Waterfront Wealth, Inc. (“Waterfront,” “We,” or “the Firm”) is a corporation organized and based in the state of Kansas. Waterfront was founded in 2012 by Roger C. Ratzlaff Jr., the firm’s principal owner, managing director, and Chief Compliance Officer. Mr. Ratzlaff began his career in investment planning in 1988 with A.G. Edwards, a predecessor firm of Wells Fargo Advisors. In May of 2012, Roger and a small group of financial advisors set out to start Waterfront Wealth. Mr. Ratzlaff remained registered with Wells Fargo Financial Advisers Network, LLC (a FINRA registered broker dealer) and representatives of Waterfront Wealth operated a registered branch office of that broker-dealer through late 2020. He and his team at Waterfront work together to provide customized strategies for a wide range of clients. Mr. Ratzlaff no longer provides brokerage services through Wells Fargo Financial Advisers Network, LLC. Advisory services are provided through Waterfront Wealth, Inc. under the business name “Waterfront Wealth Management” (in the process of being transitioned to “Waterfront Advisors”). Waterfront Wealth, Inc. also represents it division responsible for management strategies as “Waterfront Asset Management”. As of 12/31/2022, Waterfront managed approximately $645,000,000 in assets on a discretionary basis. Services Offered Portfolio Management Services Waterfront provides ongoing discretionary and non-discretionary portfolio management services to businesses, charitable organizations, endowments, estates, families, foundations, individuals, trusts, and other investment advisers. When providing portfolio management services, Waterfront not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. Clients may elect to give Waterfront discretion to make all decisions (discretionary management) or may prefer to approve all decisions before implementation (non-discretionary management). Institutional Sub-Advisory Services Waterfront also provides ongoing sub-advisory services to other investment advisers who wish to delegate some of their investment management responsibilities to Waterfront. When providing sub- advisory services, Waterfront is generally responsible for making asset allocation and investment decisions for designated accounts, and for executing and monitoring settlements of trades related to these decisions. The applicable primary investment adviser may limit or instructor Waterfront related to delegated accounts though written objectives, guidelines or restrictions furnished to Waterfront. Financial Planning Services Waterfront also provides project oriented and ongoing financial planning services to individuals and families where the firm offers advice or other strategic assistance in areas such as education

funding, retirement planning, estate planning, risk management, employee benefits planning, tax planning, etc. When engaged to provide financial planning assistance, clients are responsible for determining whether or not to implement a recommendation, and if they decide to do so, are responsible for actual implementation. The actual details of an engagement vary on a case by case basis depending on the complexity of the client’s financial situation. Generally however, an engagement will include identification of goals and objectives, collection and analysis of data, and formulation of a strategy, and may also include preparation of a written plan. Retirement Plan Services Waterfront also provides retirement plan services to businesses. Plan level services offered include discretionary management services and non-discretionary advisory/consulting services. Services are made available for different types of retirement plans, including 401K and 403B among others. When providing management services, the firm is responsible for implementing recommendations. When the firm is providing advisory/consulting services, the client is responsible for implementation of recommendations. Although the firm does not provide participant level services as part of a retirement plan engagement, participants may engage Waterfront separately for participant level services. Investment Philosophy Regardless of the type of services provided, each service is tailored to the individual needs of a particular client (whether an individual, a family, or a business) through an assessment conducted prior to an engagement. Clients may impose restrictions related to the level of discretion granted, the types of investments used, etc. Terms of an actual engagement, including description of service, limitations and restrictions, fees, etc., are all detailed before any engagement begins in a written client agreement. Fiduciary Standards Because Waterfront is a registered investment adviser, we are required to meet certain fiduciary standards when providing investment advice to clients. Additionally, when we provide investment advice related to a retirement plan account or an individual retirement account, we are considered fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As such, we are required to act in your best interest and not put our interest ahead of yours, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Our clients however are under no obligation to use services recommended by our associated persons. Furthermore, we believe that our recommendations are in the best interests of our clients and are consistent with our clients’ needs.