Firm Description and Ownership Legacy was established in May of 2000 and is registered as an advisory firm with the Securities and Exchange Commission (“SEC”). Legacy’s controlling owner is Michael Wren. Minority owners include Christopher Proctor, David Dwyer, Jacob Watts, and Andrew Rogers. Heather Hardman serves as the firm’s Chief Compliance Officer. Types of Services Offered by Legacy A. Investment Management Services Legacy provides ongoing discretionary and non-discretionary investment management services to individuals, families and businesses. When providing portfolio management services, the firm not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. In some cases, the firm may delegate certain investment management responsibilities to outside managers or platform providers. Clients may elect to give the firm discretion to make all decisions (discretionary management), or may prefer to approve all decisions before implementation (non discretionary management). Legacy also provides more streamlined, lower cost investment management services using simple ETF model portfolios which are tailored for smaller accounts (generally less than $250,000) under its Legacy Next program. Regardless of the level of discretion provided, each engagement is tailored to the individual needs of the particular client (whether an individual, a family, or a business) through an assessment conducted prior to an engagement. Clients may impose restrictions related to the level of discretion granted, the types of investments used, etc. Terms of an actual engagement, including description of service, limitations and restrictions, fees, etc., are all detailed before any engagement begins in a written client agreement. As of December 31, 2023, Legacy’s assets under management totaled $645,630,341. Of this total, $561,005,355 was managed on a discretionary basis and $84,624,986 was managed on a non-discretionary basis. Because Legacy is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered 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. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients, however, are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs. B. Retirement Plan Services Legacy provides plan level retirement plan services to retirement plans and retirement plan sponsors. These services can be structured as non-discretionary management engagements where clients make all decisions (with Legacy assisting with implementation), or as non-management advisory engagements where the client makes all decision and is responsible for implementation (with Legacy providing consulting advice and other assistance). Services provided depend on the specific needs of the client and may include assistance with plan setup, investment selection, and ongoing support services, among other things. C. Financial Planning/Consulting Services Legacy provides project oriented and ongoing financial planning services and consulting services to individuals and families where the firm offers advice or other strategic assistance in areas such as education funding, retirement planning, estate planning, risk management, employee benefits planning, tax planning, etc. When engaged to provide financial planning assistance, clients are responsible for determining whether or not to implement a recommendation, and if they decide to do so, are responsible for implementation. The details of an engagement vary on a case by case basis depending on the complexity of the client’s financial situation. Generally, however, an engagement involves identification of goals and objectives, collection and analysis of data, and formulation of a strategy, and may also include the preparation of a written plan. D. Non-Management Investment Advisory Services Legacy also provides non-management investment advisory and consulting services related to publicly traded investments, limited partnerships or private offerings in the real estate sector, alternative investments, and other types of investments.