Champion Advisors LLC

FEES AND COMPENSATION

   The Firm does not maintain a standard fee schedule applicable to individual managed
   accounts. Fees are negotiated on a case-by-case basis based upon factors determined
   by the Firm to be material including but not limited to account size and servicing
   requirements. Fees applicable to individual managed accounts can also be subject to
   change based on certain factors (e.g., account size) as described and agreed in
   advance pursuant to the investment advisory agreement between the Firm and its
   clients. Management fees will not exceed 1.0%.

   Fees are computed and billed quarterly, in advance, and are based on the market value
   of the client’s account on the last day of the month in the prior quarter. Fees will be
   prorated, on a monthly basis, with respect to new accounts opened during a quarter. Fees,
   which are deducted from clients’ accounts, include accrued interest and pending trades.

   Individual accounts for immediate family members (such as husband, wife, and dependent
   children) are aggregated, and the fee is charged based on the total value of all family
   members’ accounts.

                                                             Part 2A of Form ADV: Firm Brochure
                                                                          Champion Advisors LLC
                                                                                     March 2026

    Fees are negotiable, depending upon the complexity of the account, the individual
    client’s requirements for frequency of communication, potential future business, etc.
    Fees for the management of bonds and other fixed income instruments are negotiable
    and will vary according to the size and complexity of the account. Clients receiving the
    same service from the Firm can pay different fees. These asset management fees are
    separate from transaction, exchange, wire transfer, margin interest or account fees
    charged by the custodian. For more language on the custodian relationship, please
    refer to the section below “Brokerage Practices” for more details.

    Implementation with Mutual Funds: Funds held pending investment can be invested in a
    money market fund, or funds can also be invested in mutual fund shares. When the
    Firm recommends a mutual fund for a client’s account, three separate fees can be
    charged to the client, either directly or indirectly and are separate from the fee paid to
    the Firm. The first fee is the Firm’s investment management fee where the fund is
    included in the asset base for the quarterly fee calculation. The second is the set of
    internal fees charged by the investment company for the fund’s investment
    management, marketing, administration and marketing assistance. These internal
    expenses are disclosed in each fund’s prospectus which is provided to each client by the
    custodian. (This set of fees also applies to any ETF or money market fund purchased in
    the client’s account.) The third fee is a transaction fee which is assessed by the
    custodian for its service of providing access to a universe of mutual fund families through
    one account. To avoid such fees a client would be required to open a separate account
    with each individual mutual fund company instead of using the custodian recommended
    by the Firm, which would also negatively affect the Firm’s ability to deliver its services
    efficiently. Not all mutual fund or ETF trades enacted by the Firm incur this transaction
    fee. When recommending mutual funds for client portfolios, the Firm only recommends
    no-load funds.

    Termination

    The Investment Advisory Agreement (the “Agreement”) allows for termination by either
    party immediately upon receipt of written notice. The Agreement provides that the client
    can terminate the Agreement within five business days of its effective date without
    paying any fees or penalties to the Firm. If termination occurs after the first five days of
    the Agreement, prepaid fees which have not been earned will be returned to the client
    on a prorated basis.

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

    The Firm does not charge any performance-based fees or engage in side-by-side
    management.

TYPES OF CLIENTS

    The Firm provides investment advisory services to:
       •   Individuals
       •   High net worth individuals
       •   Trusts or estates
       •   Foundations

                                                             Part 2A of Form ADV: Firm Brochure
                                                                          Champion Advisors LLC
                                                                                     March 2026

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

   Investment advice is offered on any investments held by a client at the start of the
   advisory relationship. The primary vehicles recommended for investing are passively
   managed mutual funds and customized, laddered bond portfolios. The Firm generally
   only recommends investment grade bonds and monitors these securities for changes in
   rating.

   The Firm recommends public real estate investment trusts (REITS) and commodities
   index funds for certain clients who desire to include real estate or commodities in their
   asset allocation strategy.

   The Firm recommends alternative investments for certain clients who desire exposure to
   non-equity asset classes.

   The Firm will also evaluate insurance products such as annuities and various types of
   life insurance products.

   The Firm’s security analysis is based on a number of factors including those derived
   from commercially available software technology, securities rating services, general
   market and financial information, due diligence reviews and specific investment analysis
   that clients request.

   The Firm’s investment advice is based on long-term investment strategies incorporating
   the principles of Modern Portfolio Theory. The Firm’s investment approach is firmly
   rooted in the belief that markets are efficient and that investors' returns are determined
   principally by asset allocation decisions, not by market timing or stock selection. The
   Firm focuses on developing globally diversified portfolios, principally through the use of
   passively managed mutual funds that are available only to institutional investors and
   clients of a network of select investment advisors.

   Although all investments involve risk, the Firm’s investment recommendations seek to
   limit risk through broad global diversification and investment in high-quality fixed income
   securities. The Firm’s investment philosophy is designed for investors who desire a buy
   and hold strategy, with an investment time horizon of a minimum of five years, and
   preferably longer. Frequent trading of securities increases transaction costs that the
   Firm’s investment philosophy seeks to minimize for clients.

   Risk of Loss

   All investments present the risk of loss of principal – the risk that the value of securities
   (mutual funds, exchange traded funds (ETFs) and individual bonds), when sold or
   otherwise disposed of, could be less than the price paid for the securities. Even when
   the value of the securities when sold is greater than the price paid, there is the risk that
   the appreciation will be less than inflation. In other words, the purchasing power of the
   proceeds could be less than the purchasing power of the original investment.

   Some of the mutual funds and ETFs utilized by the Firm include funds invested in
   domestic and international equities, including real estate investment trusts (REITs),

                                                              Part 2A of Form ADV: Firm Brochure
                                                                           Champion Advisors LLC
                                                                                      March 2026

    corporate and government fixed income securities and commodity futures. Some equity
    securities include large capitalization, medium capitalization and small capitalization
    stocks. Mutual funds and ETF shares invested in fixed income securities are subject to
    the same interest rate, inflation and credit risks associated with the underlying bond
    holdings.

    Among the riskiest mutual funds used in the Firm’s investment strategies are the U.S.
    and International small capitalization and small capitalization value funds, emerging
    markets funds, and commodity futures funds. Conservative fixed income securities have
    lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation
    Protected Securities, or TIPS) present the risk of loss of purchasing power through lower
    expected return. This risk is greatest for longer-term bonds.

    Certain funds utilized by the Firm contain international securities. Investing outside the
    United States involves additional risks, such as currency fluctuations, periods of illiquidity
    and price volatility. These risks could be greater with investments in developing
    countries.

    More information about the risks of any particular market sector can be reviewed in
    representative mutual fund prospectuses within each applicable sector. Alternative
    investments usually entail a higher risk than other investments, as they are not
    regulated. Investing in any security entails risk of loss which a client should be prepared
    to bear.