FIRST LIGHT WEALTH ADVISORS, LLC

Disclosure Brochure March 24, 2026 FIRST LIGHT WEALTH ADVISORS, LLC a Registered Investment Adviser 76 East Main Street, Second Floor Little Falls, NJ 07424 (973) 435-4520 www.firstlightwa.com This brochure provides information about the qualifications and business practices of First Light Wealth Advisors, LLC (hereinafter “FLWA” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.  Disclosure Brochure First Light Wealth Advisors, LLC Item 2. Material Changes In this Item, FLWA is required to discuss any material changes that have been made to the brochure since the last annual amendment filed on March 18, 2025. The Firm made updates as part of its switch from state registration to registration with the Securities and Exchange Commission (SEC). Page | 2 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 3. Table of Contents Item 2. Material Changes .............................................................................................................................................. 2 Item 3. Table of Contents ............................................................................................................................................. 3 Item 4. Advisory Business ............................................................................................................................................ 4 Item 5. Fees and Compensation .................................................................................................................................... 6 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................ 9 Item 7. Types of Clients ............................................................................................................................................... 9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 9 Item 9. Disciplinary Information ................................................................................................................................ 13 Item 10. Other Financial Industry Activities and Affiliations .................................................................................... 13 Item 11. Code of Ethics .............................................................................................................................................. 14 Item 12. Brokerage Practices ...................................................................................................................................... 15 Item 13. Review of Accounts ..................................................................................................................................... 18 Item 14. Client Referrals and Other Compensation .................................................................................................... 18 Item 15. Custody......................................................................................................................................................... 19 Item 16. Investment Discretion ................................................................................................................................... 19 Item 17. Voting Client Securities ............................................................................................................................... 19 Item 18. Financial Information ................................................................................................................................... 20 Page | 3 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 4. Advisory Business FLWA offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to FLWA rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with FLWA setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). FLWA filed for registration as an investment adviser in January 2018 and is wholly owned by James Korzik. As of December 31, 2025, FLWA had $116,263,725 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of FLWA, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on FLWA’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services FLWA offers limited financial planning and consulting services, which can include income planning, cash flow planning, insurance planning and retirement planning. These services are rendered in conjunction with investment portfolio management, as described below. In performing these services, FLWA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. FLWA recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage FLWA or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by FLWA. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising FLWA’s recommendations and/or services. Investment Management Services FLWA manages client investment portfolios primarily on a discretionary basis, but can agree to non- discretionary services in its sole discretion. FLWA primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, public and non-traded real Page | 4 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC estate investment funds (“REITs”), and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage FLWA to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, FLWA directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. FLWA tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. FLWA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify FLWA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if FLWA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services FLWA provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: • Plan Design and Strategy • Plan Fee and Cost Analysis • Plan Review and Evaluation • Plan Committee Consultation • Executive Planning & Benefits • Fiduciary and Compliance • Investment Selection • Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by FLWA as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of FLWA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Page | 5 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Use of Independent Managers As mentioned above, FLWA selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. FLWA evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. FLWA also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. FLWA continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. FLWA seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Item 5. Fees and Compensation FLWA offers services on a fee basis, which includes fixed fees and fees based upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offers insurance products under a separate commission-based arrangement. Comparable services may be available from other sources for lower fees. Investment Management Fees FLWA offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee varies between 25 and 150 basis points (0.25% – 1.50%), depending upon the size and composition of a client’s portfolio and the type of services rendered. The annual fee is prorated and charged monthly (the “billing period”), in advance, based upon the market value of the assets being managed by FLWA on the last day of the previous billing period as determined by a party independent from the Firm (including the client’s custodian or another third-party). If assets held with the primary custodian that the Firm recommends are deposited into or withdrawn from an account Page | 6 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC after the inception of a billing period, the fee payable with respect to such assets will be prorated. For assets held outside of the primary custodian that the Firm recommends, the Firm’s billing procedures may differ since that other custodian is doing the calculations. For those held-away assets, FLWA does not prorate fees deposited or withdrawn unless that custodian does so pursuant to their terms. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. The Firm processes such refunds with or without a written request from the client, nonetheless, clients may confirm requests for refunds in writing. The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm may, in its sole discretion, not include cash in determining the fee, especially where a client has a high percentage of cash for reasons other than the Firm's investment management decision. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), FLWA may negotiate a fee rate that differs from the range set forth above. Alternatively, the Firm may negotiate a fixed fee for investment management or for more limited advice (such as periodic reviews of a client’s retirement accounts). The fixed fee will vary between $250 and $1,000, depending on the advice given and the person giving the advice. Clients are advised that a conflict of interest exists for the FLWA to recommend that clients engage the Firm for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Retirement Plan Consulting Fees FLWA charges an asset-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary between 19 and 50 basis points (0.19% – 0.50%) depending upon the amount of assets to be advised on. Fee Discretion FLWA may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. Page | 7 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Additional Fees and Expenses In addition to the advisory fees paid to FLWA, clients 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 securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent Managers, margin costs, charges imposed directly 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, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Direct Fee Debit Clients provide FLWA and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to FLWA. Alternatively, clients may elect to have FLWA send a separate invoice for direct payment. Use of Margin FLWA does not recommend that clients us margin in the management of investment portfolios. Where the client requests the Firm to do so, however, the fee payable will be assessed gross of margin such that the market value of the client’s account and corresponding fee payable by the client to FLWA will be increased. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to FLWA’s right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to FLWA, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. FLWA may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page | 8 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 6. Performance-Based Fees and Side-by-Side Management FLWA does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients FLWA offers services to individuals, pension and profit sharing plans, trusts, estates, corporations and business entities. FLWA does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis FLWA utilizes a combination of fundamental and cyclical analysis while employing an asset allocation strategy based on a derivative of Modern Portfolio Theory (“MPT”). Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For FLWA, this process typically involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall fundamental analysis of the health of the particular company that FLWA is recommending. The risks with cyclical analysis are similar to those of technical analysis. FLWA then seeks to combine the results of fundamental and cyclical analysis into a suitable portfolio for the client through the use of Modern Portfolio Theory. Modern Portfolio Theory (“MPT”) is a mathematical based investment discipline that seeks to quantify expected portfolio returns in relation to corresponding portfolio risk. The basic premise of MPT is that the risk of a particular holding is to be assessed by comparing its price variations against those of the market portfolio. However, MPT disregards certain investment considerations and is based on a series of Page | 9 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC assumptions that may not necessarily reflect actual market conditions. As such, the factors for which MPT does not account (e.g., tax implications, regulatory constraints and brokerage costs) may negate the upside or add to the actual risk of a particular allocation. Nevertheless, FLWA’s investment process is structured in such a way to integrate those assumptions and real life considerations for which MPT analytics do not account." Investment Strategies FLWA’s goal is to create a comprehensive yet easy to understand, client-driven approach. Goals FLWA strives to help clients define clear and realistic goals. These goals are unique to the client. FLWA seeks to understand its clients’ complete financial picture. This may include total net-worth, assets, liabilities, income, as well as other pertinent factors. Often clients do not have clearly defined goals. FLWA is prepared to assist the client in understanding what they may want their financial future and retirement to look like. Planning Once FLWA has analyzed the client’s complete financial picture and defined their goals, FLWA will work in unison with the client to formulate a plan. This plan can be as simple or complex as need be. However, FLWA’s goal is to make it as simple as we can for the client. FLWA will coordinate with the client’s tax professionals, legal counsel, and other service providers; in a cohesive and organized manner, to help gather the needed data. Once FLWA has all the data needed formulate a plan, the Firm will present the process to the client in a clear and concise manner. The plan will also be presented in a manner which outlines both type and quantity of investments/securities to be employed, as well as respective risk. Implementation Implementation of the aforementioned plan can be as slowly or quickly as the client prefers. FLWA seeks to implement the plan safely with respect to the risks involved. FLWA will keep the client updated as to the progress and help them understand the logic involved. Monitoring Once implemented, FLWA will consistently monitor the plan. FLWA understands markets and clients’ needs change. FLWA is prepared to modify the plan as needed due to client needs and changing conditions in the market. FLWA will conduct reviews with the client at least semi-annually. If more frequent reviews or updates are required, FLWA will attempt to accommodate the client. During each review, FLWA will Page | 10 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC help the client understand how they have moved towards their goal(s) and what changes (if any) are needed. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of FLWA’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that FLWA will be able to predict those price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption Page | 11 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Closed end funds do not trade at NAV. Closed end funds are subject to market volatility like other securities. Because closed end funds do not trade at NAV, the market price of a closed end fund may be significantly different than the fund’s NAV. The closed end fund may trade at a discount or premium to its NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, FLWA selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, FLWA continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, FLWA does not have the ability to supervise the Independent Managers on a day-to-day basis. Use of Margin While the use of margin borrowing (or any other type of borrowing) for investments can substantially improve returns, it may also increase overall portfolio risk. Margin transactions are generally effected using capital borrowed from a Financial Institution, which is secured by a client’s holdings. Under certain circumstances, a lending Financial Institution may demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the Financial Institution may liquidate account assets to satisfy the client’s outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest rates may have a significant effect on the profitability and stability of a client’s portfolio. As discussed above, the Firm only utilizes margin (or other types of borrowing) if requested by the client. Page | 12 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Investment in Thinly Traded Securities In limited circumstances the Firm will invest client assets in securities that trade with low trading volume. These securities have less liquidity and clients may be unable to sell their position as easily as more heavily traded securities. Lower liquidity can result in significant differences in bid and ask prices resulting in a reduction of returns. Thinly traded securities are also subject to extreme price swings and are more difficult to get reliable pricing for. Thinly traded securities are also more susceptible to market manipulation. Item 9. Disciplinary Information FLWA has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. Licensed Insurance Agents A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that FLWA recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. In addition, the Firm has a relationship with an unaffiliated life insurance agent, Roy Heerema, who services the life insurance needs of certain legacy clients and acts as a liaison with the Firm. The Firm compensates the agent for the services which the Firm believes allow it to provide better integrated services to clients. Page | 13 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 11. Code of Ethics FLWA has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. FLWA’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non- public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of FLWA’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact FLWA to request a copy of its Code of Ethics. Page | 14 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions FLWA recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) for investment management accounts. The final decision to custody assets with Schwab is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. FLWA is independently owned and operated and not affiliated with Schwab. Schwab provides FLWA with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which FLWA considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. Consistent with obtaining best execution, the Firm can receive investment research products and/or services which assist FLWA in its investment decision-making process. Such research will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because FLWA does not have to produce or pay for the products or services. FLWA periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions FLWA receives without cost from Schwab administrative support, computer software, related systems support, as well as other third party support as further described below (together "Support") which allow FLWA to better monitor client accounts maintained at Schwab and otherwise conduct its business. FLWA receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits FLWA, but not its clients directly. Clients should be aware that FLWA’s receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits may influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, FLWA endeavors Page | 15 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC at all times to put the interests of its clients first and has determined that the recommendation of Schwab is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, FLWA receives the following benefits from Schwab: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. In addition, the Firm receives funds to be used toward qualifying third-party service providers for research, marketing, compliance, technology and software platforms and services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset- based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Schwab. Other potential benefits may include occasional business entertainment of personnel of FLWA by Schwab personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist FLWA in managing and administering clients’ accounts. These include software and other technology (and related technological training) 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 the Firm's fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab also makes available to FLWA other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Schwab 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 the Firm. While, as a fiduciary, FLWA endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Schwab may be Page | 16 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. Brokerage for Client Referrals FLWA does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct FLWA in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by FLWA (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, FLWA may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client will be effected independently, unless FLWA decides to purchase or sell the same securities for several clients at approximately the same time. FLWA may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among FLWA’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which FLWA’s Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. FLWA does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one Page | 17 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Account Reviews FLWA monitors client portfolios on a continuous and ongoing basis while regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by the Firm’s Principal. All investment advisory clients are encouraged to discuss their needs, goals and objectives with FLWA and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and quarterly to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from FLWA and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from FLWA or an outside service provider. Item 14. Client Referrals and Other Compensation Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. Page | 18 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Other Compensation The Firm receives economic benefits from Schwab. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody FLWA is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. Item 16. Investment Discretion FLWA is given the authority to exercise discretion on behalf of clients. FLWA is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. FLWA is given this authority through a power-of-attorney included in the agreement between FLWA and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). FLWA takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities FLWA does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Page | 19 © MarketCounsel 2026  Disclosure Brochure First Light Wealth Advisors, LLC Item 18. Financial Information FLWA is not required to disclose any financial information due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 20 © MarketCounsel 2026