Firm Description Vora Wealth Management, PLLC, (“VWM,” “firm,” “we,” “us,” and “our”) was founded in 2010 and began offering investment advisory services in April 2011. VWM is owned by Vora Holdings, LLC and Om Laxmi, LLC is the operating company. We are an investment advisory firm registered with the State of Arizona. VWM provides personalized confidential financial planning, and investment management to its clients (“client,” “you,” and “your”), which include individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, and charitable organizations. Advice is provided through consultation with the client and may include determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and legacy planning. VWM is a fee-based financial planning firm. VWM is affiliated with Vora Financial Group, PLLC (“VFG”), an entity through which certain of VWM’s associated persons conduct insurance business. VFG, acting through licensed insurance agents, sells commissioned insurance products such as life insurance, health insurance, group medical insurance and fixed annuities. Investment advice is an integral part of financial planning. In addition, VWM advises clients regarding cash flow, college planning, retirement planning, tax planning and legacy planning. VWM does not act as a custodian of client assets. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the event they should occur. Amplify Platform VWM’s investment advisor representatives utilize the Amplify Wealth Management Platform (“Amplify Platform”) to manage client accounts. The Amplify Platform provides back-office operational support services such as administrative, trading, and reporting services and allows the firm and its clients to select certain independent third-party managers (“sub-advisors”) to manage client assets on a sub-advisory basis. VWM has executed a Platform Agreement with Amplify making our firm a “Platform Member.” As a Platform Member firm, we may allocate all or a portion of your assets among the different sub- advisors made available through the Amplify Platform on a discretionary basis. Sub-advisors available through the Amplify Platform will perform discretionary investment management services and shall manage, invest and reinvest your assets in accordance with the investment models or strategies so designated by VWM. The selected sub-advisor(s) shall be authorized, without prior consultation or approval from you or our firm, to buy, sell, trade and allocate your assets in accordance with your investment objectives and to deliver instructions in furtherance of this responsibility to the broker-dealer and/or custodian of your account. In addition, at VWM’s discretion, VWM may grant sub-advisors the authority to further delegate discretionary investment authority to additional sub-advisors. We will enter into a written Investment Advisory Agreement with you which grants our firm the authority to engage the Amplify Platform for the aforementioned services and will retain ongoing responsibility for the management and supervision of your account, including performing initial and ongoing suitability determinations. We shall also retain the ongoing responsibility for implementing our investment recommendations in accordance with our fiduciary duty to you by hiring, firing, and/or reallocating your assets on the Platform as we believe to be in your best interests. We will obtain client account guidelines, suitability information, and account limitations/restrictions from you and furnish the same to the sub-advisors selected on the Platform for management of your account. Please note: VWM’s investment advisor representatives are required to utilize the various services available through the Amplify Platform. The fees associated with the Amplify Platform will be paid by VWM and will not increase fees paid by clients to VWM. Types of Advisory Services VWM provides investment supervisory services, also known as asset management services and furnishes financial planning and investment advice through consultations. ASSET MANAGEMENT VWM offers discretionary direct asset management services to advisory clients. VWM will offer clients ongoing portfolio 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 VWM with discretionary authority to execute selected investment program transactions as stated within the investment advisory agreement. Assets are invested primarily in non-commissioned (no-load) mutual funds, exchange traded funds (“ETFs”) and stocks, usually through discount brokers or fund companies. Mutual fund managers charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Investments such as stocks, bonds, ETFs, and options may be transacted through a brokerage account when appropriate. The brokerage firm charges a fee for the above referenced transactions. VWM does not receive any compensation, in any form, from mutual fund companies or their managers. Investments may also include warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, U. S. government securities, options contracts, futures contracts, and interests in partnerships. When deemed appropriate for the client, VWM may hire sub-advisors to manage all or a portion of the assets in your account. VWM has full discretion to hire and fire sub-advisors as the firm deems suitable and appropriate. Sub-advisors will maintain the models or investment strategies agreed upon between the sub-advisor and VWM. Sub-advisors execute trades on behalf of VWM in client accounts. VWM will be responsible for the overall direct relationship with the client. VWM retains the authority and responsibility to terminate or reallocate the client’s assets among sub-advisor relationships. Pontera VWM uses a third-party platform to facilitate management of certain held-away assets such as defined contribution plan participant accounts, with discretion (“Pontera Platform”). The Pontera Platform allows VWM to avoid being considered to have custody of Client funds since VWM does not have direct access to client

log-in credentials to affect trades. VWM is not affiliated with the Pontera in any way and receives no compensation from Pontera for using the platform. A link will be provided to the client allowing the client to connect their designated held-away account(s) to the Pontera Platform. Once the client’s account is connected to the Pontera Platform, VWM will review the current account allocations. When deemed necessary, VWM will reallocate and/or rebalance the account in consideration of your investment goals, risk tolerance, and 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) on the Pontera Platform will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. All clients engaging our firm for Asset Management Services must either engage us for Comprehensive Financial Planning or meet a $150,000 minimum of assets under management. FINANCIAL PLANNING AND CONSULTING If financial planning and consulting services are applicable, the client will compensate VWM on an hourly basis or a negotiable fixed fee basis as described in detail in Item 5 of this brochure. Services include but are not limited to a thorough review of all applicable topics including net worth analysis, estate planning, cash flow analysis, business planning, investment planning, education planning, retirement planning, and planning for other goals and objectives as enumerated by the client. VWM will review all pertinent client data and objectives and make non-product specific recommendations including suggested strategies to help achieve the client’s stated objectives. Clients are under no obligation to act on the VWM’s financial planning and consulting recommendations. If the client elects to act on any recommendations made by VWM, the client is under no obligation to affect the transaction through VWM or any of VWM’s representatives. A conflict of interest exists between the interests of the investment advisor and the interests of the client when recommending products sold in any VWM representatives’ separate capacity as an insurance agent, insofar as insurance commissions received are separate and distinct from fees paid by the client for investment advisory services. The client is under no obligation to affect the transaction through VWM or any of its representatives. Financial plans will be completed and delivered within ninety (90) days from the date the client provides the necessary documentation and information. Clients may terminate these services with thirty (30) days’ written notice. ERISA PLAN SERVICES VWM provides services to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. VWM may act as either a 3(21) or 3(38) advisor. The specific services to be provided are selected by the plan sponsor and will be outlined in a written Investment Advisory Agreement. When we VWM provides these services it has no responsibility to provide services related to the following types of assets (collectively, “Excluded Assets”): employer securities; real estate (except for real estate funds or publicly traded real estate investment trusts); 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 VWM. Specific services will be outlined in detail to each plan in a written 408(b)2 disclosure. Limited Scope ERISA 3(21) Fiduciary. VWM may serve as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor, VWM 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 the plan, though using VWM can help the plan sponsor delegate liability by following a diligent process. Fiduciary 3(21) services may include non-discretionary investment advice regarding asset classes and investment alternatives, and options, investment policy statement (“IPS”) development, advice regarding selection of qualified default investment alternatives, assistance with monitoring of investment options, and periodic client meetings to discuss reports and investment recommendations. Non-fiduciary 3(21) services may include providing general investment education to Plan participants (consistent with the U.S. Department of Labor’s Interpretive Bulletin 96-1) and assistance with participant enrollment. VWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between VWM and client. ERISA 3(38) Investment Manager. VWM 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. VWM would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. Fiduciary 3(38) services may include discretionary investment management (including selection of investment options in accordance with the Plan’s IPS and ERISA Section 404(c) and the regulations thereunder); IPS development; selection of qualified default investment alternatives, and periodic client meetings to discuss reports and investment recommendations. The client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). Non-fiduciary 3(38) services may include providing general investment education to Plan participants (consistent with the U.S. Department of Labor’s Interpretive Bulletin 96-1) and assistance with participant enrollment. VWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between VWM and client. EDUCATIONAL SEMINARS VWM holds educational seminars on taxes and retirement. These services are free of charge to all clients and prospective clients. Client Tailored Services and Client Imposed Restrictions The goals and objectives of each client are documented in our client files. Investment strategies are created that reflect the client’s unique stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs VWM does not sponsor, advise, or recommend any wrap fee programs to its clients. Client Assets under Management As of December 31, 2022, VWM had approximately $74,797,158 of client’s assets under management on a discretionary basis and $0 on a non-discretionary basis.