A. Description of Firm Bayntree Wealth Advisors, LLC (“Bayntree” or the “Firm”) is a Scottsdale, Arizona based investment management firm founded in 2015. Bayntree provides discretionary and non- discretionary investment management to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations. The Firm focuses on income planning, risk management and comprehensive financial planning. Bayntree is an SEC-registered investment adviser and is notice filed with the states of Arizona, California, New Mexico, Texas, and Virginia. Bayntree is owned by AJW, LLC. Andrew S. Rafal is the majority owner of AJW, LLC. B. Types of Advisory Services Offered Investment Management Bayntree offers clients investment management services on a discretionary and non-discretionary basis. Under discretionary management, Bayntree will determine the securities to be bought or sold in accounts and will make changes to the asset allocation or specific securities selected, without prior consultation with the client. The investment advice provided is variable depending on the individual goals, objectives, time horizon, and risk tolerance of each client and in accordance with a written Investment Management Agreement entered into between the Firm and the client. Discretionary authority may be subject to conditions imposed by a client. This may occur when a client restricts or prohibits transactions in a security for a specific company or for an industry sector. While the Firm generally allows clients to impose reasonable restrictions on the types of securities, each client assumes responsibility for informing the Firm in writing of any restriction or changes to these restrictions or to their overall investment objectives. Risk tolerance levels are documented in the suitability documentation maintained by the Firm. Prior to entering into an Investment Management Agreement with the Firm, a client should carefully consider:  That over time the client’s assets may fluctuate and at any time be worth more or less than the amount invested; and  Bayntree’s strategies are designed for investors who practice patience with a time horizon of 3-5 years. Based on Bayntree’s research as well as the client's individual circumstances and needs, the Firm will perform searches of various third-party managers, mutual funds and exchange-traded funds (“ETFs”) to identify which portfolio management style, and the percentage allocation, is appropriate for the client. Factors considered in making this determination include account size, risk tolerance, and the investment philosophy of the selected third-party manager and/or fund. Under the Investment Management Agreement, Bayntree has the authority to delegate the active discretionary management of all or part of the client’s assets to one or more third-party managers based on the client’s stated investment objectives without prior consultation with client. Clients should refer to the selected third-party manager's Firm Brochure, fund prospectus or other disclosure document for a full description of the services offered. Bayntree will continue to remain knowledgeable about the clients account so that the client can consult with Bayntree when necessary. Generally, Bayntree will use a combination of third-party managers, mutual funds and exchange- traded funds (“ETFs”) through the Unified Managed Accounts Exchange platform (known as “UMAX”) at TD Ameritrade Institutional, a division of TD Ameritrade, Inc. Member FINRA/SIPC. TD Ameritrade Institutional will provide custodial services for the Firm’s clients. Typically, clients open a Unified Managed Account (“UMA”) by signing a Unified Managed Account Exchange Application and Agreement (“UMA Agreement”) in order to access UMAX. UMAs are a form of fee-based investment solutions that allow advisers to combine multiple professionally managed investment products into a single account with automated services such as rebalancing, performance reporting, billing and advanced functionality such as managing securities restrictions. The third-party managed investment products are managed by advisors to model portfolios (“Model Portfolio Advisors”) selected for the client by Bayntree. By signing the UMA Agreement, the client also appoints Envestnet Asset Management, Inc. (“Envestnet” or “Overlay Manager”), a third-party registered investment adviser, to provide overlay management services to Bayntree clients. Envestnet is responsible for: ongoing management and supervision of accounts; implementation and coordination of model portfolios and related recommendations received from Model Portfolio Advisors; periodic rebalancing of accounts; cash management; loss harvesting for taxable accounts (but without tax management); initial investment of accounts and tradition of legacy assets; incorporating client-requested restrictions for specific securities and social and industry categories; and providing tax overlay management on accounts for which the Advisor has selected tax management on behalf of clients. The Overlay Manager will have authority and discretion to select brokers and dealers to execute portfolio transactions initiated by Overlay Manager and to select the markets on in which the transactions will be executed. Bayntree will monitor the performance of the selected third-party manager, mutual fund or ETF. If it is determined that the manager or fund is not managing the client's portfolio in a manner consistent with the client's Profile, the Firm will suggest the client contract with a different third- party manager or program sponsor. Under this scenario, the Firm will select a new third-party manager or a program in conjunction with the client. Bayntree also offers advisory services for managing variable annuity insurance products. Bayntree will either directly manage these annuity insurance products or may recommend a third-party manager to manage the sub-accounts in accordance with your financial profile. These services would be subject to a separate written agreement covering the annuity products. Variable annuity insurance products contain sub-accounts, which are portfolios of investment assets. Based upon your financial profile, Bayntree will recommend an advisory service designed to assist in selecting which sub-accounts best help you meet your financial goals. Annuity products serviced by Bayntree are charged an asset-based management fee rather than commissions. Financial Planning Bayntree provides comprehensive financial planning services to assist clients in reaching their financial and retirement goals. The Firm develops financial plans and provides consultations by evaluating data relating to a client’s personal financial profile, investment objectives and goals, risk tolerance, and tax status in accordance with a written Financial Planning Agreement entered into between the Firm and the client. These financial planning services may be provided on an ongoing or as-needed basis, depending on the client’s needs, and may be paid through hourly fees, fixed fees, or monthly subscription billing, as further described below in Item 5. Bayntree’s financial planning services may include information regarding retirement planning, advanced education planning, college planning, long-term care needs, and estate planning issues. Our comprehensive financial planning services may also include information or analyses with respect to tax liabilities or risks. Please be advised that Bayntree does not provide legal, tax, or accounting advice, and clients should consult with qualified professionals prior to making any decisions with tax implications. In most cases, the client will supply to Bayntree information including income, investments, savings, insurance, age and many other items that are helpful to the Firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, Bayntree will discuss your financial needs and goals with you and compare your current financial situation with your stated goals and objectives. Bayntree may further create a financial and/or investment plan to help you meet your goals, depending on the services selected by the client. The plan, which we refer to as the Bayntree Blueprint, is intended to be a blueprint of how to meet your goals. Not

every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is important that you accurately and completely communicate to us the information the Firm needs. Also, your circumstances and needs may change as your engagement with us progresses. It is very important that you continually update Bayntree with any changes so that if the updates require changes to your plan, the Firm can make those changes. General Education Workshops and Seminars. Bayntree engages in the delivery of Educational Workshops and Seminars. These services focus on general education only and do not provide for individualized advice or recommendations. Most of these workshops and seminars will be free to those in attendance. If a fee is charged, it will range from $25 to $50 and is solely to recover costs associated with the workshop or seminar. Conflicts of Interest As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer’s or former employer’s retirement plan and roll the assets over to an individual retirement account (“IRA”) that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset based fee as set forth in the agreement you executed with our Firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than based solely on your needs. We manage this conflict of interest by always acting in the client’s best interest and keeping documentation of our determination that the rollover recommendation is in the client’s best interest. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our Firm. Many employers permit former employees to keep their retirement assets in their company plan. Current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits. An employee will typically have four options: 1) Leaving the funds in your employer’s (former employer’s) plan; 2) Moving the funds to a new employer’s retirement plan; 3) Cashing out and taking a taxable distribution from the plan; 4) Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. We will speak with your CPA and/or attorney if you authorize us to do so in connection with any rollover recommendation we make. Similarly, we may rely on information you obtain from your CPA or tax attorney and communicate to us prior to making any such recommendation. Please note that Bayntree’s representatives are licensed to sell insurance and related products with various unaffiliated insurance companies. Bayntree’s representatives in such cases will earn typical and customary commission for the sale of insurance products purchased for a client’s account. This represents a conflict of interest in that Bayntree’s representatives may recommend purchasing insurance products based on compensation received rather than on the needs of the client. Please see Item 10 for more information. Bayntree directs clients to third-party managers. If a client is introduced to a third-party manager by Bayntree, Bayntree may receive a solicitor fee in accordance with the requirements of state and/or federal securities law, as applicable. Please see Items 10 and 14 for more information. Bayntree participates in TD Ameritrade’s institutional customer program. Bayntree receives economic benefits through its participation in the program that are typically not available to TD Ameritrade retail investors. These benefits are paid for with client’s commissions/transactions fees or assets known as “soft dollars.” The use of soft dollar arrangements, which is governed by Section 28(e) of the Exchange Act of 1934, presents a conflict of interest because Bayntree could select a particular broker-dealer custodian that charges higher commission/transaction fees than what may be available elsewhere. Please see Item 12 for more information. As a client you are not obligated to act on any of the recommendations of our representatives, nor are you obligated to effect the transaction through our representatives if you elect to act on the recommendation. C. Advisory Agreements Prior to engaging Bayntree to provide advisory services, the client is required to enter into a written Investment Management Agreement and/or Financial Planning Agreement (“Advisory Agreement”) with the Firm which describes the advisory fees charged and the terms and conditions under which the Firm will render its services. The Firm will provide a Brochure and one or more Brochure Supplements to each client or prospective client prior to or at the same time a client executes the Advisory Agreement. The advisory relationship will continue until terminated by either party. Neither Bayntree nor the client may assign the Advisory Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of the Firm shall not be considered an assignment. The Advisory Agreement may be cancelled at any time, by either party, for any reason, upon written notice of either party. Upon receipt of notice of termination, Bayntree will commence the process of liquidating or transfer of such account. Upon completion, any prepaid, unearned fees will be promptly refunded, less any actual costs the Firm incurs upon termination, and any earned, unpaid fees will be due and payable upon termination. Additionally, if client requests the account to be transferred in-kind to another custodian, client will be responsible for any additional custodial transfer fee. D. Retirement Plan Rollovers When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our client’s interests, so we operate under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our clients. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we are asked by a client or prospective client to make a recommendation from among these choices, we have a conflict of interest in that we have an incentive to recommend that a client roll over their retirement plan assets into an account to be managed by Aspire in order to earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. E. Wrap Fee Programs Bayntree does not participate in wrap fee programs. F. Assets Under Management As of March 17, 2023, the following represents the amount of client assets under management by Bayntree on a discretionary and non-discretionary basis: Type of Account Assets Under Management (“AUM”) Discretionary $ 167,197,341 Non-Discretionary $3,943,255 Total: $171,140,596 In addition, Bayntree advises assets of approximately $82,560,173. As of March 17, 2023, Bayntree either advises or manages $253,700,769 in assets.