A. Description of the Advisory Firm Confidence Wealth Management, LLC (“CWM” or the “Firm”) is an SEC registered investment adviser and is a Nevada state limited liability company. CWM was founded on July 31, 2002, and the principal owner of the firm is Rem Oculee. B. Types of Advisory Services CWM offers the following services to advisory clients: 1. Investment Supervisory Services CWM offers its clients advanced solutions and strategies in areas of growth and protection of clients’ net worth, specifically in the areas of asset growth and protection, tax reduction strategies, estate planning strategies, legacy planning solutions, and generational wealth transfer, in addition to the ongoing discretionary and non-discretionary portfolio management services, which are based on the individual goals, objectives, time horizon, and risk tolerance of each client (“Investment Objectives”). Discretionary authority is granted via the agreement each client enters into with CWM and gives CWM the authority to make investment decisions regarding the assets in accounts managed by CWM, without prior consultation with the client. CWM also has the authority to give trading instruction to custodian and/or other parties necessary to effect transactions on behalf of a client in their managed account(s). CWM will provide non-discretionary services upon client request. The services begin with gathering pertinent information related to client’s life, family, and business, as well as the client’s investment objective. Based on the information gathered, CWM evaluates all relevant details and current investments of each client with respect to their Investment Objectives and discusses investment recommendations and/or recommends a third-party adviser to manage a portion or all of a client’s assets (see “Selection of Third Party Advisers” below for further information on the use of third party advisers by CWM). In addition to its proprietary advanced planning process, CWM provides investment advice regarding investments in mutual funds, equities, bonds, fixed income, debt securities, options, exchange traded funds (“ETFs”), third-party advisers, sub-advisers, exchange-traded real estate investment trusts (“REITs”), and government securities. Please refer to Item 8 below for further information on CWM’s investment strategies and their associated risks. 2. Selection of Third-Party Advisers In the process of client’s plan deployment, at times CWM will offer investment management services through use of independent, unaffiliated third-party investment managers (“TPAs”) for portfolio management services. Through this arrangement, CWM recommends the TPA’s investment strategies (each a “Strategy” and collectively the “Strategies”) and services to clients, when appropriate, based on client’s individual needs and in relation to the Client’s investment objectives, time horizon and risk tolerance. In this arrangement, the Firm will not have discretion to purchase securities within the TPA’s Strategies on behalf of the client (such discretion over assets within the Strategies is held solely by the TPA). However, the Firm will have discretion to choose the allocation of client’s assets among different Strategies made available by the TPA, and to change the allocation and redistribute client assets among different Strategies should such actions be determined by CWM as being in the client’s best interest. Clients are under no obligation to utilize the services of any TPA recommended by CWM. If the client chooses to work with a recommended TPA, the Client will typically be required to enter into a separate agreement with the selected TPA to manage the client’s assets within the client's account, in accordance with the selected Strategy(ies). The client, prior to entering into an agreement with a TPA, will be provided with that TPA's Form ADV Part 2A Firm Brochure which includes a description of the fees charged by the TPA. Clients are encouraged to review each disclosure document regarding the particular characteristics of any program and TPAs recommended. The TPA will have discretion to determine the securities to buy and sell within the Client’s account, based on the selected Strategy and subject to any reasonable restrictions required by the Client. CWM will meet with the client on a periodic basis to discuss changes in the client’s personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Additionally, once a TPA is selected, CWM 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. CWM '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 through the CWM client agreement, CWM has the ability to hire and fire the selected TPA(s) and reallocate client assets to other TPAs when CWM deems it to be in the best interest of the client. a. U s e o f Third Party Advisers At its discretion, CWM may enter into relationships with various companies that it believes are in the client’s best interest and benefit with including in certain cases unaffiliated registered investment advisers, to execute certain transactions on our behalf and perform discretionary asset management services to some of the Firm’s clients. These arrangements compliment CWM’s access to model portfolios, model managers, strategists, third-party money managers, and trading services. As part of one of these programs, clients will give CWM and the unaffiliated registered investment adviser discretion to select third-party, non-affiliated investment managers (“Model Managers”) to design and manage model portfolio for their assets. If CWM offers services through an unaffiliated registered investment adviser, CWM will provide the client with a copy of the registered investment adviser’s disclosure brochure which contains a detailed description of their services. CWM will retain the right to terminate service relationships with unaffiliated registered investment advisers as needed to accommodate the client’s objectives. 3. Selection of Sub-Advisers To create maximum benefits for its clients, the Firm will also utilize, at its sole discretion, one or more sub-advisers to manage all or a portion of client’s assets pursuant to investment strategy(ies) made available by the respective sub-adviser. Sub-advisers hired by CWM on behalf of each client are responsible for making investment decisions consistent with the investment guidelines and restrictions developed by the respective sub-adviser. Sub-advisers typically have discretionary authority to execute transactions on behalf of clients on a best execution basis and in accordance with each sub-adviser’s own Form ADV, Part 2 Brochure or other disclosure statement. While CWM negotiates all fees payable to the sub-advisers, such fees are separate from and in addition to the fees owed CWM. In taking into account whether to invest client assets with certain sub-advisers, the Firm takes into consideration a variety of factors, and analyzes the sub-advisers for style consistency, investment strategies, risk attribution (if available) and historical performance. The Firm also considers information about the sub-advisers as represented in its disclosure brochure, promotional and other materials supplied by the sub-adviser. The Firm also considers both quantitative and qualitative factors including, but not limited to, the respective sub-adviser’s performance during various time periods and market cycles; the sub-adviser’s reputation, experience and training; its articulation of, and adherence to, its investment philosophy; the presence and deemed effectiveness of the sub-adviser’s risk management discipline; the structure of the sub-adviser’s portfolio and the types of securities or other instruments held; its fee structure; interviews with the sub-adviser; the quality and stability of a sub-adviser’s organization, including internal and external professional staff; and whether the sub-adviser has a substantial personal investment in the investment program it pursues. 4. Retirement Planning Services CWM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). A description of these services is provided below: FIDUCIARY SERVICES CWM will perform the following Fiduciary Services: A. Plan-Level Non-Discretionary Investment Advice Services (i) CWM will assist 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 investment policy statement. (ii) CWM will provide non-discretionary investment

advice to Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, removal and addition of investment options. (iii) CWM will assist Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. (iv) CWM will assist in monitoring investment options by preparing periodic investment reports that are based on conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and/or replace investment options. (v) CWM will meet with Client on a periodic basis to discuss the reports and the investment recommendations. (vi) CWM will provide non-discretionary investment advice to the Client with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election. Client acknowledges that it is responsible for determining whether the Plan should have a QDIA. Should Client determine that Plan will have a QDIA, Adviser will make recommendations as to the investment to serve as the QDIA. The Client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5). NON-FIDUCIARY SERVICES CWM will perform the Non-Fiduciary services described below. CWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Adviser and Client. A. Plan-Level Non-Fiduciary Services (i) Educate Client as to its fiduciary responsibilities. (ii) Assist the Client in monitoring, selecting and supervising service vendors and coordinate the transition process if the service vendor is replaced. (iii) Perform benchmarking studies and fee analysis. B. Participant-Level Non-Fiduciary Services (i) Assist in the group enrollment meetings designed to increase retirement plan participation among employees, improve investment and financial understanding by the employees and promote retirement readiness. (ii) Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that CWM’s assistance in participant investment education shall be consistent with prevailing Department of Labor guidance on investment education. As such, CWM is not providing fiduciary advice (as defined in ERISA) to the participants. 5. Financial Planning Services CWM’s Financial Planning Services range from comprehensive financial and wealth planning to more focused consultations, depending on the needs of each client. Generally, CWM evaluates the client’s financial, business, family, and investment information and makes recommendations designed with the intention of achieving the client’s overall goals and objectives. Financial and wealth planning recommendations are based on the Client’s situation at the time the recommendations are provided and are based on the information provided by the client. In addition, certain assumptions may be 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 and CWM cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As a client’s financial situation, goals, objectives, or needs change, the client is strongly urged to promptly notify CWM. For more information on the risks associated with investing, please refer to Item 8, below. Please refer to Item 5 below for detailed information on fees and compensation for these services. Confidence Wealth Management has a fiduciary duty to its clients. The firm and its employees will at all times endeavor to put the interests of its clients first. Recommendations will only be made to the extent that they are reasonably believed to be in the best interests of the client. Clients should be aware that a potential conflict exists between CWM’s interests and the interest of the client when CWM recommends the client implement the financial plan through the firm. This is mainly due to the fact that CWM has an incentive to make the recommendations since the firm will receive additional fees from the client if the financial planning client becomes an investment management client. In addition, while some insurance applications might be necessary to help protect and create leverage in a client’s financial situation, should a client decide to implement any insurance recommendations made by CWM, they may, but are not obligated to do so through CWM’s affiliate, Confidence Wealth & Insurance Solutions LLC (“CWIS”). Importantly, while CWM will have the client’s best interest at its core, CWM wants you to be aware that a potential conflict of interest could potentially exist when CWM recommends that a client purchase insurance through CWIS, since CWIS and certain CWM investment adviser representatives will receive compensation should a client implement any insurance recommendations through CWM’s affiliated insurance firm (see Item 10 for further details). Clients are under no obligation to implement any of the recommendations provided by CWM. Should a financial planning client decide to implement any investment recommendations contained in their financial plan, the client may, but is under no obligation to, utilize CWM to implement any such recommendations. Financial planning clients who wish to engage CWM for investment management services will be required to enter into a separate written agreement with the firm for such services. These services also carry a separate and additional fee, which is described in Item 5 below. C. Client Tailored Services and Client Imposed Restrictions The investment recommendations provided by CWM are based upon the individual needs, objectives, and other financial goals of the client, as such information is provided to CWM as outlined in Item 4.B above. CWM will not assume any responsibility for the accuracy of the information provided by the client. CWM 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 CWM in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies CWM of changes in the client’s financial circumstances or investment goals, CWM will review such changes and recommend any necessary revisions to the client’s investments. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CWM from properly servicing the client account, or if the restrictions would require CWM to deviate from its standard suite of services, CWM reserves the right to end the relationship. CWM shall provide information and/or documentation to the TPA/sub-adviser relative to the client’s investment objective(s), initially when the client account is opened, and anytime the client’s informs CWM of any change to their investment objectives. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. D. Wrap Fee Programs CWM does not participate as a portfolio manager in or sponsor any wrap fee programs. However, certain TPAs recommended by CWM do sponsor wrap programs and in some cases the investment management services being provided to allocated CWM clients are provided under the TPA’s wrap program. E. Amounts Under Management As of December 31, 2023, CWM has $585,600,782 in total assets under advisement, which includes $267,130,014 of assets under management which is composed of $263,834,649 in discretionary assets and $3,295,365 in non-discretionary assets.