Wealth Navigation, LLC (WN) has been in operation since 2007 and is wholly owned by WN Holdings, LLC. WN Holdings, LLC is owned by Axis Family Holdings, LLC. Wealth Navigation, LLC also does business under the name Oak Lane Advisors or Oak Lane Wealth (Oak Lane) and The WN Group. Certain Investment Advisor Representatives of WN may have their own legal business entities and business names as part of RIA co-brand; however, investment advisory services of the representatives are provided through WN. See Item 10 for a list of those arrangements and business entities. WN provides both asset management services and fee-based planning services. The asset management services we provide are for discretionary accounts. The investment recommendations made for these accounts include the following steps: 1) Comprehensive Evaluation of Investment Objectives WN will meet with each client for an initial review to determine investment objectives, risk tolerance and other relevant information at the beginning of the advisory relationship. The client is provided with an Investment Advisory Agreement (IAA) which includes the fee structure, privacy policy and form CRS. Under this authority, WN has authority to purchase and sell securities for the client’s account, arrange for delivery and payment in connection with security transactions, and act on behalf of a client in all matters necessary or incidental to the purchase and sale of securities in the client’s account. Unless specifically directed otherwise in writing by a client, WN is authorized to receive and vote proxies on issues held in each account and receive annual reports. 2) Appropriate Asset Allocation Recommendation WN will recommend an asset allocation according to the client’s risk tolerance, investment objectives and various other factors as explained below in the Asset Management Services section. WN will use its best judgment and good faith efforts in rendering this service to its clients. WN cannot warrant or guarantee any particular level of account performance, or that account will be profitable over time. Not every investment decision or recommendation made by WN will be profitable. Client assumes all market risk involved in the investment of the account assets under the terms of the IAA. Except as may otherwise be provided by law, WN will not be liable to the Client for: a) Loss that Client may suffer by reason of any investment decision made or other action taken or omitted in good faith by WN with that degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use b) Loss arising from WN’s adherence to Client’s instructions c) Any act or failure to act by a custodian of Client’s account, except as may be required by law. Federal securities laws impose liabilities under certain circumstances on persons who act in good faith and therefore, nothing herein shall in any way constitute a waiver or limitation of any rights which Client may have under any federal securities laws. As of December 2023, the total discretionary assets under management were $305,164,237 and non-discretionary assets were $0. Services Offered Asset Management Services WN offers various Asset Management services as part of its investment management program. Asset Management service begins with meetings between Advisor and Client to review long-term goals and objectives. These meetings include discussions on Client’s current financial situation, goals for investment assets, risk tolerance, time horizon, liquidity needs and so forth. WN will use information provided by the client to identify an appropriate strategy. WN will then create a portfolio

using a mix of investments that can include investments such as stocks, bonds, mutual funds (stock funds, bond funds and other asset classes), exchange-traded funds (“ETFs”), alternative investments, and other securities. WN will also consider client requested investment considerations (e.g., not buy certain positions based on a client’s preference). Once the portfolio is created, WN will monitor the portfolio and adjust the portfolio as necessary. Reallocating and rebalancing in the portfolio may be required by changes in market conditions or as deemed necessary to meet the client’s needs and objectives. WN retains the right to use discretion in the purchase and sale of investment items such as but not limited to stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), alternative investments, variable annuity sub-accounts and other securities as part of its Asset Management Services. In addition to standard brokerage confirmations and statements sent by the custodian, clients can be provided with reports or portfolio evaluations as well as information detailing the performance of the investments held in the portfolio. Comprehensive Financial Planning Wealth Navigation provides comprehensive financial and wealth planning services for its Clients. Planning fees are charged according to various factors such as the income and net worth of the client and the complexity of the client assets. The fee depends on whether the fee is for a new contract, a renewal of an existing contract, or for an ongoing service contract. All planning fees are based on the specific planning services provided to the client and the complexity of the client’s financial situation and goals. The General Areas of Comprehensive Financial Planning include:
• Financial Planning Services
• Estate Planning
• Executive Consulting Services
• Income and Estate Tax Planning
• Retirement Planning
• Pension Consulting Services
• Real Estate Consulting
• Family Office Services
• Divorce Financial Planning The services included in the planning process are limited to recommending planning strategies for the client to consider. Should the Client choose to implement the recommendations contained in the Client’s plan or consultation, the implementation of those recommended strategies is entirely at Client’s discretion. In all legal matters, WN’s planning services are analytical and advisory only, and do not include any legal, accounting or other professional services. Clients are encouraged to review their plans on a regular basis, based on individual circumstances. The fee also includes the time and activities necessary to work with Clients’ attorney and/or accountant in reaching agreements on solutions, as well as assisting those advisers in implementation of all appropriate documents. WN is not responsible for attorney or accountant fees charged to Client as a result of the above activities. Separately Managed Accounts WN may recommend the use of a separate money manager, or a “managed account”. Managed accounts can be used to provide access to outside money managers and asset allocations tailored to the Client’s specific needs. The client enters into a separate and individualized contract with the outside money manager which is monitored by WN. Fees for the managed account are asset-based and include brokerage, custody and money manager services. Separately Managed Accounts will only be offered to clients if the Advisor determines it is appropriate based upon each client’s suitability standards and investment philosophy. The minimum and maintenance level of investment is determined by the outside money manager.