FIRM BROCHURE

October 29, 2026 Q2 Wealth Management LLC Principal Office Address 1792 Alysheba Way Suite 150 Lexington, KY 40509 ITEM 1: COVER PAGE Websites: October 29, 2026 www.Q2WealthManagement.com www.Q2Wealth.com www.linkedin.com/company/q2wealthma nagement www.facebook.com/Q2Wealth Phone (859) 216-2169 Text (859) 407-6355 Fax (859) 687-9463 This brochure provides information about the qualifications and business practices of Q2 Wealth Management. If you have any questions about the contents of this brochure, please contact us at the phone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration (i.e., “registered investment advisor”) does not imply a certain level of skill or training. Additional information about Q2 Wealth Management (CRD # 314932) is available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 of 27  October 29, 2026 ITEM 2: MATERIAL CHANGES The Firm will deliver to each client annually, within 120 days after the end of the Firm’s fiscal year, a current Brochure, or the summary of material changes to the Brochure. Beyond our annual delivery, we will promptly provide interim updates to clients if a material change occurs regarding our disciplinary information (Item 9). Clients and prospective clients can receive the most current Brochure at any time by contacting their investment adviser representative. This brochure is dated as of October 29, 2026 Since our last annual update on March 25, 2026, the following material changes have been made to this Brochure: ▪ Model Portfolios (Item 4): Updated our model table to show "Target" allocations and clarified that "Active" and "Customizable" models may utilize leveraged/inverse funds and short positions. ▪ Self-Directed Software (Item 4): We added that upon request, we will provide access to self-directed software to create a projection or document. This tool is provided solely for your independent use and does not include our oversight, review, or recommendations until you engage those services. ▪ Shorting & Leverage Disclosures (Items 5, 8, & 10): We added specific disclosures detailing the unique fees (such as Hard to Borrow interest), risks, and potential conflicts of interest associated with utilizing inverse funds, leveraged products, and direct short selling. ▪ Affiliated Ownership (Item 10): We updated our disclosures to note that our affiliated insurance agency, Q2 Wealth Insurance LLC, has a passive minority ownership interest in the Firm. ▪ Minimum Household Relationship (Item 7): Changed from "No Account Minimum" to a $250,000 minimum household relationship. ▪ Client Referrals and Other Compensation (Item 14): Disclosed that the Firm may compensate internal employees and third-party promoters for referring prospective clients, outlining conflicts of interest. ▪ Custodial Benefits (Item 14): We added a disclosure regarding the economic benefits the Firm receives from our custodians, such as access to institutional trading platforms and technology, and the conflicts of interest this creates. ▪ Fees and Compensation (Item 5): Disclosed that we may mutually agree upon a fixed fee (not to exceed 2.00% annually) for specific accounts, assets, or the entire portfolio instead of our tiered breakpoint schedule, along with the associated conflicts of interest and fee negotiability. Also, we are ending invoice delivery for quarterly management fees, instead relying upon the qualified custodian to deliver account statements listing the deducted advisory fee. ▪ Mutual Fund Share Class Selection (Item 5): Clarified practices regarding share class selection, noting preference for lowest-cost No-Transaction-Fee (NTF) share classes to minimize client transaction costs. ▪ Voting Client Securities (Item 17): Disclosed that when an account is allocated to a sub-adviser, clients may authorize the sub-adviser to vote proxies where offered; otherwise, clients retain proxy voting responsibility. ▪ Outside Real Estate Activities & Principal Transactions (Items 10 & 11): Disclosed Raymond M. Backers' ownership and management of a personal real estate company, Aber Point LLC, along with associated conflicts of interest, and clarified in Item 11.D that our prohibition on principal and agency cross transactions applies specifically to securities. Page 2 of 27  October 29, 2026 ITEM 3: TABLE OF CONTENTS Item 1: Cover Page ............................................................................................................................................................. 1 Item 2: Material Changes ................................................................................................................................................... 2 Item 3: Table of Contents ................................................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................................................... 5 A. Firm Description ........................................................................................................................................................ 5 B. Types of Advisory Services ......................................................................................................................................... 5 Investment Management Services ................................................................................................................................ 6 Our Model Portfolios. ............................................................................................................................................... 6 Sub-Adviser Model Portfolios ................................................................................................................................... 7 Third-party Model Portfolios .................................................................................................................................... 7 Variable Annuity or Variable Life Insurance .............................................................................................................. 7 Fixed Indexed Annuity ............................................................................................................................................... 7 Donor-Advised Funds ................................................................................................................................................ 7 529 Plan..................................................................................................................................................................... 8 Educational Classes ................................................................................................................................................... 8 Financial Planning & Consulting .................................................................................................................................... 8 Q5 Wealth® ................................................................................................................................................................ 9 Disclosures applicable to our services ......................................................................................................................... 10 C. How Services are Tailored to Client Needs .............................................................................................................. 10 D. Wrap Fee Program versus Portfolio Management Program ................................................................................... 10 E. Assets Under Management ..................................................................................................................................... 10 Item 5: Fees and Compensation ....................................................................................................................................... 11 A. Advisory Services Compensation Description ......................................................................................................... 11 Investment Management Fee ................................................................................................................................. 11 Financial Planning or Hourly Consulting Fee ........................................................................................................... 11 Educational Class Fee .............................................................................................................................................. 12 Fee Negotiability ..................................................................................................................................................... 12 B. Deduct or Bill Client Fees ......................................................................................................................................... 12 C. Third Party / Custodian Fees / Sub-Adviser fee ....................................................................................................... 13 Mutual Fund Share Class Selection ......................................................................................................................... 13 D. Fee Billing Calculations ............................................................................................................................................ 14 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................... 15 Item 7: Types of Clients .................................................................................................................................................... 15 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................. 15 A. Methods of Analysis ................................................................................................................................................ 15 B. Investment Strategies .............................................................................................................................................. 16 C. Risk of Loss ............................................................................................................................................................... 16 Item 9: Disciplinary Information ....................................................................................................................................... 21 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................ 21 A. Registration as a Broker/Dealer or Broker/Dealer Representative ......................................................................... 21 B. Registration as a Futures Commission Merchant, Commodity Pool Operator ....................................................... 21 C. Relationships Material to this Advisory Business and Possible Conflicts of Interest ............................................... 21 D. Selection of other Advisors ..................................................................................................................................... 22 Item 11: Code of Ethics, Participation or interest in client transactions and Personal Trading ....................................... 22 A. Description of Code of Ethics .................................................................................................................................. 22 B. Employee Trading with a Material Financial Interest .............................................................................................. 23 Page 3 of 27  October 29, 2026 C. Investing in the same securities as clients. .............................................................................................................. 23 D. trading securities at or around the same time as clients. ....................................................................................... 23 Item 12: Brokerage Practices ............................................................................................................................................ 23 B. Research and Other Soft Dollar Benefits ................................................................................................................. 24 C. Brokerage for Client Referrals ................................................................................................................................. 24 D. Directed Brokerage ................................................................................................................................................. 24 E. Order Aggregation ................................................................................................................................................... 24 F. Trade Error Policy..................................................................................................................................................... 25 Item 13: Review of Accounts ............................................................................................................................................ 25 A. Periodic Reviews ...................................................................................................................................................... 25 B. Other than Periodic Basis ........................................................................................................................................ 25 C. Reports .................................................................................................................................................................... 25 Item 14: Client Referrals and Other Compensation ......................................................................................................... 26 A. other compensation ................................................................................................................................................ 26 B. client referrals ......................................................................................................................................................... 26 Item 15: Custody .............................................................................................................................................................. 26 A. Custodian of Assets ................................................................................................................................................. 26 Item 16: Investment Discretion ........................................................................................................................................ 26 Item 17: Voting Client Securities ...................................................................................................................................... 26 Item 18: Financial Information ......................................................................................................................................... 27 A. Balance Sheet Requirement .................................................................................................................................... 27 B. Financial Condition .................................................................................................................................................. 27 C. Bankruptcy Petition ................................................................................................................................................. 27 Page 4 of 27  October 29, 2026 ITEM 4: ADVISORY BUSINESS A. FIRM DESCRIPTION ABOUT THE FIRM Q2 Wealth Management LLC (“Q2”, “Firm”) is an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). Founded in April 2021, the firm was initially registered with the Kentucky Department of Financial Institutions (DFI) in October 2021 and transitioned to SEC registration in August 2025. The Firm is principally owned and controlled by Raymond M. Backers, who serves as the Manager. OUR CLIENTS We provide financial planning and investment management services to individuals, families, and high-net- worth clients, as well as their related trusts and businesses. OUR MISSION & PHILOSOPHY Our mission is to guide clients through the financial stages both before and after retirement. Central to this mission is our belief that a successful retirement demands a holistic plan to serve as your financial roadmap, integrating investment, tax, insurance, and estate planning strategies. OUR VALUE & APPROACH We recognize that many investors are not sure what questions to ask to get the answers they need. Our value lies in acting as your guide, leveraging our knowledge, professional tools, and process to help you make informed decisions. Central to our approach is maintaining an open dialogue, so we understand you and so you understand the reasoning behind our strategies. B. TYPES OF ADVISORY SERVICES The Firm offers separate advisory services centered on Investment Management and Financial Planning & Consulting. You can engage one or both services. The specific nature of our relationship is detailed in a written agreement, either an Investment Advisory Agreement (IAA) or a Financial Planning & Consulting Agreement (FPA). SERVICE TYPE OF FEE ADVISORY FEE SUMMARY Investment Management % of AUM Account specific advice, portfolio management, ongoing monitoring, and periodic reviews. 1.35% - 0.50% (Tiered) Up to 2.00% (Flat) Financial Planning Flat Fee $2,000 per area One or more areas from our 5 Pillars (Retirement, Tax, Insurance, Investment, Estate) or Custom. Hourly Consulting Hourly Fee $100 - $500 per hour Advice outside normal management or planning. Help answering specific questions or assistance with distinct tasks. Important Note: This table is a summary provided for your convenience. Please read the remainder of this section for a complete description of these services and limitations. Please refer to Item 5: Fees and Compensation for a full breakdown of our fee schedules, prorated billing mechanics, and other costs. For your convenience, here is a helpful way to think about our core services: 1. Investment Management (Execution): This is how we implement a strategy, trade, and monitor your accounts. 2. Financial Planning (Preparation): This is how we build your roadmap to reach your goals. 3. Hourly Consulting (Targeted): This is how we answer certain questions you have or assist with certain tasks. Page 5 of 27  October 29, 2026 INVESTMENT MANAGEMENT SERVICES Our investment management services focus on building and managing portfolios designed to meet your specific risk tolerance, objectives, and time horizon. These are offered on either a discretionary or non- discretionary basis. On a discretionary basis, we have the authority to make investment decisions, such as buying or selling securities, on your behalf without seeking your approval for each individual transaction. Alternatively, on a non-discretionary basis, we provide recommendations, but you retain the final authority and must approve our advice before any trades are made. For ease of understanding we describe our portfolios using two primary asset classes: Equity and Fixed Income, which we define broadly to allow for greater diversification. The Equity portion is designed for growth and may include, but is not limited to, traditional asset classes such as large cap, small cap, or REITs. The Fixed Income portion is designed for stability and income and may include, but is not limited to, bonds, debt instruments, and cash equivalents. Real assets (such as gold, precious metals, and commodities) and alternatives may be counted toward either the Equity or Fixed Income portion, or maintained separately, at the Adviser's discretion. We typically use exchange-traded funds (ETFs) and/or mutual funds (MFs) for the equity portion and fixed income products for the bond portion. OUR MODEL PORTFOLIOS. We primarily use a series of model portfolios as the foundation for client accounts. As the discretionary manager of these models, we will replace funds, change asset and sub-asset allocations, and rebalance using professional judgment, specific time frequencies, drift tolerance from target, or other reasons based on our analysis. A Note on Model Implementation: Implementation of our models can be flexible to suit specific client circumstances. To ensure proper diversification, facilitate efficient portfolio management (such as cash flows), maintain consistency across client accounts, or achieve other operational efficiencies, the Adviser may construct a portfolio with other assets, mutual funds instead of ETFs, or a combination of both, regardless of account size. Our Tactical models are designed to use individual stocks for all or nearly all of their equity allocation. Similarly, our Focused models utilize a core-and-satellite approach. While the core typically holds equity funds, the satellite portion is designed to hold individual stocks or focused funds. The “Risk-Based” model noted below is fully customizable and named by the chosen risk tolerance (e.g., "Aggressive" or "Moderate"). Model Target Risk Tolerance Composition Style Allocation Strategy Risk-Based Customizable Customizable Customizable Customizable Customizable Customizable Balanced 40 Balanced 50 Balanced 60 40 / 60 50 / 50 60 / 40 Mod. Conservative Moderate Moderate Funds Factors Global Strategic Active Active Active Growth 70 Growth 80 Growth 90 Growth 100 Active Balance Active Growth 70 / 30 80 / 20 90 / 10 100 / 0 Active Active Mod. Aggressive Mod. Aggressive Aggressive Aggressive Moderate Mod. Aggressive Funds Funds Domestic Fund Core & Satellite Concentrated & Domestic Tactical Stock Selection 100 / 0 100 / 0 100 / 0 100 / 0 Aggressive Aggressive Aggressive Aggressive Blend Blend Stocks Stocks Blend Growth Blend Growth Focused Equity Focused Growth Tactical Equity Tactical Growth Key. The terms used in the table above are defined as follows: a. Target: The typical equity to fixed income target exposure. The Adviser may over or underweight target exposure. b. Risk Tolerance: The managed risk of capital loss for the potential reward (e.g., volatility). c. Composition: Describes the investment vehicle typically used in the model. i. Stocks: The model typically holds direct ownership in individual companies. Page 6 of 27  October 29, 2026 ii. Funds: The model typically holds Exchange-Traded Products (ETPs) and/or Mutual Funds (MFs). iii. Blend: The model typically holds a combination of funds and/or stocks. d. Style: Refers to an investment approach such as growth, value, or a blend of the two. Factors include characteristics like growth, value, quality, size, momentum, and themes. e. Allocation: Refers to a geographic region (e.g., domestic or global) or asset class. If an allocation is labeled “Concentrated,” it means the model focuses on a smaller group of investments rather than being broadly diversified. f. Strategy: Describes the investment methodology guiding the model’s management. Please refer to Item 8.B of this brochure for a detailed breakdown of these strategies. g. Active: Means any category (style, factors, allocation, strategy) can change at any time based on our analysis. These flexible models may use leveraged products or inverse funds, meaning your total market exposure could exceed your account value. h. Customizable: Indicates a highly flexible model built around Client requests or professional judgment. These unconstrained portfolios may also use leveraged products, inverse funds, or direct short positions, meaning your total market exposure could exceed your account value. SUB-ADVISER MODEL PORTFOLIOS We may allocate all or a portion of a client's portfolio to a sub-adviser. Our role is to select the sub-adviser, determine the appropriate asset allocation, and continuously monitor their performance. We retain full discretion to hire, replace, or blend sub-adviser models, as we deem appropriate. THIRD-PARTY MODEL PORTFOLIOS We may construct and manage all or a portion of a client's portfolio based on a third-party investment model. Unlike sub-advisers, these model providers do not manage assets directly. We retain full discretion to select or blend the models, execute trades, and rebalance the account. VARIABLE ANNUITY OR VARIABLE LIFE INSURANCE We provide discretionary and non-discretionary investment management services for assets held within fee- based variable insurance products, such as variable annuities and variable life insurance. While these products offer tax-deferred growth, clients should understand they are insurance contracts that have unique features and their own set of internal costs, which differ from those of a standard brokerage or IRA account. For our discretionary service, we will select and implement allocation changes among the subaccounts on your behalf. For our non-discretionary service, we will recommend an allocation for your approval, and you retain the final authority for all decisions. FIXED INDEXED ANNUITY As part of our services, the Firm offers non-discretionary advice regarding the purchase of fee-based Fixed Indexed Annuities (FIAs). Our role is to analyze the available indexed crediting strategies within a proposed FIA and recommend an allocation for your approval. It is important to understand that an FIA is a long-term insurance contract, not a security, and our firm does not receive a commission on its sale. Instead, the value of the annuity is included in the assets upon which you pay your advisory fee. Clients should be aware of the material risks associated with these products, including long surrender periods that make them illiquid, caps or other limits on potential gains, and the fact that any guarantees made by the insurance company are only backed by the financial strength of that issuing insurance company. DONOR-ADVISED FUNDS We offer both discretionary and non-discretionary investment management services for the assets held within Donor-Advised Funds (DAFs). A DAF is a charitable giving vehicle where you make an irrevocable contribution to a public charity that sponsors the program. While the sponsoring charity has ultimate legal control over the funds, you, as the donor, retain the privilege to advise on how the assets are invested and which charities receive grants. Our role is to act as your investment advisor for the DAF account, helping you manage the assets with the goal of maximizing their potential for charitable giving. Under our discretionary service, you grant us the authority to make investment decisions on your behalf, which we will then implement by advising the sponsoring charity. Alternatively, under our non-discretionary service, we provide investment recommendations that you must approve before we advise the sponsoring charity to make any changes. Page 7 of 27  October 29, 2026 529 PLAN We offer non-discretionary advisory services for 529 College Savings Plans. Our role is to review the menu of investment options available within a specific 529 Plan and provide a recommendation for an allocation strategy consistent with the chosen risk tolerance, objective, and time-horizon. As this is a non-discretionary service, you retain the final authority to approve our recommendation and are responsible for implementing the changes within the 529 Plan. This service is only available for direct-sold 529 Plans that permit the owner to grant access to a third-party investment advisor. Resources such as 529 Quickview® (https://www.529quickview.com/home/planlist.html) can help identify these plans. Clients should be aware that 529 Plans are administered by individual states, and the investment options are determined by a designated program manager. In some cases, actions such as portfolio rebalancing are performed automatically by the program manager and are not controlled by our firm. EDUCATIONAL CLASSES From time to time, the Firm may offer educational classes or workshops for clients and the public. These events cover financial topics such as retirement, investment, insurance, tax, and estate planning. All information presented during these events is for educational purposes only and is intended for a broad audience. The content is not an offer or solicitation for the sale of any security, product, or service, nor is it intended to provide specific tax or legal advice. Attendees should consult with their professional advisors regarding their individual situations. FINANCIAL PLANNING & CONSULTING We offer financial planning and consulting services to help you organize your financial life and create a step- by-step approach to meet your goals, with services available for a single planning area, multiple areas, or as needed on an hourly basis. OUR PLANNING AREAS We offer several limited-scope plans that may stand alone or be combined in any variation needed for your specific situation. A comprehensive plan consists of three or more areas, and each plan includes a written plan or a software report. Alternatively, you may engage the Firm for Hourly Consulting to receive advice, analysis, or Q&A across any area(s) without requiring a written plan or software report. Our core process is built around our Five Pillars of Financial Planning, with the flexibility to add custom areas for your unique needs: 1 DESCRIPTION Income, savings, growth, probability of success, and stress testing. PILLARS Retirement 2 Investment Assets or accounts unable to use our management services. 3 Tax Strategies to defer, minimize, or reduce taxation. 4 Insurance Manage risk through various types of coverage. 5 Estate Inform the client or client-attorney relationship. Unique situations like education or business needs. Custom THE STAGES OF OUR PLANNING SERVICE Our financial planning engagements are clearly defined to ensure you understand your role and ours. The service typically involves the following stages: 1. The Financial Plan: Initially, we analyze your situation and develop recommendations designed to 2. achieve your goals. Implementation: This is the process of acting on our recommendations. Once your plan is delivered, you can implement the recommendations by engaging our other services (such as Investment Management or Hourly Consulting) or by putting them into action on your own. If you engage us for implementation, we recommend and present actions, products, and services to execute. Page 8 of 27  October 29, 2026 3. Monitoring: This is tracking your progress toward your goals through periodic reviews and reasonable access for questions. This service is available while Investment Management Services (IMS) are active or for an ongoing monthly fee. Requests requiring extensive new analysis, modeling of new scenarios, or time beyond reasonable access fall outside normal service and require an additionally agreed upon hourly fee. 4. Updating: Life circumstances and financial markets change. If monitoring is applicable, we will update the plan with material information as circumstances warrant. For updates to a plan without monitoring, a Plan Update Fee may apply, provided the scope is substantially similar to the original, or a new Financial Plan Fee may apply. FINANCIAL PLANNING PROCESS The process is divided into two phases: Planning (Steps 1–5) and Additional Services (Steps 6–8). 1 STEPS Establish DESCRIPTION Define how we will be helping you. 2 Gather Collect financial data and establish personal goals. 3 Analyze Review your current financial situation. 4 Develop Receive tailored recommendations and alternatives. 5 Review and deliver the plan. Present 6 Implement Execute recommendations through specific actions, products, or services. 7 Monitor Periodically review the progress towards your goals. 8 Update Refresh planning data as your life, goals, and financial circumstances change. Pursuant to CFP Board Standards of Conduct C.6 & C.7, a CFP® Professional must establish with the Client whether the CFP® Professional has implementation, monitoring, or updating responsibilities. Monitoring and updating responsibilities are established in the financial planning and consulting agreement. Implementation responsibilities are identified after plan completion. Depending upon the plan and scope, these responsibilities may or may not be applicable. Tax and Legal Limitations: Our tax or estate analysis is designed to inform so you finalize implementation solutions with your tax or legal professional. The Adviser is not an accounting or law firm; we do not provide legal advice, legal opinions, or tax preparation. The Client remains solely responsible for selecting the final legal structure. Clients should review all tax and legal strategies with their professional before implementation. SELF-DIRECTED SOFTWARE Upon request, we provide clients with complimentary access to self-directed software. These tools allow you to input your own data for basic projections or standard documents based on your provided information. Please note: This access is provided solely as a self-directed technology tool. It does not include our firm's advisory services or recommendations. If you require our time, professional advice, customization, or specific guidance, those services can be established by discussing the need with one of our representatives. Q5 WEALTH® Our Q5 Wealth® service combines financial planning with investment management services. This service provides for a comprehensive relationship with the Adviser, offering advice across five planning areas: retirement, investment, tax, insurance, and estate. Page 9 of 27  October 29, 2026 DISCLOSURES APPLICABLE TO OUR SERVICES FIDUCIARY DUTY: The Firm and its representatives are fiduciaries and must act in the best interest of the Client at all times. RISK OF LOSS: Investing is inherently risky. Past performance does not ensure future results, and clients may suffer a loss of part or all of their investment. The Firm does not guarantee any investment returns or results. RETIREMENT PLAN AND IRA FIDUCIARY ACKNOWLEDGEMENT When the Adviser and its representatives provide advice or make recommendations regarding your retirement plan or individual retirement accounts (“IRA”) they are relying on prohibited transaction exemption 2020-02 and 84-24, as applicable, and they acknowledge their fiduciary status as written below. We are making investment recommendations to you regarding your retirement plan or individual retirement account as 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. The way we make money or otherwise are compensated creates some conflicts with your financial interest, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ▪ Meet a professional standard of care when making investment recommendations (give prudent advice) to you; ▪ Never put our financial interests ahead of yours when making recommendations (give loyal advice); ▪ Avoid misleading statements about conflicts of interest, fees, and investments; ▪ Follow policies and procedures designed to ensure that we give advice that is in your best interest; ▪ Charge no more than is reasonable compensation for our services; and ▪ Give you basic information about conflicts of interest. C. HOW SERVICES ARE TAILORED TO CLIENT NEEDS Advisory services are tailored to the specific needs of each client. Our process begins with a consultation to understand your financial situation, investment objectives, risk tolerance, and time horizon. This information forms the basis of a written Investment Policy Statement that guides our recommendations. Services are further tailored by, ▪ Offering financial plans encompassing several areas or a customizable plan. ▪ Providing hourly consulting for advice outside normal management or planning services. ▪ Engaging nondiscretionary management for allocation and holding flexibility. ▪ Allocating to a sub-adviser to manage all or a portion of your accounts. ▪ Accommodating your requests to impose reasonable investment restrictions, such as excluding specific securities. D. WRAP FEE PROGRAM VERSUS PORTFOLIO MANAGEMENT PROGRAM The Firm does not offer a Wrap Fee Program. E. ASSETS UNDER MANAGEMENT As of December 31, 2025, the Adviser has the following assets under management: Discretionary assets: $119,106,027 Non-discretionary assets: $4,385,549 Total assets: $123,491,576 Page 10 of 27  October 29, 2026 ITEM 5: FEES AND COMPENSATION A. ADVISORY SERVICES COMPENSATION DESCRIPTION INVESTMENT MANAGEMENT FEE Our investment management fee is up to 2.00% of assets under management annually, billed quarterly in arrears (meaning after the billing period has ended), and structured as either a tiered fee based on the breakpoint schedule below or a mutually agreed-upon fixed fee. Assets Under Management (AUM) Annual Fee $0 to $250,000 1.35% $250,000.01 to $1,000,000 1.30% $1,000,000.01 to $2,000,000 1.25% $2,000,000.01 to $3,000,000 1.20% $3,000,000.01 to $4,000,000 1.10% $4,000,000.01 to $5,000,000 1.00% $5,000,000.01 to $10,000,000 .90% $10,000,000.01 to $15,000,000 .80% $15,000,000.01 to $20,000,000 .70% $20,000,000.01 to $30,000,000 .60% Continual, $30,000,000.01+ .50% Under our automated tiered breakpoint schedule, the entire portfolio is charged the same management fee based on the value of the entire portfolio at the end of each quarter. For billing purposes, the "entire portfolio" includes all accounts we manage for you, your spouse, a partner, or a substantially similar relationship that allows for the aggregation of account values. Alternatively, we may mutually agree upon a fixed fee (not to exceed 2.00% annually) for specific accounts, assets, or the entire portfolio instead of our tiered investment management fee. Depending on your entire portfolio value, a fixed fee may result in a higher fee than you would pay under the breakpoint schedule. This creates a potential conflict of interest, as we have an incentive to recommend or negotiate a fixed fee that may be more favorable to us. We address this conflict by clearly disclosing the fee structure and obtaining your consent prior to implementation. To calculate a full quarterly fee, the corresponding annual fee rate is divided by four and then multiplied by the account balance at the end of the quarter. Quarterly fees are prorated for accounts that open or close during the billing period. Any earned fees are promptly owed upon account closure. Any proposed increase to the fee schedule is only effective upon your consent. FINANCIAL PLANNING OR HOURLY CONSULTING FEE FINANCIAL PLANNING FEES We offer financial planning services on a fixed fee basis. The fee is typically $2,000 for a single planning area (e.g., Retirement). The fee for updating an existing plan is typically $1,000 per area. For comprehensive plans covering multiple areas, the total fee will be higher. We will always provide you with a written quote detailing the scope and total fee in your Financial Planning Agreement before you engage our services. ▪ Plan Monitoring: We offer ongoing Plan Monitoring for the planning area(s) agreed upon in the financial planning agreement. For clients with active Investment Management Services (IMS), monitoring may be provided at no additional fee ($0) while IMS are active. For all other engagements, the fee is typically $100 monthly per monitored area, billed monthly in arrears: monitoring for existing areas continues uninterrupted on the existing billing cycle (or begins upon execution if not Page 11 of 27  October 29, 2026 previously monitored), while monitoring for new areas begins upon plan delivery and aligns with the existing or agreed-upon billing cycle. ▪ Billing Schedule: Planning and Update Fees are billed $500 in advance for one area, or $1,000 for two or more areas, with the remaining balance due upon delivery of the plan. ▪ Termination Policy: Either party may terminate a financial planning agreement or ongoing services at any time, without penalty, by providing written notice, effective upon receipt (or upon termination of Investment Management Services (IMS) when monitoring is tied to active IMS). Upon termination of a financial plan prior to delivery, the earned fee is calculated based on the work completed through the termination date at $250 per hour (not to exceed the advance deposit), and any unearned portion of the deposit will be promptly refunded; once the plan is delivered, the fixed fee is earned and owed less any advance payment. Upon termination of Plan Monitoring, the earned fee is prorated through the mid-cycle termination date. HOURLY CONSULTING FEES We offer consulting services at an hourly rate, ranging from $100 to $500 per hour depending on the nature of the work and the representative. Fees are billed in arrears for actual time worked at the agreed-upon hourly rate and up to the fee limit determined in the agreement (billed upon completion for one-time projects, or monthly in arrears for ongoing consulting). Billable work ceases once the limit is reached (resuming the following period for monthly consulting) unless you provide written authorization (via email, text, or amendment) to increase the limit. Termination Policy: Either party may terminate an hourly consulting engagement at any time by providing written notice. Upon termination, the earned fee is calculated and owed for actual time worked through the termination date (not to exceed the agreed-upon fee limit). EDUCATIONAL CLASS FEE Classes are offered free of charge or for a fee of up to $100 per student, payable in advance. Attendees receive a full refund if a class is canceled by the Firm. Specific cancellation, refund, substitution, and rescheduling terms are provided at the time of registration for each class. FEE NEGOTIABILITY Our fees are negotiable at our discretion, and the Firm retains discretion to waive, reduce, or vary fees based on scope, complexity, or client relationship. As a result, clients, or accounts of the same client, with similar assets or receiving similar services may pay different fees (more or less than other clients or accounts). B. DEDUCT OR BILL CLIENT FEES Financial planning fees can be paid by credit card, ACH, check or deducted from a Client specified account. Financial Planning fees may be billed directly to and deducted by the Custodian from the Client's account upon authorization. An educational class fee can be paid by credit card or ACH. The investment management fee is billed directly to and deducted by the Custodian from the Client's account. On at least a quarterly basis, the Custodian is required to send to the Client a statement showing all transactions within the account during the reporting period, including the amount of the advisory fee deducted. The Custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of the fee calculation. Therefore, it is important for Clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact the Firm directly if they believe there may be a billing error. The fee is directly deducted unless a separate account is specified or required for fee deduction, or alternative methods are mutually agreed upon. When direct deduction is not available or permitted, the Client must specify a separate account for fee deduction or an alternative method of payment. Page 12 of 27  October 29, 2026 C. THIRD PARTY / CUSTODIAN FEES / SUB-ADVISER FEE In addition to our fees, depending on your situation, custodian, investment, and product you will incur additional costs, such as custodian fees, account maintenance fees, transaction costs, surrender charges, wire transfer, check, or electronic fund fees, partial or full transfer fees, and fees related to exchange traded products, mutual funds, variable life or annuity products, and other custodian, investment, or product related fees. The Adviser may allocate Client assets to sub-advisers (who manage and execute trades for the account) or utilize third-party models (where the Adviser executes the trades). Both sub-advisers and model providers may charge a fee for their services. When a sub-adviser or third-party model fee is charged, it is paid by the Adviser. Furthermore, these outside managers and model providers may utilize their own proprietary funds (e.g., mutual funds or ETFs) within the portfolio. When this occurs, you pay the internal expense ratios of those funds. If your account uses direct leverage (such as borrowing on margin to purchase securities), you will incur direct margin interest and borrowing fees charged by the custodian. These fees are calculated daily and debited directly from your individual account. If your account uses direct short selling instead of inverse funds, you will incur additional fees charged by the custodian that do not apply to long-only accounts. For certain securities, this may include 'Hard to Borrow' (HTB) interest fees. These fees are calculated daily and debited directly from your individual account. Additionally, for certain block trade executions, the Custodian may charge a flat per-account fee (e.g., $5.00) rather than splitting a single cost between all participating accounts. An expense ratio, for example, is the internal management fee a fund or product charges to operate (e.g., 0.25% per year). These fees are deducted directly from the fund's assets, reducing its investment returns and, consequently, your portfolio's return over time. Performance figures quoted by a fund or product in various publications are shown after this cost has been deducted. No Revenue Sharing: The Adviser does not receive any compensation from any sub-adviser, third-party model provider, custodian, or fund company, and we do NOT share in any of the third-party fees, margin interest, or internal expense ratios. MUTUAL FUND SHARE CLASS SELECTION When implementing investment strategies that utilize or include mutual funds, the Firm owes clients a fiduciary duty to seek best execution, which includes minimizing transaction costs and internal expense ratios. No Transaction Fee (NTF) Preference: To minimize direct trading costs for client accounts, the Firm seeks the lowest-cost NTF share classes available on the specific qualified custodian's platform. This practice allows the Firm to construct, manage, and rebalance portfolios without subjecting client accounts to upfront or ongoing custodial transaction fees. Transaction-Fee Share Classes: The Firm may select a transaction-fee share class for specific long term buy- and-hold strategies or larger account scales when a fund's share class with a lower internal expense ratio is reasonably expected to offset cumulative custodial transaction costs over time. Page 13 of 27  October 29, 2026 D. FEE BILLING CALCULATIONS Billing software calculations contain several decimal places which may result in slight differences from the illustrations below. Full quarter fee: Example of an account with $1,500,000 on the last day of the most recent quarter, D X E = F D = quarterly fee: 1.25% annum fee ((1.25% / 4) = .003125) E = Account Balance: $1,500,000 F = Fee Calculation: .003125 x $1,500,000 = $4,687.50 When an account opens: Example of a prorated account funded on 5/26/2021 with $1,500,000 on the last day of the most recent quarter, Step 1: Calculate a full quarter, ((1.25% / 4) x $1,500,000) = $4,687.50 Step 2: Calculate the adjustment as follows, (C x D) X E = F C = Day Adjustment [unused days/days in quarter]: (55/91) = .604396 D = quarterly fee: 1.25% annum fee ((1.25% / 4) = .003125) E = Account Balance: $1,500,000 F = Adjustment Calculation: (.604396 x .003125) x $1,500,000 = $2,833.11 Step 3: Subtract adjustment from full quarter fee, ($4,687.50 - $2,833.11 = $1,854.39) The prorated quarterly fee is $1,854.39 When an account closes: Example of a prorated account closing on 5/26/2021 with $1,500,000 as the most recent account balance, Step 1: Calculate a full quarter, ((1.25% / 4) x $1,500,000) = $4,687.50 Step 2: Calculate the adjustment as follows, (C x D) X E = F C = Day Adjustment [unused days/days in quarter]: (36/91) = .395604 D = quarterly fee: 1.25% annum fee ((1.25% / 4) = .003125) E = Most recent account balance: $1,500,000 F = Adjustment Calculation: (.395604 x .003125) x $1,500,000 = $1,854.39 Step 3: Subtract adjustment from full quarter fee, ($4,687.50 - $1,854.39 = $2,833.11) The prorated quarterly fee is $2,833.11 Page 14 of 27  October 29, 2026 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The Firm does not charge or accept performance-based fees. ITEM 7: TYPES OF CLIENTS The Firm provides investment advice to many different types of clients. These clients generally include individuals, high net worth individuals, trusts, estates, corporations, and other types of business entities. The Firm generally seeks a minimum household relationship of $250,000. However, we do not require a specific minimum for individual accounts, and we do manage smaller accounts as part of a larger client relationship or at our discretion. All minimums are negotiable and may be waived based on factors such as plan monitoring, client contributions, anticipated additional assets, or pre-existing relationships. Third-party or sub-adviser managed accounts generally have minimum requirements, and these minimum requirements vary from manager to manager. Account minimums are generally higher on fixed income accounts than on equity-based accounts. The following discretionary models have a minimum account balance; the Adviser may deviate when suitable based upon proximity to minimum, future or continual additions, or periods of decreased value from market conditions. Model Risk-Based Balanced Growth Active Focused Tactical Minimum $1,000 $1,000 $1,000 $20,000 $1,000 $50,000 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. METHODS OF ANALYSIS To guide our investment decisions, we may use several methods of analysis. Each has its own strengths and inherent risks. Fundamental Analysis What It Is: This method focuses on determining a security's "true" value by examining the underlying company's financial health, management, competitive position, and broader economic conditions. The goal is to identify securities that may be over or undervalued by the market. Primary Risk: Our analysis and valuation may be incorrect, or the market price may not adjust to reflect the value we have calculated. Technical Analysis What It Is: This method involves analyzing market statistics, such as historical prices and trading volumes, to identify patterns and trends. We use tools like charting to visualize this data and forecast potential future price movements. Primary Risk: Past performance and historical patterns are not reliable predictors of future results. Cyclical & Economic Analysis What It Is: This approach involves analyzing recurring patterns in the broader economy and market cycles to identify how they might affect different investments. It relies on economic data such as GDP, inflation, and employment trends. Primary Risk: Historical cycles are not guaranteed to repeat, and our interpretation of economic data may be incorrect or fail to predict market reactions. Page 15 of 27  October 29, 2026 B. INVESTMENT STRATEGIES When providing investment advice, we may employ several strategies to pursue your financial objectives. To implement our strategies, we recommend the specific approach we believe is in your best interest based on your goals, risk tolerance, and objectives. Our General Investment Approach Long-Term Purchases (Generally > 1 Year): Our primary approach is to invest in securities with the expectation that their value will grow over a relatively long period. This strategy is designed to capture market rates of return and risk over time. This approach is suited for clients pursuing long-term goals such as retirement. Short-Term Purchases (Generally < 1 Year): On occasion, we may purchase securities with the expectation of selling them in a shorter period to take advantage of specific market opportunities or price fluctuations. This strategy is typically used for tactical purposes and may involve a higher level of risk and transaction costs. Our Asset Allocation Philosophies Asset allocation is the process of diversifying a portfolio across various investments (like stocks and bonds) to manage risk. We may use several distinct philosophies to manage this allocation: Strategic Allocation: This is a long-term approach where we establish a target allocation based on your goals and risk tolerance. While this target is designed to be held for the long term, we may occasionally adjust it based on significant shifts in our long-term economic forecasts. The primary activity, however, is periodically rebalancing the portfolio back to its target mix. Tactical Allocation: This is a more active approach where we make short-term, opportunistic shifts away from the long-term strategic allocation. These adjustments are made in anticipation of market trends to enhance returns or reduce risk. Dynamic Allocation: This approach involves adjusting the portfolio's asset mix based on pre-defined rules or market signals. Unlike tactical allocation, which is often predictive, dynamic allocation tends to be responsive, making changes after a specific market event or data calculation occurs. Core-Satellite Allocation: This strategy divides a portfolio into two parts: a large, stable "core" (typically made up of broad-market ETFs and bonds) and smaller "satellite" positions. The satellite holdings are more specialized investments used to seek enhanced returns or provide additional diversification. Active Management Philosophy: This describes our overarching approach. As an active manager, we have the discretion to use and blend the allocation philosophies described above. Based on our professional judgment, we may shift between strategies to best serve your account's objectives. C. RISK OF LOSS Investing in any security involves a risk of loss, and you should be prepared to lose some or all of the money you invest. Past performance is not a reliable indicator of future results, and there is no guarantee that any investment strategy will be successful. We cannot predict market movements, prevent losses from market declines, or guarantee that you will achieve your financial goals. We also cannot guarantee that third parties, such as fund companies or issuers, will meet their obligations. While we utilize a variety of investment products, the Adviser primarily uses Exchange-Traded Funds (ETFs) to implement our strategies, supplementing them with Mutual Funds (MFs), individual stocks, and other securities as we deem appropriate. All investments carry various risks, including but not limited to business, credit, market, inflation, and liquidity risks. These are often described in detail in a security's prospectus. GENERAL RISKS Advisory Risk: Our judgment may prove incorrect, and there's no guarantee our investment decisions will produce the intended results. Technical failures (e.g., computer crashes, cyber-attacks) could also disrupt our services. Concentration Risk: Holding a few large positions is riskier than diversifying. A significant loss in one investment will have a greater negative impact on your portfolio. Page 16 of 27  October 29, 2026 Cybersecurity & Information Security Risk: Our firm, like any business, is vulnerable to cyber-attacks and data breaches. A breach could disrupt our operations and compromise your confidential information, potentially leading to financial loss. We take ongoing steps to limit these threats. Dependence on Key Employees: Our success depends on our key professionals. The loss of these individuals could negatively impact our ability to manage your account and achieve your goals. Fund Manager Risk: When we invest in mutual funds or ETFs, we rely on the skill of that fund's manager. If the fund manager's strategy fails or their judgment is poor, the fund will underperform regardless of our analysis. Interest Rate Risk: Fixed income investments (bonds) typically lose value when interest rates rise. This risk is higher for portfolios with a larger allocation to bonds, or those holding longer-dated (longer maturity) bonds, which are more sensitive to rate changes. Legislative & Tax Risk: Changes in government regulations or tax laws can affect your investments. You may owe taxes on investment gains even without receiving a cash distribution. You are responsible for consulting a tax advisor about how transactions are reported. Model Risk: We may use financial models to help make investment decisions, but these models are based on assumptions that may prove wrong. There is no guarantee that any model will work in all market conditions, which is why we also rely heavily on our professional judgment. Portfolio Turnover Risk: Frequent trading increases costs and can lead to higher taxes from short-term capital gains, which are taxed at ordinary income rates in taxable accounts. Shorting and Leverage Risk: Short selling involves betting that a security's price will fall. Because a stock’s price can rise indefinitely, your potential loss is theoretically unlimited. We may also use "inverse" or leveraged funds to bet against the market or amplify its moves. These are designed for daily use; holding them for longer periods can lead to rapid, unexpected losses even if we are right about the market's direction. Collectively, these tools create "leverage," which allows us to control more market value than you have in cash. This magnifies your gains when we are right, but it also magnifies your losses when we are wrong. Short positions are also subject to 'short squeeze' risk, where a rapid price increase may force the Adviser to buy back shares at significantly higher prices to close out the position. Sub-Advisor Risk: We may recommend using a third-party investment manager (a "sub-adviser") to manage all or a portion of your portfolio. Before recommending a sub-adviser, we review their investment philosophy, strategy, and qualifications. We also monitor their results and approach on an ongoing basis. However, we do not have direct, daily control over their trading decisions. This arrangement introduces specific risks, including: (1) the sub-adviser's investment strategy may underperform or fail to meet its objectives; and (2) the sub-adviser may deviate from their stated investment style. While we select sub-advisers we believe are skilled, we cannot guarantee their performance. Third-Party Model Portfolios: The third-party provider only supplies the model and does not execute the trades, because of this there may be a delay between when the providers’ update to the model and when we execute the corresponding trades in the Client’s account. Market movements during this lag can cause the Client’s actual performance to deviate (tracking error) from the theoretical performance of the model. ▪ Manager Reliance Risk: We rely heavily on the research, proprietary analysis, and investment decisions of the third-party model providers. If the provider’s investment strategy is flawed, relies on incorrect data, or fails to anticipate market events, the Client’s portfolio will be negatively impacted. ▪ Limited Customization: Third-party models are designed to be implemented or combined with others exactly as they are. This limits customization and may not be suited for certain Client account needs. Tax-Loss Harvesting Risk: This strategy may not generate the intended benefits, as its effectiveness depends entirely on your comprehensive tax situation. Replacing securities to harvest losses can cause your portfolio's performance to deviate from its target allocation (tracking error). Furthermore, IRS "wash sale" rules will disallow the tax loss if you or your spouse purchase the identical security in an outside account within 30 Page 17 of 27  October 29, 2026 days. While we offer tax planning, we do not prepare tax returns; please consult your tax preparer regarding the impact of these trades. RISKS OF SPECIFIC SECURITIES American Depository Receipts (ADRs): ADRs represent shares of a non-U.S. company and trade on U.S. exchanges. Investing in ADRs exposes you to risks not typically associated with U.S. companies, including adverse currency fluctuations, different accounting and disclosure standards, foreign taxes, and potential political or economic instability in the company's home country. Bonds (Fixed Income): This is a broad category of debt instruments where an investor lends money to an entity (like a corporation or government) for a defined period at a variable or fixed interest rate. While used for stability and income, all fixed income securities have risks. The value of these securities changes with interest rates—when rates rise, existing bond prices tend to fall. They also carry credit risk (the issuer could default and fail to make payments) and inflation risk (inflation can erode the value of your returns). Different types include: ▪ Bills: Short-term debt, typically issued by a government, with maturities of less than one year. U.S. Treasury bills are considered to have very low credit risk. ▪ Notes: Medium-term debt with maturities typically ranging from one to ten years. ▪ Debentures: A type of long-term bond that is not secured by any physical assets or collateral, meaning it is backed only by the issuer's general creditworthiness. This makes them riskier than secured bonds. ▪ Certificates of Deposit (CDs): These are savings products that hold a fixed amount of money for a specific term at a fixed interest rate. While CDs issued by FDIC-insured banks are considered low-risk, they carry liquidity risk, as you will pay a penalty for withdrawing funds before the term ends. They also have interest rate risk; if prevailing rates rise significantly, your money is locked in at a lower rate. from the value of its underlying assets. For more Business Development Corporations (BDCs): BDCs invest in small, developing, or financially distressed private companies. These are inherently riskier than larger, public companies. The market price of a BDC can also be significantly different information, visit: https://www.investor.gov/introduction-investing/investing-basics/investment-products/closed-end- funds/publicly-traded Closed-End Funds (CEFs): A CEF's share price can trade at a significant premium or discount to the actual net asset value (NAV) of its holdings. This gap can widen during periods of market volatility. Commodity Subsidiary Risk: Some funds we utilize may gain exposure to commodities by investing a portion of their assets in a wholly owned foreign subsidiary (typically in the Cayman Islands). These subsidiaries are not registered under the Investment Company Act of 1940, meaning investors do not have the regulatory protections provided by that Act. Currencies and Digital Assets: Direct investments in foreign currencies (forex) or digital/crypto assets are highly speculative and volatile. Currency values fluctuate rapidly due to interest rates, inflation, geopolitics, and central bank interventions. Digital assets operate on decentralized networks, have no intrinsic backing, and face heightened risks of fraud, cybersecurity breaches, custody loss, illiquidity, and severe regulatory restrictions. Donor-Advised Funds (DAFs): When you contribute to a DAF, you make an irrevocable charitable donation and give up direct control of the assets. While you may recommend grants, the sponsoring organization has the final legal approval. The funds are subject to administrative and investment fees, and investment options may be limited. Exchange-Traded Products (ETPs): This is a broad category of securities that trade on an exchange like stocks but are designed to track the performance of an index, commodity, or other asset. Different types of ETPs have very different risk profiles: ▪ Exchange-Traded Funds (ETFs): The most common type of ETP. An ETF’s performance may not perfectly match the index it's designed to track due to expenses, transaction costs, and market demand. Its shares Page 18 of 27  October 29, 2026 can also trade at a premium or discount to its net asset value (NAV). For additional information, visit: https://www.sec.gov/investor/pubs/sec-guide-to-mutual-funds.pdf ▪ Exchange-Traded Notes (ETNs): Unlike ETFs, ETNs are unsecured debt notes issued by a financial institution. Their primary risk is the credit risk of the issuer. If the issuer goes bankrupt, you could lose your entire investment, even if the underlying index it tracks performs well. ▪ ▪ Commodity & Precious Metal ETPs: These ETPs seek to track the price of a physical commodity, such as gold, silver, or oil. Their value will fluctuate with the often-volatile price of the underlying commodity. Owning a commodity ETP is not the same as owning the physical asset and is subject to the specific structure and risks of the product. Leveraged & Inverse ETPs: These are speculative, short-term trading tools designed to multiply the daily return of an index, which magnifies both gains and losses. Holding them for longer than one day can lead to results that differ significantly from the underlying index's performance, often resulting in unexpected losses. For more information, read the FINRA and SEC Investor Alert: https://www.finra.org/investors/alerts/leveraged-and-inverse-etfs-specialized-products-extra-risks- buy-and-hold-investors ▪ Crypto Asset ETPs: These are highly speculative and non-diversified products with heightened risk. The underlying crypto assets have no known intrinsic backing, and their value is driven by supply and demand. Crypto ETPs face extreme regulatory risk, which could lead to delisting and a total loss of your investment. For more information, please read the SEC bulletins on Funds Trading in Bitcoin Futures and ETPs Providing Exposure to Bitcoin and Ether. Investor Bulletin Fixed Indexed Insurance Products: This is a complex insurance contract, not a direct market investment. The cash value growth is linked to a market index but is often limited by caps, participation rates, or spreads, meaning you will not capture the full upside of the index. These policies are illiquid, long-term products with surrender charges for early access to cash value. All guarantees are subject to the financial strength of the issuing insurance company. Foreign and Emerging Markets Risk: We may invest in funds that hold securities from foreign countries, including emerging or frontier markets. These markets carry greater risks than U.S. investments due to political or economic instability, currency exchange rate fluctuations, different auditing standards, and lower market liquidity. Futures Contracts: A futures contract is a standardized agreement to buy or sell a specific commodity, currency, or financial index at a predetermined price on a future date. Futures trading involves a high degree of leverage, meaning a small market movement can result in disproportionate gains or losses that exceed your initial margin deposit. Individual Stocks (Equities): Investing in individual stocks means owning a share of a specific company. The primary risk is business risk—the company itself could underperform due to factors like poor management, declining sales, or competitive pressure, causing the stock price to fall even if the overall market is rising. Stock values are also subject to broad market risk and can be more volatile than diversified funds. Insurance Product Tax Risks: The tax rules for insurance products like annuities and life insurance are complex. Withdrawals from non-qualified annuities are typically taxed on a last-in, first-out (LIFO) basis, meaning taxable gains are withdrawn first. Conversely, cash value withdrawals from a life insurance policy are generally treated on a first-in, first-out (FIFO) basis, allowing for tax-free access to your cost basis first. These rules can change if a life insurance policy is classified as a Modified Endowment Contract (MEC). Due to these complexities, it is essential to consult a tax advisor before taking any loans or withdrawals. Master Limited Partnerships (MLPs) & Publicly Traded Partnerships (PTPs): MLPs are typically focused in the energy sector, exposing you to volatility in that specific industry. They also have complex tax structures and potential conflicts of interest between partners. Consult a tax advisor before investing. For more information, see the SEC for MLPs: https://www.investor.gov/introduction-investing/general- resources/news-alerts/alerts-bulletins/investor-bulletins/updated-7 Page 19 of 27  October 29, 2026 Money Market Fund: While considered a very conservative investment, money market funds are not insured or guaranteed by the FDIC and are not risk-free. Risks include the possibility of the fund’s share price falling below $1.00 per share, known as “breaking the buck,” which would result in a loss of principal. Certain money market funds may also impose temporary “liquidity gates” or “redemption fees” during times of market stress, which could prevent you from accessing your money. Mutual Fund: A mutual fund is a company that pools money from many investors to invest in a portfolio of securities. In addition to the risks of the underlying securities in its portfolio, a mutual fund’s value is subject to management risk, meaning the fund’s manager may make poor investment decisions. Unlike stocks or ETFs, mutual funds are priced only once per day after the market closes, so the price you receive when you sell may be higher or lower than its value during the trading day. Options Contracts: An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset (like a stock) at a specific price on or before a certain date. While options can be used for hedging or income strategies, they are complex and involve a high degree of risk. The value of an option is subject to market risk and can be highly volatile. A primary risk is time decay, where an option loses value as it approaches its expiration date, potentially expiring worthless. Using options can involve a high degree of leverage, which can magnify both gains and losses. Selling options, particularly uncovered or "naked" options, exposes an investor to the risk of unlimited losses, which may be far greater than the premium received. Preferred Stock: Preferred stocks have features of both stocks and bonds. They typically pay a fixed dividend but may also appreciate in value. They are senior to common stock but subordinate to bonds in a company’s capital structure, meaning bondholders would be paid first in a bankruptcy. Key risks include interest rate risk (as rates rise, the value of fixed-dividend preferred shares tends to fall) and credit risk, as the company could suspend dividend payments if it faces financial distress. Private Investment Funds, Private Placements, and Limited Offerings: These are unregistered securities (such as private equity, hedge funds, private credit, or pooled investment vehicles) offered to accredited or qualified investors. They are highly illiquid with long lock-up periods and no secondary market, lack the regulatory oversight and transparency of publicly traded securities, charge higher management and performance fees, and carry a significant risk of total loss of capital. When advising on these offerings, the Firm relies on the disclosure materials provided by the issuer and does not independently audit the issuer's books or operations. Real Estate Investment Trusts (REITs): Non-traded REITs are illiquid, meaning you cannot easily sell your shares to get your money back quickly. Publicly traded REITs are more liquid but still subject to risks from the real estate market and economic conditions. For more information, see the SEC bulletin on REITs: https://www.sec.gov/files/reits.pdf Registered Index-Linked Products (e.g., RILA): A RILA is a complex hybrid insurance contract that offers returns linked to the performance of a market index while providing a level of protection against market loss. While these products are designed to reduce risk, they are not risk-free. Your principal is only protected up to the protection level you select; if the index loss is greater than the protection level, you will lose money. Potential gains are often limited by performance caps, participation rates, or other crediting formulas, meaning you will not capture the full upside of the index's performance. RILAs are designed as long-term products and may impose significant surrender charges for early withdrawals, making them illiquid. Finally, all guarantees are subject to the financial strength and claims-paying ability of the issuing insurance company. Structurally Leveraged Funds and Derivatives Risk: We may utilize certain actively managed funds that use derivatives (such as futures, forwards, and swaps) to gain exposure to different asset classes. This can create structural leverage, meaning the fund’s total exposure may exceed 100% of its net assets. Unlike daily-reset leveraged ETFs, these funds use leverage strategically to balance risk, but this still magnifies the effect of any increase or decrease in the value of the underlying assets and can result in significant volatility. Structured Products: These are complex debt instruments, often called structured notes, whose return is linked to the performance of an underlying asset or index. Their primary risk is the credit risk of the issuer; if Page 20 of 27  October 29, 2026 the issuing financial institution fails, you could lose your entire investment regardless of the underlying asset's performance. They are often illiquid and their payout formulas can be complex and difficult to understand. Special Purpose Acquisition Companies (SPACs): Investing in a SPAC is speculative. It's a "blank check" company with no operations, formed to acquire a private company. Risks include a lack of information about the eventual target company, potential conflicts of interest, and fees that benefit the sponsors. For additional information, visit the SEC and FINRA pages on SPACs: https://www.sec.gov/oiea/investor-alerts-and- bulletins/what-you-need-know-about-spacs-investor-bulletin Unit Investment Trusts (UITs): A UIT is a fund that holds a fixed portfolio of securities, like stocks or bonds, for a set period. Unlike a mutual fund, a UIT's portfolio is not actively managed, meaning securities are not sold if they perform poorly. Key risks include the risk of the underlying securities, and illiquidity if you need to sell your units before the trust's termination date, which may result in high costs. Variable Insurance Products (e.g., annuity and life insurance): When providing advice on variable insurance products, we focus on the investment options within them, known as subaccounts. These subaccounts, which are similar to mutual funds, are securities, and their value will fluctuate with the markets. In addition to this investment risk, variable products are often complex, carry high costs (including insurance charges), and their guarantees depend on the financial strength of the issuing insurance company. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisers are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business or integrity of the Firm’s management. The Firm has no disciplinary disclosures. Raymond M Backers, the Manager and Chief Compliance Officer, has no disciplinary disclosures. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. REGISTRATION AS A BROKER/DEALER OR BROKER/DEALER REPRESENTATIVE The Firm is not registered and does not have an application pending to register, as a broker-dealer, and its management persons are not registered as broker/dealer representatives. B. REGISTRATION AS A FUTURES COMMISSION MERCHANT, COMMODITY POOL OPERATOR The Firm and its representatives are not registered and do not have an application pending to register, as a futures commission merchant, or commodity pool operator/advisor. C. RELATIONSHIPS MATERIAL TO THIS ADVISORY BUSINESS AND POSSIBLE CONFLICTS OF INTEREST Affiliated Insurance Agency: Raymond M. Backers and other supervised persons of the Firm are licensed insurance agents of an affiliated insurance agency, Q2 Wealth Insurance LLC. Additionally, Q2 Wealth Insurance LLC holds a minority ownership interest in the Firm. Through this affiliation, our representatives may offer products such as fixed or fixed indexed annuities, life insurance, disability insurance, healthcare, and long-term care products. This activity and ownership structure represent a conflict of interest because it gives our representatives a financial incentive to recommend products based on the commissions received, and it financially benefits Mr. Backers. We mitigate this conflict by adhering to our fiduciary duty to place the best interest of the client first. Furthermore, you are never required to purchase any insurance products, and you always retain the option to purchase these products from another insurance agent of your choosing. Outside Real Estate Activities: Raymond M. Backers is the Owner and Manager of Aber Point LLC, a personal real estate company involved in activities such as property rentals and real estate purchases and sales. Aber Point LLC is independent of the Firm, is funded exclusively with personal capital, and does not solicit or raise capital. In the event an advisory client independently elects to buy, sell, or lease real estate with Aber Point LLC, a conflict of interest exists because Mr. Backers' financial interest in the real estate transaction may be adverse to the client's interest. We mitigate this conflict through this disclosure, by transacting at a mutually agreed-upon fair market price, and by adhering to our fiduciary duty. Clients retain sole discretion and are under no obligation to transact with Mr. Backers or Aber Point LLC. Page 21 of 27  October 29, 2026 Conflicting Client Positions (Shorting): Because the Firm may utilize inverse funds or direct short positions, a conflict of interest exists when the Firm recommends or takes a short position in a security for one client while another client account holds the same security long. The short sale could put downward pressure on the stock's price, harming the client holding the long position, or it may create the appearance that the firm is favoring one client over another. We mitigate this conflict by trading in accordance with each model’s strategy or each individual account’s strategy. Sub-Adviser or Third-Party Model: When utilizing a sub-adviser or third-party model, the outside provider typically charges a fee, which is paid by the Adviser. However, many providers will waive this fee (offering "free" models or services) if the portfolio is constructed using their own proprietary products, such as mutual funds or ETFs. This structure creates conflicts of interest: 1. Firm Conflict: Because the Adviser is responsible for paying the outside provider's fee, we have a financial incentive to select "free" models or sub-advisers that waive their fees in order to reduce our own operational costs. 2. Provider Conflict: The sub-adviser or model provider has a financial incentive to choose their own proprietary products over nonproprietary products, as they are directly compensated by the internal expense ratios of those funds (which are paid by the Client). We address these conflicts through disclosure and adherence to our fiduciary duty of care. To mitigate these conflicts, we do not base our selection of outside managers or models solely on the cost savings for our Firm. Instead, we review sub-advisers and third-party models prior to implementation for the characteristics that are best for the Client’s account or our models. We continually monitor these relationships to seek best execution and ensure they remain in the best interest of the client over the course of the relationship. D. SELECTION OF OTHER ADVISORS The Adviser may retain or allocate all or a portion of a discretionary account to sub-advisers (including third- party asset managers) or third-party model providers. A sub-adviser or third-party asset manager recommends and executes trades directly in the account pursuant to the discretionary authority granted in the Client's Investment Advisory Agreement (IAA) or applicable custodial authorizations. Alternatively, a third-party model provider only supplies research, trade signals, or model recommendations, and the Adviser executes the trades. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. DESCRIPTION OF CODE OF ETHICS The Code applies to “supervised” persons and “access” persons. “Supervised” persons are directors, officers, partners, employees, temporary workers, consultants, independent contractors, or access persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. The supervised persons of Q2 have committed to a Code of Ethics (“Code”). The purpose of the Code is to set forth standards of conduct expected of supervised persons to address conflicts that may arise. The Code defines acceptable behavior and the responsibility to act in the best interest of the client. One area which the Code addresses is when supervised persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest. Q2 does not allow any supervised person to use material, non-public information for personal profit or internal research for personal benefit in conflict with a client. The Firm policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No supervised person may recommend any transaction in a security to advisory Clients or engage in personal securities transactions if they possess material, non-public information regarding the security. Page 22 of 27  October 29, 2026 The firm will provide a copy of the Code of Ethics to any Client or prospective Client upon request. B. EMPLOYEE TRADING WITH A MATERIAL FINANCIAL INTEREST Neither the Adviser nor its supervised persons recommend to clients, buy, or sell for client accounts, securities in which the Adviser or its supervised persons have a material financial interest. C. INVESTING IN THE SAME SECURITIES AS CLIENTS. The Adviser and its supervised persons may invest in the same securities recommended to clients. This practice presents a conflict of interest because it may provide an incentive to recommend securities to increase demand and subsequently increase the price. We mitigate this conflict by maintaining a Code of Ethics that sets forth our basic policies of ethical conduct (available upon request). This policy includes monitoring trading practices to ensure any transactions are not deceptive, unfair, or in violation of our fiduciary duty. Specifically, our procedures include: ▪ Ensuring that the Firm and supervised persons do not engage in soft-dollar arrangements unless such engagements satisfy the standards set forth under Section 28(e) of the Exchange Act of 1934. ▪ Collecting and maintaining records of securities holdings and transactions affected by supervised persons. These records are reviewed by the Chief Compliance Officer to identify and resolve any conflicts of interest. D. TRADING SECURITIES AT OR AROUND THE SAME TIME AS CLIENTS. The Adviser and its supervised persons may recommend securities to clients, or buy and sell securities for client accounts, at or about the same time that we buy or sell the same securities for our own accounts. This practice presents a conflict of interest because it may provide an incentive to recommend securities to increase demand, increase the price, and/or buy securities at a more favorable price before buying securities for a client. We mitigate this conflict through our Code of Ethics (available upon request), which monitors trading practices to ensure fairness. Specifically, our procedures include: ▪ Collecting and maintaining records of securities holdings and transactions affected by supervised persons, which are reviewed by the Chief Compliance Officer to identify and resolve conflicts of interest. ▪ The Adviser specifically prohibits related or supervised persons from knowingly selling to or purchasing from a client any security in a principal or agency cross transaction. ▪ Prohibiting "front-running," which is the purchase or sale of individual securities for our own accounts based on the knowledge of a client’s planned trading positions (note: this does not apply to mutual funds). ▪ Aggregation procedure disclosed in Item 12.E. ITEM 12: BROKERAGE PRACTICES A. Selection and Recommendation The Firm has a duty to select brokers, dealers, and other trading venues that provide the best execution for clients. The duty of best execution requires an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account all relevant factors. The lowest possible commission, while very important, is not the only consideration. It is the policy of the Firm to seek best execution in portfolio trading activities where applicable, balancing execution quality with transaction costs to achieve the most favorable net outcome for the client. This applies to open-market trades of National Market System (NMS) securities, as well as the selection of optimal mutual fund share classes. Page 23 of 27  October 29, 2026 The Firm evaluates the execution, performance, and risk profile of the broker-dealers it uses on a periodic, risk-based schedule. To achieve best execution and maintain our approved broker list, the Firm considers the following factors, without limitation, in selecting brokers and intermediaries: • Execution & Market Capabilities: The broker's ability to execute transactions of size in both liquid and illiquid markets, order size and market depth, availability of competing markets, and the trading characteristics of the security. • Cost & Services: Commission rates and the overall quality and cost of services compared to other • • brokers, as well as the range of available technology, products, and access to securities. Integrity & Stability: The financial responsibility, ability and willingness to commit capital, reputation, responsiveness, and confidentiality of the broker-dealer. Information & Compliance: The availability of accurate information comparing markets, and the broker's recordkeeping practices. Non-NMS Custodians and Direct-to-Sponsor Platforms: Because open-market metrics like order routing and market depth do not apply, the Firm evaluates the entities it uses on a periodic, risk-based schedule. This review focuses on Integrity & Stability (financial strength and asset safety) and Cost & Services (platform fees and product offerings). B. RESEARCH AND OTHER SOFT DOLLAR BENEFITS The Adviser does not have any soft dollar benefit arrangements. C. BROKERAGE FOR CLIENT REFERRALS The Adviser does not receive client referrals from third parties for recommending the use of specific broker- dealer brokerage services. D. DIRECTED BROKERAGE The Firm does not permit the client to direct brokerage and the firm does not recommend, request, or require that a client direct the firm to execute transactions through a specified broker-dealer. Not all investment advisers require their clients to direct brokerage; by directing brokerage, the firm may be unable to achieve the most favorable execution of client transactions, and this practice may cost clients more money. E. ORDER AGGREGATION As needed, the Firm aggregates ("block trades") client orders. Block trading provides operational efficiency and helps secure consistent pricing. Aggregated orders are allocated across participating client accounts in a fair, pro-rata, or systematic manner to seek best execution. When the Firm buys or sells the same securities at a specific broker for client accounts, at or about the same time as supervised or related person accounts, the firm will use the following procedures: ▪ Pre-Trade Allocation: Before placing an aggregated block trade at a specific broker, the Firm determines the participating accounts and how it intends to allocate orders among client accounts. The Firm will maintain records of each written pre-trade allocation. ▪ Fair and Average Pricing: No advisory client will be favored over any other client. Each account participating in a block trade will receive the same average share price for that specific order executed by each broker. ▪ Participation: Orders for supervised persons or related persons may be included in an aggregated client block trade. When included, these accounts will receive the same average share price as participating client accounts. ▪ Partial Fills: If a block order only partially fills, the executed shares are divided pro rata among the participating accounts. ▪ Post-Block & Unsolicited Trades: Trades placed after a block order has been executed, limited to unsolicited client instructions or accounts where the Firm lacks timing discretion, will be processed Page 24 of 27  October 29, 2026 separately. These subsequent trades will receive the prevailing market price at the time of execution, which may differ from the block order’s average price. ▪ Exceptions: Any change from the pre-trade allocation or pro rata partial fill must be fair and equitable, be documented with a clear explanation, and be approved by the Chief Compliance Officer. F. TRADE ERROR POLICY The Firm maintains a record of any trading errors that occur in connection with the investment activities of its clients. When a trade error occurs, the Firm will instruct the custodian to make a correcting trade. If an investment gain results from the correcting trade, the gain will remain in the account unless (1) the same error involved other client account(s) that should have received the gain; (2) it is not permissible for the account to retain the gain; or (3) the gain is declined. If the actions as described in 1, 2, or 3 occur, the custodian is instructed to donate the gain to charity, the Firm will not accept the gain. Generally, if related trade errors result in both gains and losses, they are netted. If a loss occurs Q2 instructs the custodian to cover the loss. The Firm is then responsible for payment to the custodian. ITEM 13: REVIEW OF ACCOUNTS A. PERIODIC REVIEWS Investment Accounts Client accounts are periodically reviewed for compliance with the written investment policy and restrictions. At least once per calendar year a representative will seek to review the account with you. Financial Plans For Clients with Plan Monitoring, we periodically analyze your plan's progress toward your goals. We seek to review this analysis with you at appropriate intervals. For Clients who also utilize our Investment Management services, plan monitoring reviews may be aligned and conducted concurrently with your investment account reviews. B. OTHER THAN PERIODIC BASIS Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify the Firm promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. C. REPORTS Account Statement At least quarterly, the qualified custodian is required to send the Client an account statement identifying the amount of funds and of each security in the account at the end of the period and setting forth all transactions in the account during that period. Billing Reports As a supplement, the Firm generally posts itemized billing reports to our client software portal. Clients may log in to the portal at their convenience to review or download these reports. Portal access is not mandatory, but we do not automatically deliver these reports via email or mail. If a client is unable to establish portal access, they may request a one-time, nonrecurring copy by email or paper from their representative. Performance Reports As a supplement, the Firm generally posts “Net of Fee” performance reports to our client software portal. Clients may log in to the portal at their convenience to review or download these reports. Portal access is not mandatory, but we do not automatically deliver these reports via email or mail. If a client is unable to establish portal access, they may request a one-time, nonrecurring copy by email or paper from their representative. Page 25 of 27  October 29, 2026 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. OTHER COMPENSATION The Firm receives an economic benefit from the custodians because they provide access to institutional trading platforms, operational technology, and discounts on third-party products and services, at no direct cost. Receiving these benefits creates a conflict of interest, as it gives the Firm an incentive to recommend a custodian based on the benefits we receive. The Firm mitigates this conflict by disclosure and periodically evaluating its custodial selection and recommendation. B. CLIENT REFERRALS The Firm may directly or indirectly compensate third-party promoters for referring clients to the Adviser. This practice presents a conflict of interest because the promoter has a financial incentive to recommend our services. To mitigate this conflict, arrangements comply with applicable SEC rules. Clients referred by a promoter receive a disclosure outlining the material terms of the compensation arrangement and any associated conflicts of interest at the time the endorsement is disseminated. Additionally, the firm may provide a referral bonus or other compensation to its employees for referring prospective clients. This creates a conflict of interest, as employees have a financial incentive to recommend our services. We mitigate this conflict through our commitment to our fiduciary duty and by ensuring all recommendations are in the best interest of the client. ITEM 15: CUSTODY A. CUSTODIAN OF ASSETS Custody is defined as holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. The Firm is deemed to have custody whenever a client authorizes the Firm to deduct its advisory fee from an account. The SEC considers this a limited form of custody requiring certain procedures. Client funds and securities are held by a qualified custodian. The qualified custodian will send an account statement to the client at least quarterly, and clients should carefully review those statements and are urged to compare them to any statements received from the Firm. When clients have questions about a statement, they should contact the custodian or the firm preparing the statement. The Firm will form a reasonable basis, after due inquiry, to believe that the qualified custodian sends account statements directly to each client at least quarterly. ITEM 16: INVESTMENT DISCRETION Discretionary authority allows the Adviser to implement investment decisions without prior client consultation and authorizes the Adviser to grant sub-advisers discretionary authority to trade in the client account. This authority is granted by the client completing the discretionary investment advisory agreement. If a sub-adviser is utilized, you will not be required to execute a separate agreement, as the Adviser is authorized to hire and fire sub-advisers on your behalf. However, you may be required to sign specific custodial forms granting the sub-adviser authority on the account. Non-discretionary authority allows the Adviser to implement investment decisions after client approval. This authority shall only be exercised after approval from the client and completion of the non-discretionary investment advisory agreement. ITEM 17: VOTING CLIENT SECURITIES The Firm, as a matter of policy and practice, does not maintain the authority to vote proxies on behalf of advisory clients. Clients will receive their proxy materials and solicitations directly from their qualified custodian or the applicable transfer agent. Clients are encouraged to read through the proxy voting documents and make a determination based on the information provided. Upon the client's request, Firm representatives may provide objective education and limited clarification of the issues presented in the proxy voting materials based on their understanding of the issues. However, Firm representatives will not make specific recommendations on how to vote managed securities, and clients retain the ultimate responsibility to actually cast the vote. Page 26 of 27  October 29, 2026 Sub-Advisers and Third-Party Asset Managers: If we allocate all or a portion of your account to a Firm- retained sub-adviser or third-party asset manager, you may authorize that manager to vote proxies for its managed assets on your behalf (where offered by the manager). In such cases, the sub-adviser or third-party asset manager will vote proxies in accordance with their own proxy voting policies and procedures; otherwise, you retain proxy voting responsibility. ITEM 18: FINANCIAL INFORMATION A. BALANCE SHEET REQUIREMENT The Firm did not include a balance sheet because it does not require prepayment of fees for more than $1,200 per client, six (6) months or more in advance. B. FINANCIAL CONDITION The Firm has discretionary authority and is deemed to have a limited form of custody when it’s authorized to deduct fees from a client account but it does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. C. BANKRUPTCY PETITION The Firm has not been the subject of a bankruptcy petition at any time during the last 10 years. Page 27 of 27