INTRUA FINANCIAL LLC

Intrua Financial 3737 Buffalo Speedway, Ste. 400 Houston, TX 77098 (713) 355-9910 www.intrua.com March 31, 2025 This Brochure provides information about the qualifications and business practices of Intrua Financial. If you have any questions about the contents of this Brochure, please contact us at (713) 355-9910 or via email at team@intrua.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. Intrua Financial, LLC (“Intrua”) is a registered investment adviser with the U.S. Securities and Exchange Commission. Registration of an Investment Advisor does not imply any level of skill or training. This brochure has not been approved or verified by the Securities and Exchange Commission or by any state securities authority. The oral and written communications of an Advisor provide you with information that you may use to determine whether to hire or retain them. Additional information about Intrua is also available on the SEC’s website at www.advisorinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Intrua is 281554. The SEC’s website also provides information about any persons affiliated with Intrua who are registered, or are required to be registered, as Investment Advisor Representatives of Intrua. Intrua ADV Part 2A Page 1 of 35 A  Item 2 – Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 29, 2024, we have amended this Brochure to disclose that our firm’s clients may be invested in, or solicited to invest in, various private equity funds that are sponsored and/or managed by our Larson Capital Management, LLC, an SEC registered investment adviser affiliated with our firm under common control and ownership. Our firm is deemed to have custody over those client assets that invest in these affiliated fund(s) sponsored and/or managed by Larson Capital Management. Please refer to Items 10, 11, and 15 of this Brochure for more information. If you have any questions about these changes, please contact our office and ask to speak with the Chief Compliance Officer. Any material conflicts of interest between you and our firm, or our employees are disclosed in this Disclosure Brochure. If at any time additional material conflicts of interest develop, we will provide you with written notification of the material conflicts of interest or an updated Disclosure Brochure Intrua ADV Part 2A Page 2 of 35  Item 3 – Table of Contents Item 2 – Material Changes .................................................................................................................. 2 Item 3 – Table of Contents .................................................................................................................. 3 Item 4 – Advisory Business Introduction .............................................................................................. 5 Our Advisory Business ........................................................................................................................... 5 Services .................................................................................................................................................. 5 Asset Management ........................................................................................................................ 6 Held Away Account Services .......................................................................................................... 8 Third Party Money Managers ........................................................................................................ 8 Financial Planning/Consulting ........................................................................................................ 9 Qualified Retirement Plan Advisory Services ............................................................................... 10 Other Services .............................................................................................................................. 12 ERISA ............................................................................................................................................ 12 Non-Discretionary 3(21) Fiduciary Services ................................................................................. 13 Assets Under Management ................................................................................................................. 14 Item 5 – Fees and Compensation ...................................................................................................... 14 Asset Management Fee Schedule ................................................................................................ 14 Held Away Account Services ........................................................................................................ 15 Third Party Money Managers ...................................................................................................... 16 Financial Planning/Consulting Fees ............................................................................................. 18 Qualified Retirement Plan Advisory Fees .................................................................................... 19 Third-Party Fees ........................................................................................................................... 19 Other Compensation ................................................................................................................... 19 Item 6 – Performance-Based Fee and Side by Side Management ........................................................ 20 Item 7 – Types of Client(s) ................................................................................................................. 20 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ............................................... 20 Methods of Analysis ............................................................................................................................ 20 Fundamental Analysis .................................................................................................................. 21 Modern Portfolio Theory (MPT) .................................................................................................. 21 Technical Analysis ........................................................................................................................ 21 Cyclical Analysis ........................................................................................................................... 21 Investment Strategies .......................................................................................................................... 21 Risk of Loss .......................................................................................................................................... 22 Item 9 – Disciplinary Information ...................................................................................................... 26 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 26 Intrua ADV Part 2A Page 3 of 35  Other Financial Industry Affiliations .................................................................................................... 27 Selection of Other Advisors ................................................................................................................. 28 Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ................. 28 General Information ............................................................................................................................ 28 Participation or Interest in Client Accounts ......................................................................................... 28 Personal Trading .................................................................................................................................. 28 Privacy Statement................................................................................................................................ 29 Conflicts of Interest ............................................................................................................................. 29 Item 12 – Brokerage Practices ........................................................................................................... 30 Factors Used to Select Custodians ....................................................................................................... 30 Soft Dollars .......................................................................................................................................... 30 Best Execution ..................................................................................................................................... 31 Brokerage for Client Referrals ............................................................................................................. 31 Directed Brokerage .............................................................................................................................. 31 Trading ................................................................................................................................................. 31 ERISA 3(21) .......................................................................................................................................... 31 Best Execution ............................................................................................................................. 32 Trading ......................................................................................................................................... 32 Item 13 – Review of Accounts ........................................................................................................... 32 Reviews ................................................................................................................................................ 32 Review Triggers ................................................................................................................................... 32 Reports ................................................................................................................................................ 32 Item 14 – Client Referrals and Other Compensation ........................................................................... 33 Item 15 – Custody ............................................................................................................................ 33 ERISA 3(21) .......................................................................................................................................... 34 Item 16 – Investment Discretion ....................................................................................................... 34 Individual Managed Accounts ............................................................................................................. 34 Qualified Retirement Plans .................................................................................................................. 35 ERISA 3(21) .......................................................................................................................................... 35 Item 17 – Voting Client Securities ...................................................................................................... 35 Item 18 – Financial Information ........................................................................................................ 36 Item 19 – Requirements for State Registered Investment Advisors ………………………………………………………………36 Item 20 – Additional Information ……………………………………………………………………………………………………………….36 Class Action Lawsuits .......................................................................................................................... 36 Intrua ADV Part 2A Page 4 of 35  Item 4 – Advisory Business Introduction Our Advisory Business Intrua (“we”, “us”, “our”) is a Registered Investment Advisor (“Advisor”) which offers investment advice regarding securities, insurance, and other financial services to our clients. We are registered through and regulated by the United States Securities and Exchange Commission (“SEC”). We are a wholly owned subsidiary of Larson Financial Holdings, LLC (“LFH”). We provide investment advice through Investment Advisor Representatives (“IAR”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all advisors are required to have a college degree, professional designation, or equivalent professional experience. the IAR considers the client’s individual objectives, time horizons, risk tolerance, liquidity needs, and overall portfolio, among other characteristics to help them establish specific goals and objectives. The client's prior investment history, family composition and background are also taken into consideration. During the data-gathering process, a portfolio strategy is chosen for implementation and management. Intrua is owned by Larson Financial Holdings, LLC (“LFH”). We provide portfolio 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. Our minimum account opening balance is $10,000, which may be negotiable based upon certain circumstances. We also provide consulting and advisory services for employer-sponsored retirement plans in accordance with the Employee Retirement Income Security Act (“ERISA”). The services provided are ERISA 3(21) fiduciary services on a non-discretionary basis for ERISA 3(21) accounts. When delivering ERISA services, we will perform these services for the retirement plan as a fiduciary under ERISA Section 3(21)(A)(ii) will act in good faith and with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. We are committed to being involved beyond expected and to providing comprehensive strategies and expertise to our clients. 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. Tess Koncick, our Chief Compliance Officer, and other designated persons, will administer the policies and procedures to oversee adherence to the Investment Advisers Act and related rules and regulations. Services We provide various asset management, financial planning, and retirement plan advisory services. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We do participate in a wrap fee program. Please refer to ADV Part 2A Appendix 1 Wrap Fee Brochure. Intrua ADV Part 2A Page 5 of 35  Asset Management Asset management is the professional management of securities (stocks, bonds, and other securities) 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, equity options, futures, 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 quarter or annual account reviews. These reviews will be conducted in person, by telephone 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, and will rebalance portfolios 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 have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks, or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. Intrua ADV Part 2A Page 6 of 35  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 it is not suitable for the current recommended investment strategy. 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. We can also work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. We will create a formal IPS and deliver it to you upon completion. We use your specific investment objectives and goals to create your customized IPS. We will create a formal IPS and deliver it to you upon completion. 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. Intrua Financial recommends that our clients use LPL Financial LLC (“LPL”) or Charles Schwab & Co., Inc. (“Schwab”); all are FINRA-registered broker- dealers, member SIPC, as a qualified custodian. You will enter into a separate custodial agreement with the custodian which authorizes the custodian to take instructions from [us/you] 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. 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: • Securities to be bought or sold for your account • Number of securities to be bought or sold for your account • Broker-dealer to be used for a purchase or sale of securities for your account • Commission rates to be paid to a broker or dealer for your securities transaction. 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 Intrua ADV Part 2A Page 7 of 35  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 tax planning. We are available during normal business hours either by telephone, fax, email, or in-person by appointment to answer your questions. Held Away Account Services We provide an additional service for accounts not directly held in our custody but where we do have discretion and may leverage an Order Management System to implement asset allocation or rebalancing strategies on behalf of the client. These are primarily 401K accounts, 529 plans, variable annuities, and other assets we do not custody. We regularly review the current holdings and available investment options in these accounts, monitor the accounts, rebalance and implement our strategies as necessary. In cases where the client chooses to have Intrua advise on assets that are not held at a qualified custodian in which Intrua has an advisory relationship, Intrua can provide investment management services of those held-away accounts through a third-party portfolio management provider, FeeX. Such accounts will be studied, analyzed, allocated, monitored, managed, tactically adjusted, and rebalanced when necessary and periodically reviewed by the Firm in detail on behalf of the Client, taking into account the Client’s evolving individual circumstances, goals, and objectives. Access to held away accounts is achieved by the Client permitting via a provided link through FeeX for the Firm to make asset allocation changes via the Client’s online login credential. These online credentials are never made available to, or held, or stored by Intrua. Access is restricted and the Firm will only have permissions to make changes to the allocation of funds or other securities in the account and will not at any time be able to adjust, add to or subtract from investment options, or any other plan policies or fees assessed by the plan or the fund providers, access the financial assets in the account, make deposits, withdrawals or distributions. The assets will be monitored by the IAR and the investment management team to insure the portfolio adherence to the investment objectives and risk tolerances of the Client. These assets are included in calculating the total assets under management when assessing the annual advisory fee. Third Party Money Managers We may determine that opening an account with a professional third-party money manager is in your best interests. We utilize the services of LPL Financial LLC (“LPL”), SEI Investments and City National Rochdale, as third-party money managers. 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 the 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 Intrua ADV Part 2A Page 8 of 35  • 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 will receive a separate Form ADV Part 2 from the third-party money manager that discusses how its fees and expenses are paid and your relationship with them. The third-party money manager fees may be separate from our fees and vary based on the total client assets we have invested. These fees are separately charged to advisory clients. All fees are disclosed in the Client Agreement and displayed on quarterly statements. 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 and ask us any questions you may have. Please refer to the ADV Part 2A Appendix 1 for LPL, SEI Investments and City National Rochdale for a complete description of the services offered through these third-party money managers. Financial Planning/Consulting We provide services such as comprehensive financial planning, estate planning, business planning, and educational planning. Fee-based financial planning is a comprehensive relationship that incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning 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 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, or other relevant documents. 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. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. Intrua ADV Part 2A Page 9 of 35  Ongoing Financial Planning This service involves working one-on-one with a planner over an extended period of time. By paying a fixed quarterly fee, Clients will work with a planner who will walk them through developing and implementing their financial plan. The planner will monitor the plan and its implementation regularly, recommend any changes and ensure the plan remains up to date. Upon desiring a comprehensive plan, a Client will be taken through establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefit, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the Client. Clients subscribing to this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. We will schedule additional meetings throughout the year at the Client's convenience. The plan and the Client's financial situation and goals will be monitored throughout the year and, in addition to meetings, follow-up phone calls and emails will be made to the Client to confirm that any agreed upon action steps have been carried out. On at least an annual basis, there will be a full review of this plan to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time. Qualified Retirement Plan Advisory Services Plan sponsors are increasingly looking for an investment advisor to help shoulder fiduciary responsibilities. Under a 3(21)-fiduciary advisory arrangement Intrua will assist in the recommendation of investments to plan sponsors, monitor the selected investments to ensure performance, provide participant education, and provide guidance throughout the fiduciary process. As an ERISA Section 3(21) fiduciary, Intrua does not have the authority to make and implement fiduciary decisions for the plan. Our recommendations relieve plan sponsors of some of the liability associated with their investment decisions, when the decisions are based on our advice. This allows for the plan sponsor/trustee to retain ultimate decision- making authority for investments and may accept or reject the recommendations. The plan sponsor is responsible for the selection and monitoring of the 3(21)- investment manager and implementation of any of the 3(21) investment manager’s investment recommendations and assumes responsibility and liability for any overriding decisions made by the plan sponsor. The plan sponsor will have the opportunity to meet with us periodically to review the plan strategies. The data used to determine the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indexes that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indexes, and general market conditions. Before a specific Intrua ADV Part 2A Page 10 of 35  investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. We have the responsibility and authority to determine the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds that may be retained or replaced. We also encourage you to consult with your other professional advisors since we do not provide legal advice that may affect asset classes or allocations used in the modeling. We will apply guidelines you supply, as directed, however, compliance with these restrictions or guidelines is your responsibility. We will assist you in creating a written investment policy statement (“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals. We will assist with the establishment, execution, and interpretation of the Investment Policy Statement. The Investment Policy Statement serves as a guide to assist in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile various factors for the account such as investment objectives, risk tolerances, projected cash flow, and demographics of your retirement plan participants. It is your responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. We recommend that your professional advisors, such as an attorney, actuary, and/or accountant, also review the IPS. Upon your final approval, it is our responsibility to adhere to the IPS in managing the retirement program. We encourage you to review accounts periodically to verify our compliance with the IPS. The Investment Policy Statement will be reviewed at least annually to determine whether stated investment objectives are still relevant and the continued feasibility of achieving those objectives. However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will not be updated to account for short-term changes in market conditions or the economic environment. We will also monitor the current managed investment allocations including the investment’s performance compared to an applicable benchmark. If we determine that a fund no longer meets our criteria, we will select possible alternatives and assist in the selection of a replacement investment. If you decide to implement any of our recommendations, we will help you open a custodial account(s) for the plan. The funds in your account will be held in a separate account, in the plan’s name, with an independent custodian, not with us. We use a custodian for the plan. The custodian will affect transactions, deliver securities, make payments, etc. We may conduct plan participant meetings when a change is made either to the structure of the plan or if the investment lineup changes as a result of our decisions. We will detail the changes being made, how they affect the current participants, review the current investment opportunities, how participants may make changes to their investment selections, and will answer any questions a participant may have. We will review with the participants how to select the investments. Intrua ADV Part 2A Page 11 of 35  Other Services We may recommend and sell life, disability, health, and long-term care insurance. We will receive the usual and customary commissions associated with these sales from the insurance company. You will not pay a separate fee for these, and your advisory fee will not be reduced by any payments we receive from these sales. ERISA Both parties acknowledge that if the Account is subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA), the following provisions will apply: • The Advisor acknowledges that it is a “fiduciary” with respect to the Client as that term is defined under Section 3(21)(A) of ERISA. • The person signing this Agreement on behalf of the Client acknowledges its status as a “named fiduciary” with respect to the control and management of the assets held in the Account, and agrees to notify the Advisor promptly of any change in the identity of the named fiduciary with respect to the Account; • The Advisor agrees to obtain and maintain an ERISA bond satisfying the requirements of Section 412 of ERISA and include the Advisor and its members, agents, and employees among those insured under that bond. The Client confirms that any instructions that have been given to the Advisor with regard to the Account are consistent with the governing plan documents and investment policy statements of the plan. Except as otherwise provided under ERISA the Advisor shall not be liable for any error of judgment or mistake of law or for any loss suffered by the Client in connection with the matters to which this Agreement relates except a loss resulting from the Advisor’s breach of its fiduciary duty, negligence, misconduct or bad faith. The Advisor is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended (the “Code”); The Advisor is neither a law firm nor a public accounting firm and Advisor will not provide legal or accounting advice; The Client acknowledges that the services covered by this Agreement are consultative and give no investment authority (“discretion”) or responsibility to the Advisor over any assets of the Plan or Participant regardless of how and where the assets are held. Throughout the term of this Agreement, the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held with any affiliated or unaffiliated third party. Intrua understands and attests that they are an ERISA fiduciary as defined in the Fiduciary Rule under the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1986. Intrua adheres to the Impartial Conduct Standards (including the “best interest” standard, reasonable compensation, and no misrepresented information), as a condition for relying upon the Best Interest Intrua ADV Part 2A Page 12 of 35  Contract Exemption and the Class Exemption for Principal Transactions in Certain Assets Between Investment Advice Fiduciaries and Employee Benefit Plans and IRA during the transition period from June 9, 2017, through January 1, 2018. This relates to all ERISA accounts including Individual Retirement Accounts (IRAs). The Advisor provides advisory services, which include providing retirement Plan Sponsors or other plan fiduciaries (“Plan Sponsors”) investment advisory and management services by assisting plans in establishing and/or maintaining a consistent and ongoing documented process of prudent oversight and due diligence. The Advisor provides services to clients that sponsor a retirement plan that is qualified under the Internal Revenue Code of 1986, as amended (the “IRC”) and/or subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Services may include benchmarking, plan design strategies, analysis, fiduciary consulting and oversight, plan-level investment advice and investment fund selection and monitoring services, and some employee education services. The Advisor does not act as, and has not agreed to assume the duties of, a Plan trustee or the “Plan Administrator,” as defined under section 3(16) of ERISA nor as trustee as described by SEC Rule 206(4)-2. The Advisor has no discretion to interpret the Plan documents, to determine eligibility or participation under the Plan, to provide participant disclosures or communications, to ensure contributions are timely received by the Plan or to exercise any other action with respect to the management, administration, or any other aspect of the Plan. The Advisor’s services are offered to assist plan fiduciaries as they carry out their investment-related responsibilities and these services should not substitute for or diminish the careful deliberation and determination of plan fiduciaries, after appropriate consultation with their other professional advisors and the review of relevant plan documentation. Non-Discretionary 3(21) Fiduciary Services When the Advisor performs “3(21) Fiduciary Services,” the Advisor will act as a co-fiduciary “investment advisor” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this arrangement, the Advisor is appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Advisor will not have any further responsibility to communicate instructions to any third-party, including the custodian, and/or third-party administrator. The Advisor will not communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Advisor’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. The Advisor will provide the Plan Sponsor with a sample investment policy statement. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the Advisor’s investment advisory services. The Advisor offers the following 3(21) services: Investment screening • • The selection of replacement funds to which existing Plan balances may be transferred Intrua ADV Part 2A Page 13 of 35  • Assisting clients to finalize a Plan’s investment lineup of funds available for investment by Plan participants and used for other administrative purposes under the Plan • Assisting clients with electing a “qualified default investment alternative” as defined in section 404(c)(5) of ERISA • Quarterly plan review meetings – including review of Investment Funds In the Advisor’s capacity as a 3(21) plan fiduciary, they will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Advisor has the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. Assets Under Management As of December 31, 2024, we provided asset management services for 7,575 accounts, managing total assets of approximately $1,760,400,000. Of which approximately $1,372,500,000 are in discretionary accounts and approximately $387,900,000 are in non-discretionary accounts. Item 5 – Fees and Compensation We provide asset management, financial planning, financial consulting, and qualified retirement plan consulting services for a fee. 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. Asset Management Fee Schedule Our minimum account opening balance is $10,000, which may be negotiable based upon certain circumstances. 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 monthly or quarterly billing period, in arrears. Fees are Intrua ADV Part 2A Page 14 of 35  prorated based on the number of days service is provided during each billing period. Payments are due and will be assessed on the last day of each period, based on the ending balance of the account under management for the preceding period and will not exceed 2.50%. For purposes of calculating Quarterly Account Fees, the account quarter will be based on the appropriate fee cycle. Fee cycles are as follows and will be based upon the date in which the client funds their account(s): Cycle 1 Cycle 2 Cycle 3 January February March April May June July August September October November December (Ending quarter balance * Annual Rate)*(Days of the billing period/365 Days) = Fee Charged Example: (Balance $100,000*1.25% Annual Rate)*(90 Days/365Days) = $308.22 Billing Cycle Fee. The fees shown above are annual fees and may be negotiable based upon certain circumstances. No increase 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 advisors 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. 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., variable annuities, mutual funds, 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 end of the period. This fee will show up as a deduction on your next account statement from the custodian. Held Away Account Services For Intrua’ s services provided to Held Away Accounts (accounts with Custodians other than our primary approved custodians), Intrua will be paid a management fee referenced in Appendix A of their Investment Advisory Agreement, based on the market valuation of the Client’s Account. The fee will be calculated and billed quarterly in arrears when Client funds or securities have been deposited to the managed account. Fees are prorated based on the number of days service is provided during each billing period. Client Acknowledges that for the Held Away Accounts set for on Appendix A to the Intrua ADV Part 2A Page 15 of 35  Investment Advisory Agreement, FeeX Inc. allows the Firm to be able to service the Held Away Accounts and will retain a portion of the fee collected by Intrua. Third Party Money Managers LPL Financial, LLC LPL fees for discretionary investment advisory services are based upon a percentage of all assets in the account, including assets for which we do not exercise investment discretion or investment oversight, in accordance with the agreed upon fee schedule. LPL fees are billed quarterly in advance based upon the previous quarter-end account values. Fees billed by LPL, or any third party retained by us for clients will be deducted from account assets. Fee percentages and minimum fees are subject to negotiation. Annual fees do not include fees for non-standard services or transaction costs for individual securities or other services offered by us. You will receive a separate Form ADV Part 2 from LPL that discusses how its fees and expenses are paid and your relationship with them. LPL’s fees may be separate from our fees and vary based on the total client assets we have invested at LPL. These fees are separately charged to advisory clients. All fees are disclosed in the Client Agreement and displayed on quarterly statements. 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 and ask us any questions you may have. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. The advisor will assist the client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages a client’s assets on a discretionary basis. The advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. The advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Intrua ADV Part 2A Page 16 of 35  Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisors will also have discretion for selecting third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. The Advisor will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although Intrua will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and Intrua by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or Intrua, do not enter into an advisory agreement with LPL, FutureAdvisor or Intrua Financial, do not Intrua ADV Part 2A Page 17 of 35  receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. SEI Investments Intrua participates in the Separately Managed Accounts Program (the Program) sponsored by SEI Investments Management Corporation (SIMC). To participate in the Program, Intrua, SIMC and each client execute a three-party agreement (hereinafter, a Managed Account Agreement) providing for the management of certain investor assets in accordance with the terms thereof. By means of the Managed Account Agreement, the client appoints Intrua as its investment advisor to assist the client in selecting an asset diversification strategy, which includes allocating a percentage of client assets to designated portfolios of separate securities (each, a Separately Managed Account Portfolio) and which may include a percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate of SIMC. The client appoints SIMC to manage the assets in each Separately Managed Account Portfolio in accordance with a strategy selected by the client together with Intrua. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. Please refer to SIMC’s ADV Part 2 disclosure brochure for a full description of fees. Please refer to the ADV Part 2A Appendix 1 for LPL SEI Investments and City National for a complete description of the fees charged by these third-party money managers. Financial Planning/Consulting Fees In addition to Asset-based fees, Intrua can charge hourly fees for the development of wealth management plans, written financial plans, or consultations at an hourly rate not to exceed $250. Intrua may also provide a comprehensive financial plan for a fixed fee of $250 to $35,000, which may be negotiable depending upon the nature and complexity of the client's circumstances. These fees are negotiable and agreed to in writing and paid by the Client before or after services have been delivered or 50% before and 50% after delivery. Ongoing Financial Planning Annual flat fees are negotiable, pro-rated and paid in arrears on a monthly or quarterly basis. The monthly fee is then determined by dividing the annual fee by twelve. These fees will be deducted through our service AdvicePay from either your credit card or your bank account. Qualified Retirement Plan Advisory Fees Our standard fee includes establishing your Investment Policy Statement, reviewing your plan structure, investment management, investment selection and monitoring, fund changes, participant education and reporting. The fee will be outlined in your Advisory Agreement (see Appendix A of the Advisory Agreement) with us. These are paid per the fee schedule of the individual plan sponsors. Some may pay quarterly in arrears or in advance and some may pay monthly in arrears or in advance. Intrua may also provide our retirement plan advisory services for an hourly fee of $250, which may be negotiable depending upon the nature and complexity of the client's circumstances. The advisory agreement the plan sponsor has with us will outline Intrua ADV Part 2A Page 18 of 35  exactly how the fees are charged and remitted to us. You may also incur fees related to your use of outside service providers including third-party administrators and record keepers. The fee schedule for each outside service provider varies dramatically from service provider to service provider. The service provider’s fees will also vary from plan to plan as each plan’s structure and characteristics are different from the next. We believe our services help plan sponsors and plan fiduciaries meet their fiduciary duty to the plan and its participants. As a part of our services, we review the fees of service providers and the transparency of their fees. We will assist the plan sponsors with a review of service providers including the third-party administrator, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive with alternatives that are available. 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. Compensation for the Sale of Securities or Other Investment Products Certain Executive officers and other Associated Persons of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by these persons are separate from and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by Associated Persons are intended to complement our advisory services. However, this practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance services. Clients who do choose to purchase insurance services Intrua ADV Part 2A Page 19 of 35  are under no obligation to use our licensed Associated Persons and may use the insurance brokerage firm and agent of their choice. Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. 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 portfolio management, financial planning, financial consulting, and retirement plan advisory services to individuals, high net worth individuals, trusts, estates, corporate pension, and profit-sharing plans, charitable organizations, trusts, foundations, endowments, corporations, trusts, small businesses, and churches. Additionally, the Advisor provides investment advisory services to the following types of clients: • Tax-qualified retirement plans (both defined benefit and defined contribution) that are intended to receive favorable tax treatment under section 401(a) or 403(b) of the Internal Revenue Code • Non-qualified executive deferred compensation plans • Other types of retirement plans that may be introduced to the Programs. Our minimum account opening balance is $10,000, which may be negotiable based upon certain circumstances. Intrua ADV Part 2A Page 20 of 35  Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis We use Fundamental Analysis, Modern Portfolio Theory, and Technical Analysis 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: 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 returns. Cyclical Analysis While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy. Intrua ADV Part 2A Page 21 of 35  Investment Strategies In order to perform this analysis, we use many resources, such as: • Morningstar • Thompson One • 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: 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 • Margin Transactions 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 bear. 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: Alternative Investment Risk Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • Loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices • Lack of liquidity in that there may be no secondary market for the fund and none expected to develop • Volatility of returns • Absence of information regarding valuations and pricing • Delays in tax reporting Less regulation and higher fees than mutual funds. • Intrua ADV Part 2A Page 22 of 35  Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields. 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. 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. Cyclical Analysis Risk Looking at market cycles in conjunction with other investment strategies can be useful when making investment decisions. However, market cycles are not always predictable. Each financial investment strategy has benefits and risks. Not every investment decision will be profitable, and there can be no guarantee of any level of performance. Exchange Traded Fund (“ETF”) Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a Intrua ADV Part 2A Page 23 of 35  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 variable 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 charge for withdrawals within a specified period, which can be as long as six to eight 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 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 Intrua ADV Part 2A Page 24 of 35  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 advisor 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. • 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. Intrua ADV Part 2A Page 25 of 35  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 will 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 Registered Investment Advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. There have been no disciplinary, legal, or regulatory events related to us or any of our management persons. Item 10 – Other Financial Industry Activities and Affiliations Neither Intrua nor any of its management persons are registered as a broker-dealer. Intrua does not have any pending applications to register as a broker-dealer. Intrua’s management persons are registered representatives of the broker-dealer, LPL Financial, LLC. Intrua and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor. LFH Subsidiary Subsidiary’s Primary Business Larson Financial Group, LLC ……………………………………………………………………………Registered Investment Adviser Larson Financial Securities, LLC .................................................................................... Registered Broker-Dealer Larson Capital Management, LLC................................................................................. Registered Investment Adviser Larson Tax Partners, LLC ................................................................................................. Accounting company Larson Commercial Real Estate, LLC, (f/k/a MedRealty, LLC)............................... Real Estate Brokerage Student Loan Professor, LLC (f/k/a Doctors Without Quarters, LLC) ............... Student loan advisory company Doctors Only, LLC (aka Larson Network Services) .................................................. Coordinates with other companies to provide shared “bac across the affiliate network Intrua ADV Part 2A Page 26 of 35  Clients are advised that Larson Capital Management, LLC (“LCM”), which registered as an investment advisor in 2019, sponsors and manages a series of private equity funds (the "LCM Funds"). While a non- LPL Financial, LLC IAR may discuss an LCM Fund or a Private Fund with an Intrua client, clients should understand that in doing so, the IAR is acting solely in his/her capacity as an IAR and not as a LPL Financial, LLC Registered Representative, and the IAR’s corresponding compensation resulting from recommending an LCM Fund or a Private Fund presents a conflict of interest. Therefore, any Intrua client investing in an LCM Fund or a Private Fund must execute an acknowledgment of such conflict, in addition to other conflicts of interest explained in the LCM Fund’s offering documents. Other Financial Industry Affiliations Intrua Financial, LLC is owned Larson Intrua Holdings, LLC. Larson Intrua Holdings LLC. is a subsidiary of Larson Financial Holdings, LLC. Larson Financial Holdings, LLC also has other subsidiaries in the financial industry. The following is each of the subsidiaries including the primary business description: Larson Financial Securities, LLC. (Registered Broker/Dealer), Larson Financial Group LLC (Registered Investment Advisor), Larson Capital Management LLC (Registered Investment Advisor), Larson Commercial Real Estate LLC (Real estate broker or dealer.). The services provided by these affiliated companies are separate and distinct from Intrua’s advisory services. To mitigate any appearance of conflicts of interest, the services, and clients of either firm will remain separate and distinct, and clients of either firm will not be solicited to receive services of the other. Some of our IARs are registered representatives of LPL Financial, LLC. They may recommend securities products that will pay them a commission through their broker-dealer relationship. When such recommendations or sales are made, a conflict of interest exists as the registered representatives may receive more commissions from the sale of these products than from providing you with advisory services. We require that all IARs disclose this conflict of interest when such recommendations are made. We also require IARs to disclose to clients that they may purchase recommended products from other representatives not affiliated with us. Our Code of Ethics requires our IARs to do what is in the client’s best interests. Our CCO or designee monitors all transactions to ensure that representatives put their clients first, not the commission they may receive. The broker-dealer also monitors all transactions to make certain they are suitable for the client. IARs may be licensed insurance agent/broker with various companies. IARs 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 IARs earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. Intrua ADV Part 2A Page 27 of 35  Affiliated Private Funds Our firm is affiliated under common control and ownership with Larson Capital Management, LLC (“LCM”), an SEC registered investment adviser. LCM is the sponsor and manager to various private equity funds and funds of funds (“Fund”). The Fund is exempt from registration under the Investment Company Act of 1940. Investors in the Fund must be (i) “accredited investors” within the meaning of Rule 501 of Regulation D under the 1933 Act and (ii) “qualified clients” as defined under the Investment Advisers Act of 1940. Client of the firm may be invested in or solicited to invest in the Fund. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s investment objectives, fees and expenses, risks, conflicts, valuation, and other important disclosures. Selection of Other Advisors Intrua 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 IARs 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 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 Intrua 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. Intrua ADV Part 2A Page 28 of 35  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. Participation or Interest in Client Transactions As noted above in Item 10, clients may be invested in or solicited to invest in the Fund. Clients should note that the recommendation of investments in the Fund creates a conflict of interest because our firm, our affiliates, and our Associated Persons have an incentive to recommend the affiliated Fund over funds that have no relationship with our firm for the purposes of generating additional revenue for the firm and for themselves. To address this conflict, we do not charge a separate portfolio management fee on the portion of client assets that is committed and uncalled to the affiliated Fund and that pays fees through the fund. Additionally, Associated Persons of the firm are required to uphold their fiduciary duties of always acting in our clients’ best interests. Intrua 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 Advisor selects; provided, however, that at any time that the Advisor has only one Access Person, he or she shall not be required to submit any securities report described above. We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading 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 IAR(s) of Intrua, unless the information is also available to the investing public on reasonable inquiry. 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. Intrua ADV Part 2A Page 29 of 35  Conflicts of Interest Intrua’s IARs may employ the same strategy for their personal investment accounts as it does for its clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security. 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. 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 LPL Financial or Charles Schwab as qualified custodians for their accounts when utilizing our asset management services. For the Held Away Accounts, Intrua does not have the ability to select the custodian. Soft Dollars LPL and/or Schwab and other third-party managers may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934 ("Exchange Act"). These research products and/or services will assist the IARs in their investment decision making process. Such research generally will be used to service all of the IAR’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 affect the same transaction where the IAR 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 advisor 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. Intrua mitigates these conflicts of interest through oversight of soft-dollar arrangements by the Chief Compliance Officer, or their designee, in order to assess whether the soft dollar benefits serve the best interests of the client. There may be other benefits from recommending LPL Financial, Schwab, 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. Intrua ADV Part 2A Page 30 of 35  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 Intrua may contract directly. Intrua may receive seminar expense reimbursements from product sponsors which may be based on the sales of products to their clients. Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Best Execution We have an obligation to seek the 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, reputation, 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 Clients are permitted/required to use the custodian of their choosing if the external custodian is approved by our preferred custodian, LPL Financial. Not all advisory firms permit you to direct brokerage. If you elect to select your own broker-dealer or custodian and direct us to use them, you may pay higher or lower fees than what is available through our relationships. Generally, we will not negotiate lower rates below the rates established by the executing broker-dealer or custodian for this type of directed brokerage account, unless we believe that such rate is unfair or unreasonable for the size and type of transaction. In all instances, we will seek the best execution for you. Trading Transactions for each client account generally will be affected 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 and 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 Intrua ADV Part 2A Page 31 of 35  disclosed in the respective mutual fund prospectuses and third-party manager disclosure documents which will be provided to you. ERISA 3(21) As it relates to ERISA Plan business, the Advisor’s model does not involve transactional business and, consequently, the Advisor does not currently engage brokers in any transactional capacity. Best Execution The Advisor does not trade in any Plan client accounts. Trading The Advisor does not trade in individual Plan participant accounts in which the Advisor is acting as a 3(21) co-fiduciary. Item 13 – Review of Accounts Reviews Reviews will be conducted at least annually. Generally, we will evaluate asset allocation, investment strategy and objectives, cash balance, and performance, changes and shifts in the economy, changes to the management and structure of an equity or company in which client assets are invested, and market shifts and corrections. Review Triggers We conduct periodic reviews to evaluate current market, economic and political events and how these may affect client accounts. Additional reviews may be triggered by these events or by events in the client’s financial or personal status. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Reports You will be provided with account statements reflecting the transactions occurring in your account at least quarterly. These statements may be written or electronic depending upon what you selected when you opened the account. You will be provided with confirmations for each securities transaction executed in the account. You are obligated to notify us of any discrepancies in the account(s) or any concerns you have about the account(s). Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during their plan reviews. Project-based financial planning and consulting clients are provided with a one-time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Retirement plan clients may create and/or review the plan’s Investment Policy Statement (“IPS”). The plan client may also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks set forth in the IPS or as otherwise determined in our judgment. The information used to generate the reports will be derived from statements provided by the plan fiduciary or third party. This review will include a quantitative and qualitative analysis of investment selections included within the plan and provide third-party commentary on investment Intrua ADV Part 2A Page 32 of 35  options whenever available. Item 14 – Client Referrals and Other Compensation We do have compensation agreements with TPMM’s (e.g., SEI Investments, and City National Rochdale), we receive compensation based on the service they provide to our clients. Any such compensation arrangement will be formalized in an agreement and disclosed to our clients. Please see Item 4 for more information regarding the services that they provide. We may occasionally pay a referral fee to third party solicitors. However, no fee is paid unless we have a signed and executed solicitor agreement. You must sign a disclosure form that contains the details of the referral agreement. Our fiduciary duties still apply to referral relationships, and we must put the interest of our clients first and see the best execution of securities transactions on behalf of our clients. Economic Benefits Received from Vendors and Product Sponsors Occasionally, our firm and our Associated Persons will receive additional compensation from vendors. Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event; reimbursement in connection with educational meetings with an Associated Person, reimbursement for consulting services, client workshops, or events; or marketing events or advertising initiatives, including services for identifying prospective clients. Receipt of additional economic benefits presents a conflict of interest because our firm and Associated Persons have an incentive to recommend and use vendors based on the additional economic benefits obtained rather than solely on the client’s needs. We address this conflict of interest by recommending vendors that we, in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation contractually or otherwise, to use any of the vendors recommended by us. Item 15 – Custody Client funds and/or securities (assets) are held at qualified custodians. We use LPL Financial and/or Charles Schwab as the custodian and/or broker-dealer for all your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements and compare this official custodial record to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. If you notice any discrepancies, please contact Intrua. We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees and to pay them to us. You authorized the custodian to pay us directly at the onset of the relationship. Our firm is deemed to have custody of certain client assets where those clients have invested in a Fund where our firm’s affiliates and/or related persons serve as the General Partner or Manager to the Fund and therefore have access to the investments in the Fund. As required by SEC rules and in conformity with industry practice, the Fund is subject to an audit at least annually and distributes its audited financial Intrua ADV Part 2A Page 33 of 35  statements prepared in accordance with generally accepted accounting principles to all respective Fund investors. Also, as required, the audits are conducted by an independent public accountant that is registered with the Public Company Accounting Oversight Board in accordance with its rules. Our firm is also deemed to have custody of client assets where it has fee deduction authority granted by the client in the advisory agreement and in certain situations where we accept standing letters of authorization from clients to transfer assets to third parties. We maintain safeguards in accordance with regulatory requirements regarding custody of client assets. Clients will receive account statements at least quarterly from the broker-dealer or other qualified custodian holding their assets. Clients are urged to review custodial account statements for accuracy. ERISA 3(21) If authorized by the Plan Sponsor, the Advisor has the ability to debit fees directly from the Plan Sponsor’s bank account through the submission of a billing file to the plan custodian, however, the Advisor does not have authority to possess or take actual custody of clients’ funds or securities. Plan Sponsors and plan participants should receive at least quarterly statements from the recordkeeper, and Plan Sponsors; participants should carefully review such statements. Item 16 – Investment Discretion Individual Managed Accounts We usually receive discretionary authority from you at the beginning of an advisory relationship to select the identity and number 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 tax laws that require diversification of investments and favor the holding of investments once made. 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. If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, whether the security should be bought or sold before implementing changes in your account. Qualified Retirement Plans Our recommendations regarding our retirement plan advisory services are made on a non-discretionary basis. The plan sponsor retains the decision-making authority over the plan. When recommending Intrua ADV Part 2A Page 34 of 35  securities, we observe the investment policies, limitations, and restrictions set by the plan and plan sponsor. ERISA 3(21) As further described in Item 4 above, under 3(21) Fiduciary Services, the Advisor exercises limited discretion over Plan assets in that it makes investment recommendations to Plan Sponsors, but the Plan Sponsor may or may not implement the recommendation(s). 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. The custodian will 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 twelve hundred dollars and more than six months in advance of advisory services rendered. Item 19 – Requirements for State Registered Investment Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 – Additional Information Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. Intrua ADV Part 2A Page 35 of 35 

Intrua Financial 3737 Buffalo Speedway, Ste. 400 Houston, TX 77098 (713) 355-9910 www.intrua.com Form ADV Part 2A Appendix 1 Wrap Fee Brochure March 31, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Intrua Financial. If you have any questions about the contents of this Brochure, please contact us at 713-355-9910 or team@intrua.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Intrua Financial 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 Intrua Financial is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as CRD number. The CRD number for Intrua Financial is 281554. The SEC’s web site also provides information about any persons affiliated with Intrua Financial who are registered, or are required to be registered, as Investment Adviser Representatives of Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 1 of 26 Intrua  Item 2 – Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 29, 2024, we have amended this Brochure to disclose that our firm’s clients may be invested in, or solicited to invest in, various private equity funds that are sponsored and/or managed by our Larson Capital Management, LLC, an SEC registered investment adviser affiliated with our firm under common control and ownership. Our firm is deemed to have custody over those client assets that invest in these affiliated fund(s) sponsored and/or managed by Larson Capital Management. Please refer to Item 9 of this Brochure for more information. If you have any questions about these changes, please contact our office and ask to speak with the Chief Compliance Officer. Any material conflicts of interest between you and our firm, or our employees are disclosed in this Disclosure Brochure. If at any time additional material conflicts of interest develop, we will provide you with written notification of the material conflicts of interest or an updated Disclosure Brochure. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 2 of 27  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................ 1 Item 2 – Material Changes .................................................................................................................. 2 Item 3 – Table of Contents .................................................................................................................. 3 Item 4 – Services, Fees and Compensation ........................................................................................... 5 General Description of Primary Advisory Services................................................................................. 5 Financial Planning .................................................................................................................................. 5 Asset Management ................................................................................................................................ 5 Use of Third-Party Money Managers..................................................................................................... 5 Investment Management Services ........................................................................................................ 6 Portfolio Rebalancing ............................................................................................................................ 6 Arrangement with LPL Financial and Recommendation of LPL Financial Programs .............................. 7 Products and Services Available to Us from Charles Schwab & Co., Inc. ............................................... 7 Products and Services Available to Us from Fidelity Investment Company .......................................... 9 Advisory Services Tailored to Individual Needs of Clients ................................................................... 10 Wrap-Fee Program versus Portfolio Management Program ............................................................... 10 Wrap Fee Program............................................................................................................................... 10 Investment Strategies and Method of Analysis ................................................................................... 10 Third-Party Managed Account Programs ............................................................................................ 15 Item 5 – Account Requirements and Types of Clients ......................................................................... 20 Item 6 – Portfolio Manager Selection and Evaluation ......................................................................... 20 Portfolio Managers .............................................................................................................................. 20 Advisory Business ................................................................................................................................ 20 Performance-Based Fees and Side-by-Side Management ................................................................... 21 Methods of Analysis, Investment Strategies and Risk of Loss ............................................................. 21 Methods of Analysis .................................................................................................................... 21 Fundamental Analysis ........................................................................................................................ 21 Modern Portfolio Theory (MPT) ..................................................................................................... 21 Technical Analysis ............................................................................................................................... 21 Targeted Asset Allocation ................................................................................................................. 22 Cyclical Analysis ................................................................................................................................... 22 Investment Strategies .................................................................................................................. 22 Risk of Loss ................................................................................................................................... 22 Voting Client Securities ........................................................................................................................ 23 Item 7 – Client Information Provided to Portfolio Managers .............................................................. 23 Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 3 of 27  Item 8 – Client Contact with Portfolio Managers ................................................................................ 23 Item 9 – Additional Information ........................................................................................................ 23 Disciplinary Information ...................................................................................................................... 23 Other Financial Industry Activities and Affiliations .............................................................................. 23 Other Financial Industry Affiliations .................................................................................................... 23 Review of Accounts ............................................................................................................................. 26 Client Referrals and Other Compensation ........................................................................................... 26 Financial Information ........................................................................................................................... 26 Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 4 of 27  Item 4 – Services, Fees and Compensation Intrua Financial “Intrua” is a Registered Investment Adviser (“Adviser”) with the U.S. Securities and Exchange Commission ("SEC") and offers investment advisory services including financial planning and consulting, asset management, and referrals to third-party money managers. Intrua provides investment advice through the Investment Adviser Representatives (“IAR”) associated with Intrua. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. General Description of Primary Advisory Services The following are brief descriptions of our primary services. A detailed description of our services is provided in Item 4 – Services, Fees and Compensation so that clients and prospective clients can review the services and description of fees in a side-by-side manner. Financial Planning Intrua offers advisory services in the form of financial planning services. Financial planning services do not involve the active management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long- term financial goals, through investments, tax planning, asset allocation, risk management (i.e., insurance), retirement planning, and other areas. The role of a financial planner and/or the Intrua is to find ways to help the client understand their overall financial situation and help the client set and work toward their financial objectives. Asset Management Intrua offers advisory services in the form of asset management services. Asset management services involve providing clients with ongoing supervision over client accounts. This means we will continually monitor a client’s account and make trades in client accounts when necessary. Intrua generally manages client investments on a discretionary basis although the firm may provide non- discretionary investment management on a case-by-case basis. Use of Third-Party Money Managers Intrua offers advisory services by referring clients to outside, or unaffiliated, money managers that are registered or exempt from registration as investment advisors. Third-party money managers are responsible for continually monitoring client accounts and making trades in client accounts when necessary. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 5 of 27  Quantitative, momentum, and fundamental analysis The selection of mutual fund portfolios The selection of exchange-traded fund portfolios The selection of equities and fixed income investments The recommendation of asset allocations consisting of equities, fixed income, options, mutual Focus on long-term and short-term investment strategies Exchange-listed securities Securities traded over-the-counter Exchange-traded funds Corporate debt securities (other than commercial paper) Commercial paper Certificates of deposit Municipal securities Variable life insurance Variable annuities Mutual fund shares United States government securities Interests in partnerships investing in real estate, oil and gas Investment Management Services Investment Management Services include: • • • • • funds, and other general securities • Investment advice is limited to certain types of investments including: • • • • • • • • • • • • Intrua provides investment advice on interests in partnerships, investing in real estate, and oil and gas interests. Advice is provided through consultation services and is limited to review of the prospectus or the offering document to form an opinion as to the appropriateness of the investment for the client. Intrua does not include this portion of a client’s portfolio as managed assets and therefore does not charge a management fee on these investments. Intrua in certain cases, may utilize Unit Investment Trusts as part of the Investment Management Services and may charge a management fee or advisory fee on such assets. Intrua has an Investment Committee which meets regularly to evaluate products, performance, asset classes, etc., to determine if products should be added or removed from investment portfolios. The committees also discuss investment strategies and models. Minutes are kept of all meetings. Portfolio Rebalancing Each Investment advisor manages their portfolios to respond to changing capital market conditions and periodically rebalances the portfolios. Clients may change the portfolio type if their financial or life circumstances change. Intrua requests that clients provide such notification to their Intrua Financial Advisor as soon as practicable following any such changes. Intrua retains the discretionary authority to buy, hold, and sell investments in the client’s portfolio, which may include modifying portfolio allocations, and rebalancing client accounts back to their original client-authorized allocation. Rebalancing may also Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 6 of 27  occur when an Intrua Financial Advisor and/or the client give instructions to Intrua Investment Management Department to change the client’s target allocations or when a client makes additions to or withdrawals from their account(s). Arrangement with LPL Financial and Recommendation of LPL Financial Programs Intrua Financial Advisors may also be Registered Representatives of LPL Financial, LLC (“LPL”), which besides being a broker-dealer, is also an investment advisor registered with the U.S. Securities and Exchange Commission. However, all accounts and advisory services described in this brochure are through Intrua. The use of a direct or three-party agreement allows Intrua to offer LPL Financial Investment Advisory Platform accounts to Intrua clients. Intrua clients investing in LPL Financial Investment Advisory Platforms will be required to complete a three-party agreement between the client, Intrua and LPL Financial. A description of the advisory programs offered through the LPL Financial Investment Advisory Platforms is described in the LPL SWM/SWM II Account packet. The account packet is provided to any client or prospective client who is interested in or has utilized any of the available LPL Financial Investment advisory Programs. Products and Services Available to Us from Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. (“Schwab”) or Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Here is a more detailed description of Schwab’s support services: Services that Benefit the client. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit the client. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account • statements); Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 7 of 27  • facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • provide pricing and other market data; • facilitate payment of our fees from our clients’ accounts; and • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Technology, compliance, legal, and business consulting; • Publications and conferences on practice management and business succession; and • Access to employee benefits providers, human capital consultants and insurance providers. • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services: The availability of these services from Schwab benefits us because we do not have to produce or purchase them. Products and Services Available to Us from Fidelity Investment Company As custodian of your brokerage account, Fidelity, at direction of Intrua, is responsible for: • The executive, clearance, and securities transactions • Preparing and sending transaction confirmations and periodic statements of your account • The custody (or safekeeping), receipt, and delivery of funds and securities • The extension of margin credit upon approval As a registered Broker/Dealer, Fidelity is subject to the rules and regulations of the SEC, FINRA, and other exchanges of which Fidelity is a member, and the MSRB, Fidelity is also a member of the New York Stock exchange (“NYSE”) and SIPC. We are not a subsidiary of, or affiliated with Fidelity in any manner. We have sole responsibility for investment advice rendered, and advisory services are provided separately and independently from Fidelity. We participate in Fidelity Institutional Asset Management and FMR, LLC (“Programs”) for investment advisors. Our recommendation for you to custody your assets with Fidelity has no direct correlation or link between our participation in the Programs and the investment advice we offer you, although we do receive economic benefits through our participation in the Program that are typically not available to Fidelity retail clients. Many of these services generally may be used to service a substantial number, of our accounts. Fidelity also makes available other services intended to help us manage our business. These services may include: • Consulting, publications and conferences on practice management Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 8 of 27  Information technology • • Business succession • Regulatory compliance • Marketing In addition, Fidelity may make available, arrange and/or pay for these types of services rendered to us by independent third party providing these services to us. As a fiduciary, we endeavor to act in your best interest. Our recommendation that you maintain your assets in accounts at Fidelity may be based in part on the benefit to us in the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity. This may create a potential conflict of interest. Advisory Services Tailored to Individual Needs of Clients Intrua provides services based on the individual needs of the individual client. Therefore, you are given the ability to impose restrictions on your accounts, including specific investment selections and sectors. Wrap-Fee Program versus Portfolio Management Program Intrua may provide asset management services through a wrap-fee program in addition to the traditional management programs it offers. Under a wrap-fee program, advisory services and transaction services are provided for one fee. This is different from traditional management programs whereby services from Intrua are provided for a fee, but transaction services are billed separately on a per-transaction basis. From a management perspective, there is not a fundamental difference in the way Intrua would manage wrap-fee accounts versus traditional management accounts. The only significant difference is the way in which transaction services are paid. Wrap Fee Program We provide asset management services to individuals and businesses. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We currently provide our asset management services in investment programs that bundle or “wrap” services (investment advice, trade execution, custody, etc.) together and charge a single fee based on the value of assets under management. This is a program that allows us to create an investment model portfolio and manage it within your investment guidelines and financial parameters. This program enables you to pursue your investment objectives with us as manager all in one consolidated portfolio. We will serve as the investment adviser to manage only one asset class (e.g., large capitalization common stock portfolio or duration-limited fixed income portfolio) or one investment style from its investment product offering. In such an investment advisory relationship, the portfolio’s investment strategy is more limited by the specific product or investment style being sought by the client. The investments in the portfolio account may include mutual funds, stocks, bonds, ETFs, closed end funds, etc. Investment Strategies and Method of Analysis The Investment Advisors of Intrua 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. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 9 of 27  Based on the information you share with us; we will analyze your situation and recommend an appropriate Wrap Fee Program. You will be provided with a targeted strategic allocation of assets by class. We currently offer the following Wrap Fee Programs: Intrua and PEG – DSA Models The Investment Committee’s decision within the Intrua and PEG – DSA Models (collectively the “DSA Models”) will be based on the recommendations of DiMeo Schneider & Associates (“DiMeo”) and due diligence conducted by Intrua’s internal research analysts. The DSA Models are several different portfolio platforms that addresses the suitability over most of the client needs. These models will be focused on investing in Mutual Funds and Exchanged Traded Funds (“securities”) in order to achieve diversification in the overlying models. DiMeo conducts investment consulting for several investment advisers. They provide advice that is customized to Intrua’s (and its clients) needs, and goals. DiMeo provides Intrua due diligence and proprietary tools that are intended to improve the risk and returns of the Models. DiMeo’s investment insights will assist the Investment Committee on decisions on portfolio weighting and rebalancing in this dynamic market. However, DiMeo is a key tool for the DSA Models, the Investment committee is under NO OBLIGATION, to select or time the purchase/sales of securities that are recommended by DiMeo. Intrua’s research staff will continually monitor the underlying securities of the DSA Models. If a security does not maintain the risk and return requirements for the DSA Models, this will be reported to the members of the Investment Committee. The Investment Committee will determine the appropriate course of action, which may include reweighting the portfolio and/or removing the downgraded security(ies). The allocations of the DSA models will apply at the time a client establishes an account. Additions to and withdrawals from an account will generally be invested based on the suitable allocation. Fluctuations in the market value of the securities, as well as of the factors, however, will affect the actual asset allocation at any given time. Intrua will monitor the securities, in the portfolios and rebalance the allocations if those allocations exceed the predefined investment the range for the portfolio’s allocations. All models will reinvest dividends and capital gains distributions (if any) if the client does not provide instructions to hold such payments. Participation and Protection Models Intrua offers Participation and Protection Models (collectively the “P&P Models”) that will be based on the recommendations of the Q Consulting model and will be supervised by Intrua’s internal research analysts. The P&P Models are several different portfolio platforms that address the suitability over most of the client needs. These models will be focused on investing in various investment companies in order to achieve diversification in the overlying models. Models are defined by the levels of risk that are acceptable for the client with the max drawdown (tested by Monte Carlo simulations) being the differential factor. Q Consulting conducts investment consulting for several investment advisers. They provide advice that is customized to Intrua’s (and its clients) parameters. Q Consulting provides investment guidance with proprietary tools that are intended to improve the risk and returns of the Models. Q Consulting’s investment guidance will decide the portfolio weighting in this dynamic market. However, Q Consulting is Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 10 of 27  the deciding factor for the P&P Models, the Investment committee is under NO OBLIGATION, to select or time the securities that are recommended by Q Consulting. Intrua’s research staff will continually monitor the underlying securities of the P&P Models. If a security does not maintain the risk and return requirements for the P&P Models, this will be reported to the members of the Investment Committee. The Investment Committee will determine the appropriate course of action, which may include reweighting the portfolio or removing the downgraded security. The allocations of the P&P models will apply at the time a client establishes an account. Additions to and withdrawals from an account will generally be invested based on the suitable allocation. Fluctuations in the market value of the securities, as well as of the factors, however, will affect the actual asset allocation at any given time. Intrua will monitor the securities in the portfolios and rebalance the allocations if those allocations exceed the investment range (of 2% or more of the aggregated portfolio’s holdings) for the portfolio’s allocations. All models will reinvest dividends and capital gains distributions (if any) if the client does not provide instructions to hold such payments. Advisory Representative Account Programs Intrua, offers an Advisory Representative Account Program (“ARAP”) that is directed by the Investment Adviser Representatives. Rather than having guidance from a third party and Intrua’s Investment Committee, these programs will be directed by the client’s Investment Adviser Representatives. This will offer the client the opportunity to maintain investment authority within their account and delegate the level of investment discretion to their financial advisor. Intrua will provide the support services for client and financial advisers through the ARAP, such as establishing custodial service providers, initiating and/or adjusting pre-existing periodic investment and payment/disbursement plans, account inquiry services, billing and payment support, performance reporting, sales support, compliance oversight, educational/research opportunities, and other account maintenance services. The ARAP will provide the client with ongoing investment advise and monitoring of securities holdings by their Investment Adviser Representative. The Investment Adviser Representative will supervise their account on a discretionary basis, according to the client’s objectives. These accounts will be supervised by Intrua on a periodic basis to ensure that these portfolios comport with client suitability and the portfolio(s) guidelines. As part of our asset management services provided with our Wrap Fee Programs, we will: • Review your present financial situation • Monitor and track assets under management • Provide portfolio statements, 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 Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 11 of 27  • Build a risk management profile for you • Monitor our portfolios for style drift and benchmark performance, and provide portfolio rebalancing as necessary • Assist you in setting and monitoring goals and objectives • Provide personal consultations as necessary upon your request or as needed. You must notify us promptly when your financial situation, goals, objectives, personal circumstances, or needs change. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. 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 it is not suitable for the current recommended investment strategy. 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. Intrua manage assets on a discretionary basis, which means you have given us the authority to determine the following without your consent: • Securities to be bought or sold for your account • Number of securities to be bought or sold for your account • Broker-dealer to be used for a purchase or sale of securities for your account • Commission rates to be paid to a broker or dealer for your securities transaction. If you have not given us the authority to manage your account on a discretionary basis, then we cannot trade in your account without your express permission. 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 professional to assist you with tax planning. You will have the opportunity to meet with us periodically to review the assets in your account. 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 recommend LPL Financial or Schwab as the independent custodian for all accounts that we manage, and at the request of the client will utilize the services of a different custodian of the client’s choice if approved by the Intrua Financial Compliance team. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 12 of 27  You will also receive our Investment Advisory Agreement which describes what services you will receive and what fees you will be charged. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Fees and Compensation A wrap fee program allows you to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in your account. The fee is bundled with our costs for executing transactions in your account(s). Our minimum account opening balance is $15,000 which may be negotiable based upon certain circumstances. The fee charged is based upon the amount of money you invest, but maybe negotiated on a case-by-case basis. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged monthly or quarterly, in arrears. Fees will be calculated on the ending balance of the previous period, will be billed within the first two weeks of the period and will be calculated per the fee schedule negotiated fees may not exceed 2.50%. Fee Schedules For purposes of calculating quarterly Account Fees, for those participating in Strategic Wealth Management II Program (“SWM II”) the account period will be based on the appropriate fee cycle. Fee cycles are as follows and will be based upon the date in which the client funds their account(s): Cycle 1 Cycle 2 Cycle 3 January February March April May June July August September October November December For purposes of calculating Account Fees, for those participating in the Manager Access Select / Manager Access network (“MAS/MAN”), Model Wealth Portfolio (“MWP”) & Personal Wealth Portfolio (“PWP”) programs the account quarter will be based on Cycle 3 above. Our Advisory Account Application defines what fees are charged and their frequency whether monthly or quarterly. The fees shown above are annual fees and may be negotiable based upon certain circumstances. Fees for partial periods will be charged on a pro rata basis based on the number of days remaining in the billing period. No increase in the wrap fee shall be effective without prior written notification to you. We believe our wrap fee schedule is reasonable considering the fees charged by other investment advisers offering similar services/programs. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds. If the Wrap Fee Brochure is not delivered to the Client at least 48 hours prior to entering into the management agreement, the Client may terminate the agreement for services within five business days of execution without penalty. After the five-day period, either party, upon 30 days written notice to the Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 13 of 27  other, may terminate the management agreement. The management fee will be pro-rated for the month in which the cancellation notice was given, and any unearned fees will be returned to the client via check. You will authorize the custodian to directly debit fees from your account held at the custodian and to pay us. Management fees are prorated for each contribution and withdrawal made during the applicable calendar quarter (with the exception of small inconsequential contributions and withdrawals). You will be provided with a quarterly statement reflecting deduction of the advisory fees. By participating in a wrap fee program, Clients may end up paying more or less than they would through a non-wrap fee program. The relative cost of the program includes trade execution costs that would typically be passed directly through to the Client by the executing broker. Clients could invest in debt and equities directly, without the Adviser’s services. In that case, Clients would not receive the services provided by the Adviser which are designed, among other things, to assist in determining which funds are appropriate for the portfolio and the Client’s Account. In our wrap fee program, we include all trade charges for your account; however, our fees do not include other related costs and expenses. You may incur certain charges imposed by custodians, and other third parties. These include custodial fees, 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. 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. Since the Adviser does not charge Clients fees based on trading activity, the Adviser may have an incentive to limit trading activities in Client account(s) because the Adviser is charged for executing trades. In addition, the amount of compensation received by the Adviser may be more than what the Adviser would receive if the Client paid separately (“unbundled”) for investment advice, brokerage, and other services. Therefore, the Adviser may have a financial incentive to recommend the wrap fee program over other programs or services. The Adviser monitors all Client accounts to ensure that the Adviser’s fiduciary duty is met for all Clients. Any breaches of the Adviser’s fiduciary duty are noted, and appropriate repercussions are initiated to deter such behavior. Third-Party Managed Account Programs Intrua offers a variety of third-party manger programs. Under these programs, a third-party asset manager manages the client’s account. A description of the third-party manager programs and associated fees and compensation details are located below. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 14 of 27  identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion for selecting third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. [Advisor] will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 15 of 27  MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although [Advisor] will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and [Advisor] by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or [Advisor], do not enter into an advisory agreement with LPL, FutureAdvisor or Intrua Financial, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. SEI Investments Intrua participates in the Separately Managed Accounts Program (the Program) sponsored by SEI Investments Management Corporation (SIMC). To participate in the Program, Intrua, SIMC and each client execute a three-party agreement (hereinafter, a Managed Account Agreement) providing for the management of certain investor assets in accordance with the terms thereof. By means of the Managed Account Agreement, the client appoints Intrua as its investment advisor to assist the client in selecting an asset diversification strategy, which includes allocating a percentage of client assets to designated portfolios of separate securities (each, a Separately Managed Account Portfolio) and which may include a percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate of SIMC. The client appoints SIMC to manage the assets in each Separately Managed Account Portfolio in accordance with a strategy selected by the client together with Intrua. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. The Fee Schedule for the Separately Managed Accounts Program depends upon the nature of the securities in the portfolio and investment strategy as follows: • The fees payable for the Tier 1 Strategy, which includes the Tax Managed Core, Equity Core, Large Cap, Managed Volatility, Mid Cap, Multi-Strategy SMA, Global, Risk Regime, and International Developed Strategies, range from 0.90% to 0.65%. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 16 of 27  • The fees payable for the Tier 2 Strategy, which includes the Small Cap and Real Estate Strategies, range from 1.10% to 0.85% • The fees payable for the Tier 3 Strategy, which includes the International Emerging Strategy, range from 1.25% to 1.00% • The fees payable for the Tier 4 Strategy, which includes the Active Municipal Bond, Active U.S. Fixed Income, Active Preferred Stocks, Alternative Income, and Active Core Fixed Income, range from 0.65% to 0.45% • The fees payable for the Tier 5 Strategy, which includes the SEI ETF Strategies and the SEI Factor- Based Strategies, range from 0.55% to 0.20% • The fees payable for the Tier 6 Strategy, which includes the Laddered Strategies, range from 0.30% to negotiable Additionally, the SEI Program offers a feature called Automated Tax Management (ATM), formerly known as Integrated Managed Accounts Program (IMAP), which is an enhancement to the standard program. In ATM, SIMC appoints a tax overlay manager for the equity portion of the client’s Managed Account Portfolio. The various equity sub-advisors for the client’s portfolio provide buy/sell lists to the overlay manager, who then is responsible for executing the transactions (within the parameters of performance and security weighting variances from the underlying model portfolios), with the goal of increased coordination across the equity account, increased tax efficiency and minimization of wash sales. Neither the tax manager nor SIMC offers tax advice; clients should consult with their tax advisors as to the suitability of IMAP for their accounts. SIMC charges clients an integration fee when the client selects the IMAP feature. These additional fees apply only to the equity portion of a client’s account that is allocated to the integrated equities portfolio; the fees do not apply to the fixed income or mutual funds portion of the client’s account (if applicable). A selection of clients may receive a fee discount. These fees may be higher or lower than those charged by other investment advisors for similar services. SIMC pays a portion of this fee to the portfolio manager acting as the accounts’ integration manager. The fees payable for Integrated Managed Account Feature: • 0.10% in addition to the Tier fees described above SIMC may impose minimum account balances, which will typically vary between $50,000 to $250,000 depending upon the manager selected in the Managed Account Portfolio chosen and whether the client selects the ATM feature. To the extent a client’s assets in a Managed Account Program account are invested in SEI Funds, SIMC and its affiliates will earn fund-level fees on those assets, as set forth in the applicable Fund’s prospectus, but SIMC will waive the fees set forth above on Managed Account Program assets invested in any SEI Fund. Each SEI fund pays an advisory fee to SIMC that is based on a percentage of the portfolio’s average daily net assets, as described in the mutual fund’s prospectus. From such amount, SIMC pays the sub-advisor(s) to the fund. SIMC’s fee is negotiable, but it typically ranges from 0.10% to 1.50% of the portfolio’s average daily net assets for its advisory services. Affiliates of SIMC provide administrative, distribution and transfer agency services to all of the portfolios within the SEI Funds, as described in the SEI Funds’ registration statements. These fees and expenses are paid by the SEI Funds but ultimately are borne by each Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 17 of 27  shareholder of the SEI Funds. Clients may also pay custody fees to SEI Private Trust Company (SPTC) when SPTC has custody of their assets. These fees will vary depending on the account balance and trade activity in the account. Clients can refer to their account application for specific information on SPTC custody fees. SIMC investment advisory fees are calculated as a percentage of the market value of the client’s account assets. The fees are calculated and payable quarterly in arrears and net of any income, withholding or other taxes. The asset-based Intrua Fee & Compensation Schedule detailed in the Wrap Fee Program section includes the fees Intrua charges for its services in connection with SEI’s program. SEI Trust Company debits the client’s account on a quarterly basis for all of the above-mentioned fees and charges. The charges to the account are calculated and debited in arrears and are remitted quarterly net of any applicable account and performance reporting charges not charged to the customer. Upon written notification, the SEI Managed Account Agreement may be terminated by either Intrua or the client. Prorated fees will be charged based on market value on the date the termination notice is received. All fee arrangements are subject to negotiation and possible modification. Clients receive monthly statements from SEI Trust Company indicating holdings. A quarterly report, indicating market value, cash flows, gains and losses, asset allocation, and performance as it relates to market indices, is also available if the investor elects to receive it. Annually, the client will receive a tax statement for the account. Item 5 – Account Requirements and Types of Clients We require an initial minimum account size opening balance of $15,000. The account size may be negotiable based upon the individual circumstances. Participation in the wrap fee program generally is initiated by submitting a completed account application, portfolio management agreement, and questionnaire. The Adviser provides portfolio management services to individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, trusts, foundations, endowments, corporations, trusts, small businesses and churches. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Managers Intrua (and Intrua Representatives) serves as the portfolio manager for all Client accounts in the wrap fee program. We do not utilize outside portfolio managers for the wrap program sponsored by Intrua except Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 18 of 26  for those under the third-party managed account programs. All client accounts are managed in-house by Intrua’s Investment Committee and IARs of Intrua. The portfolio manager’s background information can be found in the Form ADV Part 2B Brochure Supplement attached. Advisory Business We provide various asset management, financial planning, and retirement plan advisory services. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. With respect to the wrap program, the Client has the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction requested. If such investment restrictions are implemented, the Client will experience a different investment return than what will be realized by the particular model itself. Such performance may be better or worse than the particular model. For these reasons, if a client wishes to make a request concerning restrictions based on specific securities, it may be more appropriate for the Client to participate in other portfolio management programs. It should be noted, any standardized reports of model performance will not reflect the performance of the particular model with restrictions applied. However, performance reports of the Client’s account will accurately reflect the Client’s actual account performance with restrictions. Performance-Based Fees and Side-by-Side Management The Adviser does 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. The Adviser does not perform side-by-side management. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The Independent Registered Investment Advisors of Intrua Financial use a number of different relevant analyses and/or strategies 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: 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. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 19 of 26  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. Targeted Asset Allocation We combine [relevant analyses] to determine asset allocation strategies. Six targeted asset allocation model portfolios covering everything from conservative income to very aggressive growth-oriented approaches have been compiled by us. We will assign you a targeted portfolio that meets your goals and time horizon, while addressing the level of risk you are comfortable assuming. The strategic model portfolio allocation remains constant; your specific portfolio model may change infrequently to reflect shifts in your risk tolerance and goals. We screen and select funds and securities to be added to or removed from the model portfolio on a regular basis. Rebalancing can occur after a move in the market of 15% or more within any year but at least once per year based on the annual review of your financial situation. Cyclical Analysis While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy. Investment Strategies In order to perform this analysis, we use many resources, such as: • Morningstar • DiMeo Research • Q Consulting Analysis Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 20 of 26  • Hedgeye Research • 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: 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 • Margin Transactions • Option writing, including covered options, uncovered options or spreading strategies. 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 bear. 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. Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We are authorized to instruct the custodian to forward you copies of all proxies and shareholder communications relating to your account assets. Further, the Adviser will not be required to take any action or render any advice with respect to any securities held in the Account, which are named in or subject to class action lawsuits. The Adviser will, however, forward to the Client any information the Firm receives regarding class action legal matters involving any security held in the Account and discuss such information if the Client so desires. Item 7 – Client Information Provided to Portfolio Managers The Adviser has access to all Client information obtained by the Adviser with respect to the particular Client accounts that they manage. The Adviser does not provide Client information to any other portfolio managers. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 21 of 26  Item 8 – Client Contact with Portfolio Managers Without restriction, you should contact our firm or your advisory representative directly with any questions regarding your Program account. You should contact your advisory representative with respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on the management of your Program assets. Item 9 – Additional Information Assets Under Management As of December 31, 2024, we provided asset management services for 7,575 accounts, managing total assets of approximately $1,760,400,000. Of which approximately $1,372,500,000 are in discretionary accounts and approximately $387,900,000 are in non-discretionary accounts. Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning Intrua or any of our IARs. We adhere to high ethical standards for all IARs and associates. We strive to do what is in your best interests. Other Financial Industry Activities and Affiliations Intrua is not registered as a broker-dealer, nor does it have any pending application to register. All of Intrua’s investment adviser representatives are registered as a representative of LPL Financial (LPL). Intrua and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor, nor do they have any pending application to register. Other Financial Industry Affiliations The IARs of Intrua have the following outside business activities and/or affiliations to disclose. Some of our IARs are registered representatives of LPL Financial, LLC. They may recommend securities products that will pay them a commission through their broker-dealer relationship. When such recommendations or sales are made, a conflict of interest exists as the registered representatives may receive more commissions from the sale of these products than from providing you with advisory services. We require that all IARs disclose this conflict of interest when such recommendations are made. We also require IARs to disclose to clients that they may purchase recommended products from other representatives not affiliated with us. Our Code of Ethics requires our IARs do what is in the client’s best interests at all times. Our CCO monitors all transactions to ensure that representatives put their clients first, not the commission they may receive. The broker-dealer also monitors all transaction to make certain they are suitable for the client. IARs 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 Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 22 of 26  of interest exists as the insurance licensed IARs earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. Intrua Financial Holdings, LCC, is also a direct and indirect owners of an affiliated registered investment advisory firm. In this role, they may receive profits from the ownership of this advisory firm. To mitigate any appearance of conflicts of interest, the services, and clients of either firm will remain separate and distinct, and clients of either firm will not be solicited to receive services of the other. Affiliated Private Funds Our firm is affiliated under common control and ownership with Larson Capital Management, LLC (“LCM”), an SEC registered investment adviser. LCM is the sponsor and manager to various private equity funds and funds of funds (“Fund”). The Fund is exempt from registration under the Investment Company Act of 1940. Investors in the Fund must be (i) “accredited investors” within the meaning of Rule 501 of Regulation D under the 1933 Act and (ii) “qualified clients” as defined under the Investment Advisers Act of 1940. Client of the firm may be invested in or solicited to invest in the Fund. Prior to investing in the Fund, clients should carefully review the Fund’s private placement memorandum and subscription agreement for detailed information about the Fund’s investment objectives, fees and expenses, risks, conflicts, valuation, and other important disclosures. 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 We may recommend securities to you that we have purchased 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. 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 • Participating in client accounts Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 23 of 26  Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the Chief Compliance Officer. 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. We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading 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 IAR(s) of Intrua, 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. Intrua Financial 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. Participation or Interest in Client Transactions As noted above, clients may be invested in or solicited to invest in the Fund. Clients should note that the recommendation of investments in the Fund creates a conflict of interest because our firm, our affiliates, and our Associated Persons have an incentive to recommend the affiliated Fund over funds that have no relationship with our firm for the purposes of generating additional revenue for the firm and for themselves. To address this conflict, we do not charge a separate portfolio management fee on the portion of client assets that is committed and uncalled to the affiliated Fund and that pays fees through the fund. Additionally, Associated Persons of the firm are required to uphold their fiduciary duties of always acting in our clients’ best interests. Conflicts of Interest Intrua Financial representatives may employ the same strategy for personal investment account as they do for clients. However, orders will not be placed in a way to benefit from the purchase or sale of a security. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 24 of 26  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. Review of Accounts Reviews will be conducted at least annually or as agreed to by us. Reviews will be conducted by the Investment Advisor of record or by our Chief Compliance Officer or his/her designee. 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 structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Economic Benefits Received from Vendors and Product Sponsors Occasionally, our firm and our Associated Persons will receive additional compensation from vendors. Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event; reimbursement in connection with educational meetings with an Associated Person, reimbursement for consulting services, client workshops, or events; or marketing events or advertising initiatives, including services for identifying prospective clients. Receipt of additional economic benefits presents a conflict of interest because our firm and Associated Persons have an incentive to recommend and use vendors based on the additional economic benefits obtained rather than solely on the client’s needs. We address this conflict of interest by recommending vendors that we, in good faith, believe are appropriate for the client’s particular needs. Clients are under no obligation contractually or otherwise, to use any of the vendors recommended by us. Compensation for the Sale of Securities or Other Investment Products Certain Executive officers and other Associated Persons of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to our clients. Insurance commissions earned by these persons are separate from and in addition to our advisory fees. The sale of insurance instruments and other commissionable products offered by Associated Persons are intended to complement our advisory services. However, this practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services are informed that they are under no obligation to purchase insurance services. Clients who do choose to purchase insurance services are under no obligation to use our licensed Associated Persons and may use the insurance brokerage firm and agent of their choice. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 25 of 26  Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. Reports You will be provided with account statements reflecting the transactions occurring in the account on at least a quarterly basis. These statements will be written or electronic depending upon what you selected when you opened the account. You will be provided with paper confirmations for each securities transaction executed in the account. You are obligated to notify us of any discrepancies in the account(s) or any concerns you have about the account(s). Custody Client funds and/or securities (assets) are held at qualified custodians. We use LPL Financial and/or Charles Schwab as the custodian and/or broker-dealer for all your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements and compare this official custodial record to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. If you notice any discrepancies, please contact Intrua. We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees and to pay them to us. You authorized the custodian to pay us directly at the onset of the relationship. Our firm is deemed to have custody of certain client assets where those clients have invested in a Fund where our firm’s affiliates and/or related persons serve as the General Partner or Manager to the Fund and therefore have access to the investments in the Fund. As required by SEC rules and in conformity with industry practice, the Fund is subject to an audit at least annually and distributes its audited financial statements prepared in accordance with generally accepted accounting principles to all respective Fund investors. Also, as required, the audits are conducted by an independent public accountant that is registered with the Public Company Accounting Oversight Board in accordance with its rules. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 26 of 26  Our firm is also deemed to have custody of client assets where it has fee deduction authority granted by the client in the advisory agreement and in certain situations where we accept standing letters of authorization from clients to transfer assets to third parties. We maintain safeguards in accordance with regulatory requirements regarding custody of client assets. Clients will receive account statements at least quarterly from the broker-dealer or other qualified custodian holding their assets. Clients are urged to review custodial account statements for accuracy Client Referrals and Other Compensation We do not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients nor do we directly or indirectly pay any compensation to another person if they refer clients to us. Financial Information We do not solicit fees of more than $1,200 per client, six months or more in advance. 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. Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 27 of 26