IVANOFF WEALTH MANAGEMENT INC.

Ivanoff Wealth Management, Inc. Part 2A of Form ADV: Firm Brochure This brochure provides information about the qualifications and business practices of Ivanoff Wealth Management, Inc. (Ivanoff). If you have any questions about the contents of this brochure, please contact us at 714-262-1658 or by email at: travis@ivanoffwealth.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. We are a registered investment advisor. Registration does not imply a certain level of skill or training. Additional information about Ivanoff is also available on the SEC’s website at www.advisorinfo.sec.gov. Ivanoff’s CRD number is: 325275. 6021 Katella Ave, Suite 125 Cypress, CA 90630 714-262-1658 Travis@ivanoffwealth.com Ivanoffwealthmanagement.com Version Date: April 14, 2026 1 April 14, 2026 Form ADV 2A  Item 2: Material Changes This Item identifies and summarizes only those material changes that have occurred since the last annual update of our firm brochure. Since that time, we have made the following material changes: Item 4: Our most recent assets under management calculation has been updated. Item 5: A new fee schedule was updated for Gradient Investments and for sub-advisors. 2 April 14, 2026 Form ADV 2A  Item 3: Table of Contents 2 Item 2: Material Changes 3 Item 3: Table of Contents 4 Item 4: Advisory Business 5 Item 5: Fees and Compensation 9 Item 6: Performance-Based Fees and Side-By-Side Management 9 Item 7: Types of Clients 9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss 17 Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading 18 19 Item 12: Brokerage Practices 24 Item 13: Review of Accounts 24 Item 14: Client Referrals and Other Compensation 25 Item 15: Custody 26 Item 16: Investment Discretion 27 Item 17: Voting Client Securities 27 Item 18: Financial Information 3 April 14, 2026 Form ADV 2A  Item 4: Advisory Business Introduction and Overview Ivanoff Wealth Management Inc. (“Ivanoff”) was founded in 2017 and become registered to offer advisory services in 2023. Travis Ivanoff is 100% owner. Types of Advisory Services Ivanoff offers discretionary asset management services to advisory Clients. Ivanoff will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Ivanoff discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. As part of the services provided, the Client may have a financial plan completed. This may include but is not limited to a thorough review of all applicable topics such as Investments, Taxes, Qualified Plans, Insurance, Retirement Income, College Planning, Home Buying, Budgeting, Debt Management, Emergency Funds, and Risk Tolerance Assessment. If a conflict of interest exists between the interests of Ivanoff and the interests of the Client, the Client is under no obligation to act upon Ivanoff’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Ivanoff. This service will be provided at no additional cost to the Client. When deemed appropriate for the Client, Ivanoff may hire Sub-Advisors to manage all or a portion of the assets in the Client account. Ivanoff has full discretion to hire and fire Sub- Advisors as they deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and Ivanoff. Sub-Advisors execute trades on behalf of Ivanoff in Client accounts. Ivanoff will be responsible for the overall direct relationship with the Client. Ivanoff retains the authority to terminate the Sub-Advisor relationship at Ivanoff’s discretion. Ivanoff has also entered into a Co-Advisor relationship with Gradient Investments, LLC (GI). Ivanoff will provide information to each client regarding the services offered by GI as the portfolio manager. Ivanoff will assist the Client to determine the appropriate model selection based on the Client’s investment objectives and risk tolerance. Ivanoff will have full discretion on an ongoing basis to select suitable models to maintain client’s risk tolerance. Ivanoff will share in the management fees charged by GI as described in Item 5 of this brochure. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. 4 April 14, 2026 Form ADV 2A  Agreements may not be assigned without written Client consent. Department of Labor Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Assets under Management (AUM) On April 13, 2026, our total assets under management (“AUM”) are $ 173,968,647. Discretionary assets under management are $ 173,968,647 and we have no non-discretionary assets under management or accounts. Item 5: Fees and Compensation Subadvisory Fees Ivanoff offers discretionary direct asset management services to advisory Clients. Ivanoff charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Ivanoff’s Fee Monthly Fee 1.0% 0.0833% 0.80% 0.0667% 0.60% 0.05% 0.50% 0.0417% 0.40% 0.0333% 0.30% 0.025% First $1,000,000 ($0-$1,000,000) Your next $2,000,000 ($1,000,000.01 - $3,000,000) Your next $2,000,000 ($3,000,000.01 - $5,000,000) Your next $5,000,000 ($5,000,000.01 - $10,000,000 Your next $15,000,000 ($10,000,000.01 - $25,000,000 Subsequent amounts ($25,000,000.01+) 5 April 14, 2026 Form ADV 2A  This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. Ivanoff may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example (based on monthly billing period): Client with $1,500,000 under management would pay $14,113.00 on an annual basis. (*Includes service fee.) AUM Monthly fee Total First $1,000,000 x 0.0833% = $833.00 Next $500,000 x 0.0667% = $333.50 Grand total for the month $1,171.50 (*includes $5 monthly service fee) + $5 Monthly Service Fee* * The $5 Monthly Service Fee is the technology fee charged per account or investment strategy for performance and other reporting. This fee is disclosed in our Client Agreement (Schedule D: Schedule of Fees). The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous month. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by Ivanoff with thirty (30) days written notice to Client and by the Client at any time with written notice to Ivanoff. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to Ivanoff. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Ivanoff may also utilize the services of a Sub-Advisor to manage Clients’ investment portfolios. Ivanoff will enter into Sub-Advisor agreements with other registered investment advisor firms. When using Sub-Advisors, the Client will pay additional fees up to 1.00% of assets under 6 April 14, 2026 Form ADV 2A  management annually. Sub-Advisor directly deducts their portion of the fee separately from Ivanoff. Co-Advisory Fees Ivanoff has entered into a Co-Advisor Agreement with Gradient Investments, LLC (“GI”) SEC number 801-70812. GI is a Registered Investment Advisor registered with the Securities and Exchange Commission that provides investment portfolio advice and supervisory services. GI offers an actively managed program of mutual fund and stock portfolios. The fee will be disclosed to the Client in the Investment Advisory Agreement and are negotiable. The Clients fee for these services will be based on a percentage of assets under management as follows: Portfolio GI Fee* Custom Indexing - Strategic Strategic Custom Indexing - Allocation Allocation Tactical Defined Outcome Private Wealth Preservation Client Directed Accounts Asset Valuation All Assets All Assets All Assets All Assets All Assets All Assets All Assets All Assets All Assets Stated Total Annual Fee 1.65% 1.50% 1.65% 1.50% 1.50% 1.50% 1.50% 1.00% $300 0.65% 0.50% 0.65% 0.50% 0.50% 0.50% 0.50% 0.40% $300 Ivanoff Fee (Negotiable) 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 0.60% $0 For Client Directed Accounts (CDA), GI will assist in the opening, closing and transferring of accounts. GI will not have discretion at any time on these accounts. Client is solely responsible for the assets held within the accounts and their values which could increase or decrease (potential loss of principal). GI will not execute trades in CDA accounts. GI exceptions will be made for withdrawals to client or assets transferred into a GI managed portfolio. GI will also provide performance reporting on these accounts and can furnish 3rd party analysis reports per the client’s request. Similar services may be available through other sources for a lower fee. These are flat fee schedules, the entire portfolio is charged the same asset management fee. Example: Portfolio Calculation Quarterly Fee Custom Indexing – Strategic: ($750,000*1.65%) * (91/365) $3,085.27 Strategic Portfolio: ($750,000*1.50%) * (91/365) $2,804.79 Tactical Portfolio: ($750,000*1.50%) * (91/365) $2.804.79 Custom Indexing – Allocation: ($750,000*1.65%) * (91/365) $3,085.27 Allocation & Defined Outcome Portfolio: ($750,000*1.50%) * (91/365) $2,804.79 Private Wealth Portfolio: ($750,000*1.50%) * (91/365) $2,804.79 Preservation Portfolio: ($750,000*1.00%) * (91/365) $1,869.86 7 April 14, 2026 Form ADV 2A  Fee Calculation: (Quarter End Value x Annual Fee %) x (Days in Quarter/Days in Year) + $15 Quarterly Service Fee* * The $15 Quarterly Service Fee is the technology fee charged per account or investment strategy for performance and other reporting. This fee is disclosed in our ADV Part 2A (Item 5: Fees and Compensation) and in our Investment Proposal and Contract (Schedule D: Schedule of Fees). The above fees are negotiable. Fees are assessed quarterly in arrears based on the amount of the assets managed as of the end of the previous quarter and will take into account additions and withdrawals in the time period. All management fees are withdrawn from the Client’s account unless otherwise noted. GI will receive written authorization from the Client to deduct advisory fees from their account held by a qualified custodian. GI will pay Ivanoff their share of the fees. Ivanoff does not have access to deduct Client fees. Clients may terminate their account within five (5) business days of signing the investment advisory agreement without penalty or obligation. For terminations after the initial five business days, GI will be entitled to a pro-rata fee for the days service was provided in the final quarter. GI will pay Ivanoff their portion of the final fee. Incentive Program - GI In addition to the regular advisory fee, GI has instituted a long-term incentive arrangement by Ivanoff can share in GI’s portion of the management fee. This does not change the cost to the Client; it is a sharing arrangement paid from GI’s portion of the advisory fee. The incentive arrangement will be paid annually according to the following table: Ivanoff Quarterly AUM with GI $10,000,000 $25,000,000 $50,000,000 $75,000,000 Participation rate in GI’s fee 3.00% 10.00% 12.50% 15.00% Once Ivanoff reaches and maintains the thresholds listed above, the participation rate applies to all of the AUM for the quarter. To receive the incentive award, Ivanoff needs to meet two qualifications. First, the quarter end billable AUM must be above the threshold amounts specified. Second, Ivanoff must be an advisor “in good standing” with GI at the time the annual checks are issued. “In good standing” means the advisor is proactively placing assets with GI. This relationship will be disclosed to the Client in each contract between Ivanoff and Third Party Money Manager. Ivanoff does not charge additional management fees for Third Party managed account services. Client's signature is required to confirm consent for services within Third Party Investment Agreement. Client will initial Ivanoff Investment Advisory Agreement to acknowledge receipt of Third Party fee Schedule and required documents including Form ADV Part 2 disclosures. Client Payment of Fees 8 April 14, 2026 Form ADV 2A  Fees for asset management services are deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Fees for asset management services provided by TPM are deducted from a designated Client account by TPM to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. Ivanoff does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to Ivanoff. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Ivanoff does not require any prepayment of fees. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Ivanoff. External Compensation for the Sale of Securities to Clients Investment Advisor Representatives of Ivanoff receive external compensation from sales of investment related products such as insurance as licensed insurance agents. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. This conflict is mitigated by disclosures, procedures, and Ivanoff’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6: Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. Ivanoff does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for Ivanoff to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients We generally provide advisory services to the following types of clients: Individuals • • High-Net-Worth Individuals • Other registered investment advisors • Defined Contribution & Defined Benefit Retirement Plans 9 April 14, 2026 Form ADV 2A  • Corporate and Institutional Investors Minimum Account Size There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss Methods of Analysis and Investment Strategies: We generally do not directly provide ongoing investment management services. Instead, we have engaged subadvisors or co-advisors to manage client portfolios on a discretionary basis. We evaluate and subadvisors or co-advisors based on a variety of qualitative and quantitative factors, which may include the investment philosophy, performance history, organizational stability, investment process, and adherence to regulatory and compliance requirements of the subadvisors or co-advisors. Once selected, we monitor the performance and investment strategies of the subadvisors or co-advisors on an ongoing basis to ensure they remain consistent with client objectives and our due diligence criteria. Generally, the subadvisors or co- advisors may employ a combination of fundamental, technical, and quantitative analysis in managing the portfolios. Investment strategies cover a diverse range of investment objectives and risk tolerances, and therefore may include a variety of asset class exposures, including equity, fixed income, and alternative asset classes. Risks Involved with Our Managed Portfolios and Specialty Solutions: Selection of Other Advisers – Although we seek to select only those subadvisors or co-advisors who will invest your assets with the highest level of integrity, our selection process cannot ensure that the selected subadvisor or co-advisor will have positive performance or outperform a particular benchmark. We do not have control over the day-to-day operations of the subadvisor or co-advisor. Active Management Risk - This process concentrates on factors that are believed to lead to the quality and future success of particular money managers. The risk assumed is that the manager will fail to perform as expected. Asset Allocation Risk - The success of asset allocation depends upon the manager’s ability to make decisions that will achieve an account’s objectives. Asset categories may not perform as expected due to economic and market influences both foreign and domestic and anticipated returns may not be realized. Commodities-Related Risks – Commodities may provide protection against inflation and/or the inability of fiat currencies to maintain their store of real value as well as increased diversification through reduced correlations relative to other asset classes. However, it is also important to understand that commodity-related investments are often highly volatile and can 10 April 14, 2026 Form ADV 2A  be significantly affected by commodity prices, world events, import controls, worldwide competition, government regulations, and economic conditions. Credit Risk - The value of a portfolio may change in response to changes in the credit ratings of the portfolio’s securities. Generally, investment risk and price volatility increase as a security’s credit rating declines. Default Risk - High Yield bonds are considered speculative and are susceptible to default or decline in value due to adverse economic and business developments. Dilution Risks - Issuers of private placements may be required to raise additional capital. Future issuance of additional securities could dilute the ownership stakes of issuer’s then-existing owners, and there can be no assurance that the effects of such dilution will not be substantial. Additionally, any new class units that might be issued in the future may negatively impact the issuer’s then-existing owners. Emerging Markets Risk - Investments in emerging markets may be subject to a greater risk of loss than investments in more developed markets. Emerging markets may be more likely to experience inflation risk, political turmoil and rapid changes in economic conditions than more developed markets. Emerging markets often have less consistency in accounting and reporting requirements, unreliable securities valuation and greater risk associated with custody of securities. Equity Market Risk – Stocks have risk in that their returns and the principal invested in them is not guaranteed and they are subject to changing market conditions. Small stocks are more volatile than large stocks and are subject to significant price fluctuations. Foreign Risk – Foreign investments are subject to the same risks as domestic investments and additional risks, including international trade, currency, political, regulatory and diplomatic risks, which may affect their value. Also, foreign securities are subject to the risk that their market price may not reflect the issuer’s condition because there is not sufficient publicly available information about the issuer. Inflation Risk - The value of assets or income from investments may be worth less in the future as inflation decreases the value of money. Interest Rate Risk - Portfolios may change in response to the movement of interest rates. The price of a fixed income security will generally fall when interest rates rise. Liquidity Risk - Markets can experience a decline in liquidity which can negatively impact the prices of various security types and increase the difficulty to sell these securities. Further, the ability to purchase or sell large positions of certain securities may take time and have an impact on the price. 11 April 14, 2026 Form ADV 2A  Market Index Risk – Many of the investments we utilize are largely influenced by the value of the indices they track or the asset class they represent. As the index value or asset class changes in response to news and general economic conditions of domestic, international and commodity/natural resource markets in general, so will the value of the ETF or mutual fund. This can result in a loss of your initial investment. Political Risk - Government decisions may damage the value of your investments. Changes to social security, benefits law, and tax law may impact your financial decisions. Any foreign investments may be impacted by the decisions of their local governments. Portfolio Rebalancing Risk - Depending on the rebalancing strategy implemented, long-term or short-term trading may be involved. Trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short-term trading generally holds greater risk and you should be aware that there is a material risk of loss using short-term strategies. Privately Held Investment Risks – Privately held investments typically hold more risk to the investor than publicly traded investments since they do not fall under the same regulatory requirements. As they are not publicly traded, an active market may not readily exist, which means they lack liquidity. They also typically have substantial fees relative to other types of investments. Additionally, investments in privately held companies or products have differing tax ramifications which can be complex in nature. Sector Risk - When a substantial portion of assets is devoted to a particular market sector or industry, there is potentially greater volatility compared to broadly diversified strategies. A market sector or industry may underperform the market as a whole for a variety of reasons. Tax Risks - Some of the products offered are subject to tax law that is complex and subject to varying interpretations. Moreover, the effect of existing income tax laws and possible changes in such laws will vary with the particular circumstances of each investor. You should consult with and rely on your own tax professional with respect to the possible tax consequences, including risks and advantages, of an investment. Timing Risk - While it is likely that stocks will gain over the next two decades, this may not be the case over the short-term. If you need to protect your principal investment over the short- term, timing is an important risk to consider. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized: Investing in securities involves risk. Seeking to obtain higher rates of return on investments typically entails accepting higher levels of risk. We or your investment advisor representative 12 April 14, 2026 Form ADV 2A  will work with you to identify the balance of risks and rewards that is appropriate and comfortable for you. However, it is still your responsibility to ask questions if you do not fully understand the risks associated with any investment or investment strategy. Also, while we strive to render our best judgment on your behalf, many economic and market variables beyond our control can affect the performance of your investments and we cannot assure that your investments will be profitable or that no losses will occur in your investment portfolio. Past performance is one consideration with respect to any investment or investment advisor, but it is not a predictor of future performance. We or your investment advisor representative will discuss with you the investment risks of the recommended securities to determine the investment objectives that will guide your portfolio selection. We will explain and answer any questions you have about these kinds of investments, which present special considerations. Exchange Traded Fund (ETF) - ETFs are registered investment companies that derive their value from a basket of securities such as stocks, bonds, commodities or indices, and are traded on market exchanges. ETFs are usually traded on a secondary market at a market price that may be higher or lower than its net asset value and may not have liquidity under severe market conditions. There may be brokerage commissions associated with buying and selling ETF shares. ETFs are generally passively managed vehicles which are designed to seek the investment results that correspond to the price and yield of an index. Sometimes referred to as “tracking error,” expenses and other factors may affect the performance of an ETF so that the ETF’s performance does not exactly match the performance of its respective underlying indexes. However, certain ETFs are actively managed and do not just seek to passively track an index; instead, they seek to achieve a specified investment objective using an active investment strategy. The value of an ETF will fluctuate with the value of its underlying securities. Equity- based ETFs have a similar risk profile to that of equities, while fixed income-based ETFs have a risk profile that is similar to bonds. Exchange-Traded Note (ETN) - ETNs are issued as senior, unsecured, unsubordinated debt obligations of an underlying bank or other financial institution. They are linked to the performance of an index, underlying security, or commodity. Similar to ETFs, ETNs trade on a market exchange. However, unlike ETFs, ETNs carry credit risk related to the issuer’s ability to pay back the note. This means that the market value of ETNs can be adversely affected by downgrades in the creditworthiness of the underlying issuing financial institution. In the extreme case that the issuer of the ETN goes bankrupt, you may lose your entire investment. In contrast, if an ETF were to suffer bankruptcy or close, you would usually receive cash for the market value of the basket of securities or, in the case of larger positions, you may request to take distribution of the underlying securities. While the performance of ETNs is linked to the performance of an underlying index, security, or commodity, you do not own any underlying assets. 13 April 14, 2026 Form ADV 2A  Open-End Mutual Fund - An open-end fund is a registered investment company that does not have restrictions on the number of shares the fund can issue. Generally, open-end funds are actively managed, meaning that the portfolio manager buys and sells securities with the goal of outperforming the fund’s stated benchmark. These funds may have significant tracking error or active risk, which is the risk of fund returns deviating from the benchmark returns. Open-end fund shares are bought and sold on demand at their net asset value (NAV), which is based on the value of the fund’s underlying securities and is calculated at the end of the trading day. When a large number of shares are redeemed, the fund may sell some of its investments to pay the investor. This may lead to liquidity risk which is caused by a lack of ready cash to properly handle shareholder transactions. Structured Product - Structured products are unsecured debt securities of an issuer that are linked to the performance of an underlying asset, such as a basket of securities or market index. As unsecured debt securities, structured products are not backed by collateral and they are subject to the creditworthiness of the issuer to make interest payments and repay principal. Structured products are typically the combination of a note (or other corporate bond) and a derivative (such as an option). Structured products are complex and may use advanced trading techniques such as leverage, options, futures, swaps, and other derivatives which lead to additional risks. Investing in a structured product should not be compared to investing in the underlying asset, as the features and risks may differ significantly. The structured product may not provide a return, may lose all principal invested, and/or may provide a return significantly less than what you could have received by investing directly in the underlying asset or other security. Structured products may not be appropriate for those seeking current income, as they may not pay interest or the interest they pay may vary in amount or timing. You should carefully read the offering documents and make sure you fully understand the specific terms and conditions for that product. Structured products may not be listed on a national securities exchange and a guaranteed secondary market does not exist for structured products. Issuing banks and other parties may be willing to repurchase them prior to maturity. This value appears in an account, represents an estimate of the current repurchase value and may be at a substantial discount from your original investment. Therefore, you may not be able to sell the structured product prior to maturity. Structured products are long-term investments designed to be held to maturity, at which point the issuing bank is obligated to provide a value consistent with the terms of the investment. Structured products have an uncertain tax treatment due to limited guidance. You should consult with a tax advisor prior to investing in a structured product. Market-Linked CDs (MLCDs) and Principal Protected Notes (PPNs) are two types of structured products. PPNs are not FDIC insured, whereas MLCDs are FDIC insured. FDIC coverage generally applies to the amount of invested principal only. If you hold more than the FDIC-insured limitations in deposits with the issuing bank, you will not receive the benefit of FDIC insurance for any balance in excess of FDIC limits. For more information, please visit www.fdic.gov. Variable Annuity - Variable Annuities are tax-deferred investments structured to convert a sum of money into a series of payments over time. Variable annuity policies have limitations and are 14 April 14, 2026 Form ADV 2A  not viewed as short-term liquid investments. An insurance company's fulfillment of a commitment to pay a minimum death benefit, a schedule of payments, a fixed investment account, or another form of guarantee depends on the claims-paying ability of the issuing insurance company. The financial ratings quoted for an insurance company do not apply to the separate account and its subaccount. The insurance company offering a variable annuity will charge several fees, including annual contract charges that compensate the insurance company for the cost of maintaining and administering the contract, mortality and expense risk (M&E Risk) charges based on a percentage of a subaccount’s assets to cover costs associated with mortality and expense risk, and administration fees that are based on a percentage of a subaccount’s assets to cover the costs involved in offering and administering the subaccount. You will also be charged ongoing fees related to the management of the fund and possibly be subject to surrender charges if you make a withdrawal prior to a specified time. If the variable annuity subaccount is invested in a money-market fund, the money market fund is not FDIC- insured, may lose money, and is not guaranteed by a bank or other financial institution. Fixed Indexed Annuity – Fixed Indexed Annuities are long-term financial products designed largely for asset accumulation and retirement needs. All guarantees are backed by the claims- paying ability of the issuing insurance company. Annuities generally contain fees and charges which include, but are not limited to, surrender charges, administrative fees and for optional contract riders and benefits. Withdrawals and death benefits may be subject to income tax. If withdrawals and other distributions are received prior to age 59 ½, a 10% penalty may apply. Annuities typically carry surrender charges for several years that may be assessed against withdrawals. Certain annuity product features, such as stepped-up death benefit, a bonus credit, and a guaranteed minimum income benefit, will generally incur additional fees. If you are investing in an annuity through a tax-advantaged plan such as an IRA, you will get no added tax advantage. Any comments regarding safe or secure investments or guarantees of income refer only to fixed insurance products and do not refer in any way to securities or investment advisory products. Bonds - Investing in the bond market is subject to risks, including market, interest rate, issuer credit, inflation risk, default risk, and liquidity risk. The value of most bonds and bond strategies is impacted by changes in interest rates. Bonds and bond strategies with longer durations tend to be more sensitive and volatile than those with shorter durations; bond prices generally fall as interest rates rise. Bond investments may be worth more or less than the original cost when redeemed. Municipal Bonds - Municipal Bond investing is subject to risks, including market, interest rate, issuer credit, inflation risk, default risk, and liquidity risk. The value of most bonds and bond strategies is impacted by changes in interest rates. Bonds and bond strategies with longer durations tend to be more sensitive and volatile than those with shorter durations; bond prices generally fall as interest rates rise. Bond investments may be worth more or less than the original cost when redeemed. Income from municipal bonds may be subject to the Alternative 15 April 14, 2026 Form ADV 2A  Minimum Tax (AMT), and capital appreciation from discounted bonds may be subject to state or local taxes. Capital gains are not exempt from federal income tax. Equities - Equities are securities that represent the ownership of a fraction of the issuing corporation, which entitles the shareholder to a proportion of the corporation's assets and profits. Stocks are typically bought and sold on stock exchanges and trading must conform to government regulations meant to protect investors from fraudulent practices. Corporate property is legally separated from that of the shareholder, which limits the liability of both the corporation and the shareholder. There is broad market risk involved with any form of stock market investing, known as systematic risk. However, investing in individual equities can introduce unsystematic, or stock-specific risk which impacts those investing in a certain industry, company, or specific area of the stock market. This risk is typically characterized as business, financial, strategic, operational, and legal risk. Unsystematic risk can be highly unpredictable and can have a more probable likelihood of occurrence relative to systematic risk. 529 Program - A 529 program is a tax-advantaged savings plan designed to help pay for education. 529 programs are intended to be used only to save for Qualified Education Expenses. These programs are not intended to be used, nor should they be used, for the purpose of evading federal or state taxes or tax penalties. You should seek tax advice from an independent tax advisor based on your particular circumstances. Most 529 plans are invested in exchange-traded funds or open-end mutual funds; however, other investment types are possible such as stable value funds, certificates of deposit, and separate accounts. Before investing, you should consider whether you or your designated beneficiary's home state offers any state tax benefits or other state benefits such as financial aid, scholarship funds, and protection from creditors, that are only available for investments in such state's 529 qualified tuition program. Health Savings Account - A Health Savings Account is a tax-advantaged savings plan designed to help pay for eligible medical expenses. These accounts are available to individuals and families who have high-deductible health plans. Health Savings Accounts are not intended to be used, nor should they be used, for the purpose of evading federal or state taxes or tax penalties. You should seek tax advice from an independent tax advisor based on your particular circumstances. Most Health Savings Accounts function similarly to traditional savings accounts; however, other investment types are possible such as exchange-traded funds and open-end mutual funds. 1031 Exchange - 1031 Exchanges are governed by the IRS tax code associated with the deferral of capital gains on the sale of an investment property when subsequently purchasing a “like kind” property that is the same in nature and character. Substantial fees and expenses could be incurred and there are strict timing limitations imposed on these transactions. For example, if the transaction is not properly constructed and executed in a timely manner, all tax benefits associated with the transaction may be lost while potentially incurring additional tax liability. As 1031 exchanges are based on real estate investments for which there may be no readily 16 April 14, 2026 Form ADV 2A  available market, there is liquidity risk. Additionally, the following real estate investment risks are possible: no guarantee of cash distributions; operational risks associated with property management and ownership; risk of the property being overleveraged; tax risks; interest rate risks; economic risks; risks of terrorism; environmental risks; liability risks; zoning, city ordinance, and or legal compliance risks; title and escrow risks; credit risks; and risks of obsolescence. Delaware Statutory Trust (DST) - A Delaware Statutory Trust (DST) is a trust formed by a sponsor and managed by trustees or managers for real estate investment purposes and is only available to accredited investors who meet certain income and net worth requirements. DSTs identify as separate legal entities; this means the owners have limited liability in regard to the operations and assets in the trust. Typically, DSTs are sector-specific but can include diversified exposure to residential, healthcare, office, and industrial property options. The risks involved with investing in DSTs include the potential for excessive fees, lack of liquidity, lack of share value transparency, distributions that may come from the principal investment, an inability to collect rent, vacancies, inflation and other increases in operating costs, and adverse changes in laws and regulations applicable to owners of real estate. It is important for you to review all offering materials from the product sponsor. Real Estate Investment Trust (REIT) - A Real Estate Investment Trust (REIT) is a company or investment trust that retains diverse portfolios of real estate assets. Privately traded REITs are only available to accredited investors who meet certain income and net worth requirements. Publicly traded REITs have shares that can be bought and sold on major stock exchanges. Typically, REITs are sector-specific but can include diversified exposure to residential, healthcare, office, and industrial property options. The risks involved with investing in REITs can include the potential for excessive fees, lack of liquidity, lack of share value transparency, distributions that may come from the principal investment, an inability to collect rent, vacancies, inflation and other increases in operating costs, and adverse changes in laws and regulations applicable to owners of real estate. It is important for you to review all offering materials from the product sponsor. Item 9: Disciplinary Information We have no legal or disciplinary events that are material to your evaluation of us or the integrity of our management to disclose. Item 10: Other Financial Industry Activities and Affiliations Material Relationships Maintained by this Advisory Business and Conflicts of Interest President Travis Ivanoff is also a licensed insurance agent with Travis Ivanoff Insurance Services Inc. Approximately 40% of Travis Ivanoff’s time is spent in this practice. He will offer Clients services from those activities. 17 April 14, 2026 Form ADV 2A  Mr. Ivanoff is also an Investment Advisor Representative for Tucker Asset Management LLC. He will remain in this role through his transition to Ivanoff Wealth Management Inc. These practices represent conflicts of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest We utilize the services of subadvisors or co-advisors to manage some or all of our clients’ assets on a discretionary basis and in accordance with their stated investment objectives. Subadvisors and co-advisors execute all trades on our behalf. We retain the authority to terminate the subadvisor or co-advisor at our discretion. We conduct ongoing due diligence on our subadvisory and co-advisory relationships, and ensure that any selected subadvisors or co- advisors are properly registered as an investment advisor. This practice represents a conflict of interest which is mitigated by our disclosures, policies and procedures, code of ethics, and by our fiduciary duty to place your best interests first above all others. Please refer to Item 4 and Item 5 for additional information on our use of subadvisors and co-advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of Ivanoff have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Ivanoff affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of Ivanoff. The Code reflects Ivanoff and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Ivanoff’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of Ivanoff may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. 18 April 14, 2026 Form ADV 2A  Ivanoff’s Code is based on the guiding principle that the interests of the Client are our top priority. Ivanoff’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Ivanoff will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Ivanoff and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Ivanoff and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide Ivanoff with copies of their brokerage statements. The Chief Compliance Officer of Ivanoff is Travis Ivanoff. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Ivanoff does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Ivanoff with copies of their brokerage statements. The Chief Compliance Officer of Ivanoff is Travis Ivanoff. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. 19 April 14, 2026 Form ADV 2A  Item 12: Brokerage Practices Custodian Selection When you engage us directly for our portfolio management services, we generally require that you establish an account at Charles Schwab to use their custody, brokerage, and clearing services. This custodian is qualified to hold your assets and offer services to independent investment advisors, which include custody of securities, trade execution, and clearance and settlement of transactions. We ask that you give us a written direction in our advisory agreement to use one of our custodial partners as the custodian for your account(s). Additionally, while we may recommend a custodian to you, you will make the final selection and open your account with them by entering into a separate account agreement directly with them. We do not open the account for you, although we may assist you with the paperwork in doing so. Even though your account is maintained with them, we will have discretion to use them or other brokers to execute trades for your account as described below. Factors Used to Select Custodians We have a duty to obtain best execution for client transactions, which means we must execute transactions in such a manner that your total costs or proceeds in each transaction are most favorable under the circumstances. In selecting the custodian to execute securities transactions, we consider the full range of services offered by the custodian, including, but not limited to: • Combination of transaction execution and asset custody services (generally without a separate fee for custody); • Capability to execute, clear, and settle trades (buy and sell securities for your account); • Ability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.); • Availability of investment research and tools that assist us in making investment decisions. These include recent news, graphs, charts, historical earnings data, balance sheet data, estimates of future earnings, and other information; • Quality of services, including additional reports that include gains and losses (both realized and unrealized); • Competitiveness of the price of services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices. We believe the brokerage services from our custodial partners are competitive with comparable firms for comparable services. • Reputation, financial strength, and stability; • Prior service to us and our other clients; and • Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us”). Relationships with Prime Brokers Under a Prime Broker agreement, we may "trade away" for certain transactions. Fixed income transactions may be traded away for liquidity or best execution purposes. Fixed Income 20 April 14, 2026 Form ADV 2A  securities that are traded away are subject to Prime Broker fees, which is a different brokerage cost (may be better or worse depending on the complexity of the order) than if the trades were done at the client’s custodian. These bonds will be custodied in the client's account at their custodian. Equity transactions may be traded away in certain circumstances for best execution purposes. Equities that are traded away receive a net price (price of the security inclusive of the Prime Broker’s commission, which is a different brokerage cost and may be better or worse, depending on the complexity of the order, than if the trades were done at the client’s custodian). These equities will be custodied in the client’s account at their custodian. Brokerage fees incurred from trading through one of our Prime Brokers is shown on client’s trade confirmations and statements. Your Brokerage and Custody Costs For our direct clients who have accounts at one of our custodians, the custodians do not charge you separately for custody services, but are paid by charging you commissions or other fees on trades that they execute or that settle in your account. We negotiated our commission rates with them on behalf of all our clients and not with respect to any specific client. While these commission rates may be higher than available from other discount and online brokers, we believe that the additional services and investment reports provided are of more value to us and our clients than the lower priced alternatives that provide fewer services. Therefore, we have our custodians execute most individual securities trades for your account to minimize your trading costs. We also use these custodians for most ETF and mutual fund transactions because they provide a wide array of no-load or institutional class mutual fund shares with no transaction costs to our clients. While it is our objective to obtain the lowest transaction costs possible for our clients, due to some account or asset transfer processes it is possible for clients to be charged transaction costs that exceed the amount of the transaction itself. In an effort to prevent these egregious fees to our clients, we maintain a policy that enforces a procedure by which transactions such as these are flagged for review in order to properly reverse or reduce these costs. Generally, we have determined that having our custodians execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above in the section titled, “Factors Used to Select Custodians.” In certain situations, the use of margin access through your respective custodian may be approved by us. In these cases, additional fees and interest on margin account balances may apply. These fees and interest costs are separate and independent from any fees charged by or paid to us. We receive no additional direct compensation as a result of any client’s use of margin access at their custodian. There are risks involved with utilizing margin access, including a potential drop in the underlying security value which will force the client to deposit additional cash or securities to cover the maintenance margin call issued by the custodian. A custodian has the right to increase the minimum amount required in a margin account, sell your securities without notice or sue you if a margin call is not fulfilled. The use of margin is most suitable for sophisticated investors with a thorough understanding of the risks and requirements involved. 21 April 14, 2026 Form ADV 2A  Client Directed Brokerage Arrangements Directing us to use a specific broker could, in some transactions, result in higher commissions and charges where we might otherwise go directly to a market maker in the security. Limiting the number of brokers we regularly work with leads to efficiencies that help keep our advisory fees lower. Soft Dollars We have not and do not intend to enter into any contractual third party soft-dollar arrangements. An example of such an arrangement may include a situation where we commit to place a specific level of brokerage commissions and in return the broker pays for various research-related products or services that are generally available for cash purchase. Products and Services Available to Us We generally receive benefits because clients use certain custodians for their brokerage transactions and custody services or because our subadvisory services are available through certain custodians. The services made available may be used to benefit all clients’ accounts, as well as our personal and proprietary accounts. The services include, among others, brokerage, custodial, and administrative support, recordkeeping, and related services that are intended to support us in conducting business for your account and in serving your best interests. These programs and services are essential to our service arrangements and capabilities. The availability of the services from these custodians benefits us because we do not have to purchase them separately. While this is a potential conflict of interest, we believe that this is mitigated by the following: • You will make the final selection when choosing the custodian. • All of the services received are provided by custodians on an unsolicited basis. • Custodians do not pay us any compensation or give us referrals in exchange for recommending their services to clients. • The services provided are not tied to a specific level of brokerage activity or • commissions achieved. In all cases, you will be provided with a copy of all applicable firm brochures which describe the applicable brokerage practices. Aggregation of Client Orders We may aggregate orders for securities transactions for more than one client based on our trade aggregation and allocation policy. In doing so, we strive to treat you fairly and will not favor one client or proprietary account over another. When executed, we will allocate the aggregated order in accordance with policies and procedures intended to achieve fair treatment. The purpose of aggregating orders is to obtain the same price for each client in any given security, obtain better execution for the aggregated order than might be achieved by processing each of the transactions separately, expedite the placement and processing of trade orders, as well as for our administrative convenience. The following standards are maintained for aggregated orders: 22 April 14, 2026 Form ADV 2A  • Disclose the trade aggregation policies and procedures to all clients; • Aggregate transactions only if consistent with our duty of best execution; • Allocate orders on a pro rata basis for partially filled orders; • Do not favor any client over another, and each client participating in the order will participate at an average share price of all transactions in that security on the day of execution; • Allocate transaction costs on a pro rata basis for each client’s participation in the transaction. Some brokers charge brokerage commissions to each participating client in accordance with the size of that client’s part of the aggregated order, regardless of the total size of the aggregated order; • Maintain accurate records relating to the aggregated trades, including a list of each client account that is included in an aggregated order, as well as the securities held by, bought, and sold for that client; • Do not hold client assets collectively any longer than necessary to settle the purchase or sale transaction; • Do not receive any additional compensation or remuneration as a result of any aggregated order; • Render individual advice and treatment to each client; • Make allocation decisions in a timely manner, which generally means prior to placing the order; • Exclude orders for ERISA plan clients and clients having a directed brokerage relationship from aggregated orders for those non-ERISA plan clients who do not have a directed brokerage relationship (even within the same broker). A consequence of not aggregating a client’s order with other orders for the same securities is that the client may not obtain as good a price or as low a cost in a separate transaction as clients whose orders have been aggregated; and • Perform periodic reviews of all aggregated orders and block allocations to ensure that our policies and procedures are adhered to and that trades are being allocated in a fair and equitable manner. Trade Rotation To help ensure equal investment opportunity for all clients, we have implemented a regular rotation in the order by which trades are placed at each Custodian. The order in which trades are executed at each Custodian is sequentially rotated for each regular trading cycle. Trading cycles generally occur on a daily, weekly, and quarterly basis. In situations where it is beneficial for one or more Client to purchase or sell a security (limited investment opportunities), we will allocate the opportunity proportionally among the eligible clients. Our proprietary accounts and personal accounts will not be traded in a favorable manner over client accounts. Trade Error Policy We have the responsibility to process orders correctly, promptly, and in your best interest. The purpose of our trade errors policies and procedures is to identify and correct any trade errors as promptly as possible without disadvantaging you or benefiting us in any way. Examples of trade errors may include: 23 April 14, 2026 Form ADV 2A  • Purchase or sale of an incorrect or unintended security or number of securities for a client; • Purchase or sale of a security for the incorrect or unintended client; • Purchase or sale of a security that was not authorized by you or is inconsistent with applicable law or regulations (e.g. prohibited transaction under ERISA); • Purchase or sale transpositions (where an intended purchase is entered as a sale, or vice versa); and • Trade misallocations. In most cases, we can correct all trade errors through an error account with the applicable Custodian. If a trade error does occur and a trade correction is needed, we will not pass the costs (including any losses) on to you, will bear all costs associated with correcting the trade error, will not use Soft Dollars to pay for correcting the trade error, and will not use another client’s account to correct the trade error. If a trade error results in a gain, the gain will be given to charitable causes. When we act as a subadvisor for a third-party investment advisor, the trade error policies and procedures of the third-party investment advisor will apply if a trade error occurs. However, if it is our trade error, the trade error will be corrected through our error account at the client’s custodian. Item 13: Review of Accounts Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Your assigned investment advisor representative reviews your accounts at least annually, unless you engaged us for one-time, project-based services. These individuals are instructed to review your investments based on your investment policies, risk tolerance, and investment objectives. All of our clients are assigned to these reviewers. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic, or political events, or when requested by you due to changes in your financial situation (such as retirement, termination of employment, physical move, or inheritance). Content and Frequency of Regular Reports Provided to Clients Clients receiving our discretionary investment management services will be provided with reports from the custodian on a monthly or quarterly basis. These are written reports that details your account including transactions, fees and commissions, assets held and asset value. Clients that engage us for certain specialty solution offerings, such as the financial planning solution, may be provided with a financial plan or written report based on the scope of the agreed upon advisory services. Generally, after the delivery of these advisory services, there are no further reports provided to you. You may request additional plans or reports for an additional fee. 24 April 14, 2026 Form ADV 2A  Item 14: Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) We do not have arrangements to compensate third parties for making solicitations on our behalf. Compensation to Non – Advisory Personnel for Client Referrals We do not compensate individuals and/or entities in exchange for providing client referrals, as described below. Item 15: Custody Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, including any arrangement or authorization that gives an investment advisor authority to effectuate transactions in client accounts, for purposes other than authorized trading and as it pertains to third-party transfers of client assets, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. We are deemed to have custody of client assets since we have management fees deducted directly from client accounts and paid to us. Additionally, we are deemed to have custody of client assets based on specified language contained within your advisory agreement with us, describing that you authorize us to give instructions to the broker-custodian and that you authorize the broker-custodian to follow our instructions and cause the instructions to be carried out. This language, as it appears in your advisory agreement, is not indicative of any particular instruction that may be delivered to the broker-custodian, nor that we will in fact cause any instruction to be delivered to the broker-custodian. Accordingly, regulators have determined that certain powers instilled in an investment adviser, by way of any letter of instruction, authorization, or other similar agreement, permitting an investment adviser to effectuate transactions for any purpose other than authorized trading, as it pertains to third- party transfers of client assets, are regarded as having custody of client assets – regardless of whether any action is in fact initiated by the investment advisor. However, any arrangement or authorization, as contemplated above, in which the investment advisor does not have discretion as to the payee, timing of the transfer(s), or the amount being paid will not be deemed, by regulators, as the investment adviser having custody of client assets. Moreover, it should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. Funds and securities must be maintained by a custodian, either in a separate account for you in your name or in accounts containing only funds or securities of our clients under our name as 25 April 14, 2026 Form ADV 2A  agent/trustee for you. You, or an independent representative of you, will direct, in writing, the establishment of all accounts and therefore are aware of the custodian’s name, address, and the manner in which the funds or securities are maintained. We will establish reasonable belief that your custodian is sending account statements at least quarterly to you and that the account statements identify the amount of funds and of each security in the account at the end of each quarter, as well as all transactions in the account during the quarter. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, you should contact us or the custodian preparing the statement. Item 16: Investment Discretion Discretionary authority is pre-approved authority for us and the subadvisor or co-advisor to act according to our own judgment in making investment decisions on your behalf without receiving prior authorization for each investment transaction. Discretionary authority is not required for decisions regarding the timing of an investment or the price at which the investment is bought or sold but, rather, the authority to decide whether to buy or sell, which securities to transact, and the number of shares or units to transact. Prior to any transaction being implemented for you using discretionary authority, written authorization will be received from you in the signed advisory agreement. Also, you will sign an agreement with your custodian which generally includes a limited power of attorney granting the necessary authority to direct and implement the investment and reinvestment of the assets in your account, but restricts our ability and the ability of the subadvisor or co- advisor to direct assets outside of your account. We generally do not have discretionary authority to determine the broker, custodian, or the commission rates paid for transactions. You may also grant us discretionary authority to establish and terminate a relationship with a subadvisor for purposes of managing the account or a portion of the account. In this situation, you will grant the subadvisor selected by us with discretionary authority (at the sole discretion of the subadvisor without first consulting with you) for such portion of the account managed by the subadvisor. Although discretionary authority may be granted on most accounts, it may not be used for certain trades, in which case we will be required to contact you to accept or reject our recommendations prior to implementing changes in your account. After you agree to the terms of the trades, we will be responsible for making decisions regarding the timing of buying or selling an investment, and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis and we are not able to reach you, it can have an adverse impact on the timing of trade implementations and we may not achieve the optimal trading price. 26 April 14, 2026 Form ADV 2A  Item 17: Voting Client Securities We do not vote client proxies. Custodians will forward the proxy voting materials directly to you. All questions on these materials should be directed to the issuers of the associated securities. We, in our discretionary authority over the investment management of your assets, may participate in certain corporate actions as necessary. As a fiduciary, a decision to participate in such corporate actions will only consider what result is in your best interest. In any event where we participate in a corporate action on your behalf, all relevant records will be documented, including the details on the basis for the action taken. Item 18: Financial Information We are required to provide you with certain financial information or disclosures about our financial condition if we have financial commitments that impair our ability to meet contractual and fiduciary commitments to our clients. We have not been the subject of a bankruptcy proceeding and do not have any financial commitments that would impair our ability to meet any contractual or fiduciary commitments to you. 27 April 14, 2026 Form ADV 2A