Firm Description Navigation Wealth Management, Inc. dba Navigation Wealth Management (“Navigation”) was founded and registered as an investment advisor in 2016. Adam E. Brunin is 100% owner. Types of Advisory Services ASSET MANAGEMENT Navigation offers discretionary asset management services to advisory Clients. Navigation will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Navigation discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. ASSETS HELD AWAY Navigation uses a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Navigation will review the current account allocations. When deemed necessary, Navigation will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. FINANCIAL PLANNING AND CONSULTING Navigation offers planning services to all clients. The services cover all areas of financial planning from risk management to college planning to estate conservation. Navigation specializes in helping our clients develop a comprehensive and cohesive financial strategy that fits their unique needs and enables them to meet both short and long term objectives. The client always has the right to decide whether or not to act upon the investment advisor’s recommendations. If the client elects to act on any of the recommendations, the client may effect the transaction through any advisor of their choice. QUALIFIED PLAN SERVICES Navigation offers qualified plan services to individuals. Navigation will meet with the client for information gathering. Navigation will make investment recommendations to the client based on the investment options available and the client’s financial objectives in a face to face meeting. Navigation will review the investment options available within the plan and make trades in qualified accounts utilizing an advisor log on. ERISA PLAN SERVICES Navigation provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. Navigation may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. Navigation may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non- discretionary basis. As an investment advisor Navigation has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Navigation can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Navigation acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Navigation’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of

Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Navigation is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Navigation may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. Navigation has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Navigation on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. Navigation can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Navigation would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Navigation has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the Navigation’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Navigation is not providing fiduciary advice as defined by ERISA to the Plan participants. Navigation will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Navigation may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Navigation and Client. 3. Navigation has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. SEMINARS AND WORKSHOPS Navigation holds seminars and workshops to educate clients and prospects on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. There will be no fee imposed for attendance to these seminars or workshops. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created by Navigation that reflect the stated goals and objectives of the client. These strategies could include the use of multiple fund families. Clients may impose restrictions in writing on the investment advisory agreement on investing in certain securities or types of securities that could limit the selection of particular mutual funds. Agreements may not be assigned without prior written client consent. Client Assets under Management Navigation has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $124,068,319 $0 September 25, 2023