Zephyr Wealth Management (“Zephyr, we, us, our, ours”), which is located in Westlake Village, California, is a corporation organized under the laws of the State of California. The firm was founded in 1997. Cheryl Munoz, who has been associated with Zephyr since 1997, purchased the firm in 2013 and is the firm’s President and Chief Compliance Officer. Zephyr is registered with the U.S. Securities & Exchange Commission as an investment adviser. Types of Advisory Services Offered Investment Management Services When offering Investment Management Services, we are primarily focused on the management of client investment portfolios. The transactions we execute for client accounts are effected on both a discretionary basis (meaning that we are authorized to effect transactions for the accounts of our clients without obtaining their prior approval for each individual transaction) and a non-discretionary basis (meaning that we must obtain the specific prior approval of the client before we can effect a transaction for the client’s account). In managing your investment portfolio, we consider your financial situation, risk tolerance, investment horizon, liquidity needs, tax considerations, investment objectives, and any other issues important to your state of affairs. Based upon the information you provide, we identify what we believe to be appropriate investment options for you. You should notify us promptly if there are any changes in your financial situation or investment objectives, or if you wish to impose any reasonable restrictions upon the management of your account. Your advisory representative will arrange to contact you annually to review the performance of your investment account and to recommend any changes that appear appropriate based on economic or market conditions, or changes to your financial situation, investment objectives, or risk tolerances. You may call in at any time during normal business hours to discuss your account, your financial situation, or your investment needs directly with your advisory representative. We will review our investment recommendations with you and obtain direction from you as to whether to manage your account on a discretionary or a non- discretionary basis. The scope of the discretionary authority that you may grant to us is limited to selecting specific investments for your account and deciding how to allocate your assets among those investments. We may decide if, when and how much to buy, hold, or sell the investments in your accounts without first consulting with you. Once you have granted discretionary authority to us, it is effective until you change it or revoke it in writing. We provide you with the opportunity to impose reasonable restrictions on our management of your account. These restrictions pertain to (among other things) the types of securities to be purchased for your account and the amounts to be invested. Business Cycle Asset Management We provide Investment Management Services under an investment strategy called Business Cycle Asset Management (“BCAM”) which implements a strategy that follows the economy as it flows through a series of naturally occurring stages in the business cycle. Our BCAM strategy is built to take advantage of all stages of the business cycle. Studies show that various investments provide significantly different results dependent upon where we are in the economic and market cycles. Understanding these cycles provides the foundation from which we make investment decisions. BCAM strives to assess and anticipate business cycles common in our economy by analyzing economic and market indicators. We then allocate investments to the sectors or asset classes that we believe make the most sense for the stage of the economic cycle we are entering. We then adjust your account holdings to take advantage of anticipated changes in that cycle. Please note that past performance is not a guarantee

of future returns. We analyze market trends utilizing fundamental and technical (charting) analysis, as well as our own proprietary indicators. BCAM seeks to enhance asset appreciation and reduce risk by increasing or decreasing the amount of assets placed in multiple investment categories. Our goal is to focus your account in those sectors/asset classes that we believe show the potential for appreciation and avoid those that we believe show the potential for lower value. Although we use models as the foundation for investment decisions, your specific account will be managed based on your individual financial circumstances, investment objectives, and risk tolerances. We may periodically adjust your account(a process referred to as “rebalancing”) to help ensure that your investment account remains consistent with your objectives, goals, and risk tolerances. Financial Planning We consider financial planning an important aspect of the asset management process. We will provide various levels of financial planning as part of our advisory services. Financial planning includes, but is not limited to retirement planning, goal planning, tax review, estate plan review, and insurance review. Should you choose to implement the recommendations contained in your financial plan, we encourage you to work closely with your attorney, accountant, insurance agent, and other advisers. Your advisory representative will assist you to the extent you choose. Although you may choose to implement the recommendations made in your financial plan through your advisory representative, you are free to employ the services of any adviser or registered representative of your choice, regardless of whether or not that person is associated with Zephyr. Consulting Services We will also provide consulting services to you if you desire a review of a specified area, but do not wish to engage us for investment management services. These services are not considered financial planning services because we will not perform a comprehensive analysis of your financial position. Retirement Plan Consulting Services We offer retirement plan consulting services to defined contribution retirement plans (the “Plan(s)”) and to the Plan’s named fiduciary (the “Plan Sponsor”). These services are offered on a non- discretionary investment basis. Investment Adviser 3(21) Fiduciary Services: We shall serve as an “Investment Adviser” and a “fiduciary” within the meaning of Section 3(21) of Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, with respect to accounts in the Plan. (Although 3(21) fiduciaries provide advice, they do not take control of plan assets, so the Plan Sponsor retains the final say regarding implementation of the recommended investment options.) If we are engaged as an Investment Adviser, we will provide recommendations concerning the selection of the investment options for the Plan, as well as the replacement, addition or removal of such options on an ongoing basis. In general, the services may include an existing plan review and analysis, investment performance monitoring, and/or ongoing consulting. In providing these services, we will have the ongoing responsibility to select or make recommendations based upon the needs of the Plan. While the ultimate decision to act on behalf of the Plan shall remain with the Plan Sponsor, we will generally aid with the implementation of our recommendations after approval by said Plan Sponsor. Assets Under Management As of December 31, 2023, Zephyr managed $111,956,786 in client assets on a discretionary basis where we made all investment decisions. We managed $229,524,238 in client assets on a non-discretionary basis, where our clients made the investment decisions based upon our recommendations. Total advisory assets under management were $341,481,024.