your financial goals. Casualty insurance needs (i.e., homeowners, auto, liability, etc.) may be reviewed at your request or may be part of our Agreement to provide

financial planning services. A casualty insurance review may be provided by an outside consulting firm. You should be aware that sales of investments result in taxable gain(s) or loss(es). Also, the sale of investments to maintain your asset allocation policy may cause taxable gain(s) or loss(es) to you. We provide general tax planning consultation, and while we make every effort to take these matters into consideration in the delivery of our services, you must understand we are not a Certified Public Accounting firm. Therefore, we strongly encourage you to consult your tax advisor about potential tax consequences that may result from transactions or any particular investment held in your account. We can provide general advice regarding legal considerations with regard to investment plans, but you are strongly encouraged to consult personal legal counsel on all legal matters. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Registrant) will be profitable or equal any specific performance level(s). Investing in securities involves risk of loss that clients should be prepared to bear. Investors generally face the following types of investment risks:

Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk may be caused by external factors independent of the fund’s specific investments as well as due to the fund’s specific investments. Additionally, each security’s price will fluctuate based on market movement and emotion, which may, or may not be due to the security’s operations or changes in its true value. For example, political, economic and social conditions may trigger market events which are temporarily negative, or temporarily positive. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market

value. Legal and Regulatory Risks: The regulation of the U.S. and non-U.S. securities and futures markets investment funds are subject to change. The effect of regulatory changes on accounts and/or underlying investment funds, while impossible to predict, could be substantial and adverse.

Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues Our business activities could be materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease, viruses and/or public health issues. Specifically, COVID-19 spread rapidly around the world since its initial emergence in China in December 2019 and severely negatively affected (and may continue to materially adversely affect) the global economy and equity markets (including, in particular, equity markets in Asia, Europe and the United States). Although the long-term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of disease cannot be predicted, previous occurrences of other pandemics, epidemics and other outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse effect on the economies and markets of those countries and regions in which they were most prevalent. Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic, communicable disease or virus or major public health issue could cause a slowdown in the levels of economic activity generally (or cause the global economy to enter into a recession or depression), which would adversely affect the business, financial condition and operations of the Adviser. Should these or other major public health issues, including pandemics, arise or spread farther (or continue to spread or materially impact the day to day lives of persons around the globe), the Adviser could be adversely affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or business and/or governmental actions limiting the movement of people between regions and other activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak).

Geopolitical Risk: Geopolitical and other events (e.g., war or terrorism) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism and related geopolitical events have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and world economies and markets generally.

Representatives of Liberty do not buy or sell securities for their personal accounts that are the same securities recommended to clients. The firm does not engage in principal transactions (i.e., buying from or selling securities to advisory clients for its own account), nor does it recommend securities in which the firm or its related persons have a material financial interest. Although the firm does not permit employees to trade in the same securities recommended to clients, the Code includes procedures for monitoring personal trading activity, reporting requirements, and other safeguards intended to prevent conflicts of interest. The Code also establishes certain bookkeeping requirements relating to federal reporting rules and is reviewed at least annually and updated as necessary. A complete copy of the firm’s Code of Ethics is available to clients upon request.

include software and other technology that: • Provide access to client account data (such as trade confirmations and account statements); • Facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); • Provide research, pricing information and other market data; • Facilitate payment of our fees from your accounts; • Assist with back-office functions, recordkeeping and client reporting; and • Discounts on compliance, marketing, research, technology, and practice management products or services provided to Liberty by third party vendors.

Many of these services generally may be used to service all or a substantial number of our accounts, including accounts not maintained at Schwab. Schwab also makes available to us other services intended to help us manage and further develop our business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, Schwab may make available, arrange and/or pay for these types of services provided to us by independent third parties. Schwab may discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to us. We are independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services. These services are generally not available to retail investors. Schwab’s services include brokerage, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors, or would require a significantly higher minimum initial investment For client accounts maintained at Schwab, Schwab generally does not charge separately for custody services but is compensated through commissions and other transactionrelated fees for securities trades executed through or settled into Schwab accounts. As a fiduciary, we endeavor to act in our clients’ best interests at all times. Our recommendation that clients maintain assets at Schwab may be based in part on the benefits we receive from Schwab, including access to products and services that assist us in managing and administering client accounts. This creates a potential conflict of interest, as we have an incentive to recommend Schwab based on these benefits rather than solely on the nature, cost, or quality of custody and brokerage services. We address this conflict by seeking best execution for client transactions and placing client interests ahead of our own.

We may execute certain transactions through broker-dealers other than Schwab when we believe it is consistent with our duty to seek best execution. However, Schwab is generally used as the primary custodian and broker-dealer for client accounts unless a client directs otherwise. Clients may request that we use a specific broker-dealer to execute transactions (“directed brokerage”), subject to our ability to obtain necessary account information in a timely and compatible format. In such cases, we may be unable to achieve best execution and clients may pay higher commissions or transaction costs than would otherwise be available. While it is possible that you may pay higher commission or transaction fees through Schwab, we have determined that Schwab currently offers the best overall value to us and to you for the brokerage and technology they provide. We believe that Schwab’s customer service and trade execution provide a standard of service that enables us to meet our fiduciary duty to our clients. Schwab features a broad line of products and services that are available to every investor, regardless of the amount of investable assets. We may aggregate (or “bunch”) trades when executing transactions for multiple client accounts in order to achieve more favorable execution and pricing. When trades are aggregated, they are allocated in a manner we believe to be fair and equitable to all participating clients. Generally, if we are purchasing or selling the same security for two or more clients at the same time, we will aggregate the trade, whenever possible.

Clients engaging us for discretionary Investment Management Services receive periodic performance and allocation reports, and annual realized gain and loss reports. We also prepare performance and transactional report for periodic client meetings. Clients who have engaged us for Consulting Services which may comprise services based upon various issues relating to investment or financial planning, will not receive written reports. Consulting Services are not ongoing in nature and can terminate upon the delivery of services.

Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Liberty may also have authority to transfer client assets to third parties pursuant to standing letters of authorization (“SLOAs”). In accordance with SEC staff guidance (February 21, 2017 Investment Adviser Association No-Action Letter), accounts subject to such arrangements are not required to undergo an annual surprise examination, provided certain conditions are met. Clients receive account statements directly from the qualified custodian at least quarterly. Liberty has a reasonable basis for believing that the qualified custodian sends account statements directly to clients. Liberty urges clients to carefully review these statements and compare them with any reports or statements provided by Liberty. Any discrepancies should be reported promptly to the firm.