General Information Inlight Wealth, a Georgia limited liability company, was formed in August 2017. Inlight Wealth is a Registered Investment Adviser, registered with and subject to the rules and regulations of the U.S. Securities and Exchange Commission. Advisory Clients Inlight Wealth provides discretionary and non-discretionary portfolio management as well as financial planning and general consulting services to individuals, high net worth individuals, corporations, trusts, estates, charitable organizations and retirement and pension plan participants. At the outset of each client relationship, Inlight Wealth spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Based on its reviews, Inlight Wealth 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 Inlight Wealth will make or recommend on behalf of the client based on Inlight Wealth’s own research and analysis in order to meet those goals. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client, but are not necessarily written documents. Portfolio Management As described above, Inlight Wealth will develop an Investment Plan with each portfolio management client. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Inlight Wealth based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, Inlight Wealth 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, Inlight Wealth 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 Inlight Wealth 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 Inlight Wealth. Tenderlist Inlight Wealth also offers the Tenderlist investment strategy to certain clients. Tenderlist is an investment strategy focused

on corporate tender offers and special situations. If this strategy is recommended to, and accepted by, the client, the client will be required to sign Inlight Wealth’s Tenderlist Strategy Discretionary Investment Advisory Agreement. Separate Account Managers Inlight Wealth 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. Inlight Wealth will usually select the Manager(s) it deems most appropriate for the client. Factors that Inlight Wealth considers in recommending/selecting Managers generally includes 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 supervisory services for the portfolio. In most cases, the client will select one or more Managers recommended by Inlight Wealth and enter into separate agreements which such Managers. Under certain circumstances, Inlight Wealth retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. In any case, with respect to assets managed by a Manager, Inlight Wealth’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 Inlight Wealth also offers financial planning services to those clients in need of such services in conjunction with portfolio management services. Inlight Wealth’s financial planning services normally address areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess the financial circumstances of the client in order to more effectively develop the client’s Investment Plan. Financial planning is not offered as a stand- alone service or for a separate fee, but is typically provided in conjunction with the management of the portfolio. General Consulting In addition to the foregoing services, Inlight Wealth may provide general consulting services to clients. These services are typically provided in conjunction with portfolio management services and may include, without limitation, minimal cash flow planning for certain events such as education expenses or retirement, estate planning analysis, income tax planning analysis and review of a client’s insurance portfolio, as well as other matters specific to the client as and when requested by the client and agreed to by Inlight Wealth. Services to Retirement and Pension Plan Participants Inlight Wealth may also provide investment advice directly to plan participants, but only as a non- discretionary fiduciary. Inlight Wealth provides participants with diversification strategies and recommendations, and the participants will have the sole responsibility to execute the transactions. In some cases, Inlight Wealth may, after approval of the client, instruct the record-keeper or third party administrator to execute recommendations on the client’s behalf. From time to time, Inlight Wealth will also meet with plan participants to provide general investment education, which may include basic information regarding insurance products, mutual funds, annuities, inflation, risk and diversification. Principal Owners Jason Joffe is the principal owner and Angelique Dumler, Benjamin Esser and Brian Harper are owners of Inlight Wealth. Type and Value of Assets Currently Managed As of February 21, 2024, Inlight Wealth had $339,754,000 in discretionary regulatory assets under management and $22,912,000 in non-discretionary regulatory assets under management.