The Aranda Group Advisors, LLC (“Advisor”, the “Firm”) has been in business since July of 2019. The firm is owned by its Managing Member, Steven Rosenberg. Advisor serves as an independent and unbiased investment advisor to its clients. As a fiduciary, Advisor places client interests at the forefront of all of its efforts. No adviser can guarantee that a client will meet their goals or achieve a given performance target. However, Advisor strives toward delivering to all clients the benefit of dedicated professionals serving with diligence, professionalism and integrity. Asset Management Generally, Clients will receive financial planning services at the onset of the relationship prior to beginning asset management services. Advisor believes that thoughtful financial planning can be an effective tool for protecting and accumulating wealth. It can also assist in the planning for special needs for clients, including their businesses and wealth transfer issues. In most cases, the client will supply to Advisor information including income, investments, savings, insurance, age, and many other items that are helpful to the firm in assessing financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, Advisor will discuss financial needs and goals with the client and compare the client’s current financial situation with the goals stated. Once these are compared, Advisor will create a financial plan to help clients meet their goals. The financial plan addresses the six vital areas of financial planning: Cash Flow Management, Risk Management, Investment Planning, Tax Planning Strategies, Retirement Planning, and Estate Planning. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by the client, it is very important that clients accurately and completely communicate to the firm the information it needs. Also, as circumstances and needs may change, it is very important that clients continually update the firm with any changes so that if the updates require changes to the financial plan, Advisor can make those changes. Otherwise, plans may no longer be accurate. Advisor provides all financial planning services “in house”, meaning the services are provided by Advisor professionals and not by any sort of sub-adviser or contractor. During the planning process, it may be determined that a client would benefit from the expertise of another professional, such as an estate planning attorney or tax advisor. If clients request, Advisor may recommend the services of other professionals for implementation purposes. Clients are under no obligation to engage the services of any such recommended professional. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from Advisor. If clients engage the services of any professional recommended by Advisor, and a dispute arises thereafter relative to such engagement, clients agree to seek recourse exclusively from and against the engaged professional. Advisor will not receive a fee from professionals recommended by Advisor. The financial plan is used for the creation of investment allocation guidelines which direct the asset management process. When Advisor performs asset management services, Advisor will do so on a non-discretionary basis. Advisor will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, in which case recommendations not implemented because Advisor is unable to reach a client may not perform the same as it would have had Advisor been able to reach the client for a consultation on the recommendation. Clients engaging the Firm will be asked to execute a Limited Power of Attorney (granting Advisor the non- discretionary authority to implement the investment

recommendations within the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and Advisor. Unified Managed Accounts Advisor may allocate some or all of client’s assets to Unified Managed Accounts or “UMA”, which are a single portfolio with a mix of asset classes and investment positions through the use of model portfolios, which may consist of third-party managers, and to a lesser extent, other investment options such as mutual funds and exchange traded funds. This is accomplished with the use of an Overlay Manager. The Overlay Manager that Advisor has selected is Adhesion Wealth Advisors Solutions (“Adhesion”), who provides portfolio trading, re-balancing, reporting and other administrative services. Each UMA is designed to meet a specific goal, while maintaining diversification for the purpose of mitigating short term risk, and at the same time positioned to appreciate and create income for the investor. Advisor provides UMA services on a non-discretionary basis, meaning that clients will grant Advisor non-discretionary authority to manage the accounts through the selection of an Overlay Manager, third party managers, and other investment options. In addition, clients will authorize the account custodian to follow Advisor’s instructions as well as instructions given by Adhesion to effect transactions, deliver securities, deduct fees, and take other actions with respect to the account. Clients will not have a direct contractual relationship with Adhesion or any other third-party manager. When clients engage Advisor to provide UMA services, the client and Advisor will execute an Investment Management Agreement that describes the services to be provided, the fees for the service, other expenses related to the provision of the investment management services, and how to terminate the agreement. Depending on the service a client has selected, Advisor will separately provide each client with the applicable disclosure documents for any third-party manager or service providers utilized, which includes information about their services, model portfolios, investment strategies at or before execution of our Investment Management Agreement. Securities-Based Lending: Advisor may offer clients access to a securities-based lending program in which advisory accounts are used as collateral for an extension of credit for a purpose other than to purchase, carry, or trade in securities e.g. the purchase of a house. A variable interest rate is charged on the monthly debit balances which will be added to the opening debit balance for the next interest period if not paid. If the value of the securities held in the account declines below the maintenance level determined for the account, clients may be subject to maintenance calls to post additional collateral. If a client is unable to do so, securities in the account may be liquidated to satisfy the call. These loans have a number of advantages and risks which should be considered before opening the account. Advantages include the flexibility of spending while at the same time receiving the benefits of the holdings in the collateral account such as dividends, interest, and the potential capital appreciation. Additional risks are discussed in Item 8 below. Advisor is not compensated directly for participation in securities-based lending programs however, because Advisor will continue to receive compensation for managing the assets in the account, there is a conflict of interest as the Advisor is incentivized to encourage clients to keep the securities invested and to borrow funds instead of liquidating securities to address the current capital needs. Advisor mitigates this conflict through disclosure of its existence and by giving clients the discretion to participate in such a program or to choose to borrow money or raise capital through traditional avenues. Assets under Management As of December 31, 2023, Advisor manages $199,931,919 in client assets, including $145,084,693 on a discretionary basis.