DESCRIPTION Secure Asset Management, L.L.C., (“SAM”) was founded in 2007. Bryan Spencer is 100% owner. SAM provides personalized confidential financial planning and investment management primarily to individuals. Advice is provided through consultation with the client and may include, determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. SAM is a fee-based financial planning and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm’s managing member is affiliated with entities that sell insurance products; Secure Investors Group, Inc., provides Tax Services; Secure Tax Service, and Mortgage Services, Secure Mortgage Funding, and a Broker/Dealer; Aurora Securities, Inc. SAM does not act as a custodian of client assets. The client always maintains asset control. An evaluation of each client's situation is provided to the client, often in the form of an Investment Policy Statement or similar documents. Annual reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client. Types of Advisory Services SAM provides investment supervisory services, also known as asset management services, referral to third party money managers and pension consulting services. Asset Management SAM offers discretionary direct asset management services to advisory clients. SAM will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. The client will authorize SAM discretionary authority to execute investment transactions as stated within the Investment Advisory Agreement. Clients may terminate asset management services with seven days written notice. SAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SAM’s economic, investment or other financial interests. To meet its fiduciary obligations, SAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, SAM’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 SAM’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. 5 Secure Asset Management, LLC Selection of Other Adviser Arrangements SAM solicits the services of Third Party Money Managers to manage some client accounts. In such circumstances, SAM receives solicitor fees from

the Third Party Manager. SAM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where SAM is recommending the adviser to clients. This is detailed in Item 10 of this brochure. The duties and responsibilities owed to the client by the Third Party Manager and by SAM are detailed in the Third Party Manager's Investment Advisory Agreement. SAM will be responsible for ensuring that the products and services offered by Third Party Manager are suitable and appropriate for each individual SAM client in which the services of a Third Party Manager are recommended. Pension Consulting Services SAM offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Pension consulting services may involve the direct investment management of one or more 401(k) participant accounts, provide the selection and monitoring process for the various mutual funds offered to plan participants, develop and maintain an Investment Policy Statement for the plan, and/or provide group and individual employee education on investment options, asset allocation, and retirement planning. Services Limited to Specific Types of Investments SAM generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds and options. SAM may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Arrangements may not be assigned without prior written client consent. 6 Secure Asset Management, LLC Wrap Fee Programs SAM does not participate in wrap fee programs. Client Assets under Management As of December 2023, SAM managed $ 599,576,285 in assets under management, $ 557,812,936 in discretionary assets and $ 41,763,349in non-discretionary assets. As of December 2023, SAM has $ 2,082,041,095.21. in client assets under advisement.