Smedley Financial Services, Inc. Salt Lake City, UT 84111 Mailing .

Smedley Financial Services acknowledges that in performing the Fiduciary Consulting Services listedabove that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of EmployeeRetirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investmentadvice only. Smedley Financial Services will act in a manner consistent with the requirements of afiduciary under ERISA if, based upon the facts and circumstances, such services cause SmedleyFinancial Services to be a fiduciary as a matter of law. However, in providing the Fiduciary ConsultingServices, Smedley Financial Services (a) has no responsibility and will not (i) exercise any discretionaryauthority or discretionary control respecting management of Client’s retirement plan, (ii) exercise anyauthority or control respecting management or disposition of assets of Client’s retirement plan, or (iii)have any discretionary authority or discretionary responsibility in the administration of Client’s retirementplan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” asdefined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of anyplan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA.Non-Fiduciary ServicesSmedley Financial Services provides clients with the following Non-Fiduciary Retirement Plan ConsultingServices: Participant Education. Smedley Financial Services will provide education services to Planparticipants about general investment principles and the investment alternatives available underthe Plan. Smedley Financial Services’ assistance in participant investment education will beconsistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentationswill not take into account the individual circumstances of each participant and individualrecommendations will not be provided unless otherwise agreed upon. Participant Enrollment. Smedley Financial Services will assist you with group enrollmentmeetings designed to increase retirement plan participation among employees and investmentand financial understanding by the employees. Qualified Plan Development. Smedley Financial Services will assist you with the establishmentof a qualified plan by working with you and a selected Third Party Administrator. If you have notalready selected a Third Party Administrator, we shall assist you with the review and selection ofa Third Party Administrator for the Plan. Due Diligence Review. Smedley Financial Services will provide you with periodic due diligencereviews of your Plan’s fees and expenses and your Plan’s service providers. Fiduciary File Set-up. Smedley Financial Services will help you establish a “fiduciary file” for thePlan which contains trust documents, custodial/brokerage statements, investment performancereports, services agreements with investment management vendors, the investment policystatement, investment committee minutes, asset allocation/asset liability studies, due diligencefields on funds/money managers and monitoring procedures for funds and/or money managers.Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 andrequired to meet the fiduciary duties as defined by the Advisers Act, the services listed here as nonfiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is notacting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA.Smedley Financial Services, Inc.6Disclosure Brochure

The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement PlanConsulting Agreement.All recommendations of investment options and portfolios will be submitted to the client for the client’sultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investmentrecommendations of Smedley Financial Services and then physically make changes to the plan itself.In the event a client contracts with Smedley Financial Services for one-on-one consulting services withplan participants, such services are consultative in nature and do not involve Smedley Financial Servicesimplementing recommendations in individual participant accounts. It will be the responsibility of eachparticipant to implement changes in the participant’s individual accounts.We can also meet with individual participants to discuss their specific investment risk tolerance,investment time frame and investment selections.Retirement plan consulting services are not management services, and Smedley Financial Services doesnot serve as administrator or trustee of the plan. Smedley Financial Services does not act as custodianfor any client account or have access to client funds or securities (with the exception of, some accounts,having written authorization from the client to deduct our fees). In addition, we do not implement anytransactions in a retirement plan or participant’s account. For retirement plan consulting services, theretirement plan or the plan participant who elects to implement any recommendations made by us issolely responsible for implementing all transactions.Smedley Financial Services will disclose, to the extent required by ERISA Regulation Section 2550.408b2(c), to you any change to the information that we are required to disclose under ERISA RegulationSection 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date onwhich we are informed of the change (unless such disclosure is precluded due to extraordinarycircumstances beyond our control, in which case the information will be disclose as soon as practicable).In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30)days following receipt of a written request from the responsible plan fiduciary or Plan Administrator(unless such disclose is precluded due to extraordinary circumstances beyond our control, in which casethe information will be disclosed as soon as practicable) all information related to the Qualified RetirementPlan Consulting Agreement and any compensation or fees received in connection with the Agreementthat is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISAand the regulations, forms and schedules issued thereunder.If we make an unintentional error or omission in disclosing the information required under ERISARegulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon aspracticable, but no later than thirty (30) days from the date on which we learn of such error or omission.Retirement Plan Rollover Recommendations - When Smedley Financial Services provides investmentadvice about your retirement plan account or individual retirement account (“IRA”) including whether tomaintain investments and/or proceeds in the retirement plan account, roll over such investment/proceedsfrom the retirement plan account to a IRA or make a distribution from the retirement plan account, weacknowledge that Smedley Financial Services is a “fiduciary” within the meaning of Title I of theEmployee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) asapplicable, which are laws governing retirement accounts. The way Smedley Financial Services makesmoney creates conflicts with your interests so Smedley Financial Services operates under a special rulethat requires Smedley Financial Services to act in your best interest and not put our interest ahead of you.Smedley Financial Services, Inc.7Disclosure Brochure

Under this special rule’s provisions, Smedley Financial Services must as a fiduciary to a retirement planaccount or IRA under ERISA/IRC: Meet a professional standard of care when making investment recommendations (e.g.,give prudent advice);Never put the financial interests of Smedley Financial Services ahead of you whenmaking recommendations (e.g., give loyal advice);Avoid misleading statements about conflicts of interest, fees, and investments;Follow policies and procedures designed to ensure that Smedley Financial Servicesgives advice that is in your best interest;Charge no more than is reasonable for the services of Smedley Financial Services; andGive Client basic information about conflicts of interest.To the extent We recommend you roll over your account from a current retirement plan account to anindividual retirement account managed by Smedley Financial Services, please know that SmedleyFinancial Services and our investment adviser representatives have a conflict of interest.We can earn increased investment advisory fees by recommending that you roll over your account at theretirement plan to an IRA managed by Smedley Financial Services. We will earn fewer investmentadvisory fees if you do not roll over the funds in the retirement plan to an IRA managed by SmedleyFinancial Services.Thus, our investment adviser representatives have an economic incentive to recommend a rollover offunds from a retirement plan to an IRA which is a conflict of interest because our recommendation thatyou open an IRA account to be managed by our firm can be based on our economic incentive and notbased exclusively on whether or not moving the IRA to our management program is in your overall bestinterest.We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standardwhereby our investment adviser representatives will (i) provide investment advice to a retirement planparticipant regarding a rollover of funds from the retirement plan in accordance with the fiduciary statusdescribed below, (ii) not recommend investments which result in Smedley Financial Services receivingunreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii)fully disclose compensation received by Smedley Financial Services and our supervised persons and anymaterial conflicts of interest related to recommending the rollover of funds from the retirement plan to anIRA and refrain from making any materially misleading statements regarding such rollover.When providing advice to you regarding a retirement plan account or IRA, our investment advisorrepresentatives will act with the care, skill, prudence, and diligence under the circumstances thenprevailing that a prudent person acting in a like capacity and familiar with such matters would use in theconduct of an enterprise of a like character and with like aims, based on the investment objectives, risk,tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interestsof Smedley Financial Services or our affiliated personnel.Referral of Third-Party Money Managers - Smedley Financial Services offers advisory services byreferring clients to a third-party money manager offering asset management and other investmentadvisory services. The third-party managers are responsible for continuously monitoring client accountsand making trades in client accounts when necessary. As a result of the referral, we are paid a portion ofSmedley Financial Services, Inc.8Disclosure Brochure

the fee charged and collected by the third-party money managers in the form of solicitor fees. Eachsolicitation arrangement is performed pursuant to a written solicitation agreement and is in compliancewith SEC Rule 206(4)-3 and applicable state securities rules and regulations.Under this program, we assist you with identifying your risk tolerance and investment objectives. Werecommend third-party money managers in relation to your stated investment objectives and risktolerance, and you may select a recommended third-party money manager or model portfolio based uponyour needs. You must enter into an agreement directly with the third-party money manager who providesyour designated account with asset management services.We are available to answer questions that you may have regarding your account and act as thecommunication conduit between you and the third-party money manager. The third-party moneymanager may take discretionary authority to determine the securities to be purchased and sold for youraccount. We do not have any trading authority with respect to your designated account managed by thethird-party money manager.Although we review the performance of numerous third-party investment adviser firms, we enter into onlya select number of relationships with third-party investment adviser firms that have agreed to pay us aportion of the overall fee charged to our clients. Therefore, Smedley Financial Services has a conflict ofinterest in that it will only recommend third-party investment advisors that will agree to compensate us forreferrals of our clients.Clients are advised that there may be other third-party managed programs not recommended by our firm,that are suitable for the client and that may be more or less costly than arrangements recommended byour firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by athird-party investment adviser recommended by our firm. Further, no guarantees of performance can everbe offered by our firm (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk ofLoss for more details.)SpecializationSmedley Financial Services, Inc. specializes in lifetime income investment planning. Retirees and preretirees need a solution that will help increase the probability of providing an income that will lastthroughout their lives. The solution must address the following goals: Deliver a stream of income over a period of years that will keep pace with inflation.Implement a strategy that offers the potential to reach long-term investment goals.Help preserve principal to either offset increased life expectancy or provide a legacy.Reduce risk based on an investment time-frame.Manage the emotional side of investing and the impact it has on reaching financial goals.One solution is lifetime income investment planning. Segmenting assets into separate phases or timehorizons is the backdrop of lifetime income investment planning. Each income phase is invested basedon a specific group of factors and criteria. The goal is to provide an income distribution level that will ke

Wealth Management Platform which is sponsored and administered by VISION2020 Wealth Management Corp., an affiliate of Securities America, Advisors, Inc. (SAA). . The Smedley Wealth Management Team focuses on building relationships through world class client service, specialized private wealth planning solutions, and proven wealth management .