The Firm offers discretionary and non-discretionary investment management and investment advisory services. Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Firethorn Wealth Partners, LLC (“Firethorn” or the “Firm) has been registered as an investment adviser since 2018 and is owned by Scott Benjamin, Kevin Sweeney and Gerald Rogers. As of December 31, 2023, the Firethorn Wealth Partners, LLC manages approximately $314,320,493 in assets for approximately 1700 accounts on a discretionary basis and manages approximately $145,358,114 in assets for approximately 143 accounts on a non-discretionary basis. It total, Firethorn Wealth Partners, LLC manages approximately $459,678,607 in assets for approximately 1843 accounts. While this brochure generally describes the business of the Firm, 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 any other person who provides investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Firethorn offers clients a broad range of financial planning and consulting services, which may include any of all of the following functions: Business Planning, Cash Flow Forecasting, Trust and Estate Planning, Financial Reporting, Investment Consulting, Insurance Planning, Retirement Planning, Risk Management, Charitable Giving, Distribution Planning, Tax Planning, College Planning, and Manager Due Diligence. In performing these services, the Firm is not required to verify any information received from the client or from the client’s other professionals (e.g. attorneys, accounts, etc.) and is expressly authorized to rely on such information. The Firm may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or register representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if client engages Firm or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by the Firm 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 the Firm’s recommendations and/or services. Wealth Management Services Firethorn provides clients with wealth management services which may include a broad range of comprehensive financial planning and consulting services as well as discretionary and non-discretionary management of investment portfolios. Firethorn Wealth Partners primarily allocates client assets among various mutual funds, exchange- traded funds (“ETFs”), individual debt and equity securities, options and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. In addition, Firethorn may also recommend that certain eligible clients invest structured products, as well as in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). When appropriate and fully disclosed, Firethorn may recommend investment products which require longer-term commitments from its clients. Firethorn shall provide continuous monitoring of such investments to include annual due diligence, performance tracking, amendment processing, and capital call assistance. Where appropriate, Firethorn may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage Firethorn to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e. 529 plans). In these situations, Firethorn 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. The Firm 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. The Firm 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 the Firm if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if the Firm 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 Plan Consulting Services Firethorn provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized and may include any or all of the following services: Plan Design and Strategy, Plan Review and Evaluation, Executive Planning & Benefits, Investment Selection, Plan Fee and Cost Analysis, Plan Committee Consultation, Fiduciary and Compliance, and Participant Education. As disclosed in the Firethorn Advisory Agreement, certain of the foregoing services are provided by Firethorn as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Firethorn’s fiduciary status, the specific services to be rendered and all direct and indirect compensation that Firethorn reasonably expects under the engagement. Education Advisory and Consulting Firethorn provides another dimension to the comprehensive financial process by offering a service to assist with college planning and funding. Each engagement contains a process to help families determine their EFC, eligibility for financial aid, determine what college will actually cost, what college(s) offer the best educational value, what your action items need to be and how college funding fits within your overall financial plan. Use of Independent Managers The Firm may select certain Independent Managers to actively manage a portion 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 Managers engaged to manage their assets. The Firm evaluates a variety of information about Independent Managers, which may include 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. The Firm also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. The Firm continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. The Firm seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Outsourcing of Certain Investment Operations Firethorn Wealth Partners works with various third-party service providers, including, among others, Orion, Inc., to help support the operational needs of managing and servicing Client accounts. Authority provided to the outsourced service providers may include but is not limited to placing transactions with broker-dealers at the direction of Firethorn Wealth Partners, opening accounts with Client’s account custodian, and facilitating operational requests on the Client’s behalf based on instructions provided by associated persons of Firethorn Wealth Partners. When providing these services, the third-party service provider is acting as an agent of Firethorn Wealth Partners. Betterment Program Through the Betterment Program, we offer our Clients access to, and advice regarding the Betterment for Advisers Service, which is an institutional wrap fee program (the “Betterment Program”) sponsored by Betterment LLC, an SEC registered investment adviser (referred to as “Betterment Adviser”). Betterment Adviser is affiliated with MTG, LLC dba Betterment Securities (referred to “Betterment Broker”), an SEC- registered broker-dealer, and member of SIPC and the Financial Industry Regulatory Authority (“FINRA”). Firethorn is not affiliated with Betterment Adviser or Betterment Broker. Overview of Firethorn’s Role in the Betterment Program As explained in more detail below and in Client's separate agreement with Betterment Adviser and Betterment Securities (the “Betterment Program Agreement”), in general, Firethorn has entered into an Agreement with Betterment Adviser and Betterment Securities (the "Betterment Subadvisor Agreement"), pursuant to which Betterment Adviser agrees to provide the sub advisory services in connection with Clients who participate in the Betterment for Advisors Program, as described in the Betterment Subadvisor Agreement, and Betterment Securities agrees to provide trade execution services in connection with the orders placed by Firethorn 's Clients through the Betterment for Advisors program (all the "Betterment Program"). Firethorn’s role with respect to the Betterment Program account will be limited to assisting the Client in establishing accounts with Betterment Adviser and Betterment Securities, identifying the Suitability Information (as described below) for the account, and assisting the Client in developing the initial Portfolio and Allocation, as discussed below. Once the initial Portfolio and Allocation have been selected, Firethorn will continue to assist the Client by answering general questions regarding the account, periodically discussing the Portfolio and Allocation with the Client to ensure it continues to meet the Client’s needs and recommending revisions to the Portfolio or Allocation in response to changes in the Suitability Information of which the Firm is notified. The Firm’s Clients are required to participate in the Firm's discretionary Investment Management Program which provide the Firm discretion to "hire and fire," and reallocate the assets allocated to the Betterment Program to accounts managed by the Firm if at any time Firethorn determines termination of the sub advisory relationship with Betterment is appropriate. However, refer to the limitations below on the Firm’s discretion to act with respect to the Betterment Program account. Overview of Betterment Adviser’s Role in Betterment Program The selection of the securities

that will be available for the Client Portfolios, the monitoring of the account and rebalancing according to established account parameters, and the reinvestment of investment dividends, among other key investment functions, are all functions for which Betterment Adviser is responsible on an ongoing basis. Firethorn does not supervise or participate in any way in Betterment Adviser’s or Betterment Securities’ performance of their responsibilities. Clients will initially meet with their Firethorn Representative, who will obtain information regarding the Client's personal and financial situation, and the investment objective, tolerance for risk, liquidity needs, and investment time horizon for the account that will be managed through the Betterment Program (all referred to as the "Suitability Information"), as well as any reasonable investment restrictions the Client wishes to impose. Utilizing the online tools and investments available through the Betterment’s online platform (the “Website”), the Representative will work with the Client to select a portfolio (the Portfolio”) representing an “Allocation” among equity and fixed income exchange-traded funds (“ETFs”), that are suitable for the account in view of the account's investment objective, liquidity needs, investment time horizon, risk tolerance, and any reasonable investment restrictions imposed by the Client. The Portfolio selection and Allocation will be based on the research and recommendations provided by Betterment Adviser. The Representative will work with the Client to match the Portfolio and Allocation to the account’s needs. Firethorn will not have discretion with respect to the assets invested in the Client’s Betterment Program account; and the Firm will not be responsible for or have discretion with respect to making any of the purchases or sales of securities in the Betterment Program account or selecting or removing the ETFs that are available through the Betterment Program. The Betterment Website provides self-help tools to help Clients understand their risks, access information related to transactions, and review their account’s performance. Advisory Agreements and Custodial Accounts In addition to their existing Advisory Agreement with Firethorn, Clients who desire to participate in the Betterment Program will enter into an advisory agreement with Betterment Adviser, and a brokerage agreement with Betterment Broker, which will maintain the account’s assets and provide brokerage services. We refer to Betterment Broker as the “Custodian” because it will serve as the qualified custodian of the Client’s assets. Betterment Discretion over the Account; Authority to Rebalance and Liquidate Securities In the Betterment Adviser advisory agreement, Client will grant Betterment Adviser full discretion to select the investments, to designate the strategies, and to buy, sell, or otherwise invest the assets of the account, all without prior notice or consent of the Client or Firethorn. Betterment Adviser will periodically rebalanced account (within certain “drift” parameters) to maintain their designated Allocation. Betterment Adviser’s portfolio management services also include a dividend reinvestment plan whereby dividends from Client investments are used to purchase additional investments in accordance with the account’s Allocation. Betterment requires Clients to agree to have their accounts automatically rebalanced and dividends automatically reinvested. Clients also grant Betterment Adviser authority to liquidate sufficient assets to pay the advisory fee, program fees, or any costs or expenses of the Betterment Program, when necessary; and authority to carry out related actions that the Betterment Adviser deems necessary or appropriate to fulfill these responsibilities. Types of Investments In general, the Portfolios consist of varying proportions of fixed income and equity ETFs selected by Betterment Adviser for the Betterment Program. ETFs are a type of Investment Company that aims to achieve the same return as a particular market index. They can be either open-end companies or unit investment trusts. ETFs are not considered to be, and are not permitted to call themselves, mutual funds. ETFs differ from mutual funds and unit investment trusts because shares issued by ETFs are bought and sold by investors on a secondary market. Unlike mutual funds, retail investors generally cannot tender their shares directly to the ETF for redemption because shares of ETFs are redeemable from the fund only in very large blocks (blocks of 50,000 shares, for example). Deposit Cash or Cash Equivalents Generally, the Client is expected to deliver only cash or cash equivalents to the Custodian. With our consent, Client may transfer securities to the Custodian, but the securities will be liquidated to cash as soon as reasonably practical. Client may not transfer or deposit to the account any securities that are not publicly traded or that cannot be promptly sold. Client will grant us, Betterment Adviser, and the Custodian the authority, in our respective discretion, to liquidate securities transferred into the account. Evaluate All Costs of Our Program When evaluating the overall costs and benefits of the Betterment Program, Clients should consider not just our Advisory Fees, but also the Betterment Advisory Fees (which includes the cost of the purchases and sales of securities for the Client’s Betterment Program account), and the ETF Expenses. Clients should consider carefully all of the direct and indirect fees and expenses of our services and the investment products we recommend to fully understand the total costs and assess the value of our services. Account Billing Administration Fees As one of its services, Betterment Adviser will perform account billing administration, whereby it will act as a billing service provider, to calculate and deduct from the Client’s account our Advisory Fee together with the advisory fee owed to it through the Betterment Program and pays the applicable parties. The Client account will not be charged separately for this service Betterment Adviser performs for our benefit; however, if Betterment Adviser did not provide this service, it is possible that the fees the Client paid might be lower. Information about Wrap Fee Programs The Betterment Program is a “wrap fee” program. The Client receives the Form ADV Part 2A Appendix 1 Wrap Fee Brochure from Betterment Adviser, which is the sole sponsor under the Betterment Program. Because Firethorn is not compensated for sponsoring, organizing, or administering the Betterment Program, and does not recommend any third-party managers, it is not a sponsor of the Betterment Program. Wrap fee programs have important differences from traditional investment advisory arrangements. In a traditional investment advisory arrangement, the investment adviser provides investment advisory services for managing the Client’s account, and then charges the Client an advisory fee that is based on a percentage of the account’s assets (referred to as an “asset-based fee”). When the investment adviser places trade orders with a broker-dealer to invest the account’s assets, the account pays brokerage commissions for the broker’s services in executing the trade plus related costs (referred to as “transaction- based costs”). By contrast, in a wrap fee program, the Client pays a single fee (the “wrap fee”) that includes both the advisory services of the account’s investment adviser and the brokerage services of the account’s broker and may also include custodial services of the account’s custodian. The wrap fee is based on a percentage of the account’s assets. In the Betterment Program, the fees payable to Betterment Adviser for its advisory services, and Betterment Securities, for its brokerage services, are combined and deducted from the Betterment Custodial Account. In addition, Firethorn's Advisory Fee, which is owed pursuant to the Client's Advisory Agreement, not the Betterment Agreement, will also be deducted from the Betterment Account. Although wrap fee programs can be beneficial for some Clients, they are not appropriate for everyone. Some Clients may pay higher overall costs in a wrap program than in a traditional program where they pay separately for investment advisory services and brokerage costs. The benefits of a wrap fee arrangement depend on a number of factors, most particularly the amount of the wrap fee, the number and frequency of account trades, and the types of securities the account will trade. Wrap fee programs calculate their fees based, in part, on certain assumptions regarding their expected brokerage commissions and other transaction costs. Clients who do not expect their accounts to trade frequently or for whose accounts the total number of shares traded each year is relatively low may find a wrap fee arrangement to be more costly than a traditional program where the Client pays the separate costs of brokerage commissions and fees for investment advice. A wrap fee arrangement is more likely to be beneficial for accounts that expect relatively frequent trading, such as where the account intends to pursue an active trading strategy using securities for which the transaction costs are relatively higher. In that case, the single wrap fee may cost less than the combined investment advisory fees and brokerage commissions that would be charged in a traditional arrangement. Clients who choose strategies with modest levels of trading may not incur sufficient transaction costs to justify the higher fees charged in a wrap fee program, as compared to a traditional arrangement where they pay commissions out-of-pocket. Clients are cautioned to review the information regarding the costs of the wrap fee, the anticipated level of trading anticipated for their account, the approximate transaction costs and advisory fees they might incur in a traditional arrangement, among the other matters discussed in this Brochure, to understand the costs and factors they should consider when deciding whether to participate in (or to continue to participate in) the Betterment Program. No assumption should be made that any particular fee arrangement, such as a wrap fee arrangement or a portfolio management service will provide better returns than any other fee arrangement, service, or investment strategy. Fees paid by Clients in the Betterment Program may be more or less than fees charged for advisory, custodial or brokerage services offered separately, depending on the nature, size and frequency of account transactions, and other services. Depending upon, among other things, the size of the account, changes in value over time, ability to negotiate fees or commissions, and the number of transactions, the amount of the wrap fee compensation may be more than what a Representative would receive if the Client participated in other programs, or if the Client paid separately for investment advice, brokerage and other services. Therefore, while wrap account compensation cannot be determined in advance, the Representative may have an incentive to recommend the Betterment Program over other programs or services. Further, Clients should consider that the wrap fee arrangement creates a disincentive for Betterment Adviser and Betterment Broker to trade Betterment Program accounts because the execution costs of each trade will reduce the potential profit from the Wrap Fee. A wrap program sponsor may have an incentive to limit referrals to or outright exclude from its program portfolio managers that trade actively. Please refer to Item 8 for information about Firethorn’s methods of analysis and investment strategies, the types of investments the Firm generally recommends, and the material risks involved with respect to the Investment Management Program. Refer to Item 12 for information regarding brokerage. Other Outsourced Offerings As mentioned, Firethorn provides various services to their clients. Firethorn my provide access to other services to assist clients with their planning needs. Services such as estate planning and wills, a co- branded savings account platform.