Vestpointe Wealth Management, LLC (“Vestpointe”) began conducting business in 2004 as a State registered investment adviser. In 2021, Vestpointe switched to SEC registration. Vestpointe’s one and only principal place of business is located in Scottsdale, Arizona. Joseph Ignatius McCabe III, President; and Michele McCabe, Shareholder are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). Vestpointe offers a variety of advisory services, which include investment management, wealth management, wealth advisory, financial planning, consulting and other services as disclosed, herein. Prior to our firm rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Vestpointe setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). When we act as your investment adviser, we must act in your best interest, and we do not put our interest ahead of yours. At the same time, the method that we are compensated creates some conflicts with your interests. The following items outline our activities and address conflicts associated with those activities. You should understand and ask us about these potential conflicts because they can affect the investment advice we provide you. As of December 31, 2023, Vestpointe managed $114,282,255 of assets under our discretion and also had $8,272,095 of non-discretionary assets under management. WEALTH MANAGEMENT & INVESTMENT SUPERVISORY SERVICES Our firm provides continuous advice and asset supervision, generally on a discretionary basis, to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives are established, we will either prepare a financial plan or develop a client's personal investment policy statement (“IPS”). During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. The financial plan or IPS developed through this process will guide the financial professional in creating and managing a portfolio based on that plan or policy. When clients choose wealth management, Vestpointe does not charge an additional fee for financial planning services. Clients elect to opt into the financial plan service. All investment management clients receive an IPS, either through the financial plan or through an individually tailored IPS. It is important to note that 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 service offered by a broker-dealer or insurance company and generally include advice regarding the following securities: Exchange listed securities, securities traded over-the-counter, ETFs, foreign issuers, corporate debt securities, Commercial paper, certificates of deposit, municipal securities, mutual fund shares, United States governmental securities, REITS and options contracts on securities. For many clients, Vestpointe provides investment management services based on established model strategies. The intent of the strategy is that it forms the building block in structuring the client’s portfolio. A summary of the models follows: Model Portfolio Name Description Aggressive Our Aggressive Model Portfolio is designed for the investor who has a long-term investment horizon, desires a high level of return and can tolerate a high degree of volatility. Comprised of approximately 75% stocks, 14% Bonds, 3% Alternative Investments, 8% REITS Moderate Aggressive Our Moderate Aggressive Model Portfolio is designed for the investor who has a long-term investment horizon, desires a high level of return but desires a moderate level of volatility. Comprised of approximately 60% Stocks, 30% Bonds, 7% Alternative Investments, 3% REITS Moderate Our Moderate Model Portfolio is designed for the investor who has a mid-term investment horizon, desires a moderate level of return and wants to balance growth of the portfolio with stability. Comprised of approximately 50% Stocks, 42% Bonds, 5% Alternative Investments, 3% REITS Moderate Conservative Our Moderate Conservative Model Portfolio is designed for the investor who desires a moderate level of income and a low level of risk. Comprised of approximately 33% Stocks, 49% Bonds, 5% Alternative Investments, 3% REITS, 10% Cash Conservative Our Conservative Model Portfolio is designed for the investor who desires a high level of income and a very low level of risk. Comprised of approximately 17% Stock, 65% Bonds, 5% Alternative Investments, REITs 3%, 10% Cash V.I.S.T.A. VISTA “Vestpointe Individual Security Tactical Analysis” model portfolio is designed to be an aggressive growth component of the portfolio. The VISTA portfolio will hold up to 20-30 securities at any given time and all will be liquid investments. It is designed to take advantage of stocks/ETFs that have significant growth potential and/or momentum. The holdings will not have a specific sector/style bias necessarily but may try to take advantage of depressed prices in a particular sector or style. The portfolio may use stop losses on the individual holdings to protect gains and minimize losses. The VISTA portfolio is not designed to be a core holding for a large percentage of the portfolio. For our accredited investors, and those whose portfolios are deemed appropriate, we may also use alternative investments, such as leveraged and inverse ETFs. These types of investments contain considerable risk and therefore, are only recommended for portfolios that can withstand the possibility of exposure to loss of principal. Inverse and leveraged ETFs are very short-term investments and generally not suitable for more than a daily holding. Please ask us if you have a concern regarding any holdings in your account. Unaffiliated REITS under Investment Management Vestpointe also provides investment advice regarding unaffiliated REITs. Our firm will utilize, unaffiliated REITs for certain qualified clients. Our firm’s role, relative to these types of investment funds, shall be limited to its initial and ongoing due diligence and investment monitoring services. The amount of assets invested in the REITs shall be included as part of the client’s assets under management for purposes of our firm’s calculating its investment advisory fee. Unaffiliated REITS generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each REIT’s offering documents, which will be provided to you by the Sponsor for review and consideration. Each investor will be required to complete a Subscription Agreement provided by the Sponsor, pursuant to which the client shall establish that he/she is qualified for investment in the product and acknowledges and accepts the various risk factors that are associated with such an investment. Turnkey Asset Management Program (“TAMP”) In some cases, we will construct a portfolio utilizing an unaffiliated sub-adviser platform, also referred to as a turnkey asset management program (TAMP) for the account or for a portion of a client’s account. We recommend incorporation of a TAMP when the client seeks access to personalized advice about specific areas and/or the inclusion of a large pool of mutual funds. The programs allow us to put together a personalized portfolio of mutual funds based on the client’s risk tolerance, age, goals and other investment preferences. Tamps are generally wrap programs. Because mutual fund wrap programs typically require a minimum investment of $25,000, they are normally marketed toward high-net-worth clients. Clients should be aware that robo advice platforms offer a lower budget option, providing an automated version of the same investment profiling and portfolio building services with lower fees – but do not include our management or oversight. TAMP’s also offer unified managed accounts (UMA) choices for our high

net-worth investors. The UMA is an evolution of the separately managed account, which is similar in that it is a professionally managed account that is rebalanced often and generally incorporates investments across multiple different strategies into one account. Separately managed accounts are typically not known for pooling multiple investments and investment vehicles with varying objectives as they are typically focused on a targeted strategy managed as a separate account for the investor. A unified managed account is often a better alternative for an investor seeking to combine multiple investments. The UMA removes the need to have more than one account and can combine all of an investor’s assets into one account. These accounts are meant and recommended only for sophisticated investors who understand their purpose and risk. We generally recommend clients utilize AssetMark for the above noted TAMP services. When clients elect these types of services, be aware that the service is separate from our management services and additional management and other fees will apply. Clients who add a sub-adviser service receive a separate ADV Part 2A Disclosure Brochure and Form CRS from the sub-adviser and should carefully review the disclosure for fees and other important disclosures. Please see Item 5 – Fees and Compensation for additional information regarding the fees and costs associated with the use of sub-advisers. You should understand that third-party managers (TAMP Managers noted above) are not affiliated with our firm, and we are not responsible for their services, actions, omissions, or performance. Our responsibility is limited to having the discretion to direct a portion of the client’s account to/from the third-party manager. We will initially evaluate and recommend investment advisers and portfolios based upon reasonably available information at the time and periodically report on the third-party manager’s investment performance in conjunction with our standard reporting process. Additional Information Regarding Investment Management Services Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. There is no guarantee that a diversified portfolio will outperform a non-diversified portfolio in any given market environment. Diversification cannot ensure a profit or protect against a loss. FINANCIAL PLANNING SERVICES Clients may elect to separately contract for financial planning. Upon client request, we will develop a financial plan for our client and his or her family. Included in the analysis may be subjects dealing with tax planning, health care costs, choosing a strategy to maximize social security benefits, planning for retirement, demonstrating the impact of risks and loss tolerance to a financial plan, demonstrating the impact of market corrections, early death or unexpected costs and providing our clients with a plan to focus on their long-term goals. All recommendations for this service are generic in nature. Clients should be aware that we are affiliated with an accounting firm Joseph I. McCabe III CPA, P.C. and typically will recommend our affiliate for any implementation accounting or tax advice. With this in mind, should the client choose to implement the recommendations contained in the plan, the client is under no obligation to utilize our affiliated accounting firm. Vestpointe, as the adviser, does not provide legal or tax advice and clients should work closely with their attorney, accountant or other professional for these types of concerns. Implementation of financial plan recommendations is entirely at the client's discretion. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. CONSULTING SERVICES Clients not requiring a financial plan may also elect to receive investment and other financial advice on a limited basis for a separate fee. Some of the consulting services offered include investment advice regarding non-marketable securities, trust and estate administration. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Recommendations may be of a generic nature or tailored to specific securities, as outlined in the agreement signed by the client prior to accepting the consulting engagement. ERISA PLAN SERVICES Selection of Investment Vehicles - We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) to determine which investments are appropriate to implement in the client's portfolio. For certain clients, Vestpointe will act in a fiduciary capacity, as the firm has authority to implement transactions based on the Plan’s IPS. When we implement plan transactions, Vestpointe acknowledges that it must act prudently with respect to decisions affecting the plan—that is, with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use. This is often referred to as a “prudent expert” standard. Under this standard, Vestpointe is restricted from executing certain transactions that are prohibited under set forth in Sections 406, 407 and 408 of ERISA and Section 4975 of the IRS Code. In addition, the firm will not conduct principle, cross or agency cross trades in any ERISA Plan accounts. The number of investments to be recommended will be determined by the client, based on the client’s plan documents or IPS. Our firm does not act as third-party administrator for the plan. If not self-administered, each party must appoint a separate third-party administrator for the plan. Monitoring of Investment Performance - Our firm is engaged to provide continuous monitoring of plan investments, based on the procedures and timing intervals delineated in the plan’s established IPS. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the plan's portfolio and will make recommendations to the client as market factors and the client's needs dictate. Employee Communications & Education - For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we can be engaged to provide quarterly educational support and investment workshops designed for the plan’s participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. TRUST SERVICES Should our client request, and we agree to undertake the assignment, certain designated individuals of Vestpointe will serve as a personal trustee with regard to the accounts of the trust beneficiaries of client(s) and will provide fiduciary investment management advice to the trust. Trust services are separate from wealth advisory services. With this engagement, we may refer a client to an attorney or tax professional to prepare tax returns and perform trust administration and estate settlement services for the trust. Vestpointe will not accept, nor will we pay referral fees when recommending professionals for additional services. As Vestpointe has an affiliated tax preparation entity, there is an incentive to recommend our affiliated company (See Item 10 of this disclosure brochure). Clients are never obligated to accept our recommendations and may use a professional of their own choosing. BILL PAYER SERVICES We will, upon request, provide online bill paying services to client. Clients will agree to this service in a separate agreement. We will establish an account in the client’s name with client’s permission to pay certain obligations of the client.