A. Description of the Advisory Firm Varra Wealth Management LLC d/b/a Varra Financial (hereinafter “VWML”) is a Limited Liability Company organized in the State of Colorado. The firm was formed in October 2022, and the principal owner is Gina Varra. B. Types of Advisory Services Portfolio Management Services VWML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VWML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring VWML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. VWML will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. VWML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VWML’s economic, investment or other financial interests. To meet its fiduciary obligations, VWML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VWML’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VWML’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Pension Consulting Services VWML offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives,

demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments VWML generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs. VWML may use other securities as well to help diversify a portfolio when applicable. 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. C. Client Tailored Services and Client Imposed Restrictions VWML will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by VWML on behalf of the client. VWML will review the client’s financial plan, including tax planning, retirement planning, asset allocation overview, cash flow analysis, and investment selection. VWML may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. VWML does not participate in wrap fee programs. E. Assets Under Management VWML has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 $ 106,881,022.00 April 2023