A. Description of the Advisory Firm AVIATOR FINANCIAL CONSULTING LLC d/b/a Paladino Wealth (hereinafter “AFCL”) is a Limited Liability Company organized in the State of Texas. AFCL was formed in July 2018, and the principal owner is William J. Paladino Jr. B. Types of Advisory Services Portfolio Management Services AFCL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. 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 AFCL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AFCL will require 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. AFCL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AFCL’s economic, investment or other financial interests. To meet its fiduciary obligations, AFCL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, AFCL’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 AFCL’s policy to allocate investment opportunities and transactions

it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments AFCL generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs (including ETFs in the gold and precious metal sectors). AFCL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions AFCL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by AFCL on behalf of the client. AFCL may use model allocations, together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. If the client, after entering this agreement instructs AFCL to restrict any investment that AFCL determines is appropriate, AFCL retains the right to terminate this agreement. AFCL may use different model portfolios to aid in the allocation of client’s accounts. The portfolios consider age, employment status, account type, and client’s goals. AFCL may use duplicate account strategies across similar accounts at our discretion. AFCL maintains the right to liquidate and reallocate at any time they feel is best, unless directed otherwise by the client or to meet the client’s needs. D. Wrap Fee Programs AFCL does not participate in any wrap fee programs. E. Assets Under Management F. AFCL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 129,129,429 $0.00 December 2023