A. Description of the Advisory Firm Auctus Advisors, LLC (hereinafter “Auctus Advisors”) is a Limited Liability Company organized in the State of North Carolina. The firm became registered as an investment advisor in October 2017 and the principal owner is David Miller. B. Types of Advisory Services Portfolio Management Services Auctus Advisors offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Auctus Advisors creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Auctus Advisors evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Auctus Advisors will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Auctus Advisors seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Auctus Advisors’ economic, investment or other financial interests. To meet its fiduciary obligations, Auctus Advisors attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Auctus Advisors’ policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Auctus Advisors’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Pension Consulting Services Auctus Advisors offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include but are not limited to investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments Auctus Advisors generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture

capital funds and private placements, although Auctus Advisors primarily recommends mutual funds and EFTs. Auctus Advisors may use other securities as well to help diversify a portfolio when applicable. Retirement Account Rollovers When Auctus Advisors provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way Auctus Advisors makes money creates some conflicts with client interests, so Auctus Advisors operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, Auctus Advisors must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Auctus Advisors gives advice that is in the client’s best interest;
• Charge no more than is reasonable for Auctus Advisors’ services; and
• Give the client basic information about conflicts of interest. Conflicts of interest can arise in a variety of contexts, including with respect to rollover recommendations. If Auctus Advisors recommends that a client roll over their retirement account assets into an account to be managed by Auctus Advisors, such a recommendation creates a conflict of interest if Auctus Advisors will earn a new (or increase its current) compensation as a result of the rollover. No client is under any obligation to rollover retirement plan assets to an account managed by Auctus Advisors. C. Client Tailored Services and Client Imposed Restrictions Auctus Avisors will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by Auctus Advisors on behalf of the client. Auctus Advisors may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Auctus Advisors uses goals-based investing and will generally start with comprehensive planning to determine a target rate of return needed for a client to accomplish their financial goals. We use Monte Carlo simulations of distribution planning under varioussaving and allocation scenarios to create a guideline allocation. We then evaluate market conditions and the investment landscape to tactically allocate from that baseline created by the planning. We analyze the standard deviation and beta of the portfolios to help educate clients on potential volatility needed to achieve targeted returns. This is a custom process for each client who goes through our planning process. We use both Tactical and Strategic portfolio construction. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Auctus Advisors does not participate in any wrap fee programs. E. Assets Under Management As of 2/13/2023, Auctus Advisors had a total of $342,452,191 assets under management: Discretionary Amounts: $322,493,724 Non-discretionary Amounts: $19,958,467