Adaptation Financial will provide discretionary and non-discretionary portfolio management on a continuous and regular basis, including financial planning, general investment advice, portfolio monitoring and evaluation, on the terms and conditions specified in the customer profile and advisory agreement signed by the client. Ownership Adaptation Financial is a subsidiary of APN Adaptation Financial Holdings LLC, an Oklahoma limited liability company (“APN Adaptation Financial Holdings”). APN Adaptation Financial Holdings is the majority shareholder of Adaptation Financial. The Alan P. Niemann Trust is the sole member of APN Adaptation Financial Holdings, and Alan P. Niemann is the Trustee for the Trust. Adaptation Financial was organized in February 2020, and is an investment adviser registered with the SEC. Cambridge Relationship Adaptation Financial is a registered supervisory branch office location of Cambridge Investment Research, Inc.(“CIRI”) and Cambridge Investment Research Advisors, Inc. (“CIRA”), where Alan Niemann, our CEO and registered Advisory Representative and Mitch Robinson, our CCO, supervises Registered Representatives and Advisory Representatives that are registered with CIRI and CIRA including Adaptation Financials investment Advisory Representatives. Alan Niemann and Mitch Robinson are dual registered with CIRA, CIRI and Adaptation Financial. Alan Niemann receives override compensation from CIRI for CIRI registered representatives who work under is supervision. Alan Niemann also receives compensation from assets under management in his capacity as an investment Advisory Agent with CIRA and received overrides from CIRA investment Advisory Representatives who join CIRA and use the Cambridge platform as well as compensation from the sale of annuity products on the Cambridge platform. APN Adaptation Financial Holdings, the parent company of Adaptation Financial, receives forgivable loans from CIRI and CIRA that assist in it recruiting new advisers to CIRA or registered representatives to CIRI. The receipt of forgivable loans presents a conflict of interest in that the Adaptation Financial or its Advisory Representatives have a financial incentive to maintain a relationship with CIRI and CIRA and recommend CIRI and CIRA to our clients. However, to the extent that Adaptation Financial or its Advisory Representatives recommend CIRI and CIRA to clients, is because we believe that it is in our client’s best interest to do so based on the quality and pricing of the execution, benefits of an integrated platform for brokerage and advisory accounts, and other services provided by CIRI and CIRA and its affiliates. Services Offered Adaptation Financial offers a variety of advisory services to its clients. Such services include portfolio management and wealth management, financial planning, and consulting services. In working with clients, Adaptation Financial seeks first to evaluate each client’s current, holistic 2 | P a g e financial situation. Adaptation Financial then designs and implements an investment plan aimed at achieving a client’s financial objectives. Prior to rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Investment Products Our investment recommendations will generally include advice regarding equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, U.S. Government securities, options contracts on securities and ETFs, including ETFs in the gold and precious metal sectors. Insurance products may also be recommended when we deem such an investment to be appropriate. Since Adaptation Financial is a branch office of CIRA, Investment Advisory Representatives are not permitted to provide advice on futures or commodity contracts, with the exception of managed futures or structured products approved by CIRI. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to the Firm in writing. Assets Under Management As of December 31, 2023, Adaptation Financial has $177,434,792 in assets under management on a discretionary basis. Wrap Fees Adaptation Financial serves as an investment manager to and sponsor of a wrap fee program as described further in Adaptation Financials Form ADV 2A, Appendix 1 (our “Wrap Fee Program Brochure”). A wrap fee program is a program where a client is charged a specified “bundled” fee (generally, a percentage of assets under management) for discretionary investment management services and trade execution costs and sometimes other services such as custody, recordkeeping, and reporting. Overview of Services Offered Portfolio and Wealth Management Services Adaptation Financial manages client investment portfolios on a discretionary and non- discretionary basis. In addition, we provide clients with wealth management services that include a broad range of comprehensive financial planning services in addition to the discretionary management of investment portfolios. Adaptation Financial tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. We consult with clients on 3 | P a g e an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if we determine, in our sole discretion, the conditions will not materially impact the performance of a management strategy or prove overly burdensome to our management efforts. Wealth Management Services Program: Our wealth management services comprise financial planning and portfolio management services. Our services are comprehensive, covering substantially all aspects of your personal financial situation and, importantly, take into consideration the complex interactions of the many areas involved. A thorough understanding of your total assets and obligations and income and expenses is integral to the advice and services we provide. Portfolio Management within Variable Annuities: When deemed suitable or requested by a client, Adaptation Financial may recommend the purchase of a no-load Variable Annuity. Our portfolio management services within these products are limited to the initial selection and ongoing reallocation of the Variable Annuity Sub-accounts. Portfolio Management Services with Variable Annuities are otherwise similar to our standard Portfolio Management Services. Portfolio Management within 529 Plans: Adaptation Financial will assist with portfolio management within 529 Plans. Our portfolio management services within these products are limited to the initial selection and ongoing reallocation of the available investments. 529 Plan Investments are treated differently than other investments for tax purposes, and clients should review the features and associated costs of a plan prior to purchase. Portfolio Management within 529 Plans are otherwise similar to our standard Portfolio Management Services. Wrap Program Services Portfolio management services provided through our Wrap Fee Program, participants will receive portfolio management, custodial, reporting, and clearing services for one all-inclusive fee. When providing portfolio management services, we not only make recommendations related to investments, but also implement these recommendations and provide ongoing monitoring and reporting. From a management perspective, there is not a fundamental difference in the way our Advisory Representatives manage wrap-fee accounts versus non-wrap accounts. The only significant difference is the way in which transaction services are paid. In a wrap account, advisory services and transaction services are provided for one fee and Adaptation Financial receives that portion of the fee that relates to advisory services for the services which it provides. This is different from a fee-plus account where our services are provided for a fee, but transaction services are billed to 4 | P a g e clients separately on a per-transaction basis. For a more detailed description of our Wrap Fee Program, clients should refer to our Wrap Fee Program Brochure. WealthPort Wrap Program WealthPort Wrap (“WealthPort”) is a CIRA sponsored program that is recommended to clients of Adaptation Financial. Adaptation Financial participates, under a co-advisory relationship with CIRA, in fee-based services sponsored through CIRA’s WealthPort Wrap Programs. The wrap fee programs charge an inclusive fee, covering custodial, brokerage, and investment advisory services. All clients placed in the WealthPort Wrap Program are provided with the WealthPort Wrap Brochure before or at the time they enter the program. WealthPort accounts will be established at CIRI, with NFS, Pershing, Schwab and Fidelity serving as the clearing broker- dealer. The following information provides a brief summary of WealthPort Program options available to Adaptation Financial. Advisor-Directed Program: In the WealthPort Advisor-directed Program, Adaptation Financial provides investment management services, defined as giving continuous investment advice to you and makes investments based on your individual needs. Through the Program, we are responsible for determining investment recommendations and implementing transactions. We actively manage your account(s) in accordance with your individual needs, objectives and risk tolerance. CAAP® (Cambridge Asset Allocation Platform): Within the WealthPort CAAP®, CIRA has arrangements with various strategists to provide consulting services in connection with the creation of asset allocation models and the selection of portfolio funds, ETFs, and/or Equities. The client’s investment objectives, financial situation, and risk tolerance will be considered. Consultants and/or Portfolio Managers can select their own proprietary funds to be held in a client’s portfolio, which creates a conflict of interest in that they will receive a separate and duplicitous form of income from the client when their own proprietary funds have been chosen for the client. CAAP strategists are not affiliated with Adaptation Financial or CIRA. Unified Managed Account (UMA): The UMA program offers clients

the ability to select multiple CAAP® strategies in one account. The UMA holds the investments recommended by each selected strategist in a separate sleeve. Proposal generation tools allow the client’s investment advisory representative to customize the asset allocation models on an individualized or generalized basis. Wherein the former allows for a tailored program while the latter may suit larger groups of clients with similar financial needs. The investment advisory representative is then responsible for further tailoring the chosen sleeves to meet their client’s individual needs, ongoing due-diligence, re- balancing, and suitability needs as the client’s own personal financial situation evolves over time. All clients are provided with the WealthPort Wrap Brochure before or at the time the client enters into this program. Advisory Representatives of Adaptation Financial who direct clients to the WealthPort Wrap Program provide customized portfolio management solutions based on a client’s individual circumstances, risk tolerance, investment objectives, and time horizon on a discretionary basis. Adaptation Financial investment advisory representative will meet with the 5 | P a g e client at least annually to review personal circumstances and investment objectives and adjust the portfolio’s asset allocation as needed. Third-Party Investment Advisors Services Adaptation Financial may use the services of third-party investment advisors as sub- advisors. If we choose this option, we will select a third-party investment advisor whose style and talent best fit your individual needs and objectives. Your agreement with us gives us the authority to hire or fire these managers on your behalf. Once a third-party investment advisor is selected, we will continue to monitor their performance. If our services to you include the use of these third- party investment advisors, you will typically sign an agreement with them in addition to the advisory agreement you will sign with Adaptation Financial. If you are interested in learning more about any of these third-party investment advisors and their services, a complete description of their programs, services, fees, payment structure and termination features are found in their service disclosure brochures, investment advisory contracts, and account opening documents. Our advisory responsibility is to select and monitor any third-party investment advisor that provides services to us. Factors that we consider in their selection may include:
• Their size.
• How long they have been in business.
• The experience level and turnover of their portfolio managers.
• A review of their historical performance and risk measurements.
• A review of their disclosure documents. In deciding to use a third-party investment adviser to manage your assets, we consider your risk tolerance, goals, objectives, time horizons, and general financial situation. We also consider your level of investment experience and the assets you have available for investment. If you were to go to these third-party investment advisors on your own, the fees they charge you may be more or less than going through us. However, when using their services directly, you will not receive our expertise in developing an investment strategy, selecting the third-party investment advisors to use, monitoring the performance of your account, and changing third-party investment advisors if needed. Financial Planning and Consulting Services Adaptation Financial offers clients financial planning services, which involves preparing a written financial plan that covers specific, or multiple topics. We provide full written financial plans, which typically address one or more the following topics:
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Debt Planning
• Estate Planning
• Cash flow Planning
• Charitable Giving
• Business Planning
• Trust and Estate Planning
• Succession Planning
• Special Needs Planning
• Income Planning
• Key Employee Retention Planning
• Estate Equalization 1 | P a g e While these services are generally rendered in conjunction with portfolio management as part of a comprehensive wealth management engagement (as described above), clients can engage us to provide these services on a stand-alone basis. We will consult with clients and gather appropriate information. Clients may be requested to complete a questionnaire or provide us with copies of certain client documents. In performing these services, we are not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and are expressly authorized to rely on such information. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by us under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising our recommendations and/or services. Retirement Plan Consulting Services Adaptation Financial offers retirement plan consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting their management and fiduciary obligations to the plan under ERISA. Retirement consulting services will consist of general or specific advice, and may include any one or all of the following:
• Strategic Planning and Investment Policy Development/Review.
• Plan Review.
• Plan Fee and Cost Review.
• Acting as a Third-Party Service Provider Liaison.
• Assessment of Plan Investments and Investment Options.
• Plan Participant Education and Communication. The Company may also engage us to provide the following additional services, for separate compensation:
• Review of Executive Benefits.
• Assist with Plan Conversion.
• Merger and Acquisition Assistance.
• Assist with Corrective Actions to Comply with Applicable Regulations.
• Coordination with Other Advisers. We will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the 2 | P a g e Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. When we perform our agreed upon services, we will rely on the information provided to us by the Company. We will not be required to verify the accuracy or consistency of any information received from the Company. We will serve in a fiduciary capacity with respect to some of the services that we provide, which will be further explained in the written agreement signed with the Company. The Company is always free to seek independent advice about the appropriateness of any recommendations made by us. Educational Seminars and Workshops Adaptation Financial may hold investment-related educational seminars and/or educational events to existing clients, prospective clients, and the general investing public. The seminars feature general investment-related advice for educational purposes and may include both securities and non-securities topics. No specific individualized investment advice regarding investment objectives or investment related needs of the attendees, listeners, or audience is rendered during seminars. However, participants are free to schedule meetings with the Adviser(s) in an effort to obtain personalized investment advice. Retirement Accounts – DOL Disclosure We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“Code”), as applicable, when we provide investment advice regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to collectively sometimes herein as (“Retirement Accounts”). To ensure that Adaptation Financial will adhere to fiduciary norms and basic standards of fair dealing, we are required to give advice that is in the "best interest" of the retirement client. The best interest standard has two chief components, prudence and loyalty. Under the prudence standard, the advice must meet a professional standard of care and under the loyalty standard, our advice must be based on the interests of our retirement clients, rather than the potential competing financial interest of Adaptation Financial. To address the conflicts of interest with respect to our compensation, we are required to act in your best interest and not put our interest ahead of yours. To this end, 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. 3 | P a g e
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Education All personnel of Adaptation Financial are expected to have education and business backgrounds that enable them to perform their respective responsibilities effectively. In assigning responsibilities, we consider academic background (including studies in college and graduate schools, as well as degrees earned), industry training, licenses, and certifications. Work experience in a related field, such as investments, commodities, insurance, banking, or accounting, is also considered. No formal, specific standards have been set, but appropriate education and experience are required. See our ADV Form Part 2B for additional information on our investment professionals.