A Description of Our Firm, Our Services, and Our Wrap Fees MSP Wealth Management, LLC (“MSP”) is an Oregon limited liability company founded in 2002. The principal owners of MSP are Terrence “Terry” Scroggin and Gerrin DeGroot. The firm is registered as an investment advisor with the SEC. Our principal offices are located in Klamath Falls, Oregon. We have an additional office located in Eagle Point, Oregon. The information contained in this wrap fee brochure describes the suite of ongoing portfolio management and financial planning services provided to clients under the MSP Wrap Fee Program. A description of how we tailor these combined services to the needs of our clients is below. As used throughout this wrap fee brochure, the words “we,” “our,” “firm,” “MSP,” and “us” refer to MSP Wealth Management, LLC and its investment advisor representatives, and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. We act in a fiduciary capacity and will only recommend investments to you when we believe them to be in your best interests. A description of the services included under the MSP Wrap Fee Program is set forth below. Scope of MSP Wrap Fee Program Services. When you participate in the MSP Wrap Fee Program, you will deposit your assets to an account held in your name at an independent qualified custodian (the “Custodian”) and grant us limited authority to buy and sell securities within your account either on a discretionary or non-discretionary basis. In a discretionary arrangement, we are authorized to implement our investment recommendations within your account without obtaining your specific consent for each transaction. In a non-discretionary arrangement, we must obtain your consent prior to implementing any investments within your account. The full scope of our authority with respect to management of your account will be set forth in a written advisory agreement entered at the inception of our relationship. Clients may impose reasonable restrictions on our management of their account(s), including the ability to instruct us not to purchase certain specific securities, industry sectors, and/or asset classes. All such requests must be provided to us in writing. While we generally attempt to accommodate such restrictions, we reserve the right to reject such investment limitations if we believe they would frustrate our management of your account, or for any other reason, in our sole discretion. We will notify you promptly if we are unable to honor any of your investment restrictions or limitations. Under the MSP Wrap Fee Program, we will consult with you at the inception of our relationship and periodically thereafter, as necessary, to gather information regarding your financial goals, investment objectives, tolerance for risk, and the time horizon for your investments. The information we typically request in this process will include your current and expected income level, tax information, investment experience, current and expected cash needs, current portfolio construction/asset allocation, and risk tolerance level, among other items. Based on our analysis of these factors, we will prepare an investment policy statement (or similar documentation used to establish your investment objectives and suitability) outlining parameters for our management of your account(s). We will then implement an initial investment strategy and portfolio intended to align with your unique financial situation and goals. Client portfolios are typically constructed utilizing a diversified combination of mutual funds, exchange traded funds (“ETFs”), individual bonds, stocks, and other instruments, as may be appropriate for the individual client. We may also recommend the engagement of certain independent third-party money managers (“TPMMs”) to directly manage all or a portion of your account on a discretionary basis. You will be provided with a copy of each recommended TPMM’s Form ADV Part 2A firm brochure (or the equivalent) prior to the allocation of your assets to any TPMM (each such sub-account, a “TPMM Account”). Where a TPMM is engaged, we will continue to act as your fiduciary and as a “co-advisor” to your TPMM Accounts. We will determine the initial and ongoing suitability of the TPMM’s investment program, communicate any changes in your investment profile to the TPMM, and recommend changes in your TPMM allocations as we believe to be in your best interests. The TPMM shall be responsible for all portfolio management and trading functions related to your TPMM Accounts. You may be required to execute a separate advisory agreement and/or trading authorization in favor of such TPMMs at the time of their engagement. Following implementation of your initial investment portfolio, we will monitor the performance of your investments (including any TPMM Accounts) on an ongoing basis, recommend, and implement changes within your account as needed or appropriate, in consideration of current economic conditions, our market opinions and assumptions, and your individual financial circumstances and goals. It is your ongoing responsibility to advise us in writing of any material changes to your financial circumstances. At your request, our investment recommendations under this service may also cover certain designated assets which are “held-away” from the accounts placed directly under our management (e.g., employer sponsored retirement accounts, 529 college savings plan accounts, and variable annuities). You will be responsible for monitoring these assets and keeping us informed of their status. We will provide you with advice regarding how to invest and allocate assets among the available investment options and you will make the ultimate investment decisions and be responsible for investment implementation. In certain instances, and only with your prior written consent, we will assist you with implementation of our investment recommendations regarding your held-away assets. In addition to the ongoing management of their designated investment accounts, clients who engage us for these services receive annual financial planning services as described in our firm brochure. If you did not receive a copy of our firm brochure, we will provide one to you, free of charge, by contacting us at the telephone number on the cover page of this wrap fee brochure. Wrap Fees. MSP will charge you an annual “Wrap Fee” in connection with your participation in the MSP Wrap Fee Program. The Wrap Fee you will pay to our firm will be calculated as a fixed percentage of the market value of your account, typically ranging from 0.50% to 2.00% per annum (i.e., an asset-based fee). This bundled fee covers the combined costs of our investment advice and the custodial, trade execution, and other management costs (including execution and transaction fees but excluding fees related to custody of certain alternative investments) incurred in your account. Our wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost of the MSP Wrap Fee Program to you, including the cost of our investment advice, custody, and brokerage services if you purchased them separately, the types of investments held in your account, and the frequency, type, and size of trades in your account. The program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. Clients are advised that we do not offer portfolio management services outside of the MSP Wrap Fee Program. Our Wrap Fee may be negotiated on a per client basis, and some clients may pay fees at a rate outside the range stated above or which are otherwise materially different than those described in this brochure. The specific fee rate applicable to your account will be set forth in a written advisory agreement and shall be determined prior to the commencement of our services based on the complexity and amount of your assets; the existence and value of any related accounts managed by MSP (including any accounts held individually or jointly by you, your spouse, your minor children, or your business, including retirement accounts); the use of any TPMMs; the time, research, and resources required to provide services to you; and such other factors as we deem relevant. Our Wrap Fees are calculated and payable quarterly, in advance, based on the market value of your account (including any cash balances and the value of any TPMM Accounts) at the end of the prior billing period as calculated by the Custodian of your account. The initial Wrap Fee applicable to your account will be based on the opening value of your account as of the date on which we begin to provide services and shall be pro-rated for any partial periods based on the number of days during which services are provided. Clients may make additions or withdrawals from their account at any time, however, the Wrap Fees applicable to your account may be subject to pro-rata adjustments on account of such transactions. Clients should note that some or all of the investments in their account may be intended as long-term investments and withdrawals of cash and premature liquidations of securities positions may impair the achievement of your investment objectives. Generally, all security pricing is done by the Custodian that will maintain your account(s) titled in your name. We will rely on this pricing in determining the Wrap Fee attributable to your account(s). The Custodian may use various pricing services such as Reuters and Standard & Poor’s to price securities held in your account. For actively traded securities, these services use the actual last reported sale price. For less actively traded securities such as bonds, these services will use the appropriate valuation methodology to determine the value of the security. In those rare instances where your Custodian is unable to obtain a price (e.g., Delaware Statutory Trusts/Section 1031 exchanges, hedge funds, private placements, illiquid securities, derivatives, thinly-traded securities, etc.) or where MSP strongly believes the Custodian is not pricing a security fairly, or where a security has halted trading, MSP may make a good-faith effort to determine a fair value for that security. Alternatively, and only upon obtaining the client’s prior written approval, MSP may hold certain illiquid securities at their initial cost or initial appraised value for purposes of calculating its advisory fees. In certain instances, MSP may agree to reduce its advisory fees on such assets to account for its inability to determine a fair value. Wrap Fees will be directly deducted from your account held at the Custodian upon your written approval of such arrangement and the periodic submission to the Custodian of a written invoice reflecting the amount of advisory fees to be charged to your account. Your authorization for direct fee deduction is set forth in a written advisory agreement and/or the account opening documents of your Custodian. Wrap fees will typically be paid from cash balances or through the liquidation of money market shares held in your account, however, if money market shares or cash value are not available, other investments may be liquidated to pay such fees when due. Please note that unexpected or premature liquidation of investments to pay our Wrap Fees may impair the performance of your account. We generally do not offer direct paper or electronic invoicing of our Wrap Fees. The Custodian will independently send an account statement to you no less than quarterly, identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any Wrap Fees paid from your account. The Custodian of your account is not responsible to verify the accuracy of our fee calculations. Therefore, we encourage you to review and compare the Custodian’s account statements and any reports we may provide promptly upon receipt. If you believe there has been a miscalculation of any fees or if there is any other issue with your account, you should contact us immediately at the phone number listed on the cover page of this wrap fee brochure. Services under the MSP Wrap Fee Program may be terminated at any time by either party, within five (5) business days of entering an advisory agreement, without penalty and without the client incurring any advisory fees to MSP. Thereafter, MSP Wrap Fee Program Services may be terminated by either party on ten (10) days’ written notice to the non- terminating party. In the event of termination, we shall be compensated by a pro-rated Wrap Fee based on the number of days in the terminating period during which services were provided. A refund of any excess pre-paid fees shall be returned to you promptly following termination of our services. Termination of any separate TPMM engagements and refunds shall be governed by the terms of conditions of the client’s agreement with the terminated TPMM. While we believe our Wrap Fees to be

reasonable in relation to the value of the services we provide, lower fees for comparable services may be available from other sources. We reserve the right to adjust the annual Wrap Fee to be charged to your account, however, any change in fees applicable to your account will not go into effect unless we provide you with thirty (30) days’ notice of any proposed change and the opportunity to terminate our services. Broker-Dealer Selection and Recommendation. Although clients may request that we execute transactions for their MSP Wrap Fee Program account through any broker-dealer of their choosing, we typically recommend that clients engage the custodial and trade execution services of Charles Schwab & Company, Inc. (“Schwab”). Schwab is an SEC registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investors Protection Corporation (“SIPC”). We are not affiliated with Schwab and Schwab does not monitor or control the activities of our firm or its personnel. Schwab will act solely as a custodian and/or broker-dealer and not as your investment advisor. They will hold your assets in your name in a brokerage account or accounts and buy and sell securities and execute other transactions when instructed to do so by you or MSP. In recommending broker-dealers to clients, we have an obligation to seek the “best execution” of transactions for your account. This duty requires that we seek to execute securities transactions for clients such that the total costs or proceeds in each transaction are the most favorable under the circumstances. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the recommended broker-dealer’s services. The factors we consider when evaluating a broker- dealer for best execution include, without limitation, the broker-dealer’s:  execution capability;  commission rates;  financial responsibility;  responsiveness and customer service;  custodial capabilities;  research services/ancillary brokerage services provided; and  any other factors that we consider relevant. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for specific account transactions. With this in consideration, our firm will continue to recommend the Recommended Custodians until their services do not result, in our opinion, in best execution of client transactions. If the client selects a Custodian other than those we recommend (i.e., Schwab) for execution of transactions (i.e., client directed brokerage), you are advised that we may be unable to seek best execution of your transactions and the costs you will incur may be higher than those charged by Schwab. For example, in a directed brokerage account, you may pay higher brokerage commissions and/or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using Schwab. We reserve the right to reject your request to use a particular Custodian if such selection would frustrate our management of your account, or for any other reason. A full description of our brokerage practices, including a description of certain benefits we receive from Schwab in connection with our recommendation of their services to clients and the conflict of interest this creates with clients can be found at Item 12 of our firm brochure. Our firm examined this potential conflict of interest when we chose to enter into our relationship with Schwab and we have determined that this relationship is in the best interest of our clients and satisfies our client obligations, including our duty to seek best execution. Clients should carefully consider this information when selecting a Custodian for their account. B Certain Conflicts of Interest Related to Wrap Fees The benefits a client may experience under our wrap fee program depend, in part, upon the size of the account, the costs associated with managing your account, and the frequency and/or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities, or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether the MSP Wrap Fee Program is appropriate for you, you should compare our Wrap Fee and any other costs associated with participating in the program with the amounts that would be charged to you for a similar suite of services by other investment advisors, broker-dealers, and custodians if advisory fees, brokerage and execution costs, and custodial services were to be charged to you separately. When managing a client’s account on a Wrap Fee basis, we are compensated for our investment advisory services with the balance of the Wrap Fee paid by you after certain custodial, trade execution, and other management costs incurred in your account are paid. This arrangement creates a conflict of interest, insofar as we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to our Wrap Fee. For example, this arrangement creates an incentive for MSP to trade your account less frequently and to select investments which reduce our costs. To address the foregoing conflict of interest, we manage your account in strict accordance with your investment policy statement and our ongoing fiduciary duty to you. Clients should further note that certain custodians, including those we recommend to clients, may not charge trading commissions or transaction fees in connection with the purchase of certain investments, which may include U.S. exchange listed equities, mutual funds, and exchange traded funds. We are always available to discuss the trade execution costs of the brokers we recommend so that our clients can better compare the total costs of participating in the MSP Wrap Fee Program. Ultimately, participation in the MSP Wrap Fee Program could cost you more or less than purchasing our investment advice and custody/brokerage services separately. MSP does not offer portfolio management services for an unbundled fee (i.e., where the costs of investment advice are paid separate from brokerage and custodial fees). C Additional Costs and Expenses Our Wrap Fee covers the combined costs of our investment advice, together with the custodial, trade execution, and other management costs (including execution and transaction fees but excluding fees related to custody of alternative investments) incurred in your account held at the Custodian. Our Wrap Fee does not cover the costs of wire transfer fees, stock transfer fees, or taxes associated with activity in your account, which shall be paid separately by the client. It also does not cover the costs of any client directed (non-advised) transactions within your account or trades executed away from your chosen Custodian. Clients are further advised that depending on the Custodian selected by the client, our Wrap Fee may or may not cover of any spreads, mark-ups, and mark-downs on securities transactions. To the extent your account invests in any mutual funds and/or ETFs, you will also separately bear the costs of all internal management fees and other expenses that may be charged by such mutual funds and/or ETFs to their shareholders. We do not share in any portion of the foregoing additional fees and expenses. To fully understand the total costs you will incur by participating in the MSP Wrap Fee Program, you should review the prospectus of each mutual fund, ETF, and/or TPMM advisory program in which you participate and the contractual arrangement entered with your Custodian and any other third party service providers you elect to retain. D No Compensation Paid For Referrals We do not pay any referral fees or additional compensation of any kind with respect to referrals of clients to the MSP Wrap Fee program. Rollover Recommendations As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover recommendations we are acting as fiduciaries 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. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee-based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests 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 interests;  charge no more than a reasonable fee for our services; and  give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: 1. leaving the funds in your employer’s (former employer’s) plan; 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. As an alternative to providing you with a rollover recommendation, we may instead take an entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1. Under this approach, our role will be limited only to providing you with general educational materials regarding the pros and cons of rollover transactions. We will make no recommendation to you regarding the prospective rollover of your assets and you are advised to speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this educational approach, we may provide you with materials discussing some or all of the following topics: the general pros and cons of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement withdrawals on retirement income; the investment options available inside your Plan Account; and high level discussion of general investment concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide you with questionnaires and/or interactive investment materials that may provide a means for you to independently determine your future retirement income needs and to assess the impact of different asset allocations on your retirement income. You will make the final rollover decision.