Howard Bailey Securities, LLC

Howard Bailey Securities, LLC 5916 Covington Rd Fort Wayne, IN 46804 (866} 482-9559 www.howardbailey.com March 2026 This Brochure provides information about the qualifications and business practices of Howard Bailey Securities, LLC. If you have any questions about the contents of this Brochure, please contact us at (866) 482-9559 or via email at info@howardbailey.com. 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. Howard Bailey Securities, LLC ("Howard Bailey") is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them. Additional information about Howard Bailey is also available via the SEC's website www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Howard Bailey is 282712. The SEC's web site also provides information about any persons affiliated with Howard Bailey who are registered, or are required to be registered, as Investment Adviser Representatives of Howard Bailey. Howard Bailey Page 1 of 23 ADV Part 2A March 2026  Item 2 - Material Changes This Brochure, dated March 19, 2026, represents the annual amendment to Howard Bailey's Form ADV Part 2A and replaces the previous version of Howard Bailey's Disclosure Brochure dated March 2025. Since our last annual amendment on March 19, 2025, the following material changes have been made to our last filing: • Rachel Lockwood became the firm’s CCO, replacing Marshal Johnson. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business' fiscal year end, which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting us at {866) 482-9559. Our most current Brochure can also be accessed by visiting www.advisorinfo.sec.gov. Howard Bailey Page 2 of 23 ADV Part 2A March 2026  Item 3 - Table of Contents Item 1- Cover Page ........................................................................................................................................... 1 Item 2 - Material Changes ................................................................................................................................ 2 Item 3 - Table of Contents .................................................................................................................................... 3 Item 4 -Advisory Business Introduction ............................................................................................................ 4 Item 5 - Fees and Compensation .......................................................................................................................... 7 Item 6- Performance Based Fee and Side by Side Management .................................................................... 10 Item 7 -Types of Client(s)................................................................................................................................ 10 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 10 Item 9 - Disciplinary Information ..................................................................................................................... 15 Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 15 Item 11- Code of Ethics, Participation or Interest in Client Accounts and Personal Trading .................... 16 Item 12 - Brokerage Practices .......................................................................................................................... 19 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 Howard Bailey Page 3 of 23 ADV Part 2A March 2026  Item 4 - Advisory Business Introduction Our Advisory Business Howard Bailey Securities, LLC {"Howard Bailey", "us", "we", "our") is a Registered Investment Adviser ("Adviser") with the Securities and Exchange Commission ("SEC"). The Adviser offers investment advice regarding securities and other financial services to clients. We provide investment advice through Investment Adviser Representatives ("Advisors") associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. Howard Bailey was founded in 2016. Casey Weade serves as the firm's CEO. Howard Bailey provides management services to individuals, high net worth individuals, trusts, estates, corporate pension and profit- sharing plans, charitable organizations, foundations, endowments, corporations, small businesses and churches. We are committed to the precept that by placing the client's interests first, we will add value to the asset management process and earn the client's trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business. Services We provide various asset management and financial planning services, with an emphasis on retirement planning services. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We do not participate in wrap fee programs. Asset Management Asset management is the professional management of securities (stocks, bonds and other securities) and assets (e.g., real estate) in order to meet your specified investment goals. With an Asset Management Account, you engage us to assist you in developing a custom-tailored portfolio designed to meet your unique investment objectives. The investments in the portfolio account may include mutual funds, stocks, bonds, etc. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management are based upon your investment goals and objectives, risk tolerance, and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in periodic reviews, which usually take place on an annual basis at a minimum. These Howard Bailey Page 4 of 23 ADV Part 2A March 2026  reviews will be conducted in person, by telephone or video conference, and/or via a written inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. We will: • Review your present financial situation • Monitor and track assets under management • Provide portfolio statements, periodic rate of return reports, asset allocation statement, rebalanced statements as needed • Advise on asset selection • Determine market divisions through asset allocation models • Provide research and information on performance and fund management changes • Build a risk management profile for you • Assist you in setting and monitoring goals and objectives • Provide personal consultations as necessary upon your request or as needed. You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. You shall not have the ability to impose restrictions on the management of your account. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that doing so is in your best interests. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We utilize Fidelity Brokerage Services LLC as our third-party custodian. You will enter into a separate custodial agreement with the custodian. This agreement, among other things, authorizes the custodian to take instructions from us regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. Your statement may be in either printed or electronic form based on your preferences. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We manage assets on a discretionary basis, which means you have given us the authority to determine the following with/without your consent: Howard Bailey Page 5 of 23 ADV Part 2A March 2026  • Which securities to be bought or sold for your account • Amount of securities to be bought or sold for your account Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with taxplanning. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. In addition to investment advisory services, we may assist clients in accessing third-party estate planning services through platforms such as Wealth.com. These services allow clients to create estate planning documents such as wills, trusts, and powers of attorney. We do not provide legal advice. Clients are solely responsible for reviewing any legal documents with a licensed attorney. In some cases, we may facilitate the use of these services or assist clients in navigating the process. Where applicable, clients may be billed directly by the provider or through our firm for convenience. Third Party Money Managers We may determine that opening an account with a professional third-party money manager is in your best interests. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may: • Assist in the identification of investment objectives • Recommend specific investment style and asset allocation strategies • Assist in the selection of appropriate money managers and review performance and progress • Recommend reallocation among managers or styles within the program • Recommend the hiring and firing of money managers utilized by you. You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur. Howard Bailey Page 6 of 23 ADV Part 2A March 2026  Sub-Adviser Howard Bailey has elected to utilize the investment management services of AE Wealth Management LLC ("AEWM") and its platform provider, Orion Advisor Services, LLC ("Orion"), to assist in the provision of Investment management services for the client. The client will be provided the Brochure Documents of AEWM and Orion at the time of application. Unless otherwise notified, the Advisor is appointed as his/her agent to receive the delivery of the Brochure Documents of AEWM and Orion, and the Advisor will provide, upon request, copies of any applicable Brochure Documents of AEWM and Orion to the client. The client may also, at any time, change his/her mind and request, for no additional cost, the Brochure Documents of AEWM and Orion to be delivered to the client directly. Financial Planning/Consulting We provide services such as comprehensive financial planning, estate planning, business planning, educational planning, and financial consulting. Fee based financial planning and consulting is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets specific goals and objectives. The financial planning and/or consulting relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning and/or consulting services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. Assets Under Management As of December 31, 2025, Howard Bailey Securities, LLC has approximately $582,792,249 of assets under management on a discretionary basis. In addition to the aforementioned regulatory assets under management, Howard Bailey also provides non-management advisory services on an additional $43,438,579 not included in regulatory assets under management above. Item 5 - Fees and Compensation We provide asset management, financial planning, financial consulting, and qualified retirement plan consulting services for a fee. Howard Bailey Page 7 of 23 ADV Part 2A March 2026  Either party may terminate the relationship with a thirty (30) day written notice. Upon termination of any account, any prepaid fees that are in excess of the services performed will be promptly refunded to you. Any fees that are due, but have not been paid, will be billed to you and are due immediately. All refunds will be sent via check to the address of record within 30 days for account termination. Asset Management Fee Schedule The fee charged is based upon the amount of money you invest. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged either monthly or quarterly, in either advance or arrears. Howard Bailey does not directly bill accounts. The accounts are billed by the either the third-party manager or the sub-adviser. The sub-adviser, AEWealth bills accounts on a monthly basis. Fees are charged in arrears utilizing the average daily balance over the billing period. Accounts will be billed the month following the initial investment, approximately mid-month. Our default annual fee is 1.35% for up to $1 Million in assets under managements. The annual fee will decrease to 0.75% for assets under management starting at $1,000,001. No change in the annual fee shall be effective without prior written notification to you. We believe our advisory fee is reasonable considering the fees charged by other investment advisers offering similar services/programs. You may also pay additional advisory fees to a third-party money manager depending upon which manager you select. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds. Howard Bailey does not charge fees in addition to the third-party money manager; they will receive a portion of the fee charged by the outside manager. All fees will be calculated and billed by the third-party money manager; client should refer to the ADV Part 2 of the third-party money manager for a full description of fees. Your account at the custodian may also be charged for certain additional assets managed for you by us but not held by the custodian (i.e. 401(k)s). The fees we charge can be deducted directly from your account at the custodian. We will instruct the custodian to deduct the fees from your account at the beginning of the month. This fee will show up as a deduction on your following next account statement from the custodian. Sub-Adviser Howard Bailey will be compensated by the sub-advisor(s) from the advisory fees they collect from the client. The fee charged is based upon the amount of money invested. Fees are charged monthly, in arrears. Please refer to the ADV Brochure of the Sub-Adviser(s) for a full description of fees. Financial Planning/Consulting Fees Our financial planning/consulting fees range from $50 to $200 per hour which may be negotiable depending upon the nature and complexity of the client's circumstances. Howard Bailey may also provide a comprehensive financial plan and/or consulting services for a fixed fee of $1,000-$5000, which may be negotiable depending upon the nature and complexity of the client's Howard Bailey Page 8 of 23 ADV Part 2A March 2026  circumstances. This amount is due at the time the agreement is signed. Financial plans will be presented to you on the date specified in the agreement, provided that all information needed to prepare the investment plan has been promptly provided to us. The Financial Planning/Consulting Agreement will show the fee you will pay. If the plan is implemented through us, we may receive compensation from the sale of insurance products or advisory services recommended in the financial plan. This compensation would be in addition to the financial planning fee you pay. The fees and expenses you pay for the purchase of these products may be more or less than the expenses you would pay should you decide to implement our recommendations through another investment advisory firm or broker-dealer and are typically determined by the broker-dealer or investment company sponsoring the product. Therefore, a conflict of interest may exist between our interests and your interests since we may recommend products that pay us compensation. We have an incentive to recommend particular products based upon the potential compensation rather than your needs. This conflict is addressed in our Code of Ethics. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Third Party Fees Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third party investment companies and other third parties. These include fees charged by managers, custodial fees, 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. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund's prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Certain strategies offered by us may involve investment in mutual funds and/or ETFs. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as "12(b)(1) fees". These 12(b)(1) fees come from fund assets, and thus indirectly from clients' assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Our brokerage practices are discussed in more detail under Item 12 - Brokerage Practices. For estate planning services provided through third-party platforms such as Wealth.com, our firm may collect fees from clients to cover the cost of document creation. These fees will be clearly disclosed in writing and are separate from our advisory fees. We do not receive commissions or compensation from these third-party providers. Clients are under no obligation to use any estate planning platform recommended or made available by our firm. Howard Bailey Page 9 of 23 ADV Part 2A March 2026  Other Compensation Our Advisors, through Howard Bailey Financial, Inc., recommend and sell annuities, life, disability, health, and long-term care insurance and receive the usual and customary commissions for these products in addition to any agreed upon advisory fee for asset management of securities. While our Advisors endeavor at all times to put the interests of our clients first as part of our fiduciary duty, the possibility of receiving additional compensation creates a conflict of interest, and may affect our Advisors' judgment when making recommendations. We require that all Advisors disclose this conflict of interest when such recommendations are made. Also, we require Advisors to disclose that Clients may purchase recommended insurance products from other registered insurance agents not affiliated with us. Howard Bailey Financial, Inc. and Howard Bailey Securities, LLC also receive bonus payments and or discounts, respectively, from third parties based on sales of qualifying insurance products, including from Advisors Excel Innovation & Growth fund program, Advisors Excel Legends Club program, and other general discounts offered by Advisors Excel based on production. Item 6 - Performance Based Fee and Side by Side Management We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 - Types of Client(s) We provide asset management, financial planning, and financial consulting services to individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments, corporations, small businesses and churches. We provide retirement plan services to qualified retirement plans. We have no minimum account opening balance. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use Fundamental, Technical, and Modern Portfolio Theory as part of our overall investment management discipline; the implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following: Page 10 of 23 Howard Bailey ADV Part 2A March 2026  Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security's value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced= sell or short). Modern Portfolio Theory (MPT) We use Modern Portfolio Theory to help select the funds we use in your account. Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk. Technical Analysis Technical Analysis is a technique that attempts to determine a security's value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market's price reflects all relevant information so the analysis focuses on the history of a security's trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations. As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return. Investment Strategies In order to perform this analysis, we use many resources, such as: • Morningstar • Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.) • Annual reports, prospectuses, filings • Company press releases and websites The investment strategies we use to implement any investment advice given to you include, but are not limited to: Page 11 of 23 Howard Bailey ADV Part 2A March 2026  • Long term purchases -securities held at least a year • Short term purchases - securities sold within a year • Trading -securities sold within 30 days • Short sales Risk of Loss We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to handle. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. A list of all risks associated with the strategies, products and methodology we offer are listed below: Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include: • Call Risk- The possibility that falling interest rates will cause a bond issuer to redeem-or call- its high-yielding bond before the bond's maturity date. • Credit Risk - the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. • Interest Rate Risk - the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. • Prepayment Risk - the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks: • There are an infinite number of factors that can affect the earnings of a company, and its stock price, over time. These can include economic, political and social factors, in addition to the various company statistics. • The data used may be out of date. • It is difficult to give appropriate weightings to the factors. • It assumes that the analyst is competent. • It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on. Page 12 of 23 Howard Bailey ADV Part 2A March 2026  Modern Portfolio Theory (MPT) Risk Modern Portfolio Theory tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance. Exchange Traded Fund ("ETF'J Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds: • The market price of the ETF's shares may trade at a premium or a discount to their net asset value; • An active trading market for an ETF's shares may not develop or be maintained; and • There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged Insurance Product Risk The rate of return on insurance products is not stable, but varies with the stock, bond and money market subaccounts that you choose as investment options. There is no guarantee that you will earn any return on your investment and there is a risk that you will lose money. Before you consider purchasing a variable product, make sure you fully understand all of its terms. Carefully read the prospectus. Some of the major risks include: • Liquidity and Early Withdrawal Risk- There may be a surrender charges for withdrawals within a specified period, often multiple years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. • Sales and Surrender Charges -Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero. • Fees and Expenses - There are a variety of fees and expenses which can reach 2% and more such as: o Mortality and expense risk charges o Administrative fees o Underlying fund expenses o Charges for any special features or riders. • Bonus Credits - Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus Page 13 of 23 Howard Bailey ADV Part 2A March 2026  credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods. • Guarantees- Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them. • Market Risk- The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk-The possibility that an investment will go down in value, or "lose money," from the original or invested amount. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk- The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk-The possibility that an investment will go down in value, or "lose money," from the original or invested amount. Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services. Technical Analysis Risk • Technical analysis is derived from the study of market participant behavior and its efficacy is a matter of controversy. Page 14 of 23 Howard Bailey ADV Part 2A March 2026  • Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data. • Models and rules can incur sufficiently high transaction costs. Overall Risks Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. Item 9 - Disciplinary Information In September, 2024, the Securities and Exchange Commission ("SEC") released the results of their investigation into compliance with Rule 206(4)-1, which focuses on Investment Adviser marketing. Howard Bailey Securities, LLC was among those firms found to have violated Rule 206(4)-l(b)(l), was ordered to cease and desist from committing or causing any future violations of Rule 206(4)(b)(l), censured for its conduct, and ordered to pay a civil monetary penalty in the amount of $90,000. Howard Bailey also agreed to revise all advertisements containing the Testimonials or Endorsements in question to bring the communications into compliance with Rule 206(4)-l(b)(l), or in the alternative, permanently stop disseminating all such advertisements. The SEC settled issue was exclusively in relation to marketing materials disseminated by Howard Bailey and is not related to any investments, investment strategies or financial plans implemented by Howard Bailey. Howard Bailey is committed to carefully reviewing our compliance procedures and improving our processes to ensure the marketing materials that Howard Bailey disseminates comply fully with Rule 206(4)-l(b)(l). Additional information can be requested via email at info@howardbailey.com. Item 10 - Other Financial Industry Activities and Affiliations Page 15 of 23 Howard Bailey ADV Part 2A March 2026  Neither Howard Bailey nor any of its management persons are registered as a broker-dealer or registered as a representative of a broker-dealer, nor does it have any pending application to register. In addition, neither Howard Bailey nor its management persons are affiliated with any broker-dealer. Howard Bailey and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor. Other Financial Industry Affiliations The Advisors of Howard Bailey have the following outside business activities and/or affiliations to disclose. Casey Weade and some of the investment adviser representatives of Howard Bailey are licensed insurance agents/brokers with various companies. The sale of these products accounts for approximately 35% of their time. Through Howard Bailey Financial, Inc., they may recommend insurance products and may also, as independent insurance agents, sell those recommended insurance products to clients. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed Advisors earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all lARs disclose this conflict of interest when such recommendations are made. Also, we require Advisors to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. Casey Weade is the owner of Purpose Based Properties, LLC, a real estate holding company. Clients are not solicited into these or any other real estate investments. He is also the co-owner of Rainmaker Marketing Solutions, Inc., which provides marketing consulting services. Casey Weade is owner of Captive Alternative Investments, an Alternative Investment Holding Company for various passive investment opportunities. Casey Weade is the owner of Howard Bailey Risk Management, LLC. which handles the risk management for Howard Bailey Financial, Inc. Finally, Mr. Weade is the sole owner of a solar leasing company, Yavin Solar. Selection of Other Advisers Howard Bailey will be compensated by the third party manager(s) from the advisory fees collected from the client. Details of these fees are/will be described in Item 5 - Fees and Compensation. This causes a conflict of interest in recommending certain third party managers since we may receive compensation for referring clients to these vendors. In order to mitigate this conflict of interest, we require all Advisors to inform the client that they are under no obligation to implement any recommendations made by us or the third party manager. Item 11 - Code of Ethics, Participation or Interest in Client Accounts and Personal Trading Page 16 of 23 Howard Bailey ADV Part 2A March 2026  General Information We have adopted a Code of Ethics for all supervised persons of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended. Participation or Interest in Client Accounts Our Compliance policies and procedures prohibit anyone associated with Howard Bailey from having an interest in a client account or participating in the profits of a client's account without the approval of the cco. The following acts are prohibited: • Employing any device, scheme or artifice to defraud • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading • Engaging in any fraudulent or deceitful act, practice or course of business • Engaging in any manipulative practices Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO. Personal Trading We may recommend securities to you that we will purchase for our own accounts. We may trade securities in our account that we have recommended to you as long as we place our orders after your orders. This policy is meant to prevent us from benefiting as a result of transactions placed on behalf of advisory accounts. Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Howard Bailey has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of "Access Persons". The policy requires that an Access Person of the firm provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person's current securities holdings at least once each twelve (12) month period thereafter on a date the Adviser selects; provided, however that at any time that the Adviser has only one Access Person, he or she shall not be required to submit any securities report described above. Page 17 of 23 Howard Bailey ADV Part 2A March 2026  We have established the following insider trading restrictions in order to ensure our fiduciary responsibilities to you are met: • No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of Advisors of Howard Bailey, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours. Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal to restrict the use of your information. Our Privacy Policy is available upon request. Conflicts of Interest Howard Bailey's Advisors may employ the same strategy for their personal investment accounts as it does for its clients. However, Advisors may not place their orders in a way to benefit from the purchase or sale of a security. Through Howard Bailey Financial, Inc., our financial advisors receive commission payments for insurance products sold. These commission payments create a conflict of interest in that they incentivize sale of insurance products and may incentivize certain insurance products over others based on the amount of commission paid. Please ask your financial advisor for information on commission paid for any recommended insurance product. Bonuses paid and discounts received, by Howard Bailey Financial, Inc. and Howard Bailey Securities, LLC respectively, represents a conflict of interest in that it incentivizes sale of qualifying insurance products over those not covered under any relevant bonus/discount program. Please ask your financial advisor for information on what products are covered under relevant bonus programs. In 2018, Howard Bailey Financial, Inc. began working with Advisors Excel and entered into a forgivable loan arrangement. Under this arrangement, Howard Bailey received funds to assist in the transition of client accounts to the AEWM platform. The balance of the loan was forgiven in installments based on the percentage of client accounts moved to the aforementioned platform. This loan and the forgiveness schedule create a conflict of interest as they further incentivized use of AEWM as a sub-adviser for client accounts. As of September, 2021, the balance of the loan was fully forgiven. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. Use of Disclaimers We shall not attempt to limit liability for willful misconduct or gross negligence through the use of disclaimers. Page 18 of 23 Howard Bailey ADV Part 2A March 2026  Item 12 - Brokerage Practices Factors Used to Select Custodians In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We may recommend clients use Fidelity as the qualified custodian for their accounts when utilizing our asset management services. Soft Dollars Fidelity and other third party managers may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under the rules. These research products and/or services will assist the Advisor in its investment decision making process. Such research generally will be used to service all of the Advisor's clients, but brokerage commissions paid by the client may be used to pay for research that is not used in managing the client's account. The account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where the Advisor determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Because soft dollar benefits could be considered to provide a benefit to the adviser that might cause the client to pay more than the lowest available commission without receiving the most benefit, they are considered a conflict of interest in recommending or directing custodial and third party managerial services. Howard Bailey mitigates these conflicts of interest through strong oversight of soft-dollar arrangements by the Chief Compliance Officer, in order to assure the soft dollar benefits serve the best interests of the client. There may other benefits from recommending Fidelity or other third party managers such as software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Other services may include, but are not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third party service providers who provide a wide array of business related services and technology with whom Howard Bailey may contract directly. Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Page 19 of 23 Howard Bailey ADV Part 2A March 2026  Best Execution We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for account transactions. Brokerage for Client Referrals In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third party. Directed Brokerage We do not permit directed brokerage. We will require you to use the custodian of our choosing as the custodial firm. Trading Transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or "batch" such Orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients' differences in prices and commission or other transaction costs. Under this procedure, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. Transactions placed in an asset management account by a third party manager will be executed through their broker-dealer or custodian. In determining best execution for these transactions, the third party manager is looking at whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. While they look for competitive commission rates, they may not obtain the lowest possible commission rates for account transactions. The aggregation and allocation practices of mutual funds and third party managers that we recommend to you are disclosed in the respective mutual fund prospectuses and third party manager disclosure documents which will be provided to you. Qualified Retirement Plan Trading We do not accept trading authorization with respect to any participants' plan account. Item 13 - Review of Accounts Reviews Reviews are conducted at least annually or as agreed upon by client and advisor. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and Page 20 of 23 Howard Bailey ADV Part 2A March 2026  structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Qualified Retirement Plan Reviews We will meet with the plan's Investment Committee at least annually to review the current investments, as well as custodial and service provider arrangements. Unless directed to do so by the Investment Committee, we will only review custodial and service provider arrangements on an annual basis. Reports We do not provide any other statements except the one provided by your custodian, along with an invoice copy. Item 14 - Client Referrals and Other Compensation We may receive economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients. Howard Bailey will be compensated by the third party manager(s) from the advisory fees collected from the client. This may cause a conflict of interest in recommending certain third party managers since we may receive compensation for referring clients to these vendors. In order to mitigate this conflict of interest, we require all Advisors to inform the client that they are under no obligation to implement any recommendations made by us or the third party manager. Additionally, we may pay compensation to a third party if they refer clients to us. Prior to paying such referral fees, we will verify that the third party is appropriately registered to receive such compensation. Through Howard Bailey Financial, Inc., our financial advisors receive commission payments for insurance products sold. These commission payments create a conflict of interest in that they incentivize sale of insurance products and may incentivize certain insurance products over others based on the amount of commission paid. Please ask your financial advisor for information on commission paid for any recommended insurance product. Bonuses paid and discounts received, by Howard Bailey Financial, Inc. and Howard Bailey Securities, LLC respectively, represents a conflict of interest in that it incentivizes sale of qualifying insurance products over those not covered under any relevant bonus/discount program. Please ask your financial advisor for information on what products are covered under relevant bonus programs. In 2018, Howard Bailey Financial, Inc. began working with Advisors Excel and entered into a forgivable loan arrangement. Under this arrangement, Howard Bailey received funds to assist in the transition of client accounts to the AEWM platform. The balance of the loan was forgiven in installments based on the percentage of client accounts moved to the aforementioned platform. This loan and the forgiveness schedule create a conflict of interest as they further incentivized use of AEWM as a sub-adviser for client accounts. As of September, 2021, the balance of the loan was fully forgiven. Page 21 of 23 Howard Bailey ADV Part 2A March 2026  Item 15 - Custody We do not maintain physical possession of client funds or securities. However, we are deemed to have custody of certain client accounts because we are authorized to deduct advisory fees from client accounts and because certain clients have authorized us, through standing letters of authorization (“SLOAs”), to instruct the qualified custodian to transfer funds to designated third parties. Client assets are maintained with an independent qualified custodian, generally Fidelity Brokerage Services LLC. Howard Bailey does not physically withdraw advisory fees from client accounts. Pursuant to the client’s written authorization, Howard Bailey provides the applicable fee information or instructions to the qualified custodian, and the custodian deducts the advisory fee from the client’s account and remits it to Howard Bailey. Clients should receive account statements directly from the qualified custodian at least quarterly and are encouraged to carefully review those statements. Qualified Retirement Plan Custody We do not have actual or constructive custody of any client's account. We do not have the ability to deduct fees directly from the plan accounts. Item 16 - Investment Discretion We usually receive discretionary authority from you at the beginning of an advisory relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account. When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. We require that any investment guidelines and/or restrictions be provided to us in writing. Prior to assuming discretionary authority, clients must execute the Advisory Agreement. Execution of the Advisory Agreement grants us the authority to determine, without obtaining specific client consent, both the amount and the type of securities to be bought and sold to help achieve the client account objectives. The third party money manager and/or custodians may have discretion over your account. The Advisory Agreement details this in full. Page 22 of 23 Howard Bailey ADV Part 2A March 2026  Qualified Retirement Plan Advisory Services Our recommendations regarding our qualified retirement plan consulting services are made on a non- discretionary basis. The plan sponsor retains the decision making authority over the plan. When recommending securities, we observe the investment policies, limitations, and restriction set by the plan and plan sponsor. Item 17 - Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies. We are authorized to instruct the custodian to forward you copies of all proxies and shareholder communications relating to your account assets. Item 18 - Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of five hundred dollars and more than six months in advance of advisory services rendered. Page 23 of 23 Howard Bailey ADV Part 2A March 2026  HOWARD BAILEY Investment Advisory Services may be offered through Howard Bailey Securities, LLC, a registered investment advisor. Certified Financial Planner Board of Standards Inc. owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™ and CFP® (with flame design) in the U.S., which it awards to individuals who successfully complete CFP Board’s initial and ongoing certification requirements. The CLU® mark is the property of The American College, which reserves sole rights to its use, and is used by permission. R E TI R E W ITH PU R PO S E (866) 482-9559 HOWARDBAILEY.COM