The investment advisory services of FH Consultants are provided to you through an appropriately licensed individual who is an investment adviser representative (referred to as “IAR” throughout this Brochure) of FH Consultants. The IAR is not an employee of FH Consultants; rather, the IAR is an independent contractor of FH Consultants. For more information about the IAR, you should refer to the Brochure Supplement for the IAR (also known as the Form ADV Part 2B). The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time the Plan engages the IAR. If you did not receive a Brochure Supplement for the IAR, you should contact the IAR or FH Consultants at 636- 625-0900. The IAR is limited to providing the services and charging investment advisory fees in accordance with the descriptions detailed in this Brochure. However, the exact services the Plan receives and the fees you will be charged will be specified in the Retirement Plan Services Agreement (“Advisory Agreement”). The amount of employer-sponsored retirement plan assets managed by FH Consultants as of December 31, 2023 totaled approximately $202,470,422 on a non-discretionary basis (this figure excludes participant FBO accounts). This Brochure provides information about FH Consultants and the following types of advisory services which are provided via our wrap fee program: employer-sponsored retirement plan services (excluding FBO accounts, e.g., Corporation A 401k Account FBO John Doe). Please understand that a written agreement, which details the exact terms of the services provided, must be signed by the Plan, the IAR, and FH Consultants before any services can be provided. Employer-Sponsored Retirement Plan Services Under FH Consultants’ employer-sponsored retirement plan services, IARs assist persons that are trustees or other fiduciaries to employer-sponsored retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. IARs perform one or more of the following services, as selected by the Plan in the Advisory Agreement.  Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation to ascertain the Plan’s investment objectives and constraints  Acting as a liaison between the Plan and service providers, product sponsors or vendors  Ongoing monitoring of investment manager(s) or investments in relation to the criteria specified in the Plan’s IPS or other written guidelines provided by the Plan to the IAR  Preparation of reports describing the performance of the Plan’s investment manager(s) or investments, as well as comparing the performance to benchmarks  Ongoing recommendations for consideration and selection by the Plan about specific investments to be held by the Plan or, in the case of a participant-directed plan, to be made available as investment options under the Plan  Education or training for the members of the Plan’s investment committee with regard to various matters, including plan features, retirement readiness matters, service on the committee, and fiduciary responsibilities  Assistance in enrolling participants in the Plan, including conducting enrollment meetings. As part of such meetings, IARs will provide participants with information about the Plan, which typically includes information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan  Assistance with investment education seminars and meetings for Plan participants. Such meetings can be on a group or individual basis, and typically include information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk/return), and how to determine investment time horizons and assess risk tolerance. Such meetings do not include specific investment advice about investment options under the Plan as being appropriate for a particular participant  Recommendations, for consideration and selection by the Plan, regarding target-date or risk-based model portfolios based upon criteria stated in the Plan’s IPS  As part of the ongoing investment recommendation service set out above, assistance in identifying an investment fund product or model portfolio in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA  Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support  Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans  Assistance in identifying the fees and other costs borne by the Plan for investment management, recordkeeping, participant education, participant communication and/or other services as selected by the Plan If a particular Plan makes available publicly-traded employer stock (“company stock”) as an investment option under the Plan, IARs do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan are permitted to invest their assets in accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or are permitted to obtain participant loans, IARs do not provide individualized advice or recommendations to the participants regarding these decisions. Furthermore, IARs do not provide individualized investment advice to Plan participants regarding their Plan assets. The Plan is free to select any investment advisory firm, in lieu of the IAR, to provide other advisory services to them. FH Consultants provides services under this program as an investment advisor under the Investment Advisers Act of 1940 (“Act”), and is a fiduciary under the Act with respect to such services. In addition, if you elect in the Advisory Agreement to engage FH Consultants and the IAR to perform ongoing investment monitoring and ongoing investment recommendation services to a plan subject to ERISA, such services will constitute “investment advice” under Section 3(21) of ERISA. FH Consultants and the IAR will be deemed a “fiduciary” as such term is defined under Section 3(21) of ERISA in connection with those services. The Plan should understand that to the extent FH Consultants and the IAR are engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and therefore, FH Consultants and the IAR will not be a “fiduciary” under ERISA with respect to those other services. In addition, FH Consultants and the IAR shall not provide discretionary investment manager services as that term is defined in Section 3(38) of ERISA. Discretionary investment manager services under Section 3(38) of ERISA can be selected by the Plan to be provided by an independent third-party for a separate fee. From time to time FH Consultants and/or the IAR will make the Plan or Plan participants aware of and will offer other services available from FH Consultants or First Heartland® Capital, Inc. (FH Capital), our affiliated broker-dealer, which are separate and distinct from the services provided under this program. Such other services are available to the Plan, to the trustee or other fiduciary with respect to their responsibilities to the Plan, and/or to one or more Plan participants. In offering any such services, neither FH Consultants nor the IAR is providing the services under this program or acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to the Plan’s trustee, fiduciary and/or plan participants, they should make an independent assessment of such services without reliance on the advice or judgment of FH Consultants or the IAR. Fees and Compensation This section provides details regarding our fees and compensation. It should be noted that lower fees for comparable services are available from other sources. The exact fees and other terms for the advisory services the Plan will receive will be outlined in the Advisory Agreement between the Plan, the IAR, and FH Consultants. The maximum fee for our services is 1.75% (175 basis points) of the Plan assets. Fees are negotiable and can be paid quarterly in advance or in arrears depending on the custodian and/or service provider for the Plan assets. Fees charged are negotiated between the IAR and the Plan based on the IAR providing the services. As a result, the IAR will charge more or less for the same services than another IAR of FH Consultants and the IAR will charge the Plan, specifically, more or less for the same services than another Plan of the IAR. Of the total wrap fee charged, FH Consultants will retain .03% (3 basis point Platform Fee) on each Plan based on the total value of the Plan’s assets. The remainder of the total fee is paid to the IAR. Please

see your Advisory Agreement for more details. Fees are charged as a percentage of the total value of the Plan’s assets under management, typically billed either in advance or in arrears on a quarterly calendar basis, and typically calculated based on the value of the Plan’s assets as of the last business day of the previous billing period. It should be noted that certain service providers calculate fees based on average daily balance or some other methodology and you should refer to that service providers’ disclosures for additional information. Fees are prorated if services to the Plan start at any time other than the beginning of the billing period. If advisory services are commenced in the middle of the billing period, then the prorated fee for that billing period is based on the value of the account when services commence. Performance-based fees are defined as fees based on a share of capital gains or capital appreciation of the assets held in an account. We do not charge or accept performance-based fees. The Plan will pay more or less than if the Plan were to purchase the same or similar services separately. Among the factors impacting the cost of the program are the number of participants in the Plan, the asset value of the Plan, the services provided to the Plan, the services provided to participants, and the selected service provider. The IAR negotiates the fee to charge each Plan based upon factors such as total amount of assets involved in the relationship, the complexity of the planning services, and the number and range of other advisory and participant and/or Plan-related services to be provided. You should consider the level and complexity of the services to be provided when negotiating the fee with the IAR. For Plan wrap accounts held at Pershing, LLC (“Pershing”) the total fee includes fees you will pay related to security transactions (including, clearance and execution charges or “ticket charges”) as well as fees payable to us and the IAR. The wrap fee does not include fees payable to the third-party service provider. The Plan will pay more or less than if the Plan were to purchase the same or similar services separately. For Plan wrap accounts held at Pershing (excluding Managed 360®/BNY Mellon Advisors accounts), clearance and execution charges are assessed by Pershing to our affiliated broker-dealer, FH Capital, based on a percentage of assets under management (“Asset Based Pricing”). Pershing’s Asset Based Pricing charge is 1.5 basis points (bps) annually based on the fair market value of the Plan accounts. The charge is billed to FH Capital in arrears on a monthly calendar basis based on the end of month value of the account. FH Capital then bills your IAR and your IAR reimburses FH Capital for the Asset Based Pricing charge. It should be noted that the purchase and sale of alternative investments and certain mutual funds designated by Pershing as “surcharge funds” carry additional charges in addition to the normal clearance and execution charges and these additional charges are not included in the Asset Based Pricing charge. The IAR is solely responsible for any clearance and execution charges not included as part of the Asset Based Pricing. As such, this creates a conflict of interest as the IAR has an incentive not to recommend the purchase of alternative investments or “surcharge funds” as this increases the IAR’s cost. For Plan wrap accounts utilizing Managed 360®/BNY Mellon Advisors and all third-party service providers that do not custody at Pershing, neither FH Capital nor the IAR are assessed the 1.5 bps Asset Based Pricing charge. For Managed 360®/BNY Mellon Advisors accounts, all clearance and execution charges are included as part of the Managed 360®/BNY Mellon Advisors advisory fee charged to the Plan. Using Managed 360®/BNY Mellon Advisors and/or another third-party service provider creates a conflict of interest in that the IAR has an incentive to recommend use of Managed 360®/BNY Mellon Advisors and/or another third-party service provider to reduce his/her cost (i.e., by avoiding the Asset Based Pricing charge). The Plan will pay the advisory fee owed by submitting a check or EFT made payable to First Heartland® Consultants (not the IAR or an entity controlled by the IAR) or by instructing the Plan’s service provider or custodian to debit the fee from the Plan’s account(s) at the custodian and pay such fee to First Heartland® Consultants. The method of payment will be specified in your Advisory Agreement. The Plan will incur additional fees and charges, separate and distinct from the wrap fee, imposed by applicable third-party service providers in connection with these services. These third-party fees can include fund or annuity sub-account management fees, 12(b)-1 fees, administrative servicing fees, plan recordkeeping fees, and other service provider fees. Further information regarding charges and fees assessed by the third-party service provider are available in the appropriate prospectus or Plan contract. Many of the service providers also make available to you ERISA 3(21) investment advice and 3(38) investment manager services for additional fees. All fees for these services will be detailed in the service provider’s paperwork. If the Plan chooses our affiliated broker-dealer, FH Capital and its clearing firm Pershing, to be the service provider, the Plan will also incur other costs separate and distinct from the wrap fee including custodial fees, wire transfer fees, and other types of fees and charges imposed by the broker-dealer and/or Pershing. In addition, the wrap fee does not include other amounts that the Plan will be subject to such as the initial and ongoing expenses paid to third party investments or third party pooled investment vehicles, such as mutual funds, annuities, or alternative investments. Such expenses are usually set forth in the applicable offering document (prospectus) or the investment contract, and are payable or borne by the Plan in addition to any fee outlined above. If the Plan engages FH Consultants and the IAR to provide ongoing investment recommendations to the Plan regarding investment options to be made available to Plan participants, there generally will be two layers of fees with respect to such assets. The Plan will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. The Plan will also pay FH Consultants for the investment recommendation services. Therefore, the Plan can avoid the second layer of fees by not using the advisory services of FH Consultants and the IAR and by making its own decisions regarding the Plan’s investments. IARs who recommend services in this program to the Plan and their other clients will receive compensation as a result of the Plan’s participation in the program. Typically, this compensation will be more than what the IAR would receive if the Plan participated in other programs or services, or paid separately for investment advice, brokerage and other services. Therefore, IARs have a financial incentive to recommend these programs over other services available. The Plan should review its account statement received from the qualified custodian(s) and verify that the appropriate advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the advisory fees deducted. Participation in these programs will continue in effect until terminated by either party by providing notice of termination to the other party, or upon the IAR no longer being affiliated with FH Consultants. Any prepaid, unearned advisory fees will be refunded by FH Consultants and/or the applicable service provider for credit to the Plan account(s). Fee refunds will be determined on a pro-rata basis using the number of days for which services were actually provided during the final period. Please note that once terminated, the Plan will no longer be managed by the IAR and/or FH Consultants but accounts(s) will remain open at the applicable custodian until transferred to another firm or closed. In addition, with respect to Pershing account(s), in the event the IAR ceases to be affiliated with FH Consultants or the Plan is otherwise removed from management (with the exception of transfer to another firm), the account(s) will be assigned a new account number to designate that it is no longer an advisory account. The Plan will receive a letter detailing the new account number. If the IAR recommends mutual funds as part of the services for the Plan, some of those mutual funds charge asset-based sales charges or service fees (e.g., 12(b)-1 fees). Neither the IAR, nor FH Capital nor FH Consultants will retain any commissions or 12(b)-1 fees. The receipt of commissions and 12(b)-1 fees presents a conflict of interest because it gives the IAR an incentive to recommend products based on compensation received rather than on the Plan’s investment needs. If at any time, commissions or 12(b)-1 fees are paid by product sponsors to FH Capital as the broker-dealer, FH Consultants will use the amounts received to offset the advisory fee or return such amounts to the Plan account.