Centura offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Centura rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Centura setting forth the relevant terms and conditions of Centura relationship (the "Advisory Agreement"). Centura has been registered as an investment adviser since May 2018 and is owned by Derek Myron, Kyle Malmstrom, KGMS Capital, LLC, Christopher Osmond, and CCG WM Holding Company, LLC. Centura calculates its regulatory assets under management ("RAUM") pursuant to the instructions to Form ADV. Centura's RAUM includes all client accounts that Centura manages on a discretionary basis. As of December 31, 2023, Centura had $642,975,493 in RAUM, all of which was managed on a discretionary basis. In addition to its RAUM, Centura oversees $110,684,231 of assets under advisement ("AUA"), which includes assets for which the Firm provides investment planning or consulting services and insurance accounts that require reporting or other services. Thus, as of this date, Centura's "Total Assets"—the sum of its RAUM and AUA—was approximately $753,659,724. While this brochure generally describes the business of Centura, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Centura's behalf and are subject to the Firm's supervision or control. Financial Planning and Consulting Services Centura offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning • Retirement Planning
• Cash Flow Forecasting • Risk Management
• Trust and Estate Planning • Charitable Giving
• Financial Reporting • Distribution Planning
• Investment Consulting • Tax Planning
• Insurance Planning • Manager Due Diligence
• Real Estate Planning In performing these services, Centura is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. The Firm also recommends that clients verify any guidance given by Centura with their other respective professionals in the relevant space. Centura recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Centura or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Centura under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Centura's recommendations and/or services. Investment Management Services Centura manages client investment portfolios on a discretionary or non-discretionary basis. Centura primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"), alternative investments (including privately placed securities in real estate, debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds or real estate funds), as well as a limited amount of equity and fixed income securities, including structured notes, options and independent investment managers ("Independent Managers") in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about legacy positions or other investments held in client portfolios. Clients can engage Centura to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as fixed and variable life insurance policies, fixed and variable annuity contracts, private investments, assets held in employer sponsored retirement plans, and qualified tuition plans (i.e., 529 plans). In these situations, Centura gathers related product information directly from the client or financial institution and directs or recommends the allocation of client assets among the various investment options available with the product. These assets are

generally maintained at the underwriting insurance company or the custodian designated by the product's provider. Centura tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Centura consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Centura if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Centura determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts. Retirement Accounts – When Centura provides investment advice to clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), Centura is 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. When deemed to be in the client’s best interest, Centura will provide investment advice to a client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if Centura will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by Centura. Use of Independent Managers As mentioned above, Centura selects certain Independent Managers to actively manage a portion of certain allocations of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Centura evaluates a variety of information about Independent Managers, which includes the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance, and risk results in relation to its clients' individual portfolio allocations and risk exposure. Centura also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Centura continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Centura seeks to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Retirement Plan Advisory Services Centura provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). Centura’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services available include:
• Vendor Analysis
• Investment Policy Statement (“IPS”) Design and Monitoring
• Discretionary Investment Management (ERISA 3(38))
• Investment Oversight (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Provider Search These services are provided by Centura serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Centura’s fiduciary status, the specific services to be rendered and all direct and indirect compensation Centura reasonably expects under the engagement.