Firm Description Trajan Wealth, L.L.C., (“TW” or “Advisor”) is based in Scottsdale, Arizona. TW is a Registered Investment Adviser, registered with and subject to the rules and regulations of the U.S. Securities and Exchange Commission. The firm was formed as a limited liability company under the laws of the State of Arizona. Founded in 2010, TW provides investment advice to primarily individuals which may include, but is not limited to, determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Our investment advice is tailored to work with our clients’ financial goals, investment objectives and risk tolerances. The investment advisory services of TW are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of TW (referred to as your “Investment Adviser Representative” or “IAR” throughout this brochure). Your IAR may either be an employee of TW or an independent contractor. Investment adviser representatives are free to negotiate the fees to be charged for the services provided within the parameters set by TW, as disclosed in Item 5 – Fees and Compensation of this brochure. It is possible that different IAR’s may charge different fees for providing the same service to clients. The specific level of services you will receive and the fees you will be charged will be specified in your investment advisory agreement. As used in the brochure, the words, “we,” “our,” and “us” refer to TW and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. In addition, you may see the term “Associated Person” throughout this brochure. As used in this brochure, our Associated Persons are our firm’s officers, employees and all individuals providing investment advice on behalf of our firm. The firm changed its name in 2011 from Valley Financial Wealth Management L.L.C. Jeffrey B. Junior is 100% owner. TW is also a licensed insurance agency wholly owned by Jeffrey B. Junior. Types of Advisory Services Asset Management Services TW provides investment advisory and portfolio management services on a continuing basis, which may include the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, ETF’s, mutual funds, bonds, and annuities. Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Our investment advice is tailored to meet our clients’ unique needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. TW provides investment advisory and other financial services through its IAR’s to accounts opened with TW. Managed Accounts are available to individual clients, high net-worth families, foundations, endowments, and institutional investors. We also provide personal financial planning and investment advice. Our investment plans are designed to work with our clients’ financial goals, objectives and risk tolerances. TW provides discretionary investment advisory services to its clients through various managed account programs. Through our managed account programs, we provide investment management services, including providing continuous investment advice to and making investments for you based on your individual needs. Through these services, we offer a customized and individualized investment program. These services may cost the client more or less than purchasing such services if provided separately. Some of the factors that determine total costs are the costs of the services if provided separately and the trading activity in the client’s account. During your initial meeting with your advisor, you’re asked to complete a confidential client profile to help us understand your risk tolerance and long-term financial goals. A specific asset allocation strategy and suitability profile is crafted to focus on your specific goals and objectives. The confidential client profile defines your risk tolerance and investment objectives. Your information should be updated regularly, but at a minimum every 2 years. You must appoint our firm as your investment advisor of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. Our asset management services are provided on a discretionary basis. With discretionary authority, we make all decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion without consulting with you before implementing any transactions. You must provide us with written authorization to exercise this discretionary authority. Discretionary authority is limited. We do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to us by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the client agreement. (Please see Item 16 - Investment Discretion for additional information concerning discretionary authority.) As more fully described in Item 5 – Fees and Compensation below, the annual fee is assessed on a monthly or quarterly schedule and calculated on either: (1) the client's average daily balance, for accounts billed in arrears (monthly or quarterly); or (2) calculated using the value of the account on the first day of the quarter, for certain accounts billed quarterly in advance. In addition to collecting a management fee for asset management services, TW also collects a sub-advisory fee from the Trajan Wealth™ ETF. Before we assess any fees or provide formal advice, we will provide you with an Investment Advisory Agreement (“Agreement”) for your review, understanding and signature. The Agreement includes the terms and conditions under which your assets will be managed. Your execution of the Agreement authorizes our firm to determine the specific securities, and the amount of securities to be purchased or sold for your account without your approval prior to each transaction. The Agreement will remain in effect between you and us until terminated by either party in writing according to the terms contained in the Agreement. In the event a conflict exists between the Agreement and our Form ADV, the Form ADV shall prevail. The Agreement will include schedules of the investment accounts you wish us to manage, the specific fees we propose to charge and how we propose to bill and collect those fees. You also have the ability to impose limits on investment selections and sectors. Advisory accounts will be held primarily by Fidelity Investments, Charles Schwab & Co., Inc. or other qualified custodians as approved by TW (individually, a “Custodian”). The client must designate

TW as its Investment Adviser on their accounts. The client’s qualified Custodian will maintain actual custody of all client funds and securities. Custodians are also broker/dealers, and they may have different account fees, execution charges and capacities. If you choose a different Custodian other than the one selected by us, you may pay higher account-related fees and execution charges. This may occur because custodial services are based on several factors. Factors may include, but are not limited to cost, expected level of asset safety, client confidentiality, communication, and reporting. We base all decisions on the individual investment circumstances of each client. In certain circumstances, clients may elect to have TW provide recommendations among the client’s available investment options within the client’s retirement account held and maintained at a third-party custodian or at the client’s current or former employer (“Held Away Accounts”). In connection with providing recommendations for such Held Away Accounts, TW may seek authorization from the client, and maintain, such client’s account access information, subject to TW’s Privacy Policy. Upon client authorization, TW will access client’s account directly, solely, to select among available investment options for the client based upon the client’s unique investment goals, objectives, and risk tolerance. TW will not seek to, or make, any changes to, or transfers to or from, any such Held Away Accounts without an appropriate, and separate, limited power of attorney from client. TW charges fees with respect to Held Away Accounts according to its general fee schedule. TW bills clients directly for the fees related to the servicing of Held Away Accounts. Fees may be deducted from the client’s account with the Custodian or invoiced and paid directly by the client. Please note, for any account not held on a Trajan Wealth custody platform (i.e., held-away account or 401k participant plan account) fees will be billed quarterly in arrears and based on the quarter end market value. This fee will be deducted from your account on the first day of the second month following the quarter end. Important Disclosure Regarding Fee Based Asset Management Accounts When making the determination of whether one of the advisory programs available through TW is appropriate for your needs, you should bear in mind that fee-based accounts, when compared with commission-based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee-based account arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Factors which affect the total cost include account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax situation. It should also be noted that lower fees for comparable service may be available from other sources. You should discuss the advantages and disadvantages of fee-based and commission-based accounts with your IAR. Overlay Capital Innovation Fund PV, LP In addition to advising Managed Accounts, TW provides investment advisory services on a discretionary basis to a domestic fund, not registered under the Investment Company Act of 1940, as amended, Overlay Capital Innovation Fund PV, LP (the “Fund”). As the investment manager to the Fund, TW is responsible for: (a) the formulation and implementation of the Fund’s investment strategy; (b) evaluating and monitoring investments made by the Fund; and, (c) making all investment decisions for the Fund. Overlay Capital Innovation Fund PV GP, LLC (“Overlay” or the “General Partner”), an affiliate of TW, is the General Partner of the Fund. As General Partner, Overlay is solely responsible for the management of the Fund. TW provides investment advisory services to the Fund based on the investment objectives of the Fund. This document is not an offer to sell or a solicitation of an offer to buy Interests in the Fund. Such an investment may be made only after receipt and review of the Fund’s Confidential Private Placement Memorandum and execution of certain agreements (collectively the “Governing Documents”). The Governing Documents also contain important information concerning risk factors and other material aspects of the Fund and it must be read carefully before making an investment decision. The information in this document is qualified in its entirety by, and should be read in conjunction with, the information contained in the Governing Documents. A copy of the Governing Documents is available upon request to TW to persons meeting the definitions of both accredited investor within the meaning of SEC Regulation D promulgated under the Securities Act and a qualified client as that term is defined in Rule 205-3 under the Advisers Act. TW provides investment advisory services based on the Client’s investment objectives. Investors in the Fund are limited partners (the “Limited Partners”). TW does not provide tailored investment advice to the Limited Partners in the Fund unless they have a Managed Account with the Firm. Trajan Wealth™ Exchange Traded Funds Trajan Wealth™ Income Opportunities ETF (Ticker: TWIO) TW serves as the sub-adviser to the Trajan Wealth™ Income Opportunities ETF (the “Fund”). The Fund seeks to provide current income, conservation of principal and the opportunity for limited capital appreciation. Please see the Fund’s Prospectus and Statement of Additional Information (“SAI”) for additional disclosures relating to the Fund. Prior to making any investment in the Fund, clients should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment. Sub-Advisers TW, in providing the services agreed upon with the client, may retain hereafter ("the Sub- Adviser"), an investment adviser registered under applicable securities laws, as a Sub- Adviser to manage all or a portion of the managed assets in the Client's account. If this occurs, TW will be responsible for the continuing supervision of the Client's account, and the actions of the Sub-Adviser in connection with the Client's account and the managed assets. TW also will be responsible for the payment of any advisory fee or other charges of the Sub-Adviser with respect to the managed assets unless or except as specifically authorized in advance by the Client. TW agrees that upon proper notice by the Client, TW will refrain from the appointment of, or terminate as permitted under applicable contracts, any Sub-Adviser appointed pursuant to this authority. Alternative Investments TW will offer alternative investments to clients that are either accredited or qualified for such products. Alternative investments include but are not limited to: Private Equity Real Estate, Private Equity Joint Venture and or Private Credit. These offerings are typically through a fund structure and will be sponsored through third- party managers or in cooperation with TW. Educational Seminars/Workshops TW occasionally provides seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning or other relevant financial topics. Seminars/workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. No fees are charged for seminars. Client Tailored Services and Client Imposed Restrictions The goals, objectives, risk tolerance and client-imposed restrictions for each client are documented in our client files. Investment strategies are created that seek to reflect the stated unique needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities with written notification. Agreements may not be assigned without written client consent. Wrap Fee Programs The firm does not participate in a wrap fee program. Client Assets Under Management As of December 31, 2023, Trajan Wealth had the following Assets Under Management (“AUM”): Discretionary: $ 1, 365,393,877 Non-Discretionary: $0