Page 4 A. Ownership/Advisory History Walled Lake Planning and Wealth Management, LLC (“Walled Lake” or the “firm”) is an Illinois limited liability company. Walled Lake has been registered as an investment adviser since 2018 and is owned by Howard Klieger and Noel Cooper. B. Wealth Management Services Walled Lake provides clients with wealth management services which may include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non- discretionary investment management services. Investment Management Services Walled Lake’s investment management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. Walled Lake will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. In addition, Walled Lake may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. Under an investment management engagement, Walled Lake primarily allocates client assets among various securities and strategies described in Item 8 of this brochure. Where appropriate, Walled Lake may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage the firm 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. In these situations, Walled Lake directs or recommends the allocation of client assets among the various investment options available within the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Please note that our advice for 401(k) plans and insurance and annuity contracts is confined to the investment alternatives made available by the plan sponsor or insurance company. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio (must be in writing and sent to the firm), and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Walled Lake will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Walled Lake will also Page 5 contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Use of Independent Managers Walled Lake may select certain independent managers or sub-advisors to actively manage a portion of its clients’ assets. If an independent manager is utilized for client portfolio management, Walled Lake will provide the client with Walled Lake’s disclosure documents as well as

the independent manager’s disclosure documents. Subject to the client’s written authorization, the independent managers will have limited power- of-attorney and trading authority over those assets they manage. On an ongoing basis, the firm would monitor the performance of those independent managers and seek to ensure the independent managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Financial Planning and Consulting Services Walled Lake provides financial planning and consulting services to clients of investment management services at no additional charge. These services may include any or 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 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 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 meaningful change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the firm’s recommendations and/or services. Page 6 Walled Lake’s role will be that of a coordinator between the client and their designated professional(s). When performing the financial planning services, we are neither the client’s attorneys nor accountants, and no portion of the financial plan or any financial planning services rendered by us should be interpreted by the client as legal or accounting advice. We recommend that clients seek the advice of a qualified attorney and/or accountant. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Walled Lake offers its investment management services exclusively through a wrap fee program, where brokerage commissions and transaction costs are included in the asset-based fee charged to the client. For information, please refer to Appendix 1 of Part 2A: Walled Lake Planning and Wealth Management, LLC, Wrap Fee Program Brochure. E. Client Assets Under Management As of December 31, 2023, Walled Lake managed $556,559,668 of discretionary assets. Item 5: Fees and Compensation