Overview of Shiraishi Financial Group Advisors Shiraishi Financial Group Advisors (SFGA) is the primary business name for SFGA LLC, a limited liability company established in July, 2013 for the purpose of providing a variety of investment advisory services to its clients. These services include financial planning, financial consultations, portfolio management, referrals to third-party investment advisors and retirement plan services. Herbert Shiraishi is the firm’s sole owner. Individuals associated with SFGA will provide its investment advisory services. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on behalf of SFGA. Such individuals are known as Investment Advisor Representatives (IARs). Financial Planning and Consulting Services Financial Planning Services SFGA provides a financial planning service designed to assist clients in identifying and taking steps to meet their financial and related goals. This service is provided through series of one-on-one meetings with a SFGA representative in which the client provides information concerning their financial situation, identifies goals and objectives, is informed of relevant financial concepts and strategies, including how to more efficiently handle specific financial areas, and is given specific recommendations. The primary objective of this process is to allow SFGA to assist the client in developing a strategy for the successful management of income, assets and liabilities in meeting the client's stated financial goals and objectives. Depending on the client’s situation and needs, SFGAs financial planning services may include advice in one or more of the following areas:
• Retirement Planning
• Income Planning
• Tax Planning
• Asset Protection and Risk Management
• Investment Planning
• Estate Planning
• Educational Planning
• Other areas at client’s request and agreed to by SFGA Financial planning and consulting services are based on financial and other information disclosed by the client to SFGA. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy. Clients should keep in mind that past performance is in no way an indication of future performance and that SFGA cannot offer any guarantees or promises that the client's financial goals and objectives will be met. As the client's financial situation, goals, objectives, or financial needs change, the client must notify SFGA promptly. Financial Consultation Services SFGA may also provide financial consultation services. Financial consultation services will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of their individual needs. Specific areas of analysis will be determined and agreed upon through a series of meetings and may include one or more of the following areas: retirement planning, income planning, children’s education, estate planning, disability, life and long term care insurance, investment strategies/allocation/reallocation, and cash management. SFGA may provide consultation services on others areas depending on the needs of the client. Financial consultation clients will be requested to provide personal and financial information necessary to complete the analysis. Once such information has been reviewed and analyzed, either oral or written recommendations designed to achieve the clients’ stated goals and objectives will be presented to the client. Financial consultation service recommendations are based on the client’s financial situation at the time they are presented and are based on the financial and other information disclosed by the client to SFGA. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. SFGA cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the client must notify SFGA promptly. At SFGAs sole determination, SFGA may provide financial planning and/or financial consultation services to Portfolio Management and Third-Party Investment Advisor Services clients without charging an additional fixed fee for the financial consultation services. Portfolio Management Services SFGA provides active investment management services using a tactical asset allocation methodology with the objective of maintaining returns while lowering risk and volatility of client portfolios. The investment advice provided is custom tailored to meet the client’s individual needs, risk tolerance, and personal situation. SFGA will gather information from the client including current investments (if any) and current financial condition, and obligations. SFGA will then recommend investments to construct a portfolio suited to meet the client’s identified goals, financial needs, and investment objectives in light of general economic and market conditions. Model Overview Following are descriptions of the various models

currently provided by SFGA: Active Model: This model trades between three main funds – High Yield Bond Funds, Government Bond Funds and Money Market Funds – based on ongoing analysis of the markets. Depending on market conditions, a Balanced Fund may be substituted by the advisor for a High Yield Bond Fund. Investment strategies under this model are not restricted in terms of their Balanced Fund allocation. However, accounts in the Income Portfolio are subject to a maximum Balanced Fund allocation of 50%. Balanced funds’ equity exposure typically is around 60% of the balanced funds’ portfolio, although the equity exposure may vary depending on market conditions and other factors. Seasonal Model: This model trades in Large-Cap Equity Funds and funds in the Active model. While this strategy generally participates in the Large-Cap Equity Funds during the months of November through April due to historically favorable performance, the advisor maintains flexibility in terms of timing the entry/exit points for this model. For the months of May through October, this model generally uses the Active model to allocate funds. Trading is primarily based on long-term trending for this model. The maximum equity exposure in this model is 100%. Sector Model: This Model uses both Equity and Bond Sectors. When risk is high in the Equity market, the Model switches to Bond Sectors. If both Domestic and International Equities do not have a positive outlook, the Model can select Bond Sectors. The maximum equity exposure in this model is 100%. Portfolios constructed by SFGA generally consist of shares of no-load or load-waived mutual funds or subaccounts of variable insurance products, such as variable annuities and/or variable universal life insurance. Once the portfolio is constructed, SFGA periodically monitors the portfolio as changes in market conditions and client circumstances may necessitate. SFGA may provide portfolio management services with respect to sub-accounts of variable annuities and variable universal life insurance policies to Financial Planning and Financial Consultation Services clients without charging an additional assets under management fee. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. In all cases, clients retain individual ownership of all securities. As of December 31, 2023, SFGA has $120,334,459 in discretionary assets under management and $4,663,777 in non-discretionary assets under management. SFGA does not participate as a portfolio manager in any wrap fee programs. Third-Party Investment Advisors SFGA has entered into agreements with various third-party investment advisors (TPIAs). Under these agreements, SFGA offers clients various types of programs sponsored by these advisors. All TPIAs to whom SFGA will refer clients will be licensed or on notice as investment advisors in the client’s state of residence. After gathering information about a client’s financial situation and investment objectives, SFGA may recommend specific services or programs of TPIAs to clients that are suitable and appropriate for the client based on the clients’ individual needs and circumstances, including investment objectives and risk tolerance levels, as they have made them known to SFGA. Factors that SFGA takes into consideration when making such recommendations include, but are not limited to, the TPIAs performance, methods of analysis and fees. SFGA periodically reviews the TPIA and its performance for continued consistency with the client’s investment objectives and risk tolerances. At the time of the referral, clients who are referred to TPIAs will receive the respective TPIAs Form ADV Part 2 disclosure brochure and/or other relevant disclosure documents. These documents are designed to provide complete disclosure of the TPIA, including services rendered frequency of billing, fee schedules and the compensation to be paid to SFGA as a result of the referral. Retirement Plan Services 1. SFGA may provide fiduciary and/or non-fiduciary services to retirement plans (i.e., 401k, 403b, etc.). Retirement plans may or may not be subject to the U.S. Department of Labor’s Employee Retirement Income Security Act (ERISA). To the extent that SFGA provides fiduciary services to ERISA plans, SFGA acknowledges its status as a fiduciary under ERISA. 2. Retirement plan documents typically designate one or more persons, such as the plan trustee(s), to undertake fiduciary responsibility for the operation of the retirement plan. Such persons are known as Responsible Plan Fiduciaries (RPFs). Neither SFGA nor any SFGA IAR may act in the capacity of an RFP on behalf of a client’s retirement plan. Pursuant to a Retirement Plan Services Agreement (RPSA), SFGA can offer the following types of services to a retirement plan. Please refer to the agreement for a more detailed description of these different types of services. a. Fiduciary Services  Selection of Investments  Assessment of Investments  Participant Investment Advice  Investment Policy Statement Individually Designed b. Non-ERISA Fiduciary Services  Investment Policy Statement Review  Performance Monitoring  Third Party Service Provider Liaison  Employee Enrollment  Employee Education  Vendor Review/Conversion