Position Wealth offers a variety of advisory services, which include investment and wealth management services. Prior to Position Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Position Wealth setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement"). Position Wealth allows its investment adviser representatives ("IARs") autonomy in managing client assets. Each IAR will determine the recommended investments in client accounts and will have his or her own methods of analysis and investment strategies. Position Wealth LLC filed for registration as an investment adviser in January 2023. The firm is 100% owned by Allizadeh and Marger Capital LLC, whose managing members and principal owners are Danny Allizadeh and Cary Marger. As of January 23, 2023, Position Wealth had $153,188,151 in total assets under regular and continuous management, of which $153,188,151 was managed on a discretionary basis and $0 was managed on a non-discretionary basis Position Wealth has its principal place of business in Texas, with a branch office in Utah. Investment and Wealth Management Services Position Wealth manages client investment portfolios on a discretionary basis. Position Wealth may also manage client investment portfolios on a discretionary basis per client request. Position Wealth primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"), individual debt and equity securities, options, and Independent Managers in accordance with the client's stated investment objectives. Clients can engage Position Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Position Wealth directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product's provider. Position Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Position Wealth consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Position Wealth if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Position Wealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts. Use of Independent Managers As mentioned above, Position Wealth selects certain

Independent Managers to actively manage a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Manager engaged to manage their assets. Position Wealth evaluates a variety of information about Independent Managers, which includes the Independent Manager’s public disclosure documents, materials supplied by the Independent Manager themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Manager’s investment strategies, past performance, and risk results in relation to its clients' individual portfolio allocations and risk exposure. Position Wealth also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Position Wealth continues to provide services relative to the discretionary or non-discretionary selection of the Independent Manager. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Position Wealth seeks to ensure the Independent Manager’s strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.