A. Description of the Advisory Firm Jaykay Wealth Advisors, Inc. (hereinafter “JKWAI”) is a Corporation organized in the State of Texas. The firm was formed in December 2003, and the principal owners are Jayanth Kabad, Kanchan Kabad and Anasuya Kabad Meyer. In 2018 the firm reached the level of assets under management where it changed its primary regulatory authority to the U.S. Securities and Exchange Commission. B. Types of Advisory Services JKWAI offers the following services to advisory clients: Portfolio Management Services JKWAI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 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 JKWAI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. JKWAI will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. JKWAI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of JKWAI’s economic, investment or other financial interests. To meet its fiduciary obligations, JKWAI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, JKWAI’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 JKWAI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent that might have a limited supply, among its clients on a fair and equitable basis over time. 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. Referral of Third-Party Money Managers SEI Asset Management Program The SEI Asset Management Program (SEI Program) is an institutional asset allocation program that JKWAI uses in the management of assets for client accounts. If you enroll in the SEI Asset Management Program, JKWAI will assist you in the establishment of a SEI Program Account (the Account) at SEI Private Trust Company (SEI). All Account transactions are processed and cleared through SEI. The SEI Program uses asset allocation portfolios developed by SEI Investments. The portfolios consist of SEI Family of Institutional Mutual Funds (Mutual Funds) and other securities approved by SEI to be held in an account. The SEI Program uses the Portfolio Managers selected and subject to oversight by SEI and who have entered into a sub- advisory agreement with SEI. JKWAI will provide SEI with the asset allocation policy that you select for your account. JKWAI will direct SEI to reallocate your investments in accordance with your Asset Allocation Policy. In addition, based on JKWAI instructions, SEI will rebalance the investments within your account at least annually so that the market value of the shares of each mutual fund held in your account is the same percentage of the total market value of your account as required by your Asset Allocation Policy. SEI and its Portfolio Managers will have discretionary authority over the assets and transactions in the Account. JKWAI will have discretionary authority to re- allocate your portfolios among the various Portfolio Managers as needed. SEI has the authority to replace a previously selected Portfolio Manager or SEI Fund without your prior approval. Custody of all SEI Program Client Account assets is held at SEI Private Trust Company. Retirement Plan Services JKWAI offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services JKWAI provides the following Fiduciary Retirement Plan Consulting Services:
• Non-Discretionary Investment Advice. JKWAI will provide you with general, non- discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement.
• Investment Selection Services. JKWAI will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. JKWAI will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and JKWAI will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. JKWAI will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).
• Individualized Participant Advice. Upon request, JKWAI will provide one-on-one advice to Plan participants regarding their individual situations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Fiduciary Consulting Services are not management services, and JKWAI does not serve as administrator or trustee of the plan. JKWAI does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). JKWAI acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. JKWAI will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause JKWAI to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, JKWAI (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary

authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. JKWAI provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. JKWAI will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. JKWAI’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. JKWAI will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Qualified Plan Development. JKWAI will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we shall assist you with the review and selection of a Third Party Administrator for the Plan.
• Due Diligence Review. JKWAI will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers.
• Benchmarking. JKWAI will provide you benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, JKWAI cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. JKWAI will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Educational Seminars/Workshops JKWAI occasionally provides seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning or other relevant financial topics. Seminars/ workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. Services Limited to Specific Types of Investments JKWAI generally limits its investment advice to mutual funds, equities, fixed income securities, real estate funds, real estate investment trusts (REITs), Business Development Companies, insurance products including annuities, private placements and hedge funds. JKWAI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions JKWAI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the s client’s current situation (income, tax levels, and risk tolerance levels). 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 JKWAI from properly servicing the client account, or if the restrictions would require JKWAI to deviate from its standard suite of services, JKWAI reserves the right to end the relationship. D. Wrap Fee Programs JKWAI offer services exclusively through wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure, JKWAI will receive all or a portion of the fee charged. E. Assets Under Management JKWAI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $164,534,840 0 01/03/2024