A. Description of the Advisory Firm Weinberger Asset Management, Inc. (hereinafter “WAM”) is a Corporation organized in the State of California. The firm was formed in November 1993, and the principal owner is Alexander Weinberger, President & Chief Compliance Officer. B. Types of Advisory Services Portfolio Management Services WAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WAM meets with the client to gather information regarding the client’s current situation (income, tax levels, risk tolerance levels, etc.) 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
• Asset allocation
• Risk tolerance
• Asset selection
• Regular portfolio monitoring WAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. WAM will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. WAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WAM’s economic, investment or other financial interests. To meet its fiduciary obligations, WAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WAM’s 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 WAM’s 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. Selection of Other Advisers As part of our overall portfolio management services, from time to time, we may recommend that clients use the services of one or more unaffiliated, independent third-party managers (“sub-advisers”) to manage clients’ investment portfolios. Some or all of the assets in the client’s account(s) may be managed using one or more model portfolios developed by us or others. All sub-advisers recommended by our firm must either be registered as investment advisers or exempt from registration requirements in the jurisdiction in which the client resides. When selecting a particular sub-adviser, model portfolio, or program, the client's best interest will be the main determining factor. Other factors that we take into consideration when selecting sub- advisers include, but are not limited to the sub-adviser’s performance history, methods of analysis, fees, the client’s financial needs, investment goals, risk tolerance, and investment objectives. We will regularly monitor the sub-adviser’s performance to ensure their management and investment style remains aligned with the client’s investment goals and objectives. In some cases, the client may be required to execute a separate advisory agreement or trading authorization with certain sub-advisers or the account custodian for certain managers available through the custodian’s platform. Additionally, we have engaged another investment adviser at our expense to assist us with back-office services, including placing trades through the account custodian based on our allocation instructions. In such cases, the client will not pay additional fees for these back-office services. Retirement Plan Services WAM offers services to sponsors of defined benefit or defined contribution plans based upon the plan’s specific needs and negotiated between the plan sponsor and WAM. Such services may include one or more of the following services as agreed upon between the plan sponsor and WAM as set forth in a written retirement plan consulting agreement.
• Plan Level Ongoing Services offered on a discretionary basis (ERISA 3(38) Services) include preparation of an investment policy statement (IPS), discretionary investment management, selection of a qualified default investment alternative (QDIA), performance monitoring and reporting of investments, education services to plan fiduciaries, counseling services to plan fiduciaries on increasing participant retirement readiness, participant investment education services, participant enrollment services, concierge services, requests for proposals/plan vendor search, benchmarking services, and/or assistance in identifying plan fees.
• Plan Level Ongoing Services offered on a non-discretionary basis (ERISA 3(21) Services) include advice regarding development of an investment policy statement (IPS), non- discretionary investment advice to the plan, non-discretionary advice on a qualified default investment alternative (QDIA), education services to plan fiduciaries, counseling services to plan fiduciaries on increasing participant retirement readiness, participant investment education services, participant enrollment services, concierge services, requests for proposals/plan vendor search, benchmarking services, and/or assistance

in identifying plan fees.
• Participant Level Ongoing Services offered include individualized investment adviser for plan participants as agreed upon by between the plan sponsor and WAM. Services Limited to Specific Types of Investments WAM 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. WAM may use other securities as well to help diversify a portfolio when applicable. Generally, clients may propose reasonable restrictions on the types of investments (such as specific types of securities, specific securities, or specific industries) to be made for their accounts at any time by providing a written request to us. We will promptly communicate such requests to any selected sub-advisers. However, clients whose assets are invested in model portfolios may not be able to set restrictions on the specific holdings or allocations within the model, nor on the types of securities that can be purchased in the model. However, clients may exclude certain assets from management in model portfolios. We would not have discretion to manage any assets held outside the model portfolios and the client would be responsible for the management of any outside assets, as we would not have trading authorization for those accounts. IRA Rollover Considerations As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase for the investor as a result because the above-described fees will apply to assets rolled over to an IRA, and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interests and not put our interests ahead of yours. At the same time, the way we make money creates some conflicts with clients’ interests. Non-Advisory Services We may offer tax preparation services to advisory clients and non-advisory clients. All tax services are offered through a Certified Public Accountant (CPA) or Enrolled Agent (EA) employed by the firm. Tax preparation services and fees are separate from and in addition to advisory services and fees. Clients are not obligated to utilize tax services offered through our firm or any individual associated with our firm. Tax clients are not obligated to utilize advisory services offered through our firm. None of our management persons or investment adviser representatives are licensed CPAs or EAs and do not provide tax services. C. Client Tailored Services and Client Imposed Restrictions WAM 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 WAM on behalf of the client. WAM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent WAM from properly servicing the client account, or if the restrictions would require WAM to deviate from its standard suite of services, WAM reserves the right to end the relationship. We consider liquidity needs and other client-specific needs. We tailor our advisory services to individual client needs; consistent with this approach clients may restrict both certain types of investments and investments in certain types of securities. 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. WAM does not participate in any wrap fee programs. E. Amounts Under Management WAM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $360,155,504 $0.00 02/21/2024