DESTINY CAPITAL CORPORATION

ITEM 1 – COVER PAGE Destiny Capital Corporation 1800 Wazee Street, Suite 300 Denver, CO 80202 Phone (720) 715-7570 Email cco@destinycapital.com DestinyCapital.com PART 2A BROCHURE October 14, 2025 This brochure provides information about the qualifications and business practices of Destiny Capital Corporation, which does business as Destiny Capital. If you have any questions about the contents of this brochure, please contact us at cco@destinycapital.com or (720) 715-7570. 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 with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about Destiny Capital Corporation also is available on the SEC’s website at: www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number.. Our firm's CRD number is 111196.  ITEM 2 – MATERIAL CHANGES SUMMARY OF MATERIAL CHANGES This section of the Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) www.adviserinfo.sec.gov. The following changes were made since our last other annual amendment filing on February 27, 2025: • The firm’s main office location has moved to 1800 Wazee Street, Suite 300, Street 300 Denver, CO 80202. • Item 4 was updated to include: Investment-only service offerings. o o The DBA name Entrepreneur Align, is no longer being used. • • • Item 5 was updated to reflect new pricing descriptions for Destiny for Entrepreneur Services, investment-only services and new hourly pricing payment options for stand-alone financial planning. Item 5 was also updated to include further descriptions regarding financial institution consulting fees and platform provider fees. Destiny Capital no longer provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) Item 10 was updated to include: o One of our associated persons is a licensed insurance agent. This licensed individual is not actively selling insurance products nor is this individual receiving any insurance related compensation. The license, although active, is not in use. • Item 14 Client Referrals and Other Compensation o Affiliated or unaffiliated persons (“promoters”) may, from time to time, refer, solicit, or introduce clients to our Firm. Our Firm may compensate certain promoters consistent with the requirements of applicable law and regulation, including the Advisers Act as well as applicable state/local laws and regulations. We may pay a promoter a recurring fee, a one-time fee or a portion of the advisory fees or revenues that we earn for managing client or investor assets referred to us by the promoter. The costs of such referral fees are typically paid entirely by our Firm and do not result in any additional charges to the client or investor. If you would like to request that a copy of any parts of the ADV be sent to you directly, please email cco@destinycapital.com or call (720) 715-7570. The Form ADV Part 2A and Part 3 are both available on our websites: www.destinycapital.com and www.entrepreneuraligned.com We encourage you to read this document in its entirety. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 1  ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE 0 ITEM 2 – MATERIAL CHANGES 1 ITEM 3 – TABLE OF CONTENTS 2 ITEM 4 – ADVISORY BUSINESS 3 ITEM 5 - FEES AND COMPENSATION 7 ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT 11 ITEM 7 - TYPES OF CLIENTS 12 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 12 ITEM 9 - DISCIPLINARY INFORMATION 16 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 17 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 18 ITEM 12 - BROKERAGE PRACTICES 18 ITEM 13 - REVIEW OF ACCOUNTS 20 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 21 ITEM 15 – CUSTODY 22 ITEM 16 – INVESTMENT DISCRETION 22 ITEM 17 – VOTING CLIENT SECURITIES 23 ITEM 18 – FINANCIAL INFORMATION 23 DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 2  ITEM 4 – ADVISORY BUSINESS This Disclosure document is being offered to you by Destiny Capital Corporation (“Destiny Capital” or “Firm”) the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Our Firm became a registered investment adviser in 1989. The firm's principal owner (i.e., individuals and/or entities owning 25% or more of this firm). ▪ Destiny Holdings, Inc., Owner In addition, the owners of 25% or more of Destiny Holdings, Inc. are: ▪ Jarrod Bryan Musick, CEO and CCO Jarrod B Musick is the Chief Compliance Officer. Sarah Jolly is the Chief Operations Officer. Timothy Doyle is the Chief Investment Officer. Tiffany Charles is the Chief Growth Officer. We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that help clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and Destiny Capital execute an Investment Management Agreement. DESTINY FOR ENTREPRENEURS (FORMERLY ENTREPRENEURS ALIGNED) Destiny Capital Corporation, doing business as Destiny for Entrepreneurs, offers advisory services to High-Net-Worth Clients with relatively few or no assets to be invested in public markets. Destiny for Entrepreneurs clients receive Individual Portfolio Management and Financial Planning services in addition to the services listed below: Investment Thesis that includes business interests, real estate, public markets, collectibles, etc. • Business Planning and Consulting • Business exit planning • • Center of Influence coordination • Family values discussion and statement of intent INDIVIDUAL PORTFOLIO MANAGEMENT AND FINANCIAL PLANNING- COMBINED SERVICES Destiny Capital manages advisory accounts on a discretionary. For discretionary accounts once we have determined a profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior client consent but within the expected investment guidelines. We may accept accounts with certain restrictions if circumstances warrant. We primarily allocate client assets among cash, money markets, individual stocks, bonds, exchange traded funds (“ETFs”), municipal bonds, corporate bonds, mutual funds and alternative investments. We generally invest Client’s cash balances in money market funds and/or government-backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk and conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees. Destiny Capital includes financial planning in addition to individual portfolio management for clients who wish to have both service offerings together. Please refer to the Financial Planning Services section to learn more about the specific offerings. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, it is continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background. Based on client needs, we develop a client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 3  Once we have determined the types of investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment review and management services. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client financial objectives. We trade these portfolios based on the combination of our market views and client objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to provide us with standing instructions to refrain from investing in particular industries or invest in limited amounts of securities. In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from client accounts, but only with the appropriate written authorization from clients. Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these are assets that are ineligible to be custodied at our primary custodian. Clients have the option of engaging us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. INDIVIDUAL PORTFOLIO MANAGEMENT SERVICES Destiny Capital offers stand-alone individual portfolio management services for clients who opt out of financial planning. This service includes all of the discretionary portfolio management services as described above, however, this service does not include financial planning. NITROGEN (FORMERLY RISKALYZE) To further fine-tune our understanding of a client’s risk tolerance, our Firm utilizes Nitrogen, a third-party vendor tool, to assist in identifying the client’s risk tolerance. Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and investment volatility (investment variance), which uses past data to calculate expected variance. PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least annually and allocation changes will be made as deemed necessary. USE OF MODEL MANAGERS AND PLATFORM PROVIDER If deemed suitable for our clients, our Firm may utilize a platform provider and their associated model managers. The determination to use a particular model or models is based on our advisor’s recommendation considering each client’s individual investment goals, objectives and mandates. The Firm has entered into an agreement with Orion Portfolio DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 4  Solutions, LLC investment management platform (“Orion”), an SEC registered investment advisor, to provide asset management services that include: •model money managers •portfolio managers •strategists As part of the Orion program, Clients provide the Firm and Orion discretion to select third party, non-affiliated investment managers (“Model Managers”) to design and manage model portfolios. Destiny Capital has access to Orion’s reporting systems, client relationship management systems and workflow systems to utilize their technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, quarterly performance evaluations, payable reports, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client information, but Orion will not serve as an investment advisor to the Firm’s Clients. Destiny Capital and Orion are non-affiliated companies. Orion charges the Firm an annual fee for each account administered by Orion. Refer to Item 5, of this brochure, regarding compensation of the Orion program. Clients receive continuous investment advice based on investment objective, risk profile and time-horizon. While investment strategies and recommendations are tailored to the individual needs of each client, they consist of an asset allocation consistent as outlined in Item 8 of this Brochure. Your agreement with Destiny Capital will include the authorization to utilize Third Party Model Managers and to replace (i.e., hire and fire) Model Managers on a discretionary basis. We will not enter into an investment advisor relationship with a prospective client whose investment objectives are considered incompatible with the Firm’s investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. However, Clients have the ability to impose reasonable restrictions on the management of their accounts, including the ability to instruct the Firm not to purchase certain securities. We do have limited authority to direct the Custodian to deduct the Firm’s investment advisory fees from accounts, but only with the appropriate written authorization from clients. Clients may engage us to advise on certain investment products that are not maintained at the Firm’s recommended custodian, such as life insurance, annuity contracts, and assets held in employer sponsored retirement plans. Where appropriate, we provide advice about any type of held away account that is part of a client portfolio. Clients are advised and are expected to understand that the Firm’s past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in Client accounts. We review the performance of the Model Managers on at least a quarterly basis. More frequent reviews may be triggered by changes in Manager’s management, performance or geopolitical and macroeconomic specific events. FINANCIAL PLANNING Financial planning is included for clients participating in the Destiny for Entrepreneurs program as well as clients who wish to engage the firm for investment advisory and financial planning combined services. Stand-alone financial planning services are available upon request. Through the financial planning process, our team strives to engage our clients in conversations around the client’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each client in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include: ▪ Review and clarification of your financial goals ▪ Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 5  ▪ Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals ▪ Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention ▪ Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits; and ▪ Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax adviser, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. ▪ End of life planning offered through our preferred, unaffiliated third-party provider, bQuest. Through bQuest, you’ll have access to: Aging Care Resources: Comprehensive tools and educational content to help you plan and prepare. Introductions to Vetted Professionals: Access to a trusted network of specialists in aging care. Concierge Care Coordination: Personalized support through bQuest, with our team facilitating introductions to streamline care planning and management for you or your loved ones. We also provide general non-securities advice on topics that may include tax and cash flow planning, estate planning, and business planning. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are specific to client circumstances. EMONEY ADVISOR PLATFORM Our Firm makes available to Clients the “eMoney Advisor” platform to provide periodic comprehensive reporting services which can incorporate all the Client’s investment assets, including those investment assets that are not part of the assets managed by our Firm (“Excluded Assets”). The Client and their other advisors that maintain trading authority, and not our Firm, shall be exclusively responsible for the investment performance of the excluded assets. Unless otherwise expressly agreed to in writing, our Firm’s service relative to the excluded assets is limited to reporting only. Therefore, we shall not be responsible for the investment performance of the excluded assets. Instead, the Client and the Client’s designated outside investment professional(s) maintain supervision, monitoring, and trading authority for the excluded assets. If our Client prefers we make recommendations as to any excluded assets, the Client has no obligation to accept the recommendation, and we shall not be responsible for any implementation error (timing, trading, etc.) relative to the excluded assets. If the Client prefers we provide investment advisory services for the excluded assets, the Client may engage us under the terms and conditions of a Consulting or Investment Advisory Agreement between our Firm and the Client. The eMoney Advisor Platform may also provide access to other types of information, including financial planning concepts, which should not be construed as our Firm’s personalized investment advice or recommendations. We shall not be held responsible for any adverse results a Client may experience if the Client engages in financial planning or other functions available on the eMoney Advisor platform without our assistance or oversight. CONSULTING SERVICES We also provide clients investment advice on a more-limited basis in one or more isolated areas of concern such as estate planning, real estate, retirement planning, or other specific topics. Additionally, we provide advice on non-securities matters about rendering estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. In these cases, clients will be required to select their own investment managers, custodian, and/or insurance companies for the implementation of consulting recommendations. If client needs include brokerage and/or other financial services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals ("Firms"). Consulting clients must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm they choose. Clients have the right to choose whether or not to follow the consulting advice provided. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 6  DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) rollover the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor rollover plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are also reviewed by our Firm’s Chief Compliance Officer, who is available to address any questions that a client or prospective client has regarding this disclosure. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. WRAP FEE PROGRAM Destiny Capital does not offer a Wrap Program. ASSETS As of December 31, 2024, we managed $333,286,347 in total assets of which $332,828262 on a discretionary basis and $458,085 on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION Our Firm charges a fee as compensation for providing Investment Management services on your account. These services include advisory services, trade entry, investment supervision, and other account maintenance activities. Compensation may also be earned in the form of quarterly bonuses on new account opening assets. Our recommended Custodian charges transaction costs, custodial fees, redemption fees, retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for details. DESTINY FOR ENTREPRENEURS CLIENT FEES Destiny Capital Corporation's fees for Destiny for Entrepreneurs Clients are based on the scope of work for each client. Fees for Destiny for Entrepreneur Services are a combination of a flat fee and an asset-based fee percentage that is determined by the total assets under management. Flat fees are $16,000 per year. Flat fees can be payable as a 1-time payment or quarterly at $4,000/ quarter. This flat fee is in addition to the firm’s asset management fee which is based on a percentage of total assets being managed by Destiny Capital. The first $5,000,000 of assets under management will be charged an annual fee of 0.90%. Assets that exceed $5,000,000 will be billed 0.50%. Fees are billed quarterly, in advance. In some situations, the fees may be negotiated. The fees are agreed-upon before engagement and are also outlined in the Client Contract. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 7  INDIVIDUAL PORTFOLIO MANAGEMENT AND FINANCIAL PLANNING COMBINED SERVICE FEES Fees for combined investment management and financial planning services are either a flat fee or are a percentage of assets under management. The relevant fee and billing method is defined and agreed to by the firm and the client in the executed Investment Advisory Agreement. Flat fees range from $2,500 to $20,000. Asset based fees will not exceed 1.50%. Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account, or other reasons agreed upon by our Firm and you as the client. In certain circumstances, our fees and the timing of the fee payments may be negotiated. Our employees and their immediate family members’ accounts are charged a reduced fee for our services. The following is the firm’s percentage-based fee tier: Amount of Assets Under Management $0 - $1,000,000 $1,000,001 - $5,000,000 Above $5,000,000 Annual Advisory Fee 1.50% 0.95% 0.50% *Minimum Recurring Quarterly Advisory Fee – $2,500 Advisory management fees include discretionary portfolio management, financial planning, and client service. For clients utilizing Orion Portfolio Solutions, clients will pay an additional platform fee directly to Orion. Orion Platform Solution fees will not exceed 0.15% of assets under management. Note, outside of the Destiny Capital investment advisory management fee, our firm does not share in the Orion Platform Solution fees. Advisory management fees will be billed in advance, on a quarterly basis. The asset-based fees will be based on the account’s previous quarter-end market value. Client understands that the full value of the Client’s account(s), on a gross basis, is included when calculating fees. This includes any portion of the Client’s account(s) attributable to margin. The relevant fee and billing method is defined and agreed to by the firm and the client in the executed Investment Advisory Agreement. This fee may be debited directly from your investment account or you may pay this fee separately. Additional fees and expenses you may incur are principal markups and discounts, SEC fees, mutual fund/ETF expense ratios, tax withholding on certain foreign securities, postage fees, wire fees, bank charges, and other administration fees as authorized by you. Please refer to Section 12 for information on brokerage fees and services. Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of determining the account size and annualized fee. The common practice is often referred to as “house-holding” portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios separately. Our method of house-holding accounts for fee purposes looks at the overall family dynamic and relationship. The independent and qualified custodian holding your funds and securities will debit your account directly for the advisory fee and pay that fee to us. When establishing a relationship with Destiny Capital, you provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. Further, the qualified Custodian agrees to deliver an account statement to you on a monthly or quarterly basis indicating all the amounts deducted from the account including our advisory fees. Either Destiny Capital or you may terminate the management agreement immediately upon written notice to the other party. The management fee will be pro-rated to the date of termination, for the month/quarter in which the cancellation notice was given and any unearned fees will be refunded to you by our Firm upon termination. Upon termination, you are responsible for monitoring the securities in your account, and we will have no further obligation to act or advise with respect to those assets. In the event of client’s death or disability, Destiny Capital will continue management of the account until we are notified of client’s death or disability and given alternative instructions by an authorized party. In no case are Destiny Capital fees based on, or related to, the performance of your funds or investments. INDIVIDUAL PORTFOLIO MANAGEMENT SERVICE FEES DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 8  For clients who engage Destiny Capital for stand-alone individual portfolio management services, the following illustrates the firm’s fee tier: Amount of Assets Under Management $0 - $5,000,000 Above $5,000,000 Annual Advisory Fee 0.90% 0.50% *Minimum Investable Assets, $1,000,000 MODEL MANAGER FEES Sub Advisory Service Fees As discussed in Item 4 above, there will be occasions where our Firm will engage a platform provider and their associated model managers. In those circumstances, the other investment advisor manages the assets based upon the parameters provided by our Firm. The platform provider will charge an asset-based fee that is in addition to the Firm’s advisory fee, not to exceed 0.15%. The platfom provider will directly debit this fee from client accounts. The Client, prior to entering into an agreement with the the platform provider, will be provided with the platform provider’s Form ADV Part 2A (or a brochure that makes the appropriate disclosures). The platform provider’s fee may include the securities transaction fees for all trades. Destiny Capital will only receive its investment advisory fees as detailed above and does not share in any fees earned by the platform provider. In the event that a client should wish to terminate their relationship with platform provider, the terms for the termination will be set forth in the respective agreements between the Client and that platform provider. Destiny Capital will assist the Client with the termination and transition as appropriate. In no case are our fees based on, or related to, the performance of your funds or investments. FINANCIAL PLANNING FEES Financial planning is included, at no additional fee, for clients participating in the Destiny for Entrepreneurs program as well as clients who wish to engage the firm for investment advisory and financial planning combined services. Stand-alone financial planning services are available for a separate, hourly fee. Our firm offers end of life planning through our preferred, unaffiliated third party provider, bQuest, at no additional cost to our clients. For stand-alone financial planning arrangements, we will negotiate the planning fees with you using an hourly fee arrangement. Fees may vary based on the extent and complexity of your individual or family circumstances and the amount of your assets under our management. Destiny Capital will determine your fee for the designated financial advisory services based on anticipated hours. Under our hourly fee arrangement, any fee and anticipated hours will be agreed in advance of services being performed. The fee will be determined based on factors including the complexity of your financial situation, agreed upon deliverables, and whether or not you intend to implement any recommendations through Destiny Capital. Hourly fees for financial plans are $395/ hour. Fifty percent (50%) of the Financial Planning Fee is collected upon signing the Financial Planning agreement and the other fifty percent is due upon delivery of the Plan to you. Payment will be due Thirty (30) days from the date of the invoice. If Client disputes any charges in an invoice, Client shall notify Adviser in writing of such dispute prior to the payment due date. Fees can be paid via check to Adviser or can be invoiced and processed through a third- party nonaffiliated service, AdvicePay. Clients will be asked to set up their bank account at AdvicePay to enable ACH payments. Typically, we complete a plan within a month and will present it to you within 60 days of the contract date, if you have provided us all information needed to prepare the financial plan. The entire Financial Planning Fee is collected upon delivery of the Plan to you. You may terminate the financial planning agreement by providing us with written notice. There is no penalty for termination of your financial planning agreement prior to the plan being delivered to you. We will not require prepayment of more than $1,200 in fees per client, six (6) or more months in advance of providing any services. CONSULTING DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 9  Destiny Capital provides hourly consulting services for clients who need advice on a limited scope of work. Destiny Capital will negotiate consulting fees with you. Fees may vary based on the extent and complexity of the consulting project. The hourly rate for limited scope engagements ranges from $200 – $500 an hour. You will be invoiced as services are rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date of termination and any unearned portion of the fee will be refunded to you as described above. You should be aware that lower fees for comparable services may be available from other sources. Financial Institution Consulting Services Destiny Capital does not receive a consulting fee from Brokerage Customers who have provided written consent to a broker/dealer to receive the investment consulting service from Destiny Capital and have entered into a written advisory contract with Destiny Capital. ADMINISTRATIVE SERVICES We have contracted with Orion Advisor Technology, LLC (“Orion”), an unaffiliated firm, to utilize their technology platform which supports data reconciliation, performance reporting, fee calculation, client relationship maintenance, periodic performance evaluations, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment adviser to our clients. Orion charges our Firm an annual fee for each account administered by its software. Please note that the fee charged to the client will not increase due to the annual fee Destiny Capital pays to Orion. The annual fee is paid from the portion of the management fee retained by Destiny Capital. Our firm utilizes a third-party platform to assist with our financial planning. Holistiplan is a tax planning software that may uncover potential tax strategies that will is designed to help mitigate tax burden in retirement and beyond. ADDITIONAL FEES AND EXPENSES: In addition to the advisory fees paid to our Firm, you also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include custodial fees, charges imposed by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, transaction fees, commissions and other fees and taxes on brokerage accounts and securities transactions. Our brokerage practices are described at length in Item 12, below. When selecting investments for our clients’ portfolios we might choose mutual funds on your account custodian’s Non- Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund, the position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best interest. Grandfathering of Minimum Account Requirements. Pre-existing advisory clients are subject to Destiny Capital Corporation's minimum account requirements and advisory fees in effect when the client enters the advisory relationship. Therefore, our firm's minimum account requirements will differ among clients. Advisory Fees in General. Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Unmanaged Assets. From time to time, a Client may decide to hold certain securities or other property for which our Firm does not provide investment advisory services ("Unmanaged Assets") in the account(s) held at the Custodian or outside the Custodian. Requests to hold an Unmanaged Asset must be made in writing and require the approval of our Firm. Our Firm will have no duty, responsibility or liability whatsoever with respect to these assets, and therefore, our Firm will not charge an investment advisory fee. However, if you have an account that solely contains Unmanaged Assets, the Custodian may charge an account maintenance fee as disclosed in the Custodian account paperwork executed by the DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 10  Client. In all cases, it is the clients sole responsibility to monitor, manage, and transact all Unmanaged Assets (securities and/or accounts). Periods of Portfolio Inactivity. The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). Treatment of Mutual Fund Share Classes. Mutual funds often offer multiple share classes with differing internal fee and expense structures. Our firm’s planning methodology does not include the purchase of mutual fund portfolios. However, if mutual funds are transferred to our platform, they may not be the lowest cost share class option. Other instances that may not include the lowest share class include: These instances include but are not limited to: • Instances in which a certain custodian has a share class available that has a lower internal fee and expense structure than is available for the same mutual fund at other custodians: In such instances, our Firm will select the lowest cost share class available at the custodian that holds your account even though a lower cost share class is available at another custodian. • Instances in which the custodian that holds your account offers others a share class with a lower internal fee and expense structure than what is available to our Firm at the same custodian: In such instances, our Firm will select the lowest cost share class that the custodian makes available. This situation sometimes occurs because the custodian places conditions on the availability of the lower cost share class that our Firm has determined are not appropriate to accept due to additional costs imposed by said conditions. • Instances in which a share class with a lower internal fee and expense structure than the share class you currently hold is available at your custodian, but there are limitations as it relates to share class eligibility, custodian restrictions, or additional fees/taxes that the conversion would trigger: Our Firm cannot convert to a share class with a lower internal fee and expense structure if the account is ineligible (e.g., the fund company only allows certain types of registration types to use the share class or the account doesn’t meet the investment minimum for the share class) or if the fund company won’t accept a conversion if the share amount is too small. Our Firm also cannot convert to a lower internal fee and expense structure if the custodian will not allow it (e.g., custodial restrictions). Also, our Firm does not convert to a share class with a lower internal fee and expense structure if the conversion will cause a taxable event or other expense/cost to you that negates the advantage of the lower cost share class. •When selecting investments for our clients’ portfolios we might choose mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund, the position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best interest. Instances in which you make your own investment selections in a Client-Directed Account In such circumstances, our Firm does not screen for the lowest mutual fund share class available. ITEM 6 - PERFORMANCE BASED FEES AND SIDE -BY-SIDE MANAGEMENT We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client account (so- called performance-based fees), nor engage in side-by-side management. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 11  ITEM 7 - TYPES OF CLIENTS We provide investment advice to individuals, high net worth individuals, trusts, estates, and other institutions. Our Firm maintains a $500,000 minimum in aggregate investable assets. In certain instances, at the discretion of our Firm, this minimum may be waived. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Destiny Capital offers ongoing portfolio management services based on each client's individual goals, objectives, time horizon, and risk tolerance. We oversee a consultative process which evaluates the client’s unique needs and preferences and matches those with a strategically and/or tactically managed investment portfolio. Our investment management process includes the due diligence and oversight of a diverse set of signal providers with specifically targeted strategies to meet varying risk/return and tax aware expectations. We believe that successful investment management is a combination of skilled analytics and targeted portfolio guidelines organized around specific outcomes tied to the client’s financial plan. The financial plan is driven by the clients’ unique priority matrix and risk tolerance. Risk tolerance is often specific to account type or goal while also being generalized across the financial plan. Destiny Capital prioritizes (but is not exclusive to) investment strategies that are supported by rigorous data analytics. While Destiny Capital strongly believes in the power of asset allocation and diversification, we also believe that a tactical approach to the balancing of those diversified asset classes is preferred when possible. When tax efficiency priorities of the client preclude trading activity, those preferences may be prioritized. Destiny Capital generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, and ETFs. Destiny Capital may use other securities to help diversify a portfolio when applicable. METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Portfolio Construction. We construct diversified portfolios using the primary tenets of Modern Portfolio Theory. Using annual ex-ante capital market assumption data provided by a variety of financial institutions, we identify and review the risk and return metrics for all asset classes in the investable universe. We then perform detailed analysis in order to construct portfolios with the goal of optimizing performance per unit of risk. Asset Allocation. Within each class of securities, we attempt to identify more narrow categories such as domestic vs. international, growth vs. value, large-cap vs. small-cap, long vs. short maturities, corporate vs. government vs. municipal, etc. The number of potential subcategories can be quite large. Mutual funds and exchange traded funds can be useful tools to identify and recommend narrow strategies. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash and cash equivalents will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Rebalancing. Rebalancing involves buying and/or selling assets in a portfolio in order to maintain the desired level of asset weighting. This results in a more consistent risk profile. Our Investment Committee monitors portfolio drift within each DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 12  client account regularly and rebalances each discretionary portfolio no less than annually unless individual client circumstances dictate otherwise. Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Environment, Social and Corporate Governance Research and Risk Management In addition to fundamental investment research, Destiny Capital also seeks to identify and mitigate Environmental, Social, and Corporate Governance (ESG) risk factors that may impact corporate profitability and, subsequently, shareholder value. Destiny Capital incorporates a materiality-based approach to ESG research, meaning that certain ESG risk factors are inherent in certain industries/subindustries and should, therefore, be a focus of risk identification and mitigation. This research is conducted in an effort to reduce overall portfolio volatility and enhance risk-adjusted returns for our clients. Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and anticipate changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and anticipate potential changes to share price based on that data. A risk of using qualitative analysis is that our subjective judgment may prove incorrect. ▪ Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase assets with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: • We believe the securities to be currently undervalued, and/or • We want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we do not take advantage of short-term gains that could be profitable to a client. Moreover, if our analysis is incorrect, the security may decline sharply in value before we make the decision to sell. Short-term purchases. With this rarely-used strategy, we purchase asset classes or securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A risk in a short-term purchase strategy is that by holding the security for this length of time, we do not take advantage of long-term gains that could be profitable to a client. Moreover, if our analysis is incorrect, the security may increase in value after we make the decision to sell, or may decrease in the short-term. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 13  Options strategies. In very limited circumstances, we may recommend options strategies to investors who understand the strategy and are able to bear the associated risks. Before any options strategies are recommended, the advisor and client will have a detailed discussion about the risks, and the client will be provided with a copy of the Option Clearing Corporation’s brochure: Characteristics and Risks of Standardized Options, also known as the Options Disclosure Document or ODD. RISK OF LOSS A client’s investment portfolio is affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic conditions, changes in laws and national and international political circumstances. Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Destiny Capital will assist Clients in determining an appropriate strategy based on their tolerance for risk. Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account(s). Destiny Capital shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform Destiny Capital of any changes in financial condition, goals or other factors that may affect this analysis. Our methods rely on the assumption that the underlying companies within our security allocations are accurately reviewed by the rating agencies and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investors should be aware that accounts are subject to the following risks: ▪ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer- specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon liquidation. ▪ FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. ▪ ▪ CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited resources or less diverse products or services. Their stocks have historically been more volatile than the stocks of larger, more established companies. INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. ▪ CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and thus impact the fund’s performance. ▪ SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. ▪ EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets, and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset value.” ▪ PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend on the manager of such funds to select individual investments in accordance with their stated investment strategy. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 14  ▪ CYBERSECURITY RISK - In addition to the Material Investment Risks listed above, investing involves various operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our firm or one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in the unauthorized release or other misuse of confidential information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Our Firm has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a risk that cybersecurity breaches may not be detected. ▪ NON-LIQUID ALTERNATIVE INVESTMENTS - From time to time, our Firm will recommend to certain qualifying clients that a portion of such clients’ assets be invested in private funds, private fund-of-funds and/or investments (collectively, “Nonliquid Alternative Investments”). Nonliquid Alternative other alternative Investments are not suitable for all our Firm’s clients and are offered only to those qualifying clients for whom our Firm believes such an investment is suitable and in line with their overall investment strategy. Nonliquid Alternative Investments typically are available to only a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified purchaser” under the Investment Company Act of 1940. Nonliquid Alternative Investments present special risks for our Firm’s clients, including without limitation, limited liquidity, higher fees and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited transparency, additional reliance on underlying management of the investment, special tax considerations, subjective valuations, use of leverage and limited regulatory oversight. When a Nonliquid Alternative Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to real estate investing, including but not limited to: limitations of the appraisal value; the borrower’s financial conditions (if the underlying property has been obtained by a loan), including the risk of foreclosures on the property; neighborhood values; the supply of and demand for properties of like kind; and certain city, state and/or federal regulations. Additionally, real estate investing is also subject to possible loss due to uninsured losses from natural and man-made disasters. The above list is not exhaustive of all risks related to an investment in Nonliquid Alternative Investments. A more comprehensive discussion of the risks associated with a particular Nonliquid Investment is set forth in that fund’s offering documents, which will be provided to each client subscribing to a Nonliquid Alternative Investment, for review and consideration. It is important that each potential, qualified investor carefully read each offering or private placement memorandum prior to investing. ▪ ▪ ESG (ENVIRONMENTAL–SOCIAL–GOVERNANCE) INVESTING RISK: ESG investing incorporates a materiality-based approach intended to identify and moderate material environmental, social and governance risks that could impact shareholder value. Our firm utilizes third party data in identifying material factors that could have risk/return implications on client investments. This materiality-based screening approach could result in the avoidance or exclusion of certain companies and/or sectors from an investment portfolio. As with any active investment management strategy, there is the potential for underperformance should a certain omitted company and/or sector outperform over the period of time being measured. Some ESG investing strategies and/or investment managers may also pursue corporate engagement through proxy voting, shareholder resolutions and public policy. INTERVAL FUND RISK: Where suitable, our Firm may utilize interval funds in client portfolios. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals at the fund sponsor’s sole discretion. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 15  date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund's shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client's investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. The fund sponsor determines the fund price which investors will transact at based solely on its internal policies and procedures for valuing the non-traded assets withing the fund. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct Owl Creek, in writing, not to employ any or all such strategies for the client's account. Certain Traded Interval Funds can be purchased by Destiny Capital directly with the Client’s custodian without any prior authorization from the client. In these cases, Destiny Capital will purchase these interval funds on a discretionary basis only when it deems the investments to be suitable for the client. In other cases, certain Non-Traded Interval Funds required the client to execute fund documents in order to invest. In these situations, Destiny Capital will not be able to purchase the Non-Traded Interval Funds on a discretionary basis. Both Traded and Non-Traded Interval Funds are subject to all of the risks and limitations outlined above. ▪ DIGITAL CURRENCY RISK: Our Firm’s use of digital currency in a client portfolio is limited only to publicly traded securities that passively or actively invest in digital currency assets. The shares of certain products are also publicly quoted on OTC Markets and shares that have become unrestricted in accordance with the rules and regulations of the SEC may be bought and sold throughout the day through any brokerage account. Cryptocurrency (notably, bitcoin), often referred to as “virtual currency”, “digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer financial exchange and value storage that is used like money. If deemed appropriate, Clients may have exposure to bitcoin, a cryptocurrency. Cryptocurrency operates without central authority or banks and is not backed by any government. Cryptocurrencies (i.e., bitcoin) may experience very high volatility. Cryptocurrency is also not legal tender. Federal, state, or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. The SEC has issued a public report stating U.S. federal securities laws require treating some digital assets as securities. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or malware. Due to its relatively recent launch, bitcoin has a limited trading history, making it difficult for investors to evaluate investments in this cryptocurrency. It is possible that another entity could manipulate the blockchain in a manner that is detrimental to the bitcoin network. Bitcoin transactions are irreversible such that an improper transfer can only be undone by the receiver of the bitcoin agreeing to return the bitcoin to the original sender. Digital assets are highly dependent on their developers and there is no guarantee that development will continue or that developers will not abandon a project with little or no notice. Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies. Investments in the products are speculative investments that involve high degrees of risk, including a partial or total loss of invested funds. The shares of each product are intended to reflect the price of the digital asset(s) held by such product (based on digital asset(s) per share), less such product’s expenses and other liabilities. Because each product does not currently operate a redemption program, there can be no assurance that the value of such product’s shares will reflect the value of the assets held by such product, less such product’s expenses and other liabilities, and the shares of such product, if traded on any secondary market, may trade at a substantial premium over, or a substantial discount to, the value of the assets held by such product, less such product’s expenses and other liabilities, and such product may be unable to meet its investment objective. ITEM 9 - DISCIPLINARY INFORMATION We do not have any legal, financial, or other “disciplinary” item to report. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 16  ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS INSURANCE One of our associated persons is a licensed insurance agent. This licensed individual is not actively selling insurance products nor is this individual receiving any insurance related compensation. The license, although active, is not in use. DPL FINANCIAL PARTNERS DPL Financial Partners, LLC (“DPL”) is a third-party provider of a platform of insurance consultation services to investment advisers with clients who have current or future needs for insurance products. DPL offers Destiny Capital a membership to its platform for a fixed annual fee. Through its licensed insurance agents, who are also registered representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member, DPL offers Destiny Capital a variety of services relating to commission-free insurance products. These services include, among others, providing Destiny Capital with analyses of their current methodology for evaluating client insurance needs, educating and acting as a resource to IARs of Destiny Capital regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing Destiny Capital access to, and marketing support for, commission free products that insurers have agreed to offer to Destiny Capital’s clients through DPL’s platform. For providing platform services to Destiny Capital, DPL receives service fees from the insurers that offer their commission- free products through the platform in addition to the annual fee paid by Destiny Capital. These service fees are based on the insurance premiums received by the insurers from Destiny Capital’s clients. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. OTHER INDUSTRY AFFILIATIONS Certain IARs of the firm serve on the board of directors at bQuest, the end-of-life planning platform that is offered to our clients at no additional fee. bQuest is an unaffiliated third-party provider. These IARs receive direct compensation from bQuest for their positions. It should be noted that the Firm, Destiny Capital, does not receive compensation from bQuest, nor do they pay directly for the endorsements offered through bQuest. CONFLICTS OF INTEREST Clients should be aware that our Firm and its management persons or employees have the ability to receive additional compensation which creates conflicts of interest that can impair the objectivity of the Firm and these individuals when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps, among others to address this conflict: • we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm and our employees to earn compensation from advisory clients in addition to the Firm's advisory fees; • we disclose to clients that they have the right to decide whether to purchase recommended investment products from our employees; • we collect, maintain and document accurate, complete and relevant client background information, including the • client’s financial goals, objectives, and liquidity needs; the Firm conducts regular reviews of each client advisory account to verify that all recommendations made to a client are in the best interest of the client’s needs and circumstances; • we require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • we periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by the Firm; and • we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Our Firm does not have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 17  Neither our firm nor any of its supervised persons are registered or have an application pending to register as a broker- dealer or a registered representative of a broker-dealer. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial investment in the same securities or other investments that we recommend or acquire for your account, and may engage in transactions that are the same as or different than transactions recommended to or made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in your best interest and have established polices to mitigate conflicts of interest. We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things, personal trading, gifts, outside business activities and the prohibition against the use of inside information. The Code of Ethics is designed to protect our clients, detect and deter misconduct, educate personnel regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a position of trust and must act with complete propriety at all times, protect the reputation of Destiny Capital , safeguard against the violation of the securities laws, and establish procedures for personnel to follow so that we may determine whether our personnel are complying with the Firm’s ethical principles. We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities: ▪ A director, officer, or employee of Destiny Capital shall not buy or sell any securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No supervised employee of Destiny Capital shall prefer his or her own interest to that of the advisory client. ▪ We maintain a list of all securities holdings of anyone associated with this advisory practice with access to advisory recommendations. These holdings are reviewed on a regular basis by an appropriate officer/individual of Destiny Capital ▪ We emphasize the unrestricted right of the client to decline implementation of any advice rendered, except in situations where we are granted discretionary authority of the client’s account ▪ We require that all supervised employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices ▪ Any supervised employee not in observance of the above may be subject to termination None of our associated persons may effect for himself/herself or for accounts in which he/she holds a beneficial interest, any transactions in a security which is being actively recommended to any of our clients, unless in accordance with the Firm’s procedures. You may request a complete copy of our Code by contacting us at the address, telephone, or email on the cover page of this Part 2; ATTN: Chief Compliance Officer. ITEM 12 - BROKERAGE PRACTICES We generally recommend that clients utilize the custody and brokerage services of Fidelity Institutional Wealth Services, (“Fidelity” or the “Custodian”) for investment management accounts. Our Custodian is an independent and unaffiliated FINRA-registered broker-dealer. We may recommend that you establish accounts with this custodian to maintain custody of your assets and to effect trades for your accounts. Some of the products, services and other benefits provided by our Custodian benefit us and may not benefit you or your account. Our recommendation/requirement that you place assets with this custodian may be based in part on benefits they provide us, and not solely on the nature, cost or quality of custody and execution services provided by the Custodian. We are independently owned and operated and not affiliated with any custodian. Fidelity provides us with access to their institutional trading and custody services. These services include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 18  In the event you request us to recommend a broker/dealer Custodian for execution and/or custodial services, we generally recommend your account to be maintained at Fidelity. We may recommend that you establish accounts with the Custodian to maintain custody of your assets and to effect trades for your accounts. You have the right to not act upon any recommendations, and if you elect to act upon any recommendations, you have the right to not place the transactions through any broker/dealer we recommend. Our recommendation is generally based on the broker’s cost and fees, skills, reputation, dependability and compatibility with the client. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. You may be able to obtain lower commissions and fees from other brokers and the value of products, research and services given to us is not a factor in determining the selection of broker/dealer or the reasonableness of their commissions. Fidelity’s execution quality may be different than other broker-dealers. For our client accounts maintained in custody with a Custodian, the Custodian generally does not charge separately for custody but is compensated by account holders through 12b-1 fees and ticket charges. The Custodian we utilize makes available to us other products and services that benefit us but may not benefit your accounts in every case. Some of these other products and services assist us in managing and administering your accounts. These include software and technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of our fees from your account, and assist with back-office functions, record-keeping and reporting. Many of these services generally may be used to service all or a substantial number of our accounts. The Custodian also makes available to us other services intended to help us manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, the Custodian may make available, arrange and/or pay for these services rendered to us by third parties. The Custodian may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to us. While as a fiduciary, we endeavor to act in your best interest, our recommendation that you maintain your assets in accounts at our recommended Custodian may be based in part on the benefit to us or the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the Custodian, which may create a conflict of interest. IARs endeavor at all times to put the interest of our clients first as a part of their fiduciary duty. AGGREGATION AND ALLOCATION OF TRANSACTIONS We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution for our clients and is consistent with the disclosures made to clients and terms defined in the client Investment Advisory Agreement. No advisory client will be favored over any other client, and each account that participates in an aggregated order will participate at the average share price (per custodian) for all transactions in that security on a given business day. We will aggregate clients’ trades providing that the following conditions are met: 1. Our policy for the aggregation of transactions shall be fully-disclosed to our existing clients (if any) and the broker/dealer(s) through which such transactions will be placed; 2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty to seek the best execution (which includes the duty to seek best price) for you and is consistent with the terms of our Investment Advisory Agreement with you for which trades are being aggregated. 3. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all our transactions in a given security on a given business day, with transaction costs based on each client’s participation in the transaction; 4. We will prepare a written statement (“Allocation Statement”) specifying the participating client accounts and how 5. to allocate the order among those clients; If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the allocation statement; if the order is partially filled, the accounts that did not receive the previous trade’s positions should be “first in line” to receive the next allocation. 6. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment and the reason for difference of DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 19  allocation is explained in writing and is reviewed by our compliance officer. Our books and records will separately reflect, for each client account, the orders of which aggregated, the securities held by, and bought for that account. 7. We will receive no additional compensation or remuneration of any kind as a result of the proposed aggregation; 8. and Individual advice and treatment will be accorded to each advisory client. BROKERAGE FOR CLIENT REFERRALS Our Firm does not receive client referrals from any Custodian or third party in exchange for using that broker-dealer or third party. TRADE ERRORS We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and we will absorb any loss resulting from the trade error if the error was caused by the firm. If the error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade errors. DIRECTED BROKERAGE We do not routinely recommend, request or require that you direct us to execute transaction through a specified broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for your account subject to our duty to seek best execution and other fiduciary duties. ITEM 13 - REVIEW OF ACCOUNTS PORTOLIO MANAGEMENT SERVICES Reviews. While the underlying securities within Individual Portfolio Management Services accounts are continually reviewed and monitored, accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by: Timothy Doyle, CIO; Jarrod Musick, CEO/CCO & President; and from time to time, by other financial advisory personnel employed by the firm. Reports. In addition to the monthly statements and confirmations of transactions that Portfolio Management Services clients receive from their broker-dealer, Destiny Capital Corporation provides an annual report summarizing account performance, balances, and holdings at the annual planning review. FINANCIAL PLANNING SERVICES Reviews. While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically formal reviews will be conducted annually for all discretionary clients. Reports. Financial Planning clients will receive a completed financial plan. Additional reports will be generated and provided at the annual review or as needed due to changing factors. CONSULTING SERVICES Reviews. While reviews do occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Consulting Services clients unless otherwise contracted for. Such reviews will be conducted by the client's advisor. Reports. Consulting Services clients will not receive reports unless included in the service. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 20  ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION REFERRALS & PROMOTERS Destiny Capital Corporation's policy is not to accept or allow our related persons to accept any form of compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. An Investment Adviser Representative who is invited to meet with portfolio managers of a mutual fund company will be allowed to attend. Affiliated or unaffiliated persons (“promoters”) may, from time to time, refer, solicit, or introduce clients to our Firm. Our Firm may compensate certain promoters consistent with the requirements of applicable law and regulation, including the Advisers Act as well as applicable state/local laws and regulations. We may pay a promoter a recurring fee, a one-time fee or a portion of the advisory fees or revenues that we earn for managing client or investor assets referred to us by the promoter. The costs of such referral fees are typically paid entirely by our Firm and do not result in any additional charges to the client or investor. At times, we will receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by investment sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which investment sponsors will underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Receipt of these travel and marketing expense reimbursements are dependent upon specific sales quotas, the investment sponsor reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control this conflict by always basing investment decisions on the individual needs of our clients. Our Firm and our supervised persons do not accept or receive compensation based on the sale of securities. Supervised people can be compensated for obtaining prospective clients through marketing initiatives. Destiny Capital may be asked to recommend a financial professional, such as an attorney, accountant or mortgage broker. In such cases, our Firm does not receive any direct compensation in return for any referrals made to individuals or firms in our professional network. Clients must independently evaluate these firms or individuals before engaging in business with them and clients have the right to choose any financial professional to conduct business. Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any referrals made to our firm. Our Firm does recognize the fiduciary responsibility to place your interests first and have established policies in this regard to mitigate any conflicts of interest. BROKERAGE PRACTICES As disclosed under Item 12 Brokerage Practices, we participate in Fidelity’s institutional customer programs, and we may recommend a Custodian to you for custody and brokerage services. There is no direct link between our participation in the program and the investment advice we give to our clients, although we receive economic benefits through our participation in the program that are typically not available to any other independent Investment Advisors participating in the program. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving adviser participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Custodians may also have paid for business consulting and professional services received by some of our related persons. Some of the products and services made available by Custodians through the program may benefit us but may not benefit your account. These products or services may assist us in managing and administering your account, including accounts not maintained at Custodian. Other services made available by Custodian are intended to DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 21  help us manage and further develop our business enterprise. The benefits received by our Firm or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to Custodian. As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our clients first. You should be aware, however, that the receipt of economic benefits by our Firm or our related persons in and of itself creates a conflict of interest and may indirectly influence our choice of Custodian for custody and brokerage services. ITEM 15 – CUSTODY We do not have physical custody, as it applies to investment advisors. Custody has been defined by regulators as having access or control over client funds and/or securities. DEDUCTION OF ADVISORY FEES For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients, or an independent representative of the client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address, and the way the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from Destiny Capital. When you have questions about your account statements, you should contact Destiny Capital or the qualified custodian preparing the statement. Please refer to Item 5 for more information about the deduction of adviser fees. STANDING LETTERS OF AUTHORIZATION (“SLOA”) Our Firm is deemed to have custody of clients’ funds or securities when you have standing authorizations with their custodian to move money from your account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian.. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisors Act of 1940 (“Advisors Act”). The letter provided guidance on the Custody Rule as well as clarified that an Advisor who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our Firm has adopted the following safeguards in conjunction with our custodians. The firm has elected to meet the SEC’s seven conditions to avoid the surprise custody exam, as outlined below: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ITEM 16 – INVESTMENT DISCRETION For discretionary accounts, prior to engaging Destiny Capital to provide investment advisory services, you will enter a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going basis, investments in DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 22  accordance with the client’s investment objective and guidelines. In addition, you will need to execute additional documents required by the Custodian to authorize and enable Destiny Capital, in its sole discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine the amount of securities to be bought or sold, and (3) place orders with the custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the client. The limitations on investment and brokerage discretion held by Destiny Capital for you are: ▪ For discretionary accounts, we require that we be provided with authority to determine which securities and the amounts of securities to be bought or sold. ▪ Any limitations on this discretionary authority shall in writing as indicated on the investment advisory Agreement. You may change/amend these limitations as required. In some instances, we may not have discretion. We will discuss all transactions with you prior to execution or you will be required to make the trades if in an employer sponsored account. ITEM 17 – VOTING CLIENT SECURITIES We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent third-party at your own discretion. You designate proxy voting authority in the custodial account documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We do not take action with respect to any securities or other investments that become the subject of any legal proceedings, including bankruptcies. You can contact our office with questions about a particular solicitation by phone at (720) 715-7570. ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time. DESTINY CAPITAL CORPORATION OCTOBER 2025 | PAGE 23