USA FINANCIAL EXCHANGE

EXCHANGE USA Financial Exchange Investment Advisor Disclosure Brochure This brochure provides important information about the qualifications and business practices of USA Financial Exchange, LLC. If you have questions about the contents of this brochure, please contact our compliance department at (888) 407-8198. The information contained in this document has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. This brochure is updated as of March 25, 2026. Additional information about USA Financial Exchange is also available on the SEC's website at www.adviserinfo.sec.gov. Please consider carefully before becoming a client. USA Financial Exchange is an SEC registered adviser, SEC File No. 801-107771. SEC registration does not imply a certain level of skill or training. USA Financial Exchange 6020 E. Fulton St., Ada, MI 49301 www.usafinancial.com/usaf-exchange EX-DB-14 Page 1 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE ITEM 2: MATERIAL CHANGES Date of last annual update: September 18, 2025 Date of this update: March 2026 This section summarizes the material changes made to this Firm Brochure since the last annual update. USA Financial Exchange (“USAFEX”) recommends that all clients review these changes carefully and contact us with any questions. Summary of Material Changes Since the previous update, the following material changes have been made: Item 4 – Advisory Business: USAFEX has added new information regarding the availability of J.P. Morgan Asset Management (JPMAM) model portfolios and the 55ip Direct Indexing program on the USAFEX platform. Item 5 – Fees and Compensation: Fee information, billing methodology, and platform minimums applicable to the newly added JPMAM and 55ip Direct Indexing offerings have been added and clarified. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss: Additional disclosures have been included describing the investment methodologies, operational processes, and associated risks for JPMAM strategies and the 55ip direct indexing program. Item 10 – Other Financial Industry Activities and Affiliations: New disclosures have been added regarding: • The Growth Keeper Program, including conflicts of interest related to production based incentives and Signature Strategies; and • The Signature Strategies section on the USAFEX platform, including potential revenue based conflicts. • The TruChoice referral and distribution relationship, describing affiliated entity compensation arrangements and associated conflicts of interest. Please read the remainder of this brochure for important information and disclosures related to USA Financial Exchange’s investment advisory activities. Also, you can find our Form CRS in this document or on our website at www.usafinancial.com/usaf-exchange. The Form CRS Relationship Summary provides simplified disclosures and information related to how you can engage with our firm and what conflicts or disclosures you should be aware of when working with us. The website contains the expanded disclosure information that could not fit within Form CRS's page-limit confines. You may request a copy of our Brochure by contacting the compliance department at (888) 407-8198. Additional information about our firm is also available via the SEC’s website, www.adviserinfo.sec.gov. EX-DB-14 Page 2 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE TABLE OF CONTENTS Item 2: MATERIAL CHANGES ...........................................................................................................................................................2 Item 4: ADVISORY BUSINESS .............................................................................................................................................................4 Item 5: FEES AND COMPENSATION ..................................................................................................................................................7 Item 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................................10 Item 7: TYPES OF CLIENTS ...............................................................................................................................................................10 Item 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..............................................................10 Item 9: DISCIPLINARY INFORMATION .............................................................................................................................................13 Item 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS AND OTHER CONFLICTS OF INTEREST ..........................................................................................................................14 Item 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ..................................................................................................18 Item 12: BROKERAGE PRACTICES ...................................................................................................................................................19 Item 13: REVIEW OF ACCOUNTS ......................................................................................................................................................20 Item 14: CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................................................20 Item 15: CUSTODY ...............................................................................................................................................................................20 Item 16: INVESTMENT DISCRETION ...............................................................................................................................................21 Item 17: VOTING CLIENT SECURITIES .............................................................................................................................................21 Item 18: FINANCIAL INFORMATION ..............................................................................................................................................21 EX-DB-14 Page 3 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE ITEM 4: ADVISORY BUSINESS A. USA Financial Exchange was created in January 2016 and is an investment adviser with the U.S Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). USA Financial Exchange’s registration was approved on May 18, 2016. USA Financial Exchange is owned by USA Financial, LLC. USA Financial, LLC is owned by WalEnd, Ltd. and AL Marketing, LLC, a subsidiary of AmeriLife Group, LLC (“AmeriLife”). Detailed information regarding our owners, directors, and officers can be found by visiting: www.adviserinfo.sec.gov. USA Financial Exchange’s core business is to offer operational support services (such as technology and marketing), and a turnkey asset management program to independent, registered investment advisers (“RIAs”) for use with their clients (the “Clients”). B. USA Financial Exchange provides registered investment advisors with a range of advisory and support services that investment advisors and their representatives use in servicing their Clients. Turnkey Asset Management Platform “TAMP” USA Financial Exchange offers the ability for Registered Investment Advisors and their representatives to invest client assets in two manners: Advisor Platform Manager (“APM”) or use USA Financial Exchange as a turn-key asset management platform (“TAMP”). Investment advisors and their representatives are able to utilize both functions of the USA Financial Exchange platform individually, or, in combination within client accounts. The independent registered investment advisers that utilize the USA Financial Exchange platform are responsible for ensuring that all investments are in their client’s best interest and for performing suitability related to transactions and money-manager selection. At the time an account is opened, each investment adviser is responsible for obtaining each client’s financial information, as well as information regarding their situation and investment objectives, as well as inquiring as to whether each client needs to place any reasonable restrictions on the management of their account. Each investment adviser is also responsible for implementing any reasonable restriction requests. It is important to communicate information that could impact each client’s financial situation with their respective investment adviser. USA Financial Exchange urges clients to communicate any important information to their financial adviser immediately. At least annually, each investment adviser is responsible for contacting all Clients to determine whether there have been any changes in their financial situation or investment objectives and whether clients wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. At least quarterly, investment advisers are responsible for notifying Clients in writing to contact the investment adviser if there have been any changes in the Clients’ financial situation or investment objectives, or if the Clients wish to impose any reasonable restrictions on the management of their accounts or modify any existing restrictions. Turnkey Asset Management Platform “TAMP” USA Financial Exchange also operates as a turn-key asset management platform. A TAMP is a collection of money managers made available to investment professionals through a single platform. The goal of a TAMP is to make investing client assets more streamlined and efficient. For example, if a client wants to invest with three different money managers, instead of opening three separate accounts – one direct with each money manager – the client can open one account through the TAMP and hold all of three money managers within one account. Not all TAMPs offer the same collection of money managers. USA Financial Exchange identifies and conducts due diligence on each money manager before they are included in the TAMP. USA Financial Exchange provides ongoing due diligence on each manager as well. Although USA Financial Exchange does not provide individualized investment advice to retail clients, the firm exercises discretion in selecting and monitoring third-party managers available on the platform. EX-DB-14 Page 4 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Advisor as Portfolio Manager “APM” Representatives of investment advisors are able to allocate client assets to a specific sleeve within a client account that is set aside from the rest of the assets in the account and protected from the impact of trades placed by money managers. APM provides the investment adviser the ability to purchase a variety of individual holdings within a client account. The investment adviser can invest these assets in holdings that are specific to the client’s individual investment objectives. The investment adviser bears the responsibility of determining the appropriateness of the investment decisions made in individual client accounts, as well as explaining the risks associated with these investment decisions and recommendations. Direct Indexing Co-Advisory Program (J.P. Morgan Asset Management & 55ip) As part of our turnkey asset management platform, we offer access to a tax smart direct indexing separately managed account (SMA) program (the “Direct Indexing Co Advisory Program”). This program represents a limited portion of our overall advisory services and is designed primarily for clients with taxable accounts seeking index like exposure with enhanced tax management features. The program is delivered through a co advisory structure involving J.P. Morgan Asset Management (“JPMAM”) and 55ip, an unaffiliated financial technology provider. JPMAM serves as the portfolio manager for the direct indexing SMA, responsible for index design, security selection, portfolio construction, and day to day management of the strategy. JPMAM integrates its investment expertise with the tax smart technology provided by 55ip to enable customization, tax smart transitions, and systematic portfolio management within the strategy. 55ip provides the automated tax management engine—including systematic, year round tax loss harvesting, portfolio transition analysis, and customization tools such as factor or ESG aligned exclusions. These tools allow the underlying SMA manager to identify and execute potential loss harvesting opportunities at the individual security and tax lot level, enhancing clients’ potential after tax outcomes. We provide the platform through which advisers and their clients may access the Direct Indexing Co Advisory Program. Our responsibilities include due diligence, program availability, account onboarding, and supervisory oversight, as well as coordination among JPMAM, 55ip, and the approved custodians. We do not manage the SMA directly; rather, we make the program available as one of several investment options supported on our platform. Our onboarding integration with 55ip and custodians such as Charles Schwab enables streamlined implementation and account servicing for advisers and clients using this strategy. The Direct Indexing Co Advisory Program is generally intended for taxable accounts and clients seeking tax sensitive portfolio management solutions. Minimum account sizes generally begin around $100,000, though minimums vary by custodian and strategy and may change without notice. The program’s tax management features do not guarantee improved after tax results. Neither JPMAM nor 55ip provides individualized tax or legal advice, and clients should consult their personal tax professionals prior to participating. A description of fees associated with this program appears in Item 5 (Fees and Compensation). A description of risks and investment methodology for direct indexing appears in Item 8 (Methods of Analysis, Investment Strategies & Risk of Loss). Operational Support Services USA Financial Exchange offers operational and back-office support to investment advisers looking to operate independently through third-party service providers and additional services USA Financial Exchange makes available directly to the investment adviser. USA Financial Exchange leverages our technology- vendor relationships to provide investment advisers with comprehensive and fully-integrated technology tools designed to enhance the Clients’ participation in the investment process and understanding of their overall portfolio. EX-DB-14 Page 5 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE C. USA Financial Exchange does not provide investment advice directly to any Clients nor does the firm review or supervise investment advisory transactions recommended by investment advisers. A Client’s investment adviser determines which services offered by USA Financial Exchange to use and which managers in the TAMP to utilize with their Clients. Investment advisers may use the services of other third-party providers in connection with the services provided by USA Financial Exchange. Therefore, Clients should consult their investment adviser’s Form ADV Part 2 for a full description of that investment adviser’s specific use of USA Financial Exchange’s services. Given that USA Financial Exchange’s business relationships are strictly with the investment advisers, the firm does not interact with the Clients and the firm does not have any clients, other than investment advisers. USA Financial Exchange simply manages the managers. In all cases, it is the responsibility of the investment adviser, together with its Client, to gather the pertinent financial and demographic information to develop the investment plan that meets the Client’s goals and objectives. The investment adviser will use the TAMP to allocate the Client’s assets among the available investment options. It is the investment adviser’s responsibility to determine that the asset allocation and investment options are suitable for the Client. Also, it is the investment adviser’s responsibility to provide clients with the necessary disclosure documents, including each chosen Subadviser’s ADV Disclosure Brochure. All subadvisers’ ADV Disclosure Brochures can be found at www.usafinancial.com/forms-and-disclosures. USA Financial Exchange determines which subadvisers to make available for investment on the TAMP and which subadvisers to remove from the platform. USA Financial Exchange enters into subadvisory agreements with each manager/subadviser in the TAMP. Investment advisers may independently identify subadvisers for participation in the TAMP. USA Financial Exchange may enter subadvisory agreements with those managers once the firm has completed due diligence and determined that the subadviser can be included in the TAMP. The decision to add or remove any subadviser from the TAMP is made in USA Financial Exchange’s sole discretion. Each subadviser has responsibility for trading the accounts invested in accordance with that manager’s strategy. In some cases, USA Financial Exchange may take orders directly from the subadviser and execute those orders on the subadviser’s behalf. USA Financial Exchange periodically performs due-diligence reviews on platform subadvisers to ensure they adhere to established goals and standards. As part of the due diligence, USA Financial Exchange reviews information relating to the subadviser including, historical performance, investment philosophy, investment style, volatility, and disclosures contained in the subadviser’s regulatory filings such as Form ADV. If a subadviser is consistently deviating or underperforming compared to other similarly-situated subadvisers, the firm will address our concerns with the subadviser and if the concerns are not rectified or, are not rectifiable, USA Financial Exchange will remove the subadviser from the platform. If this occurs the subadviser will typically be removed from the platform with 90 days’ notice to the investment advisers using that subadviser. However, under extreme circumstances, USA Financial Exchange reserves the right to remove a manager from the platform immediately. Many of the subadvisers create investment strategies where the subadviser constructs an asset allocation and selects the underlying investments for each portfolio. From time to time, USA Financial Exchange may replace strategies or their subadvisers or hire new subadvisers to create strategies. Therefore, USA Financial Exchange cannot guarantee the continuous availability of any particular subadviser or strategy. Amplify Platform USA Financial Exchange utilizes the Amplify Platform. The Amplify Platform provides back-office operational support services such as administrative, trading and reporting services and/or gain access to and select from independent third-party managers available through the Amplify Platform. USA Financial Exchange is considered a Platform Member. Platform Members may choose to receive certain back-office services, such as administrative, trading and reporting services and/or to select independent third-party managers to manage underlying client assets on a sub-advisory basis. Platform Members may choose to allocate all or a portion of their underlying EX-DB-14 Page 6 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE client’s assets among the different independent investment managers available through the Amplify Platform on a discretionary basis. USA Financial Exchange does not make investment decisions for individual clients. Each client is invested according to the recommendations made by the representative on their account(s). Amplify provides access to an online portal where clients can view their accounts. This portal enables clients to see the holdings in their account and generate certain reports regarding performance, values, and account history. Amplify provides account opening services in conjunction with Docusign. Amplify provides the technical infrastructure to enable representatives to complete account opening documentation online and obtain online client signatures. Amplify provides reporting services, including performance reporting. The performance reporting calculated by Amplify is believed to be correct, however, in the event of a discrepancy, the account information provided in the statement from the account custodian will prevail. More information regarding the methodology used to arrive at performance figures can be found accompanying each individual report. USA Financial Exchanges requires investment advisers to utilize the various services available through the Amplify Platform. Therefore, a portion of the fees clients incur is paid to the Amplify platform by USA Financial Exchange for these services. D. USA Financial Exchange does not sponsor a wrap-fee program. All accounts across all custodians are set up on a non-wrap fee schedule. E. As of December 31, 2025, USA Financial Exchange maintained approximately $1,635,901,063.61 in discretionary Assets Under Management on the platform. USA Financial Exchange does not provide investment advice directly to clients. USA Financial Exchange curates a TAMP with full authority to determine which investment advisers and strategies to offer for investment on the platform. ITEM 5: FEES AND COMPENSATION A. The overall fee clients pay for maintaining an account with USA Financial Exchange has three components, identified in more detail, below: the Advisor Fee, Management Fee, and Custodian Fee. The Advisor Fee, while assessed as a single fee, is comprised of the USA Financial Exchange Platform Fee and the APM Fee. The Management Fee is comprised of the Strategy Fee and Portfolio Fee. The Custodian Fee is reflective of the fees charged by the account custodian. Together, these fees represent the total platform and advisory costs associated with maintaining an account on USA Financial Exchange. ADVISOR FEE MANAGEMENT FEE CUSTODIAN FEE ACCOUNT SIZE PLATFORM FEE APM FEE STRATEGY FEE PORTFOLIO FEE CUSTODIAN FEE $0 - $250,000 0.25% $251,001 - $500,000 0.24% $501,001 - $1,000,000 0.23% 0.10% for all holdings designated as APM $1,000,001 - $2,000,000 0.22% $2,000,001 - $3,000,000 0.21% Platform users generally charge a management fee. These fees are established by the representative and may vary. Maximum portfolio fee: 1.5% Investors are able to open accounts at various custodians. These fees are set by the custodian and are not controlled or charged by USA Financial Exchange. Strategy fees are determined by the Investment Advisory Firm managing the strategy. For specific strategy fees, please review each firm's ADV or the strategy allocation form submitted with each account. $3,000,001 and up 0.20% EX-DB-14 Page 7 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Platform Fee USA Financial Exchange charges each client a tiered Platform Fee based on the assets in each account (with a tiered fee schedule, different asset levels are assessed different fees). The maximum platform fee is 0.25%. Platform Fees are assessed monthly in arrears and deducted directly from the client’s account. Advisor as Portfolio Manager (APM) Fee While TAMPs, including USA Financial Exchange, are most commonly used to facilitate diversity of investment strategies in a single account, investors may elect to set aside certain holdings that are managed separately for a variety of reasons including tax management or legacy equity positions. These assets are set aside in a channel referred to as Advisor as Portfolio Manager (“APM”). Assets in the APM channel are assessed a fee of 0.10%. Strategy Fee In addition to the Platform Fee, subadvisers (the third-party money managers who manage your assets) on the platform will also charge a fee (“Strategy Fee”). The Strategy Fee you pay depends on which subadviser selected. Some subadvisers provide USA Financial Exchange with a share of their revenue based on breakpoints – this does not increase the fee clients are charged; the subadviser simply provides USA Financial Exchange with a portion of the fee it collects. Not all managers pay revenue share to the firm. This revenue sharing arrangement provides an incentive for USA Financial Exchange to promote certain managers over others that do not have a revenue-sharing arrangement with the platform. Advisers should evaluate available money managers and strategies independently. A list of the strategies available on the USA Financial Exchange platform and their fees can be found at: Amplify Platform (https://app.amplifyplatform.com/_f/xibplod4/programmanagers) Direct Indexing Co Advisory Program (J.P. Morgan Asset Management & 55ip) MINIMUM FEE STRATEGY NAME JPM Tax Smart – Int’l Developed ADR Index $250,000 0.25% JPM Tax Smart – US All Cap Index $250,000 0.25% JPM Tax Smart – US Focused Large Cap Index $100,000 0.25% JPM Tax Smart – US Large Cap Index $250,000 0.25% JPM Tax Smart – US Large-Mid Cap Index $250,000 0.25% JPM Tax Smart – US Large Cap Value Index Strategy $250,000 0.25% Portfolio Fee Additionally, each investment adviser will charge an advisory fee (“Portfolio Fee”) for the services provided to clients. The Portfolio Fee is assessed by investment advisers and investment adviser representatives receive a portion of it. The Portfolio Fee covers service provided to clients by their financial adviser: investment advice, account monitoring, etc. USA Financial Exchange does not receive any portion of the Portfolio Fee assessed by an investment adviser. The Portfolio Fee and all other relevant fees and charges should have been disclosed to clients by their investment adviser during the new-client and/or new-account process and EX-DB-14 Page 8 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE incorporated into a written advisory agreement which each client would have signed. Clients should also refer to their investment adviser’s Form ADV 2A and the adviser’s fee schedule. Fees paid to each investment adviser in the form of an Portfolio Fee are in addition to the fees paid to USA Financial Exchange. Portfolio fees can vary and are negotiated fees between the investment adviser, investment adviser representative and the client. These negotiated fees can take into consideration the value of the total relationship among other criteria determined by the investment adviser. The fee charged for financial planning and related consulting services will be agreed upon and memorialized in the Investment Management Agreement. The maximum Portfolio fee on the USA Financial Exchange platform is 1.5% Custodial Fees The custodian selected for each USA Financial Exchange account will charge fees, such as a custodial fee, on a non-wrap basis directly to each account. Each custodian is different and charges varying fees for varying services provided to each account such as custody, trades, wire services, etc. USA Financial Exchange does not receive a portion of this fee. Fees are assessed based on the month end value of an account. The combined platform, strategy, and adviser fee is not permitted to exceed 2.7% plus custodial and transaction fees, though the exact fee varies depending on the adviser and selected strategy. Additional Charges Each custodian’s service fees are assessed on transaction activities and services outside standard asset custody and trading. These fees are assessed by the custodian and may vary and change depending on the services requested. USA Financial Exchange also offers Advisor Managed Portfolios with separate advisory fees and transaction charges (“Non-Wrap Account”). As such, in addition to the monthly account fee described above for advisory services, clients will also pay separate per-trade transaction charges. USA Financial Exchange facilitates multiple ways for a client to invest their assets using either an advisory managed portfolio or the USA Financial Exchange TAMP platform for access to third party money managers. Client accounts may include mutual funds, exchange traded funds and other pooled investment vehicles invested in the account also have their own internal fees (“internal fund expenses”) which are separate and distinct from the account fees disclosed herein. For more information on these fees, see the applicable fund prospectus. Investment advisers and their clients should consider the overall fees and expenses, including internal fund expenses, when selecting managers and other portfolio investments. For further details, please see the applicable Third-Party Money Manager’s disclosure brochures, investment advisory contracts and account opening documents. Please note that if a chosen subadviser utilizes no-transaction-fee funds (“NTFs”), Clients could be charged redemption fees for early withdrawal. For example, if Subadviser A utilizes NTFs and a Client chooses Subadviser A and invest assets today, one week from today, Subadviser A could rebalance the account and sell the NTF positions. This could result in redemption fees because the Client did not hold the NTF for the requisite holding period. Account management is controlled by the subadviser, therefore, these charges would be out of USA Financial Exchange’s control. Fee Labels USA Financial Exchange offers accounts through various custodians. Investors are charged the Advisor Fee, Management Fee and Custodian Fee. The language used to label these fees on account statements will vary based upon the custodian selected. B. Fees are deducted from client accounts by the custodian and directed to the appropriate fee listed above. Fees are deducted monthly in arrears. C. In addition to the fees mentioned in Item A., clients will incur trade costs for the trades placed in their account. Client accounts are traded along with assets from the accounts of other clients if possible, thereby reducing the trade-related costs incurred by each client. When client accounts are traded individually, oftentimes when reallocating to an alternative investment strategy, trade costs may be higher as there is not an opportunity to share proportionately with other clients engaged in the same trades. EX-DB-14 Page 9 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE D. USA Financial Exchange collects fees monthly in arrears. E. USA Financial Exchange enters into agreements with investment advisers and their representatives that wish to use the USA Financial Exchange platform. These investment advisers and their representatives are independent and not registered with USA Financial Exchange. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT USA Financial Exchange does not charge performance-based fees nor do we engage in side-by-side management, which occurs when an adviser manages accounts that are charged a performance fee and accounts that are charged another type of fee (such as hourly or flat fees) at the same time. USA Financial Exchange receives a portion of the assets under management fee clients pay – rather than performance-based fees, hourly fees, or flat fees. ITEM 7: TYPES OF CLIENTS USA Financial Exchange provides its investment services to independent investment advisers. USA Financial Exchange does not work directly with individual retail clients. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. USA Financial Exchange does not provide direct investment advice or directly manage client assets. As mentioned above, USA Financial Exchange determines the managers and strategies available on the platform; each manager is responsible for providing investment advice and managing client assets as it relates to the managers investment strategies. Instead, USA Financial Exchange provides due diligence assessments of third-party managers. As part of the due diligence, the firm reviews information relating to the third-party manager including, historical performance, investment philosophy, investment style, volatility, and disclosures contained in the manager’s regulatory filings such as Form ADV. Although USA Financial Exchange provides due diligence on the third-party managers, it is up to the investment advisers and financial advisers, and not USA Financial Exchange, to determine if a third-party manager’s strategy is suitable for each client. It is also important to understand that if clients are utilizing any money managers (through USA Financial Exchange’s TAMP or otherwise), purchasing investments, or implementing investment advice, investing in securities involves a very real risk of loss. The market moves – often drastically and without notice – and therefore, it is important that clients understand the risk they are taking, and they need to be willing and able to bear that risk. USA Financial Exchange’s due diligence does not guarantee superior performance or lower risk. Direct Indexing Co Advisory Program (J.P. Morgan Asset Management & 55ip) The Direct Indexing Co Advisory Program uses a combination of index based portfolio construction and systematic tax management technology. J.P. Morgan Asset Management (“JPMAM”) manages the SMA using an index replication methodology designed to provide broad market exposure and index like return characteristics, while integrating customization constraints and risk controls. 55ip supplies the technology overlay that employs ongoing, automated tax loss harvesting, evaluates tax lot–level opportunities, and facilitates customization options such as factor tilts, exclusions, or legacy asset coordination. This technology seeks to improve clients’ after tax outcomes, although no tax results are guaranteed. Because the Program incorporates active tax management techniques, portfolios may differ from the underlying benchmark, introducing tracking error risk. The degree of customization, tax budget constraints, and frequency of tax loss harvesting can increase these deviations. 55ip notes that while frequent tax loss harvesting may add value, it can also create structural differences relative to the benchmark and requires technology to balance tracking error with tax benefits. EX-DB-14 Page 10 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Clients should understand that all investing involves risk, including the risk of loss of principal. Key risks specific to this Program include: • Market and Equity Risk: Portfolio values may decline due to broad market movements. • Tracking Error Risk: Customization and tax loss harvesting may cause the SMA to diverge from index performance. • Tax Management Limitations: Harvested losses may not always result in net tax benefits and may be limited by wash sale rules, future gains, and the client’s tax position. • Technology & Automation Risk: The Program relies on algorithmic processes for loss harvesting and optimization; errors, delays, or system limitations could affect outcomes. • Transition Risk: Transitioning legacy holdings into the direct indexing model may generate taxable gains and may require multi period or tax budgeted transitions. Neither our Firm, JPMAM, nor 55ip provides individualized tax or legal advice. Clients should consult their personal tax professionals when evaluating the potential tax impact of the Program. (JPMAM has publicly stated that it does not provide tax, legal, or accounting advice.) Risk Disclosures Capital Risk Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100 percent of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. Credit Risk Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk. Currency Risk Fluctuations in the value of the currency in which your investment is denominated may affect the value of your investment and thus, your investment may be worth more or less in the future. All currency is subject to swings in valuation and thus, regardless of the currency denomination of any particular investment you own, currency risk is a realistic risk measure. That said, currency risk is generally a much larger factor for investment instruments denominated in currencies other than the most widely used currencies (U.S. dollar, British pound, German mark, Euro, Japanese yen, French franc, etc.). Cybersecurity Risk The Firm is subject to cybersecurity risks, including potential breaches of its systems or those of its service providers. Cyber incidents, such as unauthorized access, data theft, system disruptions, or malware attacks, could impair the Firm’s ability to conduct operations, compromise confidential client information, or result in financial losses. While the Firm employs measures designed to reduce these risks, such measures cannot fully eliminate the possibility of a cybersecurity event Economic Risk The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. EX-DB-14 Page 11 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Financial Risk Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Higher Trading Costs For any investment instrument or strategy that involves active or frequent trading, you may experienced larger than usual transaction-related costs. Higher transaction-related costs can negatively affect overall investment performance. Inflation Risk Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest- paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Legal/Regulatory Risk Certain investments or the issuers of investments may be affected by changes in state or federal laws or in the prevailing regulatory framework under which the investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws can affect the performance of certain investments or issuers of those investments and thus, can have a negative impact on the overall performance of such investments. Liquidity Risk Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, you may experience the risk that your investment or assets within your investment may not be able to be liquidated quickly, thus, extending the period of time by which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Manager Risk The market value of an investment will fluctuate as a result of the occurrence of the natural economic forces of supply and demand on that investment, its particular industry or sector, or the market as a whole. Market risk may affect a single issuer, industry or sector of the economy or may affect the market as a whole. Market risk can affect any investment instrument, or the underlying assets or other instruments held by or traded within that investment instrument. Market Risk The market value of an investment will fluctuate as a result of the occurrence of the natural economic forces of supply and demand on that investment, its particular industry or sector, or the market as a whole. Market risk may affect a single issuer, industry or sector of the economy or may affect the market as a whole. Market risk can affect any investment instrument, or the underlying assets or other instruments held by or traded within that investment instrument. EX-DB-14 Page 12 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Operational Risk Operational risk can be experienced when an issuer of an investment product is unable to carry out the business it has planned to execute. Operational risk can be experienced as a result of human failure, operational inefficiencies, system failures, or the failure of other processes critical to the business operations of the issuer or counter party to the investment. Past Performance Charting and technical analysis are often used interchangeably. Technical analysis generally attempts to forecast an investment’s future potential by analyzing its past performance and other related statistics. In particular, technical analysis often times involves an evaluation of historical pricing and volume of a particular security for the purpose of forecasting where future price and volume figures may go. As with any investment analysis method, technical analysis runs the risk of not knowing the future and thus, investors should realize that even the most diligent and thorough technical analysis cannot predict or guarantee the future performance of any particular investment instrument or issuer thereof. Platform Risk The Firm’s services rely on various technology systems, integrations, and third party service providers. Failures, interruptions, or deficiencies in the platform’s technology, such as trading systems, data feeds, model delivery, custodial integrations, or operational infrastructure, may impair the Firm’s ability to implement investment strategies, process transactions, or deliver services. Additionally, disruptions or failures by third party vendors or service providers could result in delays, errors, or an inability to execute advisory functions, potentially causing client harm or operational impacts. Strategy Risk There is no guarantee that the investment strategies discussed herein will work under all market conditions and each investor should evaluate his/her ability to maintain any investment he/she is considering in light of his/her own investment time horizon. Investments are subject to risk, including possible loss of principal. Subadviser Risk The Firm utilizes third party subadvisers whose investment decisions may underperform relative to their stated benchmarks, peer groups, or expectations. Subadvisers may also deviate from their published strategy, investment style, or risk parameters, intentionally or unintentionally. Such deviations or performance shortfalls may negatively affect client portfolios. Clients are further subject to the specific risks associated with each subadviser’s strategy, as described in their respective Form ADV and disclosure documents Third-Party Provider Risk The Firm relies on various third party vendors, service providers, and integration partners to support its technology platform, trading processes, data management, and overall operations. Interruptions, failures, or performance issues involving these third parties, including custodians, software providers, data sources, and operational vendors, may impair the Firm’s ability to deliver services, process transactions, or maintain accurate and timely information. Any disruption, delay, or error by a third party provider could negatively impact clients and the Firm’s operations. ITEM 9: DISCIPLINARY INFORMATION USA Financial Exchange has not been the subject of any disciplinary action. EX-DB-14 Page 13 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. USA Financial Exchange is a wholly-owned subsidiary of USA Financial, LLC. USA Financial, LLC also owns five other public-facing companies: USA Financial Securities, LLC, USA Financial Insurance Services, LLC, USA Financial Formulas, LLC, USA Financial Protocol, LLC. USA Financial Securities is an SEC-registered investment adviser and broker-dealer. USA Financial Insurance Services wholesales fixed insurance products to independent insurance agents. USA Financial Formulas is an SEC-registered investment adviser. USA Financial Protocol develops and distributes marketing and technology solutions for financial professionals. USA Financial Protocol provides business consulting and branding services to financial advisers. Michael Walters is the chief executive officer of USA Financial and all subsidiaries and Brent Enders is the president. USA Financial LLC, and therefore all subsidiaries, are owned by WalEnd, Ltd. and AL Marketing, LLC (“AmeriLife”). AmeriLife, a Florida domiciled company, specializes in marketing and distributing annuity, life, and health insurance products. Consequently, USA Financial Exchange is affiliated, through common ownership, with all entities owned by AmeriLife including insurance marketing organizations and other broker dealers and registered investment advisors. Should any party choose to conduct business with both USA Financial Exchange and AmeriLife, both entities would benefit from receiving compensation on such transactions. AmeriLife is ultimately owned by two private equity investment firms, Genstar Capital and Thomas H. Lee Partners (THL). Due to this ownership structure, potential conflicts of interest may arise. These conflicts could stem from the fact that Genstar and THLhave various other business interests and holdings that are not disclosed to USA Financial. Consequently, these other interests may potentially influence decision making processes. While we strive to act in the best interests of our clients, it is possible that the business activities of our private equity owners may occasionally affect our advisory services. To mitigate these conflicts, we adhere to strict policies and procedures designed to manage and disclose potential conflicts of interest. The same potential conflicts of interest that exist with the private equity firms, Genstar and THL, that indirectly own the majority interest in the USA Financial are possible with any of the other companies that are also indirect owners of the firm. A list of related entities and direct and indirect owners can be found at: https://reports.adviserinfo.sec.gov/reports/ADV/283466/PDF/283466.pdf B. USA Financial Exchange is not registered and does not have a pending application to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. C. USA Financial Securities Registered Investment Adviser and Broker-Dealer USA Financial Securities operates as a broker dealer in addition to a registered investment advisor. Representatives who are registered with the broker-dealer have the ability to utilize both advisory accounts and commission accounts, depending on which recommendation is most appropriate for their client. Representatives of USA Financial Securities could make recommendations for clients to open accounts through USA Financial Exchange, which would result in fees for both USA Financial Securities as well as USA Financial Exchange. These recommendations would benefit USA Financial, LLC more than if USA Financial Securities’ representatives recommended an unaffiliated money manager. USA Financial Securities Written Supervisory Procedures address these possibilities and implement stringent supervision requirements to mitigate this conflict. USA Financial Securities operates as a sub-adviser on the USA Financial Exchange TAMP. This relationship poses a conflict of interest for USA Financial Securities as USA Financial, LLC gets paid more, overall, if a representative recommends assets to be allocated to a USA Financial Exchange account. Clients are not required to implement recommendations to open a USA Financial Exchange account. EX-DB-14 Page 14 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE USA Financial Formulas USA Financial Formulas' primary objective is to eliminate human emotion from the investing process. USA Financial Formulas does this by using a step-by-step, objective stock-selection process. The firm does not use money managers. USA Financial Formulas' stock selection criteria is based on a particular portfolio's objective, and then a formula selects only those equities that meet the qualification criteria. USA Financial Formulas charges a strategy fee to investors that invest in USA Financial Formulas strategies through USA Financial Exchange. USA Financial Formulas is an affiliate of USA Financial Securities and therefore, recommending USA Financial Formulas creates a conflict of interest because USA Financial, LLC gets paid more, overall, if clients invest in USA Financial Formulas rather than other unaffiliated money managers. USA Financial Insurance USA Financial Insurance serves as both an FMO and wholesaler for many fixed annuity products, meaning, USA Financial Insurance gets paid for each annuity policy that is issued through this entity. USA Financial, LLC gets paid more overall if recommendations for annuity products are implemented using USA Financial Insurance. D. Conflicts of Interest There are, necessarily, conflicts of interest that arise in the financial services industry. A conflict of interest is anything that could cause USA Financial Exchange to place its interests ahead of the clients’. These conflicts are found everywhere in the financial industry, but USA Financial Exchange tries to mitigate them and disclose them to clients so that clients are informed. In this section, we disclose conflicts that clients should understand and consider before investing. One money manager on USA Financial Exchange, Horizon, provides revenue share on any mutual fund assets in the strategies we host in exchange for the trading and services we provide. This creates a conflict because it provides an incentive for USA Financial Exchange to recommend Horizon to clients over other managers who do not provide this revenue share. USA Financial believes this conflict is mitigates because on the firm level, the firm is not recommending money managers to clients directly: that decision is between each client and their financial professional based on which managers’ investment philosophies meet each client’s needs, goals, and objectives and the financial professional does not receive a portion of this revenue. Another conflict that clients should understand is recruiting arrangements. Recruiting arrangements in the financial services industry are not uncommon – whether the payment is up front (e.g., recruiting bonuses or forgivable loans) or ongoing (e.g., increased payouts or additional compensation through affiliated entities). To support the transition of certain investment adviser representatives joining USA Financial Securities, an affiliate firm, from other advisory firms, we may provide financial assistance and other benefits. These transition assistance arrangements are designed to help offset the costs associated with establishing their practice within USA Financial Securities. Such assistance may include, but is not limited to, funding for working capital, repayment of outstanding obligations to the representative’s prior firm, technology setup, marketing and mailing expenses, licensing and registration fees, relocation costs, office space, and staffing support. The amount and structure of transition assistance typically correlate with the size and scope of the representative’s prior business. Assistance is generally provided in the form of forgivable loans, with forgiveness contingent upon continued affiliation with the Firm over a specified period, and placement of client assets in accounts at USA Financial Exchange. These arrangements create a potential conflict of interest, as the financial professional may have an incentive to recommend that clients open and maintain accounts with the Firm to fulfill the terms of the assistance agreement and avoid repayment. We address these conflicts through disclosure and supervision of recommendations at USA Financial Securities designed to ensure that recommendations are made in the best interest of the client. EX-DB-14 Page 15 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Third Party Support Payments. From time to time the Firm may offer nominal, infrequent marketing support or business development assistance. These payments include small cash contributions (typically no more than $2,500/year/individual) intended to offset costs of client seminars, educational events, or marketing initiatives. The payments are not tied to any specific client transactions, referrals, or assets under management. Additionally, USA Financial Exchange may offer events such as seminars, conferences, and entertainment events. While believe these payments do not influence the investment advice provided to clients, they may give rise to a perceived or potential conflict of interest. Such support may create an incentive for representatives to favor or give additional visibility to the products or services offered by USA Financial Exchange. USA Financial Exchange encourages platform users to allocate assets to the USA Financial Exchange platform by providing cost reduction. Moreover, because USA Financial Exchange is affiliated with USA Financial Securities and USA Financial Formulas, we have a conflict of interest when recommending these entities to clients because it means USA Financial gets paid more than if the firm recommended other non-affiliated investment firms. Promotional Opportunities for Asset Managers. USA Financial Exchange may offer certain asset managers or third-party investment strategists the opportunity to participate in promotional activities on the USA Financial Exchange platform or at affiliated events. These opportunities may include, but are not limited to, increased visibility on the platform, participation in educational webinars, and speaking engagements at advisor-facing conferences or meetings. In some cases, these promotional opportunities are made available to managers who agree to pay additional basis points (“bps”) to USA Financial Exchange beyond standard platform fees, or for a flat cost. While these arrangements may create a perceived or actual conflict of interest, whereby managers paying higher fees receive more exposure, USA Financial Exchange does not endorse, recommend, or otherwise promote these managers or their strategies. All such content is presented as informational only, and this distinction is clearly communicated on the platform and at events. USA Financial Exchange maintains policies and procedures designed to ensure that promotional visibility does not influence the platform’s neutrality or the investment recommendations made by affiliated advisors. Advisors using the platform are encouraged to conduct independent due diligence and consider the best interests of their clients when selecting investment strategies. Affiliate Access USA Financial Exchange does not utilize investment adviser representatives – meaning that the firm has no individual financial advisers registered as representatives with the firm. However, an affiliate, USA Financial Securities, does have investment adviser representatives who may use USA Financial Exchange’s services. USA Financial Securities’ investment adviser representatives may also have access to technology not available to independent investment advisers simply based on the fact that USA Financial Securities bundles technology applications and offers it to its representatives as a package, thereby permitting USA Financial Securities to take advantage of economies of scale through the technology vendors. USA Financial Securities representatives have the ability to act as a subadviser on the USA Financial Exchange platform. Representatives are able to create their own strategies and establish the fee schedules for these strategies. Because certain representatives act as the manager in these instances, the manager fee on any of these strategies is paid to that representative. This creates a conflict of interest in the various money managers available on the USA Financial Exchange platform, as a representative affiliated with USA Financial Securities that offers their strategies would benefit from receiving additional compensation in the form of the manager/strategy fee. Therefore, representatives that offer their own strategies on this USA Financial Exchange platform may be more inclined to recommend strategies they manage over those of unaffiliated third party asset managers. EX-DB-14 Page 16 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Some independent investment advisers choose to register with USA Financial Securities as their broker dealer while maintaining their own registration as an investment adviser. As a broker dealer, USA Financial Securities has supervision obligations for each customer account. In these cases, to aide in the supervision of client accounts, USA Financial Securities requires representatives to utilize the USA Financial Exchange platform for the majority of the client assets they manage. Failure to move the majority of assets to the USA Financial Exchange platform will result in a fee to the investment adviser that is registered with USA Financial Securities. Therefore, representatives and investment advisers have an incentive to recommend accounts on the USA Financial Exchange platform. USA Financial’s affiliate, USA Financial Formulas, also offers strategies available on the USA Financial Exchange platform. USA Financial Formulas strategies charge a strategy fee for the management of the strategies. When a client invests in a strategy with USA Financial Formulas on the USA Financial Exchange platform, USA Financial, LLC receives compensation from both the platform and the strategy a client is invested in. While USA Financial Formulas and USA Financial Exchange are separate companies, the parent organization, both companies are subsidiaries of the same parent company, USA Financial, LLC. This could provide a conflict of interest as USA Financial, LLC may be more likely to encourage investment advisers to utilize strategies available from USA Financial Formulas over other, non affiliated third party money managers. Investment advisers that utilize the USA Financial Exchange platform may also recommend or be affiliated with another USA Financial, LLC affiliate, USA Financial Insurance. A recommendation that a client purchase a commission insurance product through our related insurance agency could result in a conflict of interest for USA Financial Exchange as an affiliate (USA Financial Insurance) would profit from this recommendation. Please be aware that you are under no obligation to purchase products or services recommended in connection with providing you with any platform service that we offer. Incentive Compensation Certain USA Financial Exchange Platform Users and their representatives are eligible to receive compensation based on sales incentive agreements made between USA Financial Exchange and the platform users/representatives. These incentives are based on meeting certain production goals in support of USA Financial Exchange’s long-term growth goals, but are not based on specific strategy recommendations or the purchase of specific holdings. Each platform user is responsible for the recommendations made to investors through the USA Financial Exchange platform. Growth Keeper Program - Compensation and Conflicts of Interest USA Financial, LLC administers a practice development reimbursement program known as the Growth Keeper Program. The program provides non cash benefits to participating advisory offices based on aggregated production metrics determined by USA Financial. One of the datapoints used in this calculation is the level of net new advisory assets directed to USA Financial Exchange, which operates solely as a Turnkey Asset Management Platform, USAF Exchange does not make recommendations to clients; all recommendations are the responsibility of the independent registered investment adviser (“RIA”) or investment adviser representative (“IAR”) using the platform. USA Financial may award Growth Keeper credits based on an office’s combined qualifying activity, which may include net new assets placed on the USAF Exchange platform or allocated to certain USA Financial supported model portfolios. All Growth Keeper benefits are funded and provided exclusively by USA Financial, not by USAF Exchange. Growth Keeper credits may be used only for USA Financial approved business development, technology, or practice management expenses. Credits cannot be redeemed for cash, used for personal purposes, or transferred. Conflict of Interest Disclosure: Because net new assets directed to USAF Exchange or to supported model strategies may increase an office’s eligibility for Growth Keeper benefits, IARs have a financial incentive to recommend platforms or strategies that contribute positively to these datapoints. USA Financial discloses this conflict through this Investment Adviser Disclosure Brochure. Ultimately the responsibility for recommendations remains with the platform user. The Growth Keeper Program does not increase advisory fees charged to clients. Clients do not fund the program and do not receive any direct benefit from it. EX-DB-14 Page 17 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE Signature Strategies USAFEX maintains a designated section of the platform called Signature Strategies, which includes certain model portfolios and investment programs that generate higher revenue for USAFEX and related affiliates than other available platform options. This structure creates a conflict of interest, as increased allocations to these strategies may provide greater financial benefit to USAFEX and to USA Financial, LLC. In addition, USA Financial, LLC administers the Growth Keeper Program, which may reward participating advisory offices based on aggregated production metrics that include net new assets placed on the USAFEX platform and allocations to supported strategies such as Signature Strategies. Although the Growth Keeper Program is funded solely by USA Financial, LLC—and not by USAFEX—the inclusion of Signature Strategies in the production metrics may incentivize advisers to utilize these strategies over other options. These conflicts are mitigated by the fact that USAFEX serves only as a platform and does not influence or direct client recommendations. Independent RIAs and IARs are required to act in the client’s best interest when selecting investment platforms or strategies, regardless of any firm level revenue considerations or Growth Keeper incentives. Clients do not pay higher advisory fees as a result of these arrangements and do not directly fund or receive benefits from the Growth Keeper Program. While certain strategies may generate greater revenue for USA Financial Exchange, the firm does not recommend strategies to clients and platform users remain responsible for strategy selection. TruChoice Referral and Distribution Agreement TruChoice Financial Group (“TruChoice”) is an affiliate of USA Financial Exchange (“USAFEX”). TruChoice is not a registered investment adviser and does not provide advisory services to retail clients. Instead, TruChoice acts as a marketing and distribution partner for the USA Financial family of companies and may promote USAFEX as a Turnkey Asset Management Platform (“TAMP”) to independent investment advisers. USAFEX compensates TruChoice for these promotional and referral activities through a revenue sharing arrangement. Under this arrangement, TruChoice receives a share of the revenue that USAFEX earns from net new advisory assets placed on the USAFEX platform by advisers referred through TruChoice. This compensation is based on revenue generated from platform assets rather than a fixed asset based fee. This arrangement creates a conflict of interest, as TruChoice has a financial incentive to encourage advisers it refers to utilize the USAFEX platform for advisory accounts instead of considering other available TAMPs or investment platforms. Neither TruChoice nor USAFEX makes recommendations directly to retail clients; however, clients should be aware that TruChoice receives financial benefits when advisers allocate new assets onto the USAFEX platform. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING A. Pursuant to rule 204A-1 under the Investment Advisers Act of 1940 (the “Act”), as amended, all registered investment advisers must adopt a code of ethics (the “Code”). USA Financial Exchange’s Code sets forth standards of conduct expected of advisory personnel and establishes procedures for dealing with conflicts that arise from personal trading by advisory personnel. USA Financial Exchange maintains an investment policy relative to personal securities transactions for its supervised persons. In USA Financial Exchange’s case, this means all internal employees since the firm does not utilize investment adviser representatives. Our investment policy is a subset of the Code. Additionally, USA Financial Exchange also maintains and enforces written policies and procedures designed to prevent the misuse of material, non-public information by USA Financial Exchange or any person associated with the firm or our affiliates. USA Financial Exchange will provide a copy of the code of ethics to any client or prospective client upon request. EX-DB-14 Page 18 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE B and C. USA Financial Exchange does not recommend securities to clients, in general, nor does the firm buy or sell securities for client accounts. USA Financial Exchange also does not buy or sell securities for its own accounts. ITEM 12: BROKERAGE PRACTICES A. USA Financial Exchange’s entire business model is built on making various platforms available to registered investment advisers. These services are offered through various custodians including Axos, Schwab, and Pershing. Since the firm does not work directly with individual retail clients, the brokerage or custodial relationships available to the client will depend on their independent financial adviser’s clearing or custodial agreements. However, in the event a client requests that USA Financial Exchange recommend a broker-dealer or custodian for execution or custodial services, USA Financial Exchange would recommend an affiliate, USA Financial Securities, which would result in additional compensation to a related entity and, it is possible that clients could receive services cheaper at another broker-dealer. Directed Brokerage Because USA Financial Exchange does not execute transactions for retail clients, the firm does not recommend, request, or require that a client direct us to execute transactions through a specific broker-dealer. Best Execution The Firm is obligated to ensure orders are being sent to the markets in an efficient manner and to execute any transactions in the manner it believes is in the client’s best interest. The Firm’s primary consideration with regard to purchases and sales for its clients is obtaining the most favorable execution of the transactions needed to implement client’s investment strategy. Price received on an execution is obviously an important factor in determining best execution, but it is certainly not the only factor to consider. So therefore, in addition to reviewing execution prices, the firm conducts a comprehensive review of non-price factors having a direct impact on overall execution quality. The areas reviewed include but are not limited to: 1. The custodian’s overall pricing structure, 2. The custodian’s execution capability during volatile market conditions, 3. The custodian’s response to trade corrections, requests for information and general willingness, ability, facilities and infrastructure to work with regional broker- dealer and investment advisor firms, 4. The frequency of trade errors, 5. Confidentiality of orders, and 6. The custodian’s overall financial strength and reputation. Execution may vary based on the selection of custodian. Soft Dollars The term “soft dollars” is used to describe arrangements whereby advisory firms pay for research, products, or services from a broker-dealer with client commissions rather than paying directly from the firm’s revenue. In contrast, when a firm uses its own money to pay for products or services, it is said to be using “hard dollars.” USA Financial Exchange does not participate in soft dollar arrangements. If USA Financial Exchange buys products or pays for services, we pay for those products and services out of our share of the revenue. B. TRADING PRACTICES Occasionally, a trading error may occur where either USA Financial Exchange or the investment adviser are at fault for effecting one or more erroneous securities transactions for a client’s account. If this occurs in a client’s account, the error will be corrected, and the client’s account will be restored to the same economic position had the error never occurred. In the process of restoring the account, a profit may be realized, or a loss suffered in connection with correcting this error. Neither losses nor gains realized will be passed on to the client. Custodians are limited to those USA Financial Exchange has executed an agreement with. EX-DB-14 Page 19 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE USA Financial Exchange may aggregate orders with those of other clients in a bunched trade or trades when securities are purchased or sold. For each account that the firm includes in the bunched trade, USA Financial Exchange must reasonably believe that the bunched order is consistent with the firm’s duty to seek best execution and benefit each client participating in the aggregated order. The average price per share of each bunched trade is allocated to each account that participates in the bunched trade. Accounts that participate in the same bunched trade are charged transaction costs, if applicable, in accordance with their advisory contracts. If a bunched order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation. Partial fills will be allocated in a way that does not consistently advantage or disadvantage particular client accounts and are generally filled pro-rata among participating accounts. ITEM 13: REVIEW OF ACCOUNTS USA Financial Exchange does not work with retail clients; therefore, the firm generally does not review client accounts or financial plans. All client accounts and account transactions are reviewed by the clients’ independent registered investment adviser. USA Financial Exchange strictly provides platform manager monitoring. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. USA Financial Exchange does not receive an economic benefit from anyone who is not a client for providing investment advice or other advisory services to clients other than revenue received from subadvisers, as reference above in Item 5 – Fees and Compensation. USA Financial Exchange also does not compensate anyone for client referrals. USA Financial Exchange does not consider itself a promoter for any third party money manager available for investment on the platform. While USA Financial Exchange does receive compensation for the amount of assets invested in various strategies on the USA Financial Exchange platform, the firm does not receive additional compensation for assets to be placed in strategies from one money manager over another. B. Independent investment advisers that utilize the US Financial Exchange platform are considered platform users. The Firm has entered into arrangements with certain third parties, including solicitors and promoters, who provide testimonials or endorsements in exchange for compensation. These arrangements are conducted in accordance with the Securities and Exchange Commission’s Marketing Rule (Rule 206(4)-1), which governs both cash and non-cash compensation provided to promoters. Forms of compensation may include, but are not limited to, advisory fees based on assets under management or investment amounts, flat fees, hourly fees, reduced advisory fees, fee waivers, cash awards, and other monetary or non-monetary incentives. If you are introduced to the Firm through a promoter, you will receive a separate written disclosure outlining the nature of the relationship and the compensation arrangement between the Firm and the promoter. This disclosure is intended to ensure transparency and help you make an informed decision regarding your engagement with the Firm. ITEM 15: CUSTODY USA Financial Exchange does not have custody of client assets. Client assets are held at one of the qualified custodians that has an agreement with USA Financial Exchange. The desire to use one custodian over another is up to the client or their investment advisor to decide which custodian is best to hold the assets for each account. Our firm may be authorized to request the disbursement of client funds from custodial accounts. Such disbursements are limited to transfers to the client's own address or bank account on record with the custodian. These disbursements are made pursuant EX-DB-14 Page 20 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE to standing instructions provided by the client directly to the qualified custodian. Because we do not have access to client funds or securities and the instructions meet the SEC's criteria for the "first-party transfer exception," we are not deemed to have custody of client assets under SEC rules. Clients receive statements directly from the custodian and are encouraged to review them carefully. ITEM 16: INVESTMENT DISCRETION USA Financial Exchange does not manage securities accounts on behalf of clients – discretionary or otherwise. USA Financial Exchange has discretion over which subadvisers are allowed on the platform - USA Financial Exchange has the ability to remove and replace managers on the platform in the firm’s discretion. USA Financial Exchange does not operate with client portfolio discretion, rather, the Firm exercises program level discretion by determining which money managers and strategies are available for platform user investment advisers to recommend to clients. USA Financial Exchange requires clients to identify a representative to exercise discretion over their accounts on the USA Financial Exchange platform. Clients will work with their representative to identify the scope of this authority, and each investment adviser will have their own documentation to be completed to communicate the scope of the representative’s role. Additionally, please note that because fees are pulled from the cash portion of each account, if a situation arises where fees are owed to USA Financial Exchange or the custodian and the account does not have enough cash to cover the fees, USA Financial Exchange will place trades in the account in order to generate cash to pay the fees owed. ITEM 17: VOTING CLIENT SECURITIES USA Financial Exchange does not vote client securities. ITEM 18: FINANCIAL INFORMATION USA Financial Exchange does not collect prepayment from any clients for any fees associated with an investment in an account on the USA Financial Exchange platform. EX-DB-14 Page 21 of 21 Rev. 03.25.26 IMPORTANT NOTICE: Past performance is no guarantee of future results. Your actual results may vary. Investing carries an inherent element of risk.Potential for substantial loss in principal and income exists. This material is not complete unless all pages are included.USA Financial Exchange is an SEC-registered investment advisor (SEC File No. 801-107771). SEC registration does not imply a certain level of skill or expertise. USA Financial Exchange provides access to a custodial platform for independent investment advisors, who are responsible for suitability and ensuring investments are in your best interest. USA Financial Exchange’s involvement is limited to selecting money managers for the platform; your investment advisor may utilize managers or strategies that were not selected by USA Financial Exchange. ©2026 USA Financial Exchange All Rights Reserved.EXCHANGE