A. Description of Firm Sandeep Varma Wealth Strategies, LLC dba ATS Wealth Management (“ATSWM” or the “Firm”) is a San Diego, California-based investment management firm founded in 2008.As further detailed in Item 4.B., below, ATSWM offers services covering the areas of financial planning and asset management. The Firm typically provides its services to individuals and high net worth individuals. Some of the investment instruments ATSWM advises its clientele on include, among other things, mutual funds, exchange traded funds (“ETFs”), variable annuities, equities, high-yield bonds, fixed income instruments including money market funds and options. The Firm also utilizes third-party asset managers, where appropriate. Additionally, dependent upon the needs of the client, the Firm will at times utilize margin in client accounts (please refer to Item 8 below for detailed information regarding the risks surrounding margin). ATSWM is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser and organized under the laws of California as a limited liability company. The Firm conducts business primarily in the State of California. Representatives of ATSWM also act as registered representatives (“RR(s)”) and investment adviser representatives (“IAR(s)”) of Avantax Investment ServicesSM . ("Avantax Investment ServicesSM "). Such representatives perform these services under the name of ATS Advanced Trustee Strategies, Inc., a branch office and “dba” of Avantax Investment ServicesSM. It should be noted that while ATSWM is not affiliated with Avantax Investment ServicesSM, it is affiliated with ATS Advanced Trustee Strategies, Inc. through common ownership. Avantax Investment ServicesSM is registered with the Securities and Exchange Commission (“SEC”) as both a broker-dealer and investment adviser, and is also a member of FINRA/SIPC. Please refer to Items 4, 5, 10 and 14 for additional information pertaining to this affiliation. ATSWM’s principal owner is Sandeep Varma, who also serves as the Firm’s President. For information on his qualifications and business background, please refer to his Form ADV Part 2B Brochure Supplement. B. Types of Advisory Services Offered ATSWM provides two types of advisory services: Financial Planning Services and Asset Management Services, both of which are more fully described below. 1. Financial Planning Services ATSWM offers personalized financial planning services. The services range from comprehensive financial planning to more focused consultations, depending on the needs of each client. Generally, ATSWM first conducts a complimentary initial consultation during which pertinent information about the client’s financial circumstances and objectives is collected which involves the gathering of personal and financial data, establishing client's needs, goals, and objectives. For more comprehensive services, the Firm reviews and analyzes the information provided by the client to develop a specific plan to meet the client's stated objective(s). Based upon the complexity of a client's financial situation, a financial analysis and recommendations may be provided in the following areas: retirement planning, portfolio analysis, financial planning, gifting strategies and insurance analysis, among others. Financial analyses are based on the client’s financial situation at the time of presentation and based on the information disclosed by the client to ATSWM. Clients are advised that certain assumptions are made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. ATSWM cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the clients are strongly urged to promptly notify the Firm. For more information on the risks associated with investing, please refer to Item 8, below. No client is obligated to implement any recommendations provided by the Firm. Should the client decide to follow the adviser's recommendations, typically ATSWM recommends these investment and insurance product offerings through ATSWM and/or Avantax Investment ServicesSM, for which certain ATSWM advisors are IARs of Avantax Investment ServicesSM’s advisory business, RRs of Avantax Investment ServicesSM’s broker-dealer and insurance agents licensed with Avantax Investment ServicesSM’s insurance agency (please see Item 10 below for additional information). ATSWM is not affiliated with Avantax Investment ServicesSM. Clients will need to sign a separate agreement to engage and compensate Avantax Investment ServicesSM for these services. Clients also should realize that such referrals to ATSWM and Avantax Investment ServicesSM represent a conflict of interest since ATSWM advisors receive fees, compensation or other concessions for products sold through their capacity as an IAR of ATSWM and/or Avantax Investment ServicesSM, a RR of Avantax Investment ServicesSM or an insurance agent. However, the client is under no obligation to purchase the products or services that ATSWM may recommend, or to purchase products through any representative of ATSWM, or through any particular advisory firm, broker-dealer or insurance agency including ATSWM and/or Avantax Investment ServicesSM. In addition to their relationship with Avantax Investment ServicesSM, various ATSWM representatives also are licensed insurance agents through one or more additional insurance agencies. In such capacity, these representatives will offer insurance products and receive normal and customary commissions as a result of any insurance purchase. Under all circumstances, ATSWM only makes product or service recommendations to clients if it believes it is in the clients' best interests to do so and it reminds them of any and all potential conflicts of interest at the time of the recommendation via disclosure as part of this Brochure and/or the client’s agreement. 2. Asset Management Services ATSWM provides clients with ongoing asset management services, which is performed on a fully discretionary basis. The Firm typically offers five types of model portfolios: aggressive growth (100% equity model), growth (80% equity / 20% fixed income model), moderate growth (70% equity / 30% fixed income model), balanced (60% equity / 40% fixed income model) and conservative (20% equity / 80% fixed income model), each of which typically consists of stocks, mutual funds, and exchange traded funds (“ETFs”), but also typically includes high-yield bonds, fixed income instruments, money market funds and other financial products. Client account assets are invested and managed based on a model portfolio of securities that pertains to the investment strategy selected by the client. Such model portfolios are not typically customized to the client, and several clients will be invested in the same or similar strategy. However, ATSWM will at times, if deemed to be in the best interest of the client, create a customized portfolio for the client that differs from the portfolios described above. The percentages of the model portfolios will vary at times due to market conditions, or in the sole discretion of the adviser. Further, while the Firm will at times make decisions to add or remove certain securities within a model portfolio that is applied to all clients then invested in the model portfolio; clients should be aware that model portfolios are not typically rebalanced on a continuous basis. Rather, portfolios are generally rebalanced following a client meeting, if applicable, or following the addition/withdrawal of client funds. Rebalancing also may occur more frequently as dictated by market conditions or if such actions are deemed by the Firm to be in the best interest of clients. Clients that generally have $1,500,000 or above within their investment management account(s) receive the option to have more frequent meetings with the Firm, which may result in more frequent reviews and rebalancing of their portfolio(s) than those clients with smaller amounts of assets managed by the Firm. This creates a conflict in that clients with smaller account balances could have model portfolio allocations that vary greater from the intended allocation percentages than clients with larger account balances due to less frequent rebalancing. ATSWM recommends the type of portfolio model most suitable for the client based on a variety of factors, including the client's individual risk tolerance, time horizon and specific goals. Prior to ATSWM providing asset management services, each client is required to enter into an Investment Advisory Agreement with the Firm setting forth the terms and conditions of the engagement, including the fees as well as describing the specific scope of the services to be provided. Please refer to Item 8 for additional information about the Firm’s methods of analysis, investment strategies, and their associated risks. While clients can place certain restrictions on their accounts, such as restricting the Firm from purchasing or selling a specific security, ATSWM does not allow clients to place restrictions on the types of industries or sectors that may be included as part of the client’s account. Clients who place restrictions on their portfolios should be aware that such restrictions could affect returns experienced by such client’s portfolio relative to other ATSWM clients who do not impose restrictions. Note that cash positions may be a tactical asset, and there

may be times when ATSWM recommends that a client go to cash – such as during extreme market conditions. Clients are charged ATSWM’s customary asset under management fees pursuant to the terms of the Client Agreement regardless of what type of positions are held in the account. There can be no assurance that the services of the Firm will be at the lowest available cost. a. Use of Third-Party Advisers The Firm utilizes the services of an unaffiliated, independent Third-Party Adviser (“TPAs”) to assist in designing and monitoring the model portfolios on a continuous basis. The TPA provides recommendations and updates to ATSWM with respect to each model portfolio pursuant to an agreement by and between ATSWM and the TPA. The Firm may terminate its relationship with the TPA at any time as the Firm may determine in its sole discretion. Clients are not required to enter into a separate agreement with the TPA, nor pay any additional fees to the TPA. b. Use of Sub-Advisers From time to time and depending on the clients’ needs, the Firm will recommend one or more TPAs to manage all or a portion of client assets. The recommendation will be based on the Firm’s determination that such recommendation is suitable in light of the client’s stated investment objectives, guidelines and restrictions. In some cases, depending on the type of arrangement, the client will enter into a separate advisory agreement with the TPA, which will be in addition to, and distinct from the agreement with the Firm. In other cases, ATSWM will enter into an agreement with the TPA directly. At the beginning of the engagement, the client will receive a copy of the TPA’s Form ADV Part 2A which includes information about the TPA’s services, fees and other important disclosures and should be ready fully upon receipt. The TPAs will usually have discretionary authority over ATSWM clients’ assets allocated to them for management and authorized to buy, sell, and trade in securities in accordance with the client’s investment objectives and selected investment strategy(ies), without obtaining prior approval from the client. Once a TPA is selected, ATSWM monitors the chosen TPA to help ensure the TPA adheres to the mandates of the selected investment strategy(ies) and to help ensure the selected strategy(ies) remain suitable for the client. ATSWM’s review generally includes, but is not limited to, a combination of the following: (i) assessment of the TPA’s registration status; (ii) a review of the TPA’s disclosure brochures, performance information, and other materials supplied by the TPA; (iii) an evaluation of the TPA’s investment strategies, key personnel turnover, regulatory events, and ownership changes. As authorized by the client, ATSWM will have the ability to hire and fire the selected TPAs and reallocate client assets to other TPAs when ATSWM deems it to be in the best interest of the client. c. Management of Variable Annuity Sub-Accounts Under the Firm’s sub-account management services, ATSWM offers discretionary management of the client’s variable annuity contract and will make selections and exchanges between sub-accounts available from the insurance company issuing the variable annuity. Clients requesting such services will be asked to sign a separate engagement agreement with ATSWM. Under this program, ATSWM will assist the client in completing a questionnaire which details the client’s financial goals, risk tolerance and time horizon. The client will have the opportunity to place reasonable restrictions on the sub-accounts available for selection. Model allocations are strategically developed utilizing the sub-accounts available within the variable annuity products. ATSWM may limit the product offerings at insurance companies on which investment management services are available. The limitations may be due to variable annuity sub-account options, annuity riders added to contracts or other factors. Total portfolio expenses may be higher than other mutual fund or managed portfolios based on the product, mortality and expenses and additional riders that may be added to the policy. Clients should be aware that these sub-account management services present a conflict of interest in that, at times, the ATSWM representative performing these services will have sold the variable annuity to the client and received a commission for doing so (please see Items 5, 10 and 14 below for additional information). In such cases, ATSWM will not charge a fee for managing the variable annuity sub- accounts for twelve (12) months from the date of purchase. In some cases, fees for managing the subaccounts may be deducted from the annuity. Fee deductions are generally considered distributions from the annuity, and will affect the annuity contract terms, and typically have tax consequences. Clients are encouraged to consult with a tax professional regarding any tax ramifications related to the variable annuity. Please see Item 5 below for additional information relating to fees. d. Non-Managed (Courtesy) Account Services Upon discretion and final approval by ATSWM, some clients may be allowed to establish one or more non-managed (also known as “courtesy”) accounts through Charles Schwab & Co., Inc. and appoint ATSWM as the investment adviser to the account. While our Firm will be listed as an investment adviser on a courtesy account; courtesy accounts do not receive ongoing supervision and monitoring services like those provided to accounts through our Asset Management Services described above. The Firm will not make any investment recommendations and will not monitor specific securities or general portfolios for these accounts. The primary purpose for this service is to include non-managed accounts owned by the client in the performance reports and/or financial analyses provided by the Firm to those clients. Clients are solely responsible for initiating all purchase and sale decisions of general securities held in non-managed accounts. Therefore, clients with courtesy accounts, and not ATSWM or any of our employees, will have the exclusive responsibility for the performance and monitoring of all securities that are purchased for, or held, in the non-managed account. ATSWM does not currently charge a fee for this service. However, such accounts will be charged typical fees by the custodian where assets are held (ATSWM does not receive any such fees). Clients will be required to enter into a written agreement with ATSWM prior to establishing such courtesy accounts. 3. Newsletters and other Publications Mr. Varma also serves as the President to AMS Advanced Marketing Strategies, Inc., a business created for the creation and dissemination of financial market related publications. Such publications include newsletters, magazines and books focusing on the financial market. These materials are made available to clients of ATSWM at no charge. However, ATSWM typically receives compensation from unaffiliated third-parties who pay for advertising space within the magazine published through Advanced Marketing Strategies. 4. Educational Seminars ATSWM provides periodic educational seminars and workshops to potential clients and the general public free of charge. C. Wrap-Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. ATSWM does not participate in any wrap fee programs. D. General Information About ATSWM’s Advisory Services As indicated above, advisory services provided by ATSWM take into account the individual needs, objectives, and other financial goals of the client. Early on in the relationship, ATSWM will typically memorialize each client’s investment objectives, risk tolerance, time horizons and other important information, including any investment guidelines, in a client profile or similar document. This information, together with any other information relating to the client’s overall financial circumstances, will be used by the Firm to determine the most appropriate asset allocation and investment strategy to best meet the client’s financial goals. ATSWM will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that the Firm may have relied upon in rendering its services. In the event that a client notifies the Firm of such changes, ATSWM will review the changes and may recommend revisions to the client’s financial plan and/or portfolio. In addition, various ATSWM advisors also are licensed RRs of Avantax Investment ServicesSM and insurance agents through numerous insurance agencies. In such capacity, those advisors offer brokerage and/or insurance products and receive normal and customary commissions as a result. E. Amount of Client Assets Managed As of December 2022, the following represents the amount of client assets under management by ATSWM on a discretionary and non-discretionary basis: Type of Account Assets Under Management (“AUM”) Discretionary $ 235,620,000 Non-Discretionary $0 Total: $ 235,620,000