VISTA INVESTMENT PARTNERS

Item 1 - Cover Page Orange Horizon Wealth, LLC One Woodside Drive Richmond, Indiana 47374 765-962-5153 2215 Perrygreen Way, Suite 3 Rockford, Illinois 61107 (815) 970-9104 www.orangehorizonwealth.com March 31, 2026 This brochure provides information about the qualifications and business practices of Orange Horizon Wealth, LLC (“OHW”). If you have any questions about the contents of this brochure, please contact us at 765-962-5153. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state authority. www.AdviserInfo.sec.gov Additional information about OHW also is available on the SEC’s website at .  Item 2 - Material Changes This brochure contains the following material changes since our last annual updating amendment: • • • • Item 4 – Added a description of investment consulting services involving principal transactions; Item 5 – Added information about fees related to investment consulting services involving principal transactions; Item 11 – Added information related to principal transactions; Items 12 and 15 – Added information related to principal transactions and removed references to Charles Schwab. Page 2  Item 3 - Table of Contents Page Item 1 - Cover Page ................................................................................................................................................................ 1 Item 2 - Material Changes ................................................................................................................................................... 2 Item 3 - Table of Contents ................................................................................................................................................... 3 Item 4 - Advisory Business ................................................................................................................................................. 4 Item 5 - Fees and Compensation ...................................................................................................................................... 6 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................................... 8 Item 7 - Types of Clients ...................................................................................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 9 Item 9 - Disciplinary Information ................................................................................................................................. 12 Item 10 - Other Financial Industry Activities and Affiliations .......................................................................... 12 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .... 14 Item 12 - Brokerage Practices ........................................................................................................................................ 15 Item 13 - Review of Accounts ......................................................................................................................................... 17 Item 14 - Client Referrals and Other Compensation ............................................................................................. 17 Item 15 - Custody ................................................................................................................................................................ 18 Item 16 - Investment Discretion ................................................................................................................................... 19 Item 17 - Voting Client Securities ................................................................................................................................. 19 Item 18 - Financial Information .................................................................................................................................... 19 Page 3  Item 4 - Advisory Business General Information Vista Investment Partners II, LLC d/b/a Vista Investment Partners (“we” or “Vista”) was formed in 2017 and provides financial planning and portfolio management services to its clients. Brett D. Guiley is the principal owner of Vista. Vista also does business as Orange Horizon Wealth, LLC (”OHW”). At the outset of each client relationship, OHW spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, OHW generally develops with each client: • • a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”); and the client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments OHW will make on behalf of the client in order to meet those goals. The Financial Profile and the Investment Plan are discussed regularly with each client but are not necessarily written documents. Portfolio Management As described above, at the beginning of a client relationship, OHW meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by OHW based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, OHW will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, OHW will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on OHW in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of OHW. Page 4  Separate Account Managers OHW may utilize one or more Separate Account Managers (each a “Manager”), when appropriate and in accordance with the Investment Plan for a client. Having access to various Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. OHW will usually select the Manager(s) that it deems most appropriate for the client. Factors that OHW considers in recommending/selecting Managers generally include the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. The Manager(s) will generally be granted discretionary trading authority to provide investment Item 8 – Methods of Analysis, advisory services for the portfolio. Pursuant to the Manager(s)’ investment authority, the Manager(s) Investment Strategies and Risk of Loss may select one or more of OHW’s investment strategies described in in varying combinations over time for a given client, depending upon the client’s individual circumstances. Under certain circumstances, OHW retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. In other cases, the client will ultimately select one or more Managers recommended by OHW. In any case, with respect to assets managed by a Manager, OHW’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio. Financial Planning OHW also offers financial planning services, as described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning may include advice that addresses one or more areas of a client’s financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation and the client’s specific needs, financial planning may include some or all of the following: • • • • • • • • • Gathering factual information concerning the client’s personal and financial situation; Assisting the client in establishing financial goals and objectives; Analyzing the client’s present situation and anticipated future activities in light of the client's financial goals and objectives; Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; Making recommendations to help achieve retirement plan goals and objectives; Designing an investment portfolio to help meet the goals and objectives of the client; Estate planning strategies; Assessing risk and reviewing basic health, life, and disability insurance needs; or Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have OHW implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by OHW under a financial planning engagement and/or engage the services of any recommended professional. Page 5  Assets in Held-away Accounts OHW provides an additional service for accounts that OHW cannot manage directly (“Held-away Accounts”), but where OHW does have discretion, and may leverage an Order Management System to implement tax-efficient asset allocation and opportunistic rebalancing strategies on behalf of the client. These Held-away Accounts are primarily 401(k) accounts, HSAs, and other assets OHW cannot directly access. OHW will regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Investment Consulting Services We offer a limited service to certain clients involving transactions in which we act as principal. In these transactions, we may purchase a specific security directly from a client and sell bitcoin to that client in a contemporaneous or related transaction. This service is offered only to a limited number of clients who meet our eligibility criteria and who provide appropriate consent. Type and Value of Assets Currently Managed As of December 31, 2025, Vista and OHW managed $383 million on a discretionary basis and $112,954 on a non-discretionary basis. Item 5 - Fees and Compensation Item 12 - Brokerage Practices Management Fee Information Clients generally enter into one of two fee arrangements. Clients may pay management fees to OHW separately from the brokerage expenses of the account. Accordingly, client accounts pay a management fee, plus the cost of transactions in the account. The brokerage expenses may take the form of asset-based pricing, meaning that the broker-dealer charges the account a flat-rate percentage to cover all brokerage expenses, or these expenses may be assessed on a per-trade basis. Please see for additional information. i.e. Portfolio Management Fees Alternatively, clients may participate in a wrap program (the “Wrap Program”) sponsored by Raymond James & Associates, Inc. (“Raymond James”) member New York Stock Exchange/SIPC. The Wrap Program fee structure includes the brokerage expenses ( , commissions, ticket charges, etc.) of the account as well as the charges for custody services and the management fee paid to OHW. Under the Wrap Program, Raymond James assesses one client fee that captures the management, brokerage, custody and administrative portions collectively. OHW receives a portion of the Wrap Program fees in accordance with the fees described below under “ .” OHW, in its sole discretion, may establish a minimum portfolio asset value size requirement for participation in the Wrap Program. In either of these arrangements, the fees noted above are separate and distinct from the internal fees and expenses charged by mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders (generally including a management fee and fund expenses, as described in each fund’s prospectus or offering materials). The client should review all fees charged by funds, brokers, OHW and others to fully understand the total amount of fees paid by the client for investment and financial-related services. Financial Planning Fees OHW offers financial planning services in conjunction with its portfolio management services for no additional fee when the client’s assets under OHW’s management equal at least $500,000. When the client’s assets under OHW’s management are less than $500,000, OHW offers financial planning services on a stand-alone separate fee basis. OHW's financial planning fees are outlined in a separate financial planning and consulting agreement between the client and OHW. Page 6  Portfolio Management Fees When one or more of OHW’s proprietary investment strategies is used with respect to an account, the maximum annual fee schedule, based on a percentage of assets under management, is as follows: Portfolio Asset Value Annual Fee Rate $0-$500,000 $500,001-$1,000,000 $1,000,001-$2,000,000 $2,000,001+ 1.50% 1.25% 1.00% Negotiable Portfolio management fees for accounts trading fixed income securities will generally be lower than those shown in the fee schedule above and will be individually negotiated with each client. When one of OHW’s proprietary investment strategies is not used with respect to an account, the maximum annual fee based on a percentage of assets under management is 2.00%. The actual fee charged is disclosed in the Investment Management Agreement entered into between OHW and each client and is individually negotiated with the client. Factors considered in determining the fees charged generally include, but are not limited to: the complexity of the client’s portfolio; assets to be placed under management; anticipated future assets; related accounts; portfolio style; account composition; or other special circumstances or requirements. Typically, OHW requires a minimum of $500,000 of investable assets from a client. There is no minimum annual fee. OHW may, at its discretion, make exceptions to the foregoing or negotiate special fee arrangements where OHW deems it appropriate under the circumstances. Portfolio management fees for accounts serviced through the Wrap Program are generally payable quarterly, in advance, while the portfolio management fees for all other accounts are generally payable monthly, in advance. Partial periods will be prorated based on the value of the Portfolio at the beginning of the period. Fees are normally debited directly from client account(s), unless other arrangements are made. Either OHW or the client may terminate their Investment Management Agreement at any time, subject to any written notice requirements in the agreement. In the event of termination, any paid but unearned fees will be promptly refunded to the client based on the number of days that the account was managed, and any fees due to OHW from the client will be invoiced or deducted from the client’s account prior to termination. Separate Account Manager Fees When one or more Managers are utilized, the Manager(s)’ fees will be included in OHW’s fee. When a Manager selects one or more of OHW’s investment strategies for a client, the client will not pay additional fees to OHW for the use of the strategy. Held-away Account Fees Investment management fees are generally debited directly from client account(s). However, it is not normally possible to debit investment management fees from Held-away Accounts, such as 401(k)’s. Fees for these accounts will normally be allocated to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account managed by OHW, fees will be billed directly to the client. Accounts initiated or terminated during a fee billing period will be charged a pro-rated fee based on the amount of time remaining in the billing period. Page 7  Investment Consulting Services Fees In connection with the limited principal transactions described in Item 4 above, we will charge a transaction fee of up to 3%. In addition, although it is not our intention, we may earn compensation through spreads or markups/markdowns between the price at which we purchase securities from clients and the price at which we sell bitcoin to clients. These amounts are not advisory fees and create a financial incentive for us to structure transactions in a manner that is favorable to us. Clients will receive disclosure of pricing prior to completing any transaction. Bitcoin Related Fees When client assets are invested in bitcoin, the client will pay fees in addition to OHW’s portfolio management fee. These fees include: a transaction fee of 30 basis points on each buy and sell transaction; and an annual administrative fee of 50 basis points based on the daily average account value of the client’s account. The administrative fee is charged monthly in arrears. Clients will pay additional fees when bitcoin is owned through an individual retirement account or similar account. These fees include an annual fee up to $250, $225 account termination fees, wire transfer, paper statement and other service fees. Clients should consider the impact of these fees before making the decision to invest in bitcoin through a retirement account. Insurance Disclosure Other Compensation : Certain employees of OHW are also licensed to sell insurance products. In providing advisory services, these individuals may recommend the purchase of products under circumstances where they would be entitled to receive a commission or other compensation in the transaction. In all such circumstances, however, the client will be notified of this payment in advance of the transaction, and under no circumstances will the client pay both a commission to an employee of OHW for an insurance product and an advisory fee to OHW on the same pool of assets. Broker Disclosure : Certain employees of OHW are also Registered Representatives of Level Four Financial, LLC (“Level Four”), a FINRA and SIPC member and registered broker/dealer. As such, these employees are entitled to receive brokerage commissions. In order to protect client interests, OHW’s policy is to fully disclose all forms of compensation before any such transaction is executed. Clients will not pay both a commission to the applicable Registered Representative and also pay an advisory fee to OHW on assets held in the same account. These fees are exclusive of each other. e.g. Furthermore, as a result of this relationship, Level Four may have access to certain confidential information ( , financial information, investment objectives, transactions, and holdings) about OHW clients, even if the client does not establish any account through Level Four. If you would like a copy of Level Four’s privacy policy, please contact OHW. Item 6 - Performance-Based Fees and Side-By-Side Management OHW does not have any performance-based fee arrangements. “Side by Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because OHW has no performance-based fee accounts, it has no side-by-side management. Item 7 - Types of Clients OHW serves individuals, pension and profit-sharing plans, corporations, trusts, estates and charitable organizations. With some exceptions, OHW requires a minimum of $500,000 of investable assets from a client for conventional investment advisory services. Under certain circumstances and in its sole discretion, OHW may negotiate such minimums. The limited principal transactions Page 8  described in Item 4 above are only available to certain individuals in appropriate circumstances. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies In accordance with the Investment Plan, OHW will primarily invest in mutual funds, ETFs, common stocks, fixed income securities, including municipal bonds, corporate bonds and collateralized mortgage obligations (“CMOs”), and other types of investments. Methods of Analysis In making investment selections for client portfolios, OHW may use any of the following types of analysis: Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to the client's investment goals and risk tolerance, and we seek to create a portfolio using mean variance optimization to maximize potential return relative to portfolio risk. A risk of asset allocation is the potential the client will miss the opportunity to participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client's goals. Mutual Fund, ETF and/or SMA Analysis. We look a variety of factors, including, as applicable and without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client's portfolio. Risks include that, as in all securities investments, past performance does not guarantee future results. A manager having success in the past does not indicate that they will have success in the future. In addition, as we do not control the underlying investments, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager will deviate from the stated investment mandate or strategy, which could make the holding(s) less suitable for the client's portfolio. Fundamental Analysis. Fundamental Analysis involves review of the business and financial information about an issuer. Without limitation, the following factors generally will be considered: • • • • Financial strength ratios; Price-to-earnings ratios; Dividend yields; and Growth rate-to-price earnings ratios Our analysis methods rely on the assumption that the investment vehicles which we recommend for our clients, the companies whose securities we purchase and sell on behalf of our clients, the rating agencies that review these securities, and other publicly or privately available sources of information about these securities, provide accurate, timely and unbiased data. While we are always looking for indications of inaccuracy in the data we use, there is always a risk that our analysis could be compromised by inaccurate, misleading or untimely information. This is an ongoing risk and could impact all the strategies discussed below. Investment Strategies Page 9  OHW’s strategic approach is to invest each portfolio in accordance with the Investment Plan that has been developed specifically for each client. As a general matter, OHW seeks to reduce volatility in its clients’ portfolios by balancing investment strategies with regard to growth and value, as well as capitalization size with respect to growth strategies. OHW further attempts to balance risk with exposure to fixed income securities. OHW has various investment strategies which it may utilize in varying combinations over time for a given client, depending upon the client’s individual circumstances. However, OHW may deviate from these strategies in its discretion and make any other investment recommendations and decisions for the client as appropriate based on the Investment Plan pursuant to OHW’s investment authority. OHW may develop new investment strategies from time to time. Set forth below are descriptions of the general investment strategies that OHW may loosely follow in managing its clients’ portfolios. Investing For Growth Strategy – client portfolios will typically hold between 15 and 25 stocks in companies that have two or more earnings estimate increases within the previous 6 months and have a return on equity that is two times the price-earnings ratio. Growth of Income Strategy – client portfolios will typically hold between 15 and 25 stocks in companies that have two or more earnings estimate increases within the previous 6 months, a yield greater than or equal to the S&P 500 Index, and have increased their dividends for at least 3 of the last 5 years. BOX Strategy – client portfolios will typically hold ETFs or mutual fund shares to balance between growth and value, periodically adjusted. Twenty First Century Balanced Strategy – client portfolios will typically hold ETFs and mutual fund shares allocated among equities, bonds, gold, bitcoin, cash and cash alternatives rebalanced periodically. Fixed Income Strategies: Tax-Free and Taxable – the portion of the client’s portfolio assets allocated to fixed income is divided among fixed income securities with varying maturity dates in an attempt to take advantage of the steepest part of the yield curve. Stock Options – typically covered calls are sold against positions to produce additional income and to fix prices that clients would be willing to reduce their positions. The options used generally are in concentrated equity positions. Balanced Market Rotation Strategy – client portfolios will typically hold one equity index ETF representing 60% of the portfolio and one bond ETF representing 40% of the portfolio, selected using a momentum test. Bitcoin – client portfolios will hold bitcoin either as a buy-and-hold long term savings strategy or managed as a target allocation in a client’s overall portfolio. Alternatively, OHW may use one or more strategic model portfolios offered by a client’s custodian in managing client portfolios. Risk of Loss While OHW seeks to diversify clients’ investment portfolios across various asset classes consistent with their Investment Plan in an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no assurance that client investment portfolios will be able to fully meet their investment objectives and goals, or that investments will not lose money. Page 10  Below is a description of several of the principal risks that client investment portfolios face. Management Risks. While OHW manages client investment portfolios, or recommends one or more Managers, based on OHW’s experience, research and proprietary methods, the value of client investment portfolios will change daily based on the performance of the underlying securities in which they are invested. Accordingly, client investment portfolios are subject to the risk that OHW or a Manager allocates assets to asset classes that are adversely affected by unanticipated market movements, and the risk that OHW’s specific investment choices could underperform their relevant indexes. Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, OHW or a Manager(s) may invest client portfolios in mutual funds, ETFs and other investment pools (“pooled investment funds”). Investments in pooled investment funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills of their particular managers and their performance in managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940. Equity Market Risks. e.g. OHW and any Manager(s) will generally invest portions of client assets directly into equity investments, primarily stocks, or into pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets, and that stock values will decline over longer periods ( , bear markets) due to general market declines in the stock prices for all companies, regardless of any individual security’s prospects. Fixed Income Risks. OHW and any Manager(s) may invest portions of client assets directly into fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). Foreign Securities Risks. OHW and any Manager(s) may invest portions of client assets into pooled investment funds that invest internationally. While foreign investments are important to the diversification of client investment portfolios, they carry risks that may be different from U.S. investments. For example, foreign investments may not be subject to uniform audit, financial reporting or disclosure standards, practices or requirements comparable to those found in the U.S. Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in investment or exchange control regulations. Finally, foreign investments may involve currency risk, which is the risk that the value of the foreign security will decrease due to changes in the relative value of the U.S. dollar and the security’s underlying foreign currency. Covered Calls and Puts Risks. OHW and any Managers, on behalf of its clients, may purchase or write (sell) “covered” call and put options on securities, indexes or currencies. OHW or a Manager may purchase call options for investment purposes when it is anticipated that the price of the underlying Page 11  security or currency will rise. OHW or a Manager may also purchase put options for investment purposes when it is anticipated that the price of the underlying security or currency will decline. If OHW or a Manager writes a covered call option on behalf of a client account, the client account will either own the security or currency subject to the option or own an option to purchase the same underlying security or currency having an exercise price equal to or less than the exercise price of the “covered” option. When writing a covered call option, the client account, in return for the premium, gives up the opportunity for profit from a price increase in the underlying security or currency above the exercise price, but conversely retains the risk of loss should the price of the security or currency decline. If OHW or a Manager writes a covered put option on behalf of a client account, the client account will maintain sufficient liquid assets to purchase the underlying security or currency if the option is exercised, in an amount not less than the exercise price. The risk in such a transaction would be that the market price of the underlying security or currency would decline below the exercise price, less the premiums received. Such a decline could be substantial and result in a significant loss to client accounts. To the extent OHW or a Manager acquires options that it does not exercise, it suffers the loss of the premium paid to the writer in connection with such purchase, and any gain or loss derived from the exercise of an option or other liquidation of an option is reduced or increased, respectively, by the amount of the premium paid. Closing transactions will be effected in order to realize a profit on an outstanding call option, to prevent an underlying security or currency from being called, or to permit the sale of the underlying security or currency. There is, of course, no assurance that OHW or a Manager will be able to effect such closing transactions at favorable prices. If OHW or a Manager cannot enter into such a transaction on behalf of client accounts, client accounts may be required to hold a security or currency that is depreciating in value that otherwise might have sold. Bitcoin Risks. OHW and any Manager(s), on behalf of its clients, may invest portions of client assets directly into bitcoin. Investments in bitcoin are subject to the risk that bitcoin’s value will decline due to daily fluctuations in the market, and that bitcoin’s value will decline over longer periods. The value of bitcoin can be more volatile than other assets. Bitcoin also carries risks that may be different from securities. These risks include disruptions to the Bitcoin network such as distributed denial of service (“DDoS”) attacks that could delay the settlement of bitcoin transactions or impair the value of bitcoin as an asset. The Bitcoin network may experience a hard fork, producing two or more incompatible networks which could dilute bitcoin’s market value. A hard fork may also result in conflicting opinions among market participants regarding what is, and is not, Bitcoin. Bitcoin’s characteristics as a monetary good may incentivize political jurisdictions to engage in hostile enforcement actions against it, either to defend the value of those jurisdictions’ sovereign currencies or to enforce regulations related to financial transactions. These hostile enforcement actions may be directed at Bitcoin the network, bitcoin the asset, or the technological infrastructure Bitcoin relies on, such as internet networks, energy grids, hardware devices, or cryptography techniques. The limited principal transactions described in Item 4 involving the exchange of securities for bitcoin involve unique risks, including market volatility, liquidity differences between asset classes, valuation uncertainty, and regulatory and tax law risks associated with digital assets. Item 9 - Disciplinary Information There have been no legal or disciplinary events related to OHW or any management person to disclose. Item 10 - Other Financial Industry Activities and Affiliations Certain of OHW’s employees are Registered Representatives of Level Four Financial, LLC, a FINRA Page 12  and SIPC member and registered broker/dealer. As such, these employees are entitled to receive brokerage commissions. In order to protect client interests, OHW’s policy is to fully disclose all forms of compensation before any such transaction is executed. Clients will not pay both a commission to such employee and also pay an advisory fee to OHW on assets held in the same account. These fees Item 5 – Fees and are exclusive of each other. Clients are not obligated, contractually or otherwise, to use the services Compensation of these insurance agents or Registered Representatives. Please see for more information. Insurance Products Sales Our representatives can sell other products or provide services outside of their role as investment adviser representatives with us. Due to the firm’s financial planning philosophy, it is common for our financial professionals to recommend that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income asset classes).You should be aware that there are a number of conflicts of interests that are present due to our planning philosophy and recommendations to utilize insurance products in this nature. Item 5 – Fees and Compensation As an estimate, our financial professionals that are registered as investment advisor representatives Item spend approximately 25% of their time on insurance sales and services and 75% of their time on 14 – Client Referrals and Other Compensation investment advisory services in the future. Please refer to and for more details. You may therefore work with your financial professional in both their capacity as an investment adviser representative of OHW, as well as in their capacity as an insurance agent. As such, your OHW financial professional, in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance products to you), and then assist you in implementing the recommendations by selling you those same products. When acting as an insurance agent, in exchange for selling you those products, the financial professional will typically be paid a commission. This recommendation that a client purchase an insurance product through them as an insurance agent presents a conflict of interest, as the receipt of commissions is an incentive to recommend products that could potentially be based on commissions rather than your personal needs and objectives. Furthermore, commissions may vary by product, and each individual product may have different commission rates, encouraging the financial professional to recommend products that may pay higher commissions over the products that make the most sense for you. In addition, insurance products may also have different payment schedules depending on the nature of the product, and the timing of the payments likely differ from that of the advisory options offered by OHW. This timing difference has the potential to create a conflict of interest since some financial professionals may have the incentive to recommend a product that pays commissions now, over an advisory product that pays fees over a relatively longer period. As an example, all other variables held equal, a 5% commission paid by an insurance company upon sale of a $100,000 annuity product, may be more attractive to a financial professional than a one percent (1%) advisory fee charged on a $100,000 account paid over a period of five (5) years, despite the overall pre-tax compensation paid to the financial professional being equal. There are other conflicts present as well. At times, our financial professionals receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or Page 13  insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of clients. Level Four provides advisors such as OHW with marketing assistance and business development tools to acquire new clients, technology with the goal of improving the client experience and our firm’s efficiency, back office and operations support to assist in the processing of insurance for clients. Although some of these services may directly benefit a client, other services obtained by us from Level Four such as marketing assistance and business development may not benefit an existing client. We have taken a number of steps to manage these types of conflict of interests. We attempt to control for these sales-related conflicts by always basing investment decisions on the individual needs of clients. As a fiduciary, we expect and require that each investment adviser representative only recommend insurance and annuities when in the best interest of the client. The sale of commission- based products is supervised by the firm’s Branch Manager, and the firm makes periodic reviews of its insurance recommendations to ensure that our financial professionals act in accordance with our fiduciary duty. If you have any questions or concerns about annuity recommendations made during the financial planning process, we encourage you to immediately bring it to the attention of the Managing Partner or the CCO. Finally, you should be aware that there are other insurance products that are offered by other insurance agents other than those recommended by our financial professionals. You are under no obligation to implement any insurance or annuity transaction through OHW. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading OHW has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request. OHW’s Code has several goals. First, the Code is designed to assist OHW in complying with applicable laws and regulations governing its investment advisory business. Under the Investment Advisers Act of 1940, OHW owes fiduciary duties to its clients. Pursuant to these fiduciary duties, the Code requires OHW associated persons to act with honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits associated persons from trading or otherwise acting on insider information. The Code sets forth guidelines for professional standards for OHW’s associated persons (managers, officers and employees). Under the Code, OHW expects its associated persons to put the interests of its clients first, ahead of personal interests. In this regard, OHW associated persons are not to take inappropriate advantage of their positions in relation to OHW clients. The Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. From time-to-time OHW’s associated persons may invest in the same securities recommended to clients. Under the Code, OHW has adopted procedures designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading policies Page 14  include procedures for limitations on personal securities transactions of associated persons, reporting and review of such trading and pre-clearance of certain types of personal trading activities. These policies are designed to discourage and prohibit personal trading that would disadvantage clients. The Code also provides for disciplinary action as appropriate for violations. Participation or Interest in Client Transactions As outlined above, OHW has adopted procedures to protect client interests when its associated persons invest in the same securities as those selected for or recommended to clients. In the event of any identified potential trading conflicts of interest, OHW’s goal is to place client interests first. Consistent with the foregoing, OHW maintains policies regarding participation by Vista associated persons in initial public offerings (IPOs) and private placements in order to comply with applicable laws and avoid conflicts with client transactions. If a OHW associated person wishes to participate in an IPO or invest in a private placement, he or she must submit a pre-clearance request and obtain the approval of the Chief Compliance Officer. e.g. If associated persons trade with client accounts ( , in a bundled or aggregated trade), and the trade is not filled in its entirety, the associated person’s shares will be removed from the block, and the balance of shares will be allocated among client accounts in accordance with OHW’s written policy. Principal Transactions We offer a limited service to certain clients involving transactions in which we act as principal. In these transactions, we may purchase a specific security directly from a client and sell bitcoin to that client in a contemporaneous or related transaction. This service is offered only to a limited number of clients who meet our eligibility criteria and who provide appropriate consent. Management of Vista reviews each client desiring to participate in these principal transactions and must provide approval before a transaction can proceed. Item 12 - Brokerage Practices Bitcoin Transactions OHW will trade bitcoin on behalf of clients using entities, including BitGo Prime LLC, that provide bitcoin trading services and are not affiliated with OHW. These entities will not maintain custody of clients’ assets and are not regulated by FINRA, or the SEC. When trading bitcoin, OHW will seek “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates, however, these factors will likely differ from factors relevant to transactions in securities. Best Execution and Benefits of Brokerage Selection When given discretion to select the brokerage firm that will execute orders in client accounts, OHW seeks “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates. Therefore, OHW may use or recommend the use of brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination), and may be used in servicing any or all of OHW’s clients. Therefore, research services received may not be used for the account for which the particular transaction was effected. OHW may recommend that clients establish brokerage accounts with Raymond James, a FINRA registered broker-dealer and member SIPC, to maintain custody of clients’ assets. OHW may effect trades for client accounts at the client’s custodian or may in some instances, consistent with OHW’s Page 15  duty of best execution and specific investment advisory agreement with each client, elect to execute trades elsewhere. Although OHW may recommend that clients establish accounts at Raymond James, it is ultimately the client’s decision where to custody assets. OHW is independently owned and operated and is not affiliated with Raymond James. OHW participates in the Raymond James Asset Management Services program. While there is no direct link between the investment advice OHW provides and participation in either program, OHW receives certain economic benefits from this program. These benefits may include software and other technology that provides access to client account data (such as trade confirmations and account statements), facilitates trade execution (and allocation of aggregated orders for multiple client accounts), provides research, pricing information and other market data, facilitates the payment of OHW’s fees from its clients’ accounts, and assists with back-office functions, recordkeeping and client reporting. Many of these services may be used to service all or a substantial number of OHW’s accounts, including accounts not held at Raymond James. Raymond James may also make available to OHW other services intended to help OHW manage and further develop its business. These services may include consulting, publications and conferences on practice management, information technology, business succession, and marketing. In addition, Raymond James may make available, arrange and/or pay for these types of services to be rendered to OHW by independent third parties. Raymond James may discount or waive fees it would otherwise charge for some of these services, pay all or a part of the fees of a third-party providing these services to OHW, and/or Raymond James may pay for travel expenses relating to participation in such training. Finally, participation in the Raymond James service program provides OHW with access to mutual funds which normally require significantly higher minimum initial investments or are normally available only to institutional investors. The benefits received through participation in the Raymond James service program do not necessarily depend upon the proportion of transactions directed to Raymond James. The benefits are received by OHW, in part because of commission revenue generated for Raymond James by OHW’s clients. This means that the investment activity in client accounts is beneficial to OHW, because Raymond James assesses a fee to OHW for these services. This creates an incentive for OHW to continue to recommend Raymond James to its clients. While it may be possible to obtain similar custodial, execution and other services elsewhere at a lower cost, OHW believes that Raymond James provide an excellent combination of these services. These services are not soft dollar arrangements, but are part of the institutional platforms offered by Raymond James. Directed Brokerage OHW does not allow directed brokerage accounts. Aggregated Trade Policy OHW may enter trades as a block where possible and when advantageous to clients whose accounts have a need to buy or sell shares of the same security. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rata basis between all accounts included in any such block. Block trading allows OHW to execute equity trades in a timelier, equitable manner, and may reduce overall costs to clients. OHW will only aggregate transactions when it believes that aggregation is consistent with its duty to seek best execution (which includes the duty to seek best price) for its clients, and is consistent with the terms of OHW’s Investment Advisory Agreement with each client for which trades are being aggregated. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all OHW’s transactions in a given Page 16  security on a given business day, with transaction costs generally shared pro-rata based on each client’s participation in the transaction. On occasion, owing to the size of a particular account’s pro rata share of an order or other factors, the commission or transaction fee charged could be above or below a breakpoint in a pre-determined commission or fee schedule set by the executing broker, and therefore transaction charges may vary slightly among accounts. Accounts may be excluded from a block due to tax considerations, client direction or other factors making the account’s participation ineligible or impractical. OHW will prepare, before entering an aggregated order, a written statement (“Allocation Statement”) specifying the participating client accounts and how it intends to allocate the order among those clients. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the Allocation Statement. If the order is partially filled, it will generally be allocated pro-rata, based on the Allocation Statement, or randomly in certain circumstances. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment, and the reason for different allocation is explained in writing and is approved by an appropriate individual/officer of OHW. OHW’s books and records will separately reflect, for each client account included in a block trade, the securities held by and bought and sold for that account. Funds and securities of clients whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither the clients’ cash nor their securities will be held collectively any longer than is necessary to settle the transaction on a delivery versus payment basis; cash or securities held collectively for clients will be delivered out to the custodian bank or broker-dealer as soon as practicable following the settlement, and OHW will receive no additional compensation or remuneration of any kind as a result of the proposed aggregation. Principal Transactions Principal transactions are not executed through an independent broker-dealer. Instead, we act as counterparty to the client. As a result, clients will not receive the benefit of price competition or best execution in the same manner as agency transactions. Item 13 - Review of Accounts Managed portfolios are reviewed periodically and may be reviewed if requested by the client, upon receipt of information material to the management of the portfolio, or at any time such review is deemed necessary or advisable by OHW. These factors may include, but are not limited to, the following: change in general client circumstances (marriage, divorce, retirement); or economic, political or market conditions. One of OHW’s investment adviser representatives or principals is responsible for reviewing all accounts. Account custodians are responsible for providing monthly or quarterly account statements which reflect the positions (and current pricing) in each account as well as transactions in each account, including fees paid from an account. Account custodians also provide prompt confirmation of all trading activity, and year-end tax statements, such as 1099 forms. In addition, OHW provides at least an annual report for each managed portfolio. This written report normally includes a summary of portfolio holdings and performance results. Additional reports are available at the request of the client. Item 14 - Client Referrals and Other Compensation Although OHW does not currently have an arrangement with third parties, OHW may, from time to time, enter into arrangements with third parties to identify and refer potential clients to OHW. Page 17  Consistent with legal requirements under the Investment Advisers Act of 1940, as amended, OHW enters into written agreements with third parties under which, among other things, third parties are required to disclose their compensation arrangements to prospective clients before such clients enter into an agreement with OHW. for more information. Certain employees of OHW are also licensed to sell insurance products. These employees will earn commission-based compensation for selling insurance products, including insurance products sold to clients of OHW. In addition, certain employees of OHW are also Registered Representatives of Level Four Financial, LLC, a FINRA and SIPC member and registered broker-dealer. As such, these Item employees are entitled to receive brokerage commissions. Insurance commissions and brokerage 5 – Fees and Compensation commissions earned by employees of OHW are separate from OHW’s advisory fees. Please see Item 15 - Custody Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third parties. OHW is deemed to have custody of certain client accounts due to the limited powers of attorney and/or third-party standing letters of authorization that clients maintain with respect to these accounts. OHW does not provide custodial services to its clients. Client assets are held with a qualified custodian. Raymond James is the custodian of securities for client accounts at OHW. From time to time, however, clients may select a different custodian to hold client assets. It is the custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and at least quarterly account statements. Clients are advised to review this information carefully, and to notify OHW of any questions or concerns. Clients are also asked to promptly notify OHW if the custodian fails to provide statements on each account held. OHW uses BitGo Trust Company, Inc., a South Dakota public trust company, as the custodian of client bitcoin accounts. From time to time, however, clients may select a different custodian to hold bitcoin. It is the custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and at least quarterly account statements. Clients are advised to review this information carefully, and to notify OHW of any questions or concerns. Clients are also asked to promptly notify OHW if the custodian fails to provide statements on each account held. OHW is deemed to have constructive custody of client bitcoin accounts and has been authorized by these clients to execute transfers of cash out of the bitcoin accounts. In connection with principal transactions involving bitcoin, OHW may facilitate the transfer of bitcoin to client wallets or custodial accounts. Clients should be aware of the risks associated with bitcoin custody, including cybersecurity risks and potential loss of access. From time to time and in accordance with OHW’s agreement with clients, OHW will provide additional reports. The account balances reflected on these reports should be compared to the balances shown on the brokerage statements to ensure accuracy. At times there may be small differences due to the timing of dividend reporting, pending trades or other similar issues. With specific client authorization, OHW may automatically deduct management fees from some client accounts by billing the clients’ custodian directly. OHW or the client’s custodian will provide copies of the invoices for such fees to the client. The invoice will show the amount of the fees, the value of the assets on which the fees were based, and the specific manner in which the fees were calculated. In the event OHW or any of its affiliates inadvertently receives client funds or securities, it will forward such funds or securities to the client or the client’s custodian or return them to the sender, as appropriate in accordance with the Custody Rule and the interpretive guidance thereunder. Page 18  Item 16 - Investment Discretion Item 4 - Advisory Business discretionary , OHW manages portfolios on either a As described above under discretionary or non-discretionary basis. For accounts, this means that after an Investment Plan is developed for the client’s investment portfolio, OHW will execute the Investment Plan without specific consent from the client for each transaction. A Limited Power of Attorney (“LPOA”) is executed by the client, giving OHW the authority to carry out various activities in the account, generally including the following: trade execution; the ability to request checks on behalf of the client; and, the withdrawal of advisory fees directly from the account. OHW then directs investment of the client’s portfolio using its discretionary authority. The client may limit the terms of the LPOA to the extent consistent with the client’s investment advisory agreement with OHW and the requirements of the client’s custodian. The discretionary relationship is further described in the agreement between OHW and the client. non-discretionary For accounts, the client may also execute an LPOA, which allows OHW to carry out trade recommendations and approved actions in the portfolio. However, in accordance with the investment advisory agreement between OHW and the client, OHW does not implement trading recommendations or other actions in the account unless and until the client has approved the recommendation or action. As with discretionary accounts, clients may limit the terms of the LPOA, subject to OHW’s investment advisory agreement with the client and the requirements of the client’s custodian. Item 17 - Voting Client Securities As a policy and in accordance with OHW’s client agreement, OHW does not vote proxies related to securities held in client accounts. The custodian of the account will normally provide proxy materials directly to the client. Clients may contact OHW with questions relating to proxy procedures and proposals; however, OHW generally does not research particular proxy proposals. Item 18 - Financial Information OHW has no financial issues that impair our ability to carry out our fiduciary duty to our clients and has never been the subject of a bankruptcy petition. OHW does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore has no disclosure with respect to this item. Page 19 

Item 1 - Cover Page Vista Investment Partners One Woodside Drive Richmond, Indiana 47374 765-962-5153 www.vistainvestment.net March 31, 2026 This brochure provides information about the qualifications and business practices of Vista Investment Partners II, LLC d/b/a Vista Investment Partners (“Vista”) also doing business as Orange Horizon Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at 765-962-5153. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state authority. www.AdviserInfo.sec.gov Additional information about Vista also is available on the SEC’s website at .  Item 2 - Material Changes This brochure contains the following material changes since our last annual updating amendment dated March 31, 2025: • • • • Item 4 – Added a description of investment consulting services involving principal transactions; Item 5 – Added information about fees related to investment consulting services involving principal transactions; Item 11 – Added information related to principal transactions; Items 12 and 15 – Added information related to principal transactions and removed references to Charles Schwab. Page 2  Item 3 - Table of Contents Page Item 1 - Cover Page ................................................................................................................................................................ 1 Item 2 - Material Changes ................................................................................................................................................... 2 Item 3 - Table of Contents ................................................................................................................................................... 3 Item 4 - Advisory Business ................................................................................................................................................. 4 Item 5 - Fees and Compensation ...................................................................................................................................... 6 Item 6 - Performance-Based Fees and Side-By-Side Management .................................................................... 8 Item 7 - Types of Clients ...................................................................................................................................................... 8 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 9 Item 9 - Disciplinary Information ................................................................................................................................. 12 Item 10 - Other Financial Industry Activities and Affiliations .......................................................................... 13 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .... 14 Item 12 - Brokerage Practices ........................................................................................................................................ 15 Item 13 - Review of Accounts ......................................................................................................................................... 17 Item 14 - Client Referrals and Other Compensation ............................................................................................. 18 Item 15 - Custody ................................................................................................................................................................ 18 Item 16 - Investment Discretion ................................................................................................................................... 19 Item 17 - Voting Client Securities ................................................................................................................................. 19 Item 18 - Financial Information .................................................................................................................................... 19 Page 3  Item 4 - Advisory Business General Information Vista Investment Partners II, LLC d/b/a Vista Investment Partners (“we” or “Vista”) was formed in 2017 and provides financial planning and portfolio management services to its clients. Brett D. Guiley is the principal owner of Vista. Vista also does business as Orange Horizon Wealth, LLC. At the outset of each client relationship, Vista spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Vista generally develops with each client: • • a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”); and the client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments Vista will make on behalf of the client in order to meet those goals. The Financial Profile and the Investment Plan are discussed regularly with each client but are not necessarily written documents. Portfolio Management As described above, at the beginning of a client relationship, Vista meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Vista based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, Vista will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, Vista will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on Vista in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Vista. Page 4  Separate Account Managers Vista may utilize one or more Separate Account Managers (each a “Manager”), when appropriate and in accordance with the Investment Plan for a client. Having access to various Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. Vista will usually select the Manager(s) that it deems most appropriate for the client. Factors that Vista considers in recommending/selecting Managers generally include the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. The Manager(s) will generally be granted discretionary trading authority to provide investment Item 8 – Methods of Analysis, advisory services for the portfolio. Pursuant to the Manager(s)’ investment authority, the Manager(s) Investment Strategies and Risk of Loss may select one or more of Vista’s investment strategies described in in varying combinations over time for a given client, depending upon the client’s individual circumstances. Under certain circumstances, Vista retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. In other cases, the client will ultimately select one or more Managers recommended by Vista. In any case, with respect to assets managed by a Manager, Vista’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio. Financial Planning Vista also offers financial planning services, as described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning may include advice that addresses one or more areas of a client’s financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation and the client’s specific needs, financial planning may include some or all of the following: • • • • • • • • • Gathering factual information concerning the client’s personal and financial situation; Assisting the client in establishing financial goals and objectives; Analyzing the client’s present situation and anticipated future activities in light of the client's financial goals and objectives; Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; Making recommendations to help achieve retirement plan goals and objectives; Designing an investment portfolio to help meet the goals and objectives of the client; Estate planning strategies; Assessing risk and reviewing basic health, life, and disability insurance needs; or Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have Vista implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by Vista under a financial planning engagement and/or engage the services of any recommended professional. Page 5  Assets in Held-away Accounts Vista provides an additional service for accounts that Vista cannot manage directly (“Held-away Accounts”), but where Vista does have discretion, and may leverage an Order Management System to implement tax-efficient asset allocation and opportunistic rebalancing strategies on behalf of the client. These Held-away Accounts are primarily 401(k) accounts, HSAs, and other assets Vista cannot directly access. Vista will regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Investment Consulting Services We offer a limited service to certain clients involving transactions in which we act as principal. In these transactions, we may purchase a specific security directly from a client and sell bitcoin to that client in a contemporaneous or related transaction. This service is offered only to a limited number of clients who meet our eligibility criteria and who provide appropriate consent. Type and Value of Assets Currently Managed As of December 31, 2025, Vista managed $383 million on a discretionary basis and $112,954box on a non-discretionary basis. Item 5 - Fees and Compensation Item 12 - Brokerage Practices Management Fee Information Clients generally enter into one of two fee arrangements. Clients may pay management fees to Vista separately from the brokerage expenses of the account. Accordingly, client accounts pay a management fee, plus the cost of transactions in the account. The brokerage expenses may take the form of asset-based pricing, meaning that the broker-dealer charges the account a flat-rate percentage to cover all brokerage expenses, or these expenses may be assessed on a per-trade basis. Please see for additional information. i.e. Portfolio Management Fees Alternatively, clients may participate in a wrap program (the “Wrap Program”) sponsored by Raymond James & Associates, Inc. (“Raymond James”) member New York Stock Exchange/SIPC. The Wrap Program fee structure includes the brokerage expenses ( , commissions, ticket charges, etc.) of the account as well as the charges for custody services and the management fee paid to Vista. Under the Wrap Program, Raymond James assesses one client fee that captures the management, brokerage, custody and administrative portions collectively. Vista receives a portion of the Wrap Program fees in accordance with the fees described below under “ .” Vista, in its sole discretion, may establish a minimum portfolio asset value size requirement for participation in the Wrap Program. In either of these arrangements, the fees noted above are separate and distinct from the internal fees and expenses charged by mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders (generally including a management fee and fund expenses, as described in each fund’s prospectus or offering materials). The client should review all fees charged by funds, brokers, Vista and others to fully understand the total amount of fees paid by the client for investment and financial-related services. Financial Planning Fees Vista offers financial planning services in conjunction with its portfolio management services for no additional fee when the client’s assets under Vista’s management equal at least $500,000. When the client’s assets under Vista’s management are less than $500,000, Vista offers financial planning services on a stand-alone separate fee basis. Vista's financial planning fees are outlined in a separate financial planning and consulting agreement between the client and Vista. Page 6  Portfolio Management Fees When one or more of Vista’s proprietary investment strategies is used with respect to an account, the maximum annual fee schedule, based on a percentage of assets under management, is as follows: Portfolio Asset Value Annual Fee Rate $0-$500,000 $500,001-$1,000,000 $1,000,001-$2,000,000 $2,000,001+ 1.50% 1.25% 1.00% Negotiable Portfolio management fees for accounts trading fixed income securities will generally be lower than those shown in the fee schedule above and will be individually negotiated with each client. When one of Vista’s proprietary investment strategies is not used with respect to an account, the maximum annual fee based on a percentage of assets under management is 2.00%. The actual fee charged is disclosed in the Investment Management Agreement entered into between Vista and each client and is individually negotiated with the client. Factors considered in determining the fees charged generally include, but are not limited to: the complexity of the client’s portfolio; assets to be placed under management; anticipated future assets; related accounts; portfolio style; account composition; or other special circumstances or requirements. Typically, Vista requires a minimum of $500,000 of investable assets from a client. There is no minimum annual fee. Vista may, at its discretion, make exceptions to the foregoing or negotiate special fee arrangements where Vista deems it appropriate under the circumstances. Portfolio management fees for accounts serviced through the Wrap Program are generally payable quarterly, in advance, while the portfolio management fees for all other accounts are generally payable monthly, in advance. Partial periods will be prorated based on the value of the Portfolio at the beginning of the period. Fees are normally debited directly from client account(s), unless other arrangements are made. Either Vista or the client may terminate their Investment Management Agreement at any time, subject to any written notice requirements in the agreement. In the event of termination, any paid but unearned fees will be promptly refunded to the client based on the number of days that the account was managed, and any fees due to Vista from the client will be invoiced or deducted from the client’s account prior to termination. Separate Account Manager Fees When one or more Managers are utilized, the Manager(s)’ fees will be included in Vista’s fee. When a Manager selects one or more of Vista’s investment strategies for a client, the client will not pay additional fees to Vista for the use of the strategy. Held-away Account Fees Investment management fees are generally debited directly from client account(s). However, it is not normally possible to debit investment management fees from Held-away Accounts, such as 401(k)’s. Fees for these accounts will normally be allocated to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account managed by Vista, fees will be billed directly to the client. Accounts initiated or terminated during a fee billing period will be charged a pro-rated fee based on the amount of time remaining in the billing period. Page 7  Investment Consulting Services Fees In connection with the limited principal transactions described in Item 4 above, we will charge a transaction fee of up to 3%. In addition, although it is not our intention, we may earn compensation through spreads or markups/markdowns between the price at which we purchase securities from clients and the price at which we sell bitcoin to clients. These amounts are not advisory fees and create a financial incentive for us to structure transactions in a manner that is favorable to us. Clients will receive disclosure of pricing prior to completing any transaction. Bitcoin Related Fees When client assets are invested in bitcoin, the client will pay fees in addition to Vista’s portfolio management fee. These fees include: a transaction fee of 30 basis points on each buy and sell transaction; and an annual administrative fee of 50 basis points based on the daily average account value of the client’s account. The administrative fee is charged monthly in arrears. Clients will pay additional fees when bitcoin is owned through an individual retirement account or similar account. These fees include an annual fee up to $250, $225 account termination fees, wire transfer, paper statement and other service fees. Clients should consider the impact of these fees before making the decision to invest in bitcoin through a retirement account. Insurance Disclosure Other Compensation : Certain employees of Vista are also licensed to sell insurance products. In providing advisory services, these individuals may recommend the purchase of products under circumstances where they would be entitled to receive a commission or other compensation in the transaction. In all such circumstances, however, the client will be notified of this payment in advance of the transaction, and under no circumstances will the client pay both a commission to an employee of Vista for an insurance product and an advisory fee to Vista on the same pool of assets. Broker Disclosure : Certain employees of Vista are also Registered Representatives of Level Four Financial, LLC (“Level Four”), a FINRA and SIPC member and registered broker/dealer. As such, these employees are entitled to receive brokerage commissions. In order to protect client interests, Vista’s policy is to fully disclose all forms of compensation before any such transaction is executed. Clients will not pay both a commission to the applicable Registered Representative and also pay an advisory fee to Vista on assets held in the same account. These fees are exclusive of each other. e.g. Furthermore, as a result of this relationship, Level Four may have access to certain confidential information ( , financial information, investment objectives, transactions, and holdings) about Vista clients, even if the client does not establish any account through Level Four. If you would like a copy of Level Four’s privacy policy, please contact Vista. Item 6 - Performance-Based Fees and Side-By-Side Management Vista does not have any performance-based fee arrangements. “Side by Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because Vista has no performance-based fee accounts, it has no side-by-side management. Item 7 - Types of Clients Vista serves individuals, pension and profit-sharing plans, corporations, trusts, estates and charitable organizations. With some exceptions, Vista requires a minimum of $500,000 of investable assets from a client for conventional investment advisory services. Under certain circumstances and in its sole discretion, Vista may negotiate such minimums. The limited principal transactions described in Page 8  Item 4 above are only available to certain individuals in appropriate circumstances. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies In accordance with the Investment Plan, Vista will primarily invest in mutual funds, ETFs, common stocks, fixed income securities, including municipal bonds, corporate bonds and collateralized mortgage obligations (“CMOs”), and other types of investments. Methods of Analysis In making investment selections for client portfolios, Vista may use any of the following types of analysis: Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to the client's investment goals and risk tolerance, and we seek to create a portfolio using mean variance optimization to maximize potential return relative to portfolio risk. A risk of asset allocation is the potential the client will miss the opportunity to participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client's goals. Mutual Fund, ETF and/or SMA Analysis. We look a variety of factors, including, as applicable and without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client's portfolio. Risks include that, as in all securities investments, past performance does not guarantee future results. A manager having success in the past does not indicate that they will have success in the future. In addition, as we do not control the underlying investments, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager will deviate from the stated investment mandate or strategy, which could make the holding(s) less suitable for the client's portfolio. Fundamental Analysis. Fundamental Analysis involves review of the business and financial information about an issuer. Without limitation, the following factors generally will be considered: • • • • Financial strength ratios; Price-to-earnings ratios; Dividend yields; and Growth rate-to-price earnings ratios Our analysis methods rely on the assumption that the investment vehicles which we recommend for our clients, the companies whose securities we purchase and sell on behalf of our clients, the rating agencies that review these securities, and other publicly or privately available sources of information about these securities, provide accurate, timely and unbiased data. While we are always looking for indications of inaccuracy in the data we use, there is always a risk that our analysis could be compromised by inaccurate, misleading or untimely information. This is an ongoing risk and could impact all the strategies discussed below. Page 9  Investment Strategies Vista’s strategic approach is to invest each portfolio in accordance with the Investment Plan that has been developed specifically for each client. As a general matter, Vista seeks to reduce volatility in its clients’ portfolios by balancing investment strategies with regard to growth and value, as well as capitalization size with respect to growth strategies. Vista further attempts to balance risk with exposure to fixed income securities. Vista has various investment strategies which it may utilize in varying combinations over time for a given client, depending upon the client’s individual circumstances. However, Vista may deviate from these strategies in its discretion and make any other investment recommendations and decisions for the client as appropriate based on the Investment Plan pursuant to Vista’s investment authority. Vista may develop new investment strategies from time to time. Set forth below are descriptions of the general investment strategies that Vista may loosely follow in managing its clients’ portfolios. Investing For Growth Strategy – client portfolios will typically hold between 15 and 25 stocks in companies that have two or more earnings estimate increases within the previous 6 months and have a return on equity that is two times the price-earnings ratio. Growth of Income Strategy – client portfolios will typically hold between 15 and 25 stocks in companies that have two or more earnings estimate increases within the previous 6 months, a yield greater than or equal to the S&P 500 Index, and have increased their dividends for at least 3 of the last 5 years. BOX Strategy – client portfolios will typically hold ETFs or mutual fund shares to balance between growth and value, periodically adjusted. Twenty First Century Balanced Strategy – client portfolios will typically hold ETFs and mutual fund shares allocated among equities, bonds, gold, bitcoin, cash and cash alternatives rebalanced periodically. Fixed Income Strategies: Tax-Free and Taxable – the portion of the client’s portfolio assets allocated to fixed income is divided among fixed income securities with varying maturity dates in an attempt to take advantage of the steepest part of the yield curve. Stock Options – typically covered calls are sold against positions to produce additional income and to fix prices that clients would be willing to reduce their positions. The options used generally are in concentrated equity positions. Balanced Market Rotation Strategy – client portfolios will typically hold one equity index ETF representing 60% of the portfolio and one bond ETF representing 40% of the portfolio, selected using a momentum test. Bitcoin – client portfolios will hold bitcoin either as a buy-and-hold long term savings strategy or managed as a target allocation in a client’s overall portfolio. Alternatively, Vista may use one or more strategic model portfolios offered by a client’s custodian in managing client portfolios. Risk of Loss While Vista seeks to diversify clients’ investment portfolios across various asset classes consistent with their Investment Plan in an effort to reduce risk of loss, all investment portfolios are subject to Page 10  risks. Accordingly, there can be no assurance that client investment portfolios will be able to fully meet their investment objectives and goals, or that investments will not lose money. Below is a description of several of the principal risks that client investment portfolios face. Management Risks. While Vista manages client investment portfolios, or recommends one or more Managers, based on Vista’s experience, research and proprietary methods, the value of client investment portfolios will change daily based on the performance of the underlying securities in which they are invested. Accordingly, client investment portfolios are subject to the risk that Vista or a Manager allocates assets to asset classes that are adversely affected by unanticipated market movements, and the risk that Vista’s specific investment choices could underperform their relevant indexes. Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, Vista or a Manager(s) may invest client portfolios in mutual funds, ETFs and other investment pools (“pooled investment funds”). Investments in pooled investment funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills of their particular managers and their performance in managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940. Equity Market Risks. e.g. Vista and any Manager(s) will generally invest portions of client assets directly into equity investments, primarily stocks, or into pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets, and that stock values will decline over longer periods ( , bear markets) due to general market declines in the stock prices for all companies, regardless of any individual security’s prospects. Fixed Income Risks. Vista and any Manager(s) may invest portions of client assets directly into fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). Foreign Securities Risks. Vista and any Manager(s) may invest portions of client assets into pooled investment funds that invest internationally. While foreign investments are important to the diversification of client investment portfolios, they carry risks that may be different from U.S. investments. For example, foreign investments may not be subject to uniform audit, financial reporting or disclosure standards, practices or requirements comparable to those found in the U.S. Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in investment or exchange control regulations. Finally, foreign investments may involve currency risk, which is the risk that the value of the foreign security will decrease due to changes in the relative value of the U.S. dollar and the security’s underlying foreign currency. Page 11  Covered Calls and Puts Risks. Vista and any Managers, on behalf of its clients, may purchase or write (sell) “covered” call and put options on securities, indexes or currencies. Vista or a Manager may purchase call options for investment purposes when it is anticipated that the price of the underlying security or currency will rise. Vista or a Manager may also purchase put options for investment purposes when it is anticipated that the price of the underlying security or currency will decline. If Vista or a Manager writes a covered call option on behalf of a client account, the client account will either own the security or currency subject to the option or own an option to purchase the same underlying security or currency having an exercise price equal to or less than the exercise price of the “covered” option. When writing a covered call option, the client account, in return for the premium, gives up the opportunity for profit from a price increase in the underlying security or currency above the exercise price, but conversely retains the risk of loss should the price of the security or currency decline. If Vista or a Manager writes a covered put option on behalf of a client account, the client account will maintain sufficient liquid assets to purchase the underlying security or currency if the option is exercised, in an amount not less than the exercise price. The risk in such a transaction would be that the market price of the underlying security or currency would decline below the exercise price, less the premiums received. Such a decline could be substantial and result in a significant loss to client accounts. To the extent Vista or a Manager acquires options that it does not exercise, it suffers the loss of the premium paid to the writer in connection with such purchase, and any gain or loss derived from the exercise of an option or other liquidation of an option is reduced or increased, respectively, by the amount of the premium paid. Closing transactions will be effected in order to realize a profit on an outstanding call option, to prevent an underlying security or currency from being called, or to permit the sale of the underlying security or currency. There is, of course, no assurance that Vista or a Manager will be able to effect such closing transactions at favorable prices. If Vista or a Manager cannot enter into such a transaction on behalf of client accounts, client accounts may be required to hold a security or currency that is depreciating in value that otherwise might have sold. Bitcoin Risks. Vista and any Manager(s), on behalf of its clients, may invest portions of client assets directly into bitcoin. Investments in bitcoin are subject to the risk that bitcoin’s value will decline due to daily fluctuations in the market, and that bitcoin’s value will decline over longer periods. The value of bitcoin can be more volatile than other assets. Bitcoin also carries risks that may be different from securities. These risks include disruptions to the Bitcoin network such as distributed denial of service (“DDoS”) attacks that could delay the settlement of bitcoin transactions or impair the value of bitcoin as an asset. The Bitcoin network may experience a hard fork, producing two or more incompatible networks which could dilute bitcoin’s market value. A hard fork may also result in conflicting opinions among market participants regarding what is, and is not, Bitcoin. Bitcoin’s characteristics as a monetary good may incentivize political jurisdictions to engage in hostile enforcement actions against it, either to defend the value of those jurisdictions’ sovereign currencies or to enforce regulations related to financial transactions. These hostile enforcement actions may be directed at Bitcoin the network, bitcoin the asset, or the technological infrastructure Bitcoin relies on, such as internet networks, energy grids, hardware devices, or cryptography techniques. The limited principal transactions described in Item 4 involving the exchange of securities for bitcoin involve unique risks, including market volatility, liquidity differences between asset classes, valuation uncertainty, and regulatory and tax law risks associated with digital assets. Item 9 - Disciplinary Information There have been no legal or disciplinary events related to Vista or any management person to disclose. Page 12  Item 10 - Other Financial Industry Activities and Affiliations Certain of Vista’s employees are Registered Representatives of Level Four Financial, LLC, a FINRA and SIPC member and registered broker/dealer. As such, these employees are entitled to receive brokerage commissions. In order to protect client interests, Vista’s policy is to fully disclose all forms of compensation before any such transaction is executed. Clients will not pay both a commission to such employee and also pay an advisory fee to Vista on assets held in the same account. These fees Item 5 – Fees and are exclusive of each other. Clients are not obligated, contractually or otherwise, to use the services Compensation of these insurance agents or Registered Representatives. Please see for more information. Insurance Products Sales Our representatives can sell other products or provide services outside of their role as investment adviser representatives with us. Due to the firm’s financial planning philosophy, it is common for our financial professionals to recommend that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income asset classes).You should be aware that there are a number of conflicts of interests that are present due to our planning philosophy and recommendations to utilize insurance products in this nature. Item 5 – Fees and Compensation As an estimate, our financial professionals that are registered as investment advisor representatives Item spend approximately 25% of their time on insurance sales and services and 75% of their time on 14 – Client Referrals and Other Compensation investment advisory services in the future. Please refer to and for more details. You may therefore work with your financial professional in both their capacity as an investment adviser representative of Vista, as well as in their capacity as an insurance agent. As such, your Vista financial professional, in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance products to you), and then assist you in implementing the recommendations by selling you those same products. When acting as an insurance agent, in exchange for selling you those products, the financial professional will typically be paid a commission. This recommendation that a client purchase an insurance product through them as an insurance agent presents a conflict of interest, as the receipt of commissions is an incentive to recommend products that could potentially be based on commissions rather than your personal needs and objectives. Furthermore, commissions may vary by product, and each individual product may have different commission rates, encouraging the financial professional to recommend products that may pay higher commissions over the products that make the most sense for you. In addition, insurance products may also have different payment schedules depending on the nature of the product, and the timing of the payments likely differ from that of the advisory options offered by Vista. This timing difference has the potential to create a conflict of interest since some financial professionals may have the incentive to recommend a product that pays commissions now, over an advisory product that pays fees over a relatively longer period. As an example, all other variables held equal, a 5% commission paid by an insurance company upon sale of a $100,000 annuity product, may be more attractive to a financial professional than a one percent (1%) advisory fee charged on a $100,000 account paid over a period of five (5) years, despite the overall pre-tax compensation paid to the financial professional being equal. Page 13  There are other conflicts present as well. At times, our financial professionals receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of clients. Level Four provides advisors such as Vista with marketing assistance and business development tools to acquire new clients, technology with the goal of improving the client experience and our firm’s efficiency, back office and operations support to assist in the processing of insurance for clients. Although some of these services may directly benefit a client, other services obtained by us from Level Four such as marketing assistance and business development may not benefit an existing client. We have taken a number of steps to manage these types of conflict of interests. We attempt to control for these sales-related conflicts by always basing investment decisions on the individual needs of clients. As a fiduciary, we expect and require that each investment adviser representative only recommend insurance and annuities when in the best interest of the client. The sale of commission- based products is supervised by the firm’s Branch Manager, and the firm makes periodic reviews of its insurance recommendations to ensure that our financial professionals act in accordance with our fiduciary duty. If you have any questions or concerns about annuity recommendations made during the financial planning process, we encourage you to immediately bring it to the attention of the Managing Partner or the CCO. Finally, you should be aware that there are other insurance products that are offered by other insurance agents other than those recommended by our financial professionals. You are under no obligation to implement any insurance or annuity transaction through Vista. Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading Vista has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request. Vista’s Code has several goals. First, the Code is designed to assist Vista in complying with applicable laws and regulations governing its investment advisory business. Under the Investment Advisers Act of 1940, Vista owes fiduciary duties to its clients. Pursuant to these fiduciary duties, the Code requires Vista associated persons to act with honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits associated persons from trading or otherwise acting on insider information. The Code sets forth guidelines for professional standards for Vista’s associated persons (managers, officers and employees). Under the Code, Vista expects its associated persons to put the interests of its clients first, ahead of personal interests. In this regard, Vista associated persons are not to take inappropriate advantage of their positions in relation to Vista clients. Page 14  The Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. From time-to-time Vista’s associated persons may invest in the same securities recommended to clients. Under the Code, Vista has adopted procedures designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading policies include procedures for limitations on personal securities transactions of associated persons, reporting and review of such trading and pre-clearance of certain types of personal trading activities. These policies are designed to discourage and prohibit personal trading that would disadvantage clients. The Code also provides for disciplinary action as appropriate for violations. Participation or Interest in Client Transactions As outlined above, Vista has adopted procedures to protect client interests when its associated persons invest in the same securities as those selected for or recommended to clients. In the event of any identified potential trading conflicts of interest, Vista’s goal is to place client interests first. Consistent with the foregoing, Vista maintains policies regarding participation by Vista associated persons in initial public offerings (IPOs) and private placements in order to comply with applicable laws and avoid conflicts with client transactions. If a Vista associated person wishes to participate in an IPO or invest in a private placement, he or she must submit a pre-clearance request and obtain the approval of the Chief Compliance Officer. e.g. If associated persons trade with client accounts ( , in a bundled or aggregated trade), and the trade is not filled in its entirety, the associated person’s shares will be removed from the block, and the balance of shares will be allocated among client accounts in accordance with Vista’s written policy. Principal Transactions We offer a limited service to certain clients involving transactions in which we act as principal. In these transactions, we may purchase a specific security directly from a client and sell bitcoin to that client in a contemporaneous or related transaction. This service is offered only to a limited number of clients who meet our eligibility criteria and who provide appropriate consent. Management of Vista reviews each client desiring to participate in these principal transactions and must provide approval before a transaction can proceed. Item 12 - Brokerage Practices Bitcoin Transactions Vista will trade bitcoin on behalf of clients using entities, including BitGo Prime LLC, that provide bitcoin trading services and are not affiliated with Vista. These entities will not maintain custody of clients’ assets and are not regulated by FINRA, or the SEC. When trading bitcoin, Vista will seek “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates, however, these factors will likely differ from factors relevant to transactions in securities. Best Execution and Benefits of Brokerage Selection When given discretion to select the brokerage firm that will execute orders in client accounts, Vista seeks “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates. Therefore, Vista may use or recommend the use of brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination), and may be used in servicing any or all of Vista’s clients. Therefore, research services received may not be used for the account for which the particular transaction was effected. Page 15  Vista may recommend that clients establish brokerage accounts with Raymond James, a FINRA registered broker-dealer and member SIPC, to maintain custody of clients’ assets. Vista may effect trades for client accounts at the client’s custodian or may in some instances, consistent with Vista’s duty of best execution and specific investment advisory agreement with each client, elect to execute trades elsewhere. Although Vista may recommend that clients establish accounts at Raymond James, it is ultimately the client’s decision where to custody assets. Vista is independently owned and operated and is not affiliated with Raymond James. Vista participates in the Raymond James Asset Management Services program. While there is no direct link between the investment advice Vista provides and participation in either program, Vista receives certain economic benefits from this program. These benefits may include software and other technology that provides access to client account data (such as trade confirmations and account statements), facilitates trade execution (and allocation of aggregated orders for multiple client accounts), provides research, pricing information and other market data, facilitates the payment of Vista’s fees from its clients’ accounts, and assists with back-office functions, recordkeeping and client reporting. Many of these services may be used to service all or a substantial number of Vista’s accounts, including accounts not held at Raymond James. Raymond James may also make available to Vista other services intended to help Vista manage and further develop its business. These services may include consulting, publications and conferences on practice management, information technology, business succession, and marketing. In addition, Raymond James may make available, arrange and/or pay for these types of services to be rendered to Vista by independent third parties. Raymond James may discount or waive fees it would otherwise charge for some of these services, pay all or a part of the fees of a third-party providing these services to Vista, and/or Raymond James may pay for travel expenses relating to participation in such training. Finally, participation in the Raymond James service program provides Vista with access to mutual funds which normally require significantly higher minimum initial investments or are normally available only to institutional investors. The benefits received through participation in the Raymond James service program do not necessarily depend upon the proportion of transactions directed to Raymond James. The benefits are received by Vista, in part because of commission revenue generated for Raymond James by Vista’s clients. This means that the investment activity in client accounts is beneficial to Vista, because Raymond James assesses a fee to Vista for these services. This creates an incentive for Vista to continue to recommend Raymond James to its clients. While it may be possible to obtain similar custodial, execution and other services elsewhere at a lower cost, Vista believes that Raymond James provide an excellent combination of these services. These services are not soft dollar arrangements, but are part of the institutional platforms offered by Raymond James. Directed Brokerage Vista does not allow directed brokerage accounts. Aggregated Trade Policy Vista may enter trades as a block where possible and when advantageous to clients whose accounts have a need to buy or sell shares of the same security. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rata basis between all accounts included in any such block. Block trading allows Vista to execute equity trades in a timelier, equitable manner, and may reduce overall costs to clients. Vista will only aggregate transactions when it believes that aggregation is consistent with its duty to seek best execution (which includes the duty to seek best price) for its clients, and is consistent with Page 16  the terms of Vista’s Investment Advisory Agreement with each client for which trades are being aggregated. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all Vista’s transactions in a given security on a given business day, with transaction costs generally shared pro-rata based on each client’s participation in the transaction. On occasion, owing to the size of a particular account’s pro rata share of an order or other factors, the commission or transaction fee charged could be above or below a breakpoint in a pre-determined commission or fee schedule set by the executing broker, and therefore transaction charges may vary slightly among accounts. Accounts may be excluded from a block due to tax considerations, client direction or other factors making the account’s participation ineligible or impractical. Vista will prepare, before entering an aggregated order, a written statement (“Allocation Statement”) specifying the participating client accounts and how it intends to allocate the order among those clients. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the Allocation Statement. If the order is partially filled, it will generally be allocated pro-rata, based on the Allocation Statement, or randomly in certain circumstances. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment, and the reason for different allocation is explained in writing and is approved by an appropriate individual/officer of Vista. Vista’s books and records will separately reflect, for each client account included in a block trade, the securities held by and bought and sold for that account. Funds and securities of clients whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither the clients’ cash nor their securities will be held collectively any longer than is necessary to settle the transaction on a delivery versus payment basis; cash or securities held collectively for clients will be delivered out to the custodian bank or broker-dealer as soon as practicable following the settlement, and Vista will receive no additional compensation or remuneration of any kind as a result of the proposed aggregation. Principal Transactions Principal transactions are not executed through an independent broker-dealer. Instead, we act as counterparty to the client. As a result, clients will not receive the benefit of price competition or best execution in the same manner as agency transactions. Item 13 - Review of Accounts Managed portfolios are reviewed periodically and may be reviewed if requested by the client, upon receipt of information material to the management of the portfolio, or at any time such review is deemed necessary or advisable by Vista. These factors may include, but are not limited to, the following: change in general client circumstances (marriage, divorce, retirement); or economic, political or market conditions. One of Vista’s investment adviser representatives or principals is responsible for reviewing all accounts. Account custodians are responsible for providing monthly or quarterly account statements which reflect the positions (and current pricing) in each account as well as transactions in each account, including fees paid from an account. Account custodians also provide prompt confirmation of all trading activity, and year-end tax statements, such as 1099 forms. In addition, Vista provides at least an annual report for each managed portfolio. This written report normally includes a summary of portfolio holdings and performance results. Additional reports are available at the request of the client. Page 17  Item 14 - Client Referrals and Other Compensation Although Vista does not currently have an arrangement with third parties, Vista may, from time to time, enter into arrangements with third parties to identify and refer potential clients to Vista. Consistent with legal requirements under the Investment Advisers Act of 1940, as amended, Vista enters into written agreements with third parties under which, among other things, third parties are required to disclose their compensation arrangements to prospective clients before such clients enter into an agreement with Vista. for more information. Certain employees of Vista are also licensed to sell insurance products. These employees will earn commission-based compensation for selling insurance products, including insurance products sold to clients of Vista. In addition, certain employees of Vista are also Registered Representatives of Level Four Financial, LLC, a FINRA and SIPC member and registered broker-dealer. As such, these Item employees are entitled to receive brokerage commissions. Insurance commissions and brokerage 5 – Fees and Compensation commissions earned by employees of Vista are separate from Vista’s advisory fees. Please see Item 15 - Custody Some clients may execute limited powers of attorney or other standing letters of authorization that permit the firm to transfer money from their account with the client’s independent qualified Custodian to third parties. Vista is deemed to have custody of certain client accounts due to the limited powers of attorney and/or third-party standing letters of authorization that clients maintain with respect to these accounts. Vista does not provide custodial services to its clients. Client assets are held with a qualified custodian. Raymond James is the custodian of securities for client accounts at Vista. From time to time, however, clients may select a different custodian to hold client assets. It is the custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and at least quarterly account statements. Clients are advised to review this information carefully, and to notify Vista of any questions or concerns. Clients are also asked to promptly notify Vista if the custodian fails to provide statements on each account held. Vista uses BitGo Trust Company, Inc., a South Dakota public trust company, as the custodian of client bitcoin accounts. From time to time, however, clients may select a different custodian to hold bitcoin. It is the custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and at least quarterly account statements. Clients are advised to review this information carefully, and to notify Vista of any questions or concerns. Clients are also asked to promptly notify Vista if the custodian fails to provide statements on each account held. Vista is deemed to have constructive custody of client bitcoin accounts and has been authorized by these clients to execute transfers of cash out of the bitcoin accounts. In connection with principal transactions involving bitcoin, Vista may facilitate the transfer of bitcoin to client wallets or custodial accounts. Clients should be aware of the risks associated with bitcoin custody, including cybersecurity risks and potential loss of access. From time to time and in accordance with Vista’s agreement with clients, Vista will provide additional reports. The account balances reflected on these reports should be compared to the balances shown on the brokerage statements to ensure accuracy. At times there may be small differences due to the timing of dividend reporting, pending trades or other similar issues. With specific client authorization, Vista may automatically deduct management fees from some client accounts by billing the clients’ custodian directly. Vista or the client’s custodian will provide copies of the invoices for such fees to the client. The invoice will show the amount of the fees, the value of Page 18  the assets on which the fees were based, and the specific manner in which the fees were calculated. In the event Vista or any of its affiliates inadvertently receives client funds or securities, it will forward such funds or securities to the client or the client’s custodian or return them to the sender, as appropriate in accordance with the Custody Rule and the interpretive guidance thereunder. Item 16 - Investment Discretion Item 4 - Advisory Business discretionary , Vista manages portfolios on either a As described above under discretionary or non-discretionary basis. For accounts, this means that after an Investment Plan is developed for the client’s investment portfolio, Vista will execute the Investment Plan without specific consent from the client for each transaction. A Limited Power of Attorney (“LPOA”) is executed by the client, giving Vista the authority to carry out various activities in the account, generally including the following: trade execution; the ability to request checks on behalf of the client; and, the withdrawal of advisory fees directly from the account. Vista then directs investment of the client’s portfolio using its discretionary authority. The client may limit the terms of the LPOA to the extent consistent with the client’s investment advisory agreement with Vista and the requirements of the client’s custodian. The discretionary relationship is further described in the agreement between Vista and the client. non-discretionary For accounts, the client may also execute an LPOA, which allows Vista to carry out trade recommendations and approved actions in the portfolio. However, in accordance with the investment advisory agreement between Vista and the client, Vista does not implement trading recommendations or other actions in the account unless and until the client has approved the recommendation or action. As with discretionary accounts, clients may limit the terms of the LPOA, subject to Vista’s investment advisory agreement with the client and the requirements of the client’s custodian. Item 17 - Voting Client Securities As a policy and in accordance with Vista’s client agreement, Vista does not vote proxies related to securities held in client accounts. The custodian of the account will normally provide proxy materials directly to the client. Clients may contact Vista with questions relating to proxy procedures and proposals; however, Vista generally does not research particular proxy proposals. Item 18 - Financial Information Vista has no financial issues that impair our ability to carry out our fiduciary duty to our clients and has never been the subject of a bankruptcy petition. Vista does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore has no disclosure with respect to this item. Page 19