LEGAL DISCLOSURES

Cambridge Wealth Advisors, LLC, doing business as Cambridge Retirement Partners (“the Adviser”), is a Registered Investment Adviser registered with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940. The Adviser has been designated as an “investment manager,” as defined in Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), for certain assets of the Southeastern Pooled Employer Plan (PEP) (“the Plan”).

As an ERISA §3(38) investment manager, the Adviser has full discretion to:

- Select, monitor, and replace the Plan’s designated investment options.

- Develop and maintain model portfolios and/or qualified default investment alternatives (QDIAs), if applicable.

- Monitor ongoing investment performance and prudence in accordance with ERISA fiduciary standards.

- Act in accordance with the Investment Policy Statement (“IPS”) adopted by the Plan.

Fiduciary Acknowledgment:

The Adviser recognizes its fiduciary status under ERISA §3(38) regarding the Plan assets it has discretionary authority over. The Adviser accepts fiduciary responsibility for the prudence of investment decisions made on behalf of the Plan, following ERISA’s care standards.

Scope of Responsibility:

The Adviser’s discretionary authority is limited to selecting, monitoring, and replacing Plan investment options. The Adviser does not assume responsibility for:

- The selection, monitoring, or oversight of the Pooled Plan Provider (“PPP”) or other service providers.

- Administration, recordkeeping, custody, or compliance duties performed by the PPP or other vendors.

Employer responsibilities include remitting contributions, ensuring payroll data accuracy, and determining employee eligibility.

No Guarantee of Outcomes:

The Adviser does not guarantee investment performance or that any decision will be profitable. Investments involve risks, including potential loss of principal. Past performance does not predict future results.

Conflicts of Interest:

The Adviser receives compensation for its services through an agreement with the Plan’s Pooled Plan Provider. It does not receive compensation from investment managers, mutual funds, or other investment vehicles used in the Plan unless specifically disclosed in Form ADV Part 2 or the investment management agreement. The Adviser strives to avoid conflicts of interest and will disclose any material conflicts in writing.

Participant Responsibility:

Participants are responsible for making their own investment choices among the designated options unless they are defaulted into a QDIA, as permitted by ERISA and Department of Labor regulations. Participants should review all available materials, prospectuses, and disclosures before investing.

Regulatory Oversight:

As a Registered Investment Adviser, the Adviser is regulated by the SEC. Disclosures about the Adviser’s business, services, fees, and potential conflicts are available in the Adviser’s Form ADV Part 2A and Part 2B, which should be reviewed carefully at https://brokercheck.finra.org/ using CRD #: 148889.

Acknowledgment of Reliance:

By participating in the Plan, adopting employers acknowledge that the Adviser acts as an ERISA §3(38) investment manager solely for investment selection and monitoring, and that employers retain responsibility for functions not explicitly delegated.