A. Description of the Advisory Firm Harbourfront Wealth America Inc. (hereinafter “HWAI”) is a corporation organized in Canada. The firm was formed in November 2019, and the principal owner is Harbourfront Wealth Holdings Inc. B. Types of Advisory Services Portfolio Management Services HWAI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. HWAI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring HWAI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. HWAI may request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. HWAI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HWAI’s economic, investment or other financial interests. To meet its fiduciary obligations, HWAI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HWAI’s policy is to seek fair and equitable allocation of investment opportunities/transactions

among its clients to avoid favoring one client over another over time. It is HWAI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments HWAI generally limits its investment advice to mutual funds and equities. HWAI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions HWAI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent HWAI from properly servicing the client account, or if the restrictions would require HWAI to deviate from its standard suite of services, HWAI reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. HWAI does not participate in wrap fee programs. E. Assets Under Management HWAI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 11,166,693 $ 938,247 December 2023