Firm Description and History Kelly Financial Services LLC (“Kelly Financial Services” or “KFS”) is a fee-based, registered investment adviser with its principal place of business located in Braintree, Massachusetts. The firm was established by William A. Kelly and Kelly D. Kelly in 2004 as a sole proprietorship owned by Mr. Kelly. Upon William Kelly’s death in October 2017, Kelly Kelly became the owner of the firm. She is continuing the business of KFS as a Massachusetts limited liability company of which she is the sole Managing Member and President. The management team is responsible for all investment decisions made on behalf of clients. Management has over 25 years combined experience in the financial services industry. The firm currently has Four investment professionals and several additional employees and service providers for administrative and technical support. For more information about KFS investment professionals please consult the ADV Brochure Supplement. Business Summary Wealth Management Services Kelly Financial Services provides wealth management to individual and high net-worth individuals. The Advisor charges a fee as a percentage of assets under management or a minimum flat fee, depending on account size. Generally, the client accounts are managed on a discretionary basis. However, the client is under no obligation to act upon any of the recommendations made by Kelly Financial Services and is free at any time to impose reasonable restrictions on investments in the account. Kelly Financial Services' principal service is managing the client’s investment portfolio based on the client’s specific investment objectives, goals and financial situation. The advisor will consider investment in individual stocks, ADRs, municipal, government and corporate debt securities, mutual funds, exchange-traded funds, REITs and publicly traded oil and gas interests As further described below, KFS’ investment advisor representatives may, in their capacity as licensed insurance agents, offer fixed index annuities and other insurance products to clients, for which they are paid a commission by the insurance company. Financial Planning Kelly Financial Services provides Financial Planning services to individuals and high net-worth individuals. The Advisor charges a fee to provide these services, which is based on an hourly or monthly rate. In addition to the hourly rate, Kelly Financial Services may change an additional fee based on the type of financial plan. All fees for Financial Planning services are disclosed in the Kelly Financial Services Custom Planning agreement. Other Services Kelly Financial Services may a l so render non-discretionary investment management services to clients relative to: (1) variable life/annuity products that they may own, and/or (2) their individual employer-sponsored retirement plans (e.g. 401k, 403b, 529 plans, and Thrift Savings Plan). In doing so, Kelly Financial Services recommends the allocation of client assets among the various mutual fund options that comprise the variable life/annuity product or the retirement plan. The client assets shall be maintained at either the specific insurance company that issued the variable life/annuity product, which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan. Strategy and Objective KFS’ investment strategies are principally geared toward income and capital growth consistent with the preservation of capital. However, in appropriate circumstances KFS may utilize strategies more strongly geared towards capital appreciation. The Adviser’s business is largely tailored to the investment needs of individuals and couples who are nearing retirement or already in retirement, though the Adviser does serve other clients as well, including small businesses. A KFS Investment Advisor Representative meets with the client to gather information about the client’s overall financial condition and specific objectives and needs including risk tolerance. The Representative then formulates an investment strategy accordingly. This information is reviewed with the client at least annually. REV 03302022 Page 5 of 18 KFS2004 Accounts

are generally invested in individual debt and equity securities, mutual funds, index funds, and/or exchange- traded funds in accordance with the client’s investment objectives. From time to time, a representative may assist a client in purchasing an investment in precious metals - there is no cost for this service. Clients should be aware of investments risks as well as other risks, restrictions on withdrawals and other information relevant to their investment. Additional information on certain investment risks is provided under Item 8, subsection Market, Security and Regulatory Risks below. Except as discussed below (under Fixed Index Annuities), Kelly Financial Services derives its revenues from investment advisory fees only. Fees are calculated as a percentage of the portfolio’s AUM and are typically directly debited from the client custodial accounts as allowed by the client/custodian agreement. No referral fees are paid or accepted. No cash payments or other benefits (e.g., “soft dollars”) are received from custodians or broker-dealers based on client securities transactions. All assets under the direct management of Kelly Financial Services are held by an independent qualified custodian, Fidelity Investments, and are held in the client’s name. Kelly Financial Services does not act as a custodian of client assets. Kelly Financial Services actively seeks to avoid conflicts of interest which may exist between the firm and its clients. In instances, when unavoidable conflicts of interest arise, they are fully disclosed to clients. KFS has adopted policies designed to mitigate conflicts and advance the clients’ best interests. Fixed Index Annuities Consistent with the investment objectives of many of its clients, in particular clients at or near retirement age, KFS may often recommend that clients invest a portion of their investible assets in fixed index annuities. These are insurance contracts which pay interest based on the performance of an external index, with the principal investment insured by the insurance company. Currently all KFS investment advisor representatives are also licensed as insurance agents in Massachusetts and some are registered in other states as well. At the time that a new client relationship is established, the client receives a disclosure document that explains the representatives’ dual roles. In addition, when the representatives determine that the purchase of a fixed index annuity or other insurance product is in the client’s best interest, the client is reminded that the investment adviser representative, while making the recommendation in his or her fiduciary capacity, is also acting in a sales capacity, and the dual roles create a conflict of interest. Third Party Manager KFS may, in appropriate cases, with a client’s consent, use the services of a third-party investment advisor (“sub-advisor”) to manage all or a portion of a client’s investment portfolio. Prior to engaging the sub-advisor, KFS will provide the sub- advisor’s Brochure on Form ADV2 to the client, disclose any other pertinent details of the arrangement, and obtain the client’s written consent. KFS will be responsible for paying the sub-advisor’s fee through a fee sharing arrangement with the sub-advisor. Other Service Providers KFS will cooperate with a client’s attorney, tax professional or other specialized advisers in developing an investment portfolio that is consistent with the client’s tax, estate planning and other personal objectives. Such professionals are hired directly by the clients. At a client’s request, the Adviser may provide the names of one or more of such professional firms. While such firms may at times recommend KFS to their clients as well, there are no compensatory arrangements between KFS and such firms. Wrap Fee Programs Kelly Financial Services does not manage assets under wrap fee programs or manage assets for any wrap fee accounts. Assets Under Management REV 03302022 Page 6 of 18 KFS2004 As of December 31, 2023, Kelly Financial Services had $ 426,845,780in assets under management in over 2,820 accounts for about 1,581 client households, of which $398,446,978 is held in discretionary accounts and $28,398,802 in non- discretionary accounts.