A. Firm Information Vigil Wealth Management, LLC (“Vigil Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of Florida. Vigil Wealth was founded in May 2017 and became a registered investment advisor in December 2018. Vigil Wealth is owned and operated by David J. Vigil (Principal, Chief Compliance Officer, and Private Wealth Advisor). This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Vigil Wealth. David J. Vigil, CFP,® CIMA®, Principal and Private Wealth Advisor David works with a wide array of successful families, business owners, and corporations. He works with clients individually to ensure he understands their current situation, personal feelings, family dynamics, and financial goals. David began his financial advisor career at UBS in 2004 and has also worked at Morgan Stanley and SunTrust in the Ponte Vedra Beach, FL area. Prior to his investment career, David served as a Supply Specialist in the U.S. Army and as the Head Golf Professional at Sawgrass Country Club. A graduate of Central Washington University with a bachelor’s degree in Accounting, David attended the Wharton Business School to attain the CIMA® Certified Investment Management AnalystSM designation and holds the CFP®, CERTIFIED FINANCIAL PLANNER™ designation. David is married to Vicky, who together have an adult daughter Baylee. David is an active member of the Ponte Vedra community, having served as a youth basketball coach at the YMCA and assisted with the First Tee of Jacksonville. In his spare time, David enjoys golfing and competing as a Triathlete. B. Advisory Services Offered Vigil Wealth offers investment advisory services to individuals, high-net-worth individuals, trusts, estates, businesses, pension and profit-sharing plans, and broker-dealers (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. Vigil Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Vigil Wealth provides Clients with wealth management services, which generally include discretionary management of investment portfolios in connection with a broad range of comprehensive financial planning services. Investment Management Services – Vigil Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non- discretionary investment management and related advisory services. Vigil Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Vigil Wealth will then construct a portfolio consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, options contracts, or other types of investments as necessary and appropriate to meet the needs of the Client. The Advisor may also retain certain legacy investments based on portfolio fit and/or tax implications. Vigil Wealth selects, recommends, and/or retains mutual funds on a fund-by-fund basis and seeks to use non- retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax considerations, and/or systematic investment plans, Vigil Wealth may select, recommend, and/or retain a mutual fund share class that has a higher expense ratio than an equivalent share class. Vigil Wealth will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and state investment guidelines. Vigil Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Vigil Wealth will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Vigil Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Vigil Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Vigil Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Vigil Wealth may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, changes in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. LPL Financial Sponsored Advisory Programs – Vigil Wealth may provide advisory services through certain programs sponsored by LPL Financial, LLC (“LPL”), a registered investment advisor and broker-dealer (CRD# 6413). LPL charges fees for these sponsored programs that are in addition to Vigil Wealth’s advisory fees. Below is a brief description of each LPL advisory program used by the Advisor. For more information regarding the LPL programs, including information on the advisory services and fees that apply, the types of investments available in the programs, and the conflicts of interest presented by the programs, please refer to the applicable LPL program client account packet.
• Manager Access Select Program (“MAS”) – Manager Access Select offers Clients access to the investment advisory services of professional portfolio management firms for the individual management of Client accounts. The Advisor will assist the Client in identifying a third-party portfolio manager (“Portfolio Manager”) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages Clients’ assets on a discretionary basis. The Advisor will provide the initial and ongoing assistance regarding the Portfolio Manager selection process. LPL requires a minimum account value of $50,000 for Manager Access Select; however, in certain instances, the minimum account size may be lower or higher.
• Model Wealth Portfolios Program (“MWP”) – MWP offers Clients a professionally managed mutual fund asset allocation program. The Advisor will obtain the necessary financial data from the Client, assist the Client in determining the suitability of the MWP program, and assist the Client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have the discretion to select a model portfolio designed by LPL’s Research Department consistent with the Client’s stated investment objective. LPL’s Research Department or a third-party portfolio strategist act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The Client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The Client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio[s] selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $10,000. Use of Independent Managers – Vigil Wealth will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the

Client’s investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. Prior to entering into an agreement with an Independent Manager, the Client will be provided with the Independent Manager’s Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures). Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor 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, the Advisor will provide investment advice to the 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 the Advisor earns a new (or increases 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 the Advisor. Participant Account Management – As part of the Advisor’s investment management services, when appropriate, the Advisor will use a third-party platform to facilitate the management of held-away assets, such as defined contribution plan participant accounts, with investment discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. Vigil Wealth is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client, allowing the Client to connect an account[s] to the platform. Once the Client’s account[s] is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account[s] will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. At no time will Vigil Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Financial Planning Services – Vigil Wealth will typically provide a variety of financial planning and consulting services to Clients either as a component of its wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings, and/or charitable giving programs. Vigil Wealth may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive for Clients to engage the Advisor for investment management services or increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect the transaction through the Advisor. Retirement Plan Advisory Services Vigil Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’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 generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendations and Assistance
• ERISA 404(c) Assistance These services are provided by Vigil Wealth, serving in the capacity of 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 Vigil Wealth’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Institution Consulting Services Vigil Wealth provides investment consulting services to Mutual Securities, Inc. (“Mutual Securities”) brokerage clients (“Brokerage Clients”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with Vigil Wealth. Consulting services are strictly provided on the products Brokerage Clients have with Mutual Securities. Please see Items 5 and 10 for additional details. C. Client Account Management Prior to engaging Vigil Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Vigil Wealth, in connection with the Client, develops a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Vigil Wealth will develop a strategic asset allocation targeted to meet the investment objectives, time horizon, financial situation, and tolerance of risk for each Client.
• Portfolio Construction – Vigil Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Vigil Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Vigil Wealth includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program.” The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Vigil Wealth Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2022, Vigil Wealth manages $104,790,761 in Client assets, $100,045,361 of which are managed on a discretionary basis, and $4,745,400 are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.