Integrity Wealth Advisors, Inc.: investment adviser

Types of Advisory Services Offered

Asset Management: As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their speci�ic needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. As a supplement to this service, we may recommend the use of certain Fee-based Variable Annuities. For these services, the clients will enter into a separate agreement provided by the product sponsor outlining all applicable terms and conditions.

Comprehensive Portfolio Management:

As part of our Comprehensive Portfolio Management service clients will be provided asset management and �inancial planning or consulting services. This service is designed to assist clients in meeting their �inancial goals through the use of a �inancial plan or consultation. Our �irm conducts client meetings to understand their current �inancial situation, existing resources, �inancial goals, and tolerance for risk. Based on what is learned, an investment approach is presented to the client, consisting of individual stocks, bonds, ETFs, mutual funds and other public and private securities or investments. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request, our �irm provides a summary of observations and recommendations for the planning or consulting aspects of this service.

We have entered into an agreement with Invesco Advisers, Inc. (“Invesco”) to provide model portfolios (the “Invesco Models”) for use as an option in our portfolio management services. Under this agreement, Invesco provides asset allocation recommendations, which we use to inform client allocations. Although we consider Invesco’s recommendations, we retain full discretion over all trading decisions, responsibility for determining the suitability of each Invesco model for our clients, and communication with clients regarding their accounts. This arrangement allows us to leverage Invesco’s expertise while maintaining control over the management of our clients’ portfolios. The Invesco Models include underlying Invesco mutual funds and/or ETFs (the “Invesco Products), which will pay fees to Invesco for management, administrative, or other services at the fund level. Total fee revenue to Invesco and its affiliates may increase due to the decision to invest in Invesco Products instead of third-party products. This creates a conflict of interest because Invesco has a financial incentive to allocate Invesco Models to Invesco Products. IWA clients do not pay additional fees for use of the Invesco Models.

We have entered into an agreement with DPL in which we pay DPL an annual fee which provides our clients with access to commission-free life insurance and annuities. DPL performs due diligence on insurance carriers and makes those carriers available to us and our clients. We receive a fee from these clients by providing investment advice on the underlying investments of the insurance or annuity product.

Our Firm leverages an Order Management System through Ponetra to facilitate management of held away assets such as de�ined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We will review the current account allocations. When deemed necessary, we will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Where we may leverage an Order Management System through Ponetra, we shall have discretionary authority over the assets in your account subject to reasonable restrictions Financial Planning & Consulting: Our Firm provides a variety of standalone �inancial planning and consulting services to clients for the management of �inancial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a �inancial plan or rendering a �inancial consultation for clients based on the client’s �inancial goals and objectives. Our Firm utilizes Right Capital when providing our �inancial planning services. Right Capital provides our clients access to an online platform that allows them to access investment-related information and assists them reaching their �inancial goals and objectives. Online access to Right Capital will typically be available to the client once we have received all data from the client.

This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning.

Written �inancial plans or �inancial consultations rendered to clients usually include general recommendations for a course of activity or speci�ic actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our �irm provides clients with a summary of their �inancial situation, and observations for �inancial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within six (6) months of the client signing a contract with our Firm.

Retirement Plan Consulting:

Our Firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education.

Retirement Plan Consulting services typically include: • Establishing an Investment Policy Statement – Our Firm will assist in the development a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. • Investment Options – Our Firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. • Investment Monitoring – Our Firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility.

In providing services for retirement plan consulting, our Firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly/privately traded REITS), participant loans, or brokerage window programs (collectively, “Excluded Assets”). Furthermore, we may recommend the use of various outside custodians for our plan clients. We have no formal relationship with any of these Firms and do not receive any direct or indirect compensation from them in exchange for our recommendations. All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee bene�it plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our Firm accepts appointments to provide services to such accounts, our Firm acknowledges its �iduciary standard within the meaning of Section 3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein.

Estate Planning:

We offer Estate Planning services in conjunction with Wealth.com for our clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide outside Firm in the creation of documents, and updating existing plans for clients. The fees associated with estate planning related services are separate and in addition to your ongoing �inancial planning or advisory fees and are disclosed in Item 5.

Tailoring of Advisory Services

Our Firm offers individualized investment advice to our Comprehensive Portfolio Management clients. General investment advice will be offered to our Financial Planning & Consulting and Retirement Plan Consulting clients.

Each Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of dif�iculty this would entail in managing the account.

Participation in Wrap Fee Programs

Our Firm does not offer or sponsor a wrap fee program.

Regulatory Assets Under Management

As of December 31, 2025, our Firm has discretionary assets under management of $285,486,435.

As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our Firm; b) Clients will provide authorization permitting our Firm to be directly paid by these terms. Our Firm will send an invoice directly to the custodian; and c) If our Firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the quali�ied custodian will be included.

Comprehensive Portfolio Management: The fees for this service may be billed as a percentage of assets under management (AUM), or on an hourly basis. The maximum annual AUM based fee charged for this service will not exceed 1.75%. The maximum hourly rate shall not exceed $350. The fee to be assessed to each account as well as the speci�ic fee billing details will be detailed in the client’s signed advisory agreement. Unless otherwise agreed to in writing, advisory fees will be applicable to cash and cash equivalents. In rare cases, our Firm will agree to direct bill clients. As part of this process, the client is made aware of the following:

a) Clients must provide our Firm with written authorization permitting direct payment of advisory fees from their account(s) maintained by a custodian who is independent of our Firm; b) Our Firm sends quarterly statements to the client showing the fee amount, the value of the assets upon which the fee is based, and the speci�ic manner in which the fee is calculated as well as disclosing that it is the client’s responsibility to verify the accuracy of fee calculation, and that the custodian does not determine its accuracy; and c) The account custodian sends a statement to the client, at least quarterly, showing all account disbursements, including advisory fees.

For assets held at a custodian that is not directly accessible by us ("Held Away Accounts"), we may, but are not required to, manage these Held Away Accounts using the Order Management System, Pontera, that allows us to view and manage assets. We are not af�iliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Our annual fee for investment management services for held away accounts utilizes the same Annual Fee Schedule as outlined above. For Held Away Accounts we will bill an existing account designated on the executed management agreement. You will not pay our �irm a higher advisory fee other than what is listed above due to the use of Pontera. We pay 0.30% from our advisory fee that we receive from you to Pontera. Financial Planning & Consulting: Our Firm charges on an hourly or �lat fee basis for �inancial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. The maximum hourly fee to be charged will not exceed $350. Flat fees range from $1,000 to $15,000. The fee will be directly billed to the client and due within thirty (30) days of a �inancial plan being delivered or consultation rendered. Our Firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months.

Retirement Plan Consulting:

Our Retirement Plan Consulting services are billed on an hourly or a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. The maximum hourly fee to be

charged will not exceed $350. Fees based on a percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangements for Retirement Plan Consulting service will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Clients will be invoiced directly for the fees. Estate Planning: We charge a �lat fee of $1,500 for a standard Estate Plan. Though we reserve the right to charge an hourly fee of up to $350 for more complex situations. The �inal details will be speci�ied in the executed advisory agreement. Our Firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months. This service is free of charge for our clients with over $3 million in assets under our management.

Termination & Refunds Either party may terminate the signed advisory agreement at any time. Upon receipt of your notice of we will process a pro-rate refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter.

Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a �inancial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our Firm.

Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within �ive (5) business days of signing an agreement. After �ive (5) business days from initial signing, either party must provide the other party thirty (30) days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our Firm on behalf of the client. Clients will incur charges for bona ide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable.

We use the following methods of analysis in formulating our investment advice and/or managing client assets:

Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and �inancial factors (including the overall economy, industry conditions, and the �inancial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and �inancial factors considered in evaluating the stock.

Technical Analysis: We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying �inancial condition of a company. This

presents a risk in that a poorly managed or �inancially unsound company may underperform regardless of market movement.

Investment Strategies We Use We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations:

Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be pro�itable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Typically, we employ this sub-strategy when we believe the securities to be well valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. The potential risks associated with this investment strategy involve a lower than expected return, for many years in a row. Lower-than-expected returns that last for a long time and/or that are severe in nature would have the impact of dramatically lowering the ending value of your portfolio and thus could signi�icantly threaten your ability to meet �inancial goals.

Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. The potential risk associated with this investment strategy is associated with the currency or exchange rate. Currency or exchange rate risk is a form of risk that arises from the change in price of one currency against another. The constant �luctuations in the foreign currency in which an investment is denominated vis-à -vis one's home currency may add risk to the value of a security. Currency risk is greater for shorter term investments, which do not have time to level off like longer term foreign investments.

Structured Products: Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive bene�its provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation.

Investing in structured products includes signi�icant risks, including valuation, lack of liquidity, price, credit and market risks. The relative lack of liquidity is due to the highly customized nature of the investment and the fact that the full extent of returns from the complex performance features is often not realized until maturity.

Another risk with structured products is the credit quality of the issuer. Although the cash �lows are derived from other sources, the products themselves are legally considered to be the issuing �inancial institution's liabilities. The vast majority of structured products are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers.

Cryptocurrency Products: We may recommend investment in digital (crypto) currency products. These products are typically structured as a trust or exchange traded fund which pool capital together to purchase holdings of digital currencies or derivatives based on their value. Such products are extremely volatile and are suitable only as a means of diversi�ication for investors with high risk tolerances. Furthermore, these securities carry very high internal expense ratios, and may use derivatives to achieve leverage or exposure in lieu of direct cryptocurrency holdings. This can result in tracking errors and may sell at a premium or discount to the market value of their underlying holdings. Security is also a concern for digital currency investments which make them subject to the additional risk of theft.

Margin Loans: Our �irm may allow or recommend that you pledge securities from your portfolio as collateral for a loan by using margin in brokerage account. This allows you to own more stock than you would be able to with your available cash. Margin accounts and transactions are risky and not necessarily appropriate for every client.

The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time.

Options: An option is a �inancial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other �inancial asset at an agreed-upon price (the strike price) during a certain period of time or on a speci�ic date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have con�licting views regarding the outlook on the performance of a: •

Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum pro�it. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a pro�it. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option.

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Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the speci�ied strike price on or before a speci�ied date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase about a speci�ied price on or before the expiration date. If the underlying stock's price closes above the speci�ied strike price on the expiration date, the put option writer's maximum pro�it is achieved. Conversely, a put option holder would only bene�it from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price.

The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Covered Calls: The risks associated with this type of strategy involve having the underlying stock called away. Each contract has a strike price at which the writer of the contract agrees to allow the purchaser to call the stock away from the writer. This can create a taxable event whereby the writer of the option is required to recognize a capital gain on the underlying security. Furthermore, the market price could appreciate beyond the strike price, forcing the writer to sell their holdings below current market value.

Uncovered Options: Uncovered option writing is suitable only for the knowledgeable investor who understands the risks, has the �inancial capacity and willingness to incur potentially substantial losses, and has suf�icient liquid assets to meet applicable margin requirements. If the value of the underlying instrument moves against an uncovered writer’s options position, our �irm may request signi�icant additional margin payments. If an investor does not make such margin payments, we may be forced to close stock or options positions in the investor’s account. The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position and may incur large losses if the value of the underlying instrument increases above the exercise price.

As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. Such loss could be substantial if there is a signi�icant decline in the value of the underlying instrument.

Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, are appropriately diversi�ied in investments, and ask any questions.

Additional Information Our Firm generally invests client cash balances in money market funds, FDIC Insured Certi�icates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our Firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our Firm may debit advisory fees for our services related to our Comprehensive Portfolio Management service, as applicable.

Firm will acknowledge receipt, understanding and compliance with our Firm’s Code of Ethics. Our Firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request.

Our Firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our Firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities.

Neither our Firm nor a related person recommends, buys or sells for client accounts, securities in which our Firm or a related person has a material �inancial interest without prior disclosure to the client. Related persons of our Firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this con�lict of interest, our related persons will place client interests ahead of their own interests and adhere to our Firm’s Code of Ethics, a copy of which is available upon request.

Likewise, related persons of our Firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this con�lict of interest, our related persons will place client interests ahead of their own interests and adhere to our �irm’s Code of Ethics, a copy of which is available upon request.

With this in consideration, our Firm has an arrangement with Charles Schwab & Co. Inc. (“Schwab”), a quali�ied custodian from whom our Firm is independently owned and operated. Schwab offers services to independent investment advisers which includes custody of securities, trade execution, clearance and settlement of transactions. Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab does not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees are negotiated with Schwab and are generally discounted from customary retail commission rates. This bene�its clients because the overall fee paid is often lower than would be otherwise.

Schwab may make certain research and brokerage services available at no additional cost to our Firm. Research products and services provided by Schwab may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; �inancial publications; portfolio evaluation services; �inancial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab to our Firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption de�ined in Section 28(e) of the Securities Exchange Act of 1934.

Schwab does not make client brokerage commissions generated by client transactions available for our �irm’s use. The aforementioned research and brokerage services are used by our Firm to manage accounts. Without this arrangement, our Firm might be compelled to purchase the same or similar services at our own expense. As part of our �iduciary duty to our clients, our Firm will endeavor at all times to put the interests of our clients �irst. Clients should be aware, however, that the receipt of economic bene�its by our Firm or our related persons creates a potential con�lict of interest and may indirectly in�luence our Firm’s choice of Schwab as custodial recommendations. Our Firm examined this potential con�lict of interest when our Firm chose to recommend Schwab and have determined that the recommendation is in the best interest of our Firm’s clients and satis�ies our �iduciary obligations, including our duty to seek best execution.

Our clients may pay a transaction fee or commission to Schwab that is higher than another quali�ied broker dealer might charge to effect the same transaction where our Firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole.

In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our Firm will seek competitive rates, to the bene�it of all clients, our Firm may not necessarily obtain the lowest possible commission rates for speci�ic client account transactions.

Soft Dollars

Our Firm does not participate in soft dollar arrangements as allowed by Section 28(e) of the Securities Exchange Act of 1934. The products and services obtained by our Firm will generally be used to service all of our clients but not necessarily all at any one particular time. Brokerage for Client Referrals

Our Firm does not receive brokerage for client referrals.

Directed Brokerage

Neither our Firm nor any of our Firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Our Firm routinely recommends that clients direct us to execute through a speci�ied broker-dealer. Our Firm recommends the use of LPL and Schwab.

Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a speci�ic broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive bene�it of the plan. Consequently, our irm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive bene�it of the plan.

Client-Directed Brokerage

Our Firm allows clients to direct brokerage outside our recommendation. Our Firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our Firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices.

Aggregation of Purchase or Sale

Our Firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our Firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when our Firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our Firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently nonarbitrary methods of allocation.

Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a �inancial consultation with us. Our Firm does not provide ongoing services to �inancial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their �inancial plans unless they separately engage our Firm for a post-�inancial plan meeting or update to their initial written �inancial plan.

Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our Firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our Firm for ongoing services.

Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations.

The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clari�ied that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our irm has adopted the following safeguards in conjunction with our custodian: •

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The client provides an instruction to the quali�ied custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. The client authorizes the investment adviser, in writing, either on the quali�ied custodian’s form or separately, to direct transfers to the third party either on a speci�ied schedule or from time to time. The client’s quali�ied custodian performs appropriate veri�ication of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. The client has the ability to terminate or change the instruction to the client’s quali�ied custodian. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. The client’s quali�ied custodian sends the client, in writing, an initial notice con�irming the instruction and an annual notice recon�irming the instruction.