von Borstel & Associates, Inc. (“we,” “us,” or “Advisor”) was initially registered as an investment advisor in 1992 under the name Oregon Trail Financial Services, Inc. After changing the name to von Borstel & Associates, Inc. in 2014, we withdrew registration in 2017. After utilizing two other advisory firms for a few years, we have registered in 2020 for Financial Planning and Investment Management Services. We are solely owned by Wayne von Borstel, who has been helping individuals with financial services since 1985. All Financial Planning and Investment Management Services are provided through our investment advisor representatives (“Representatives”). Financial Planning We provide clients with a comprehensive evaluation of their current financial state. Through careful analysis we will help clients reach their financial goals and objectives by projecting future cash-flows, asset values and withdrawal plans. Clients purchasing this service from us will receive written or electronic reports, or verbal directions for making financial decisions. In general, financial planning may include the evaluation of family records, budgeting, personal liability, estate information and financial goals. Educational, insurance and estate planning issues may also be included in the financial plan. Tax and cash flow analysis may also be provided, as well as income tax and spending analysis for past, current and future years. We may illustrate the impact of various investments on a client's current income tax and future tax liability. We may also assist clients with retirement analysis by reviewing and proposing current strategies and investment plans to help the client achieve their financial goals. During the planning process, investments will be reviewed for the appropriateness, including standard and alternative investment choices, and the impact these investments may have on the client’s financial plan. Additionally, advice may be given to assist clients with death and disability situations, including cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. We gather information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents and questionnaires completed by the client to prepare the financial plan or recommendations. Should a client choose to implement the recommendations or suggestions in the plan, we suggest they work closely with their attorney, accountant, insurance agent, and/or other financial services providers for execution of the plan. Implementation of financial plan recommendations are entirely at the client's discretion. Neither we or our Representatives provide any accounting or legal advice or services. Typically, our recommendations or financial plan will be presented to the client within

90 days of the contract date, provided that all information needed to prepare the financial plan has been provided by the client. Investment Management Services (“The Vision to Wealth Process™”) Investment Management Services, also known as “The Vision to Wealth Process™”, provides continuous advice and investment management for a client based on their individual needs. During our personal interviews and data-gathering process, we determine the client’s individual objectives, time horizon, risk tolerance, and liquidity needs to develop their personal investment strategy. We then create and manage a portfolio based on that strategy. We manage these advisory accounts on a discretionary basis. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or services. Generally, investments used include stocks, bonds, mutual funds, exchange traded funds, fee-based annuities, options, unit-investment trusts, third-party managers or other investments available through the custodian (“Custodian”) selected by the client. Intelligent Portfolios— In some cases, we may recommend utilization of an online, automated program called Institutional Investment Program (“IIP®”). Through IIP® , clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. IIP® is offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Charles Schwab & Co.(“Schwab”). We are not affiliated with or sponsored by Schwab or SPT. IIP® provides us a technology platform for trading and account management, including an online questionnaire that assists clients in determining their investment objectives and risk tolerance. Utilization of IIP®, may produce a conflict of interest because it automates the trading process for us. However, we will only recommend IIP® when appropriate and it is up to the client to determine if IIP® is fitting for their financial circumstances. In some cases when appropriate for the client, we may recommend insurance products that are “fee-based”, meaning, there are no commissions earned for us or the Representative. The fee-based insurance products are offered through various insurance companies and are utilized to provide additional diversification for client investments. Advisor also provides investment consulting services to certain broker/dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the Advisor’s services. Brokerage Customers have entered into a written advisory agreement with the Advisor. Our discretionary assets under management as of December 31, 2023 was $504,442,247.