A. OWNERSHIP/ADVISORY HISTORY Sterling Retirement Group of Sacramento (“we”) is an investment adviser registered in California. The firm is a California corporation that was formed on July 3, 2013. It was subsequently registered as a California investment adviser in September 2013. In March 2023, we applied for registration with the U.S. Securities and Exchange Commission. Gary Frontiera is the owner and investment adviser representative. B. ADVISORY SERVICES OFFERED Before we enter into an Adviser-Client relationship, we may offer a complimentary general consultation to discuss services available, give a prospective client time to review services desired, and determine whether a relationship might benefit the client. Investment advisory services begin only after we and the client formalize the relationship with a properly executed agreement. We offer the following services to our clients: i. FINANCIAL PLANNING Comprehensive Financial Planning: Comprehensive Financial Planning is a multiple meeting process that results in a written financial plan for the client. First we have a discovery meeting, the purpose of which is to introduce ourselves, discuss the client’s financial circumstances and the concerns that prompted the client to contact us, and determine whether and how we will work together. During a second meeting the client will be asked to share in a data gathering and discovery process to determine the client’s specific needs, goals, intentions, time horizons, risk tolerance and investment objectives. Finally, at the last meeting, we will present the client’s written financial plan. At this meeting, we will also discuss options regarding implementation of any recommendations made following the conclusion of the planning process. Clients are not obligated to follow any recommendations we may make or to implement their financial plan through us. Consulting Services: For clients who do not wish to engage in comprehensive financial planning, we offer consulting services. Consulting services typically focus on one or two specific areas such as financial and cash management, risk management, financial issues relating to divorce or death of a family member, estate planning, tax issues, retirement planning, educational funding, goal setting, or other needs identified by the client or by our review of the client’s financial circumstances. Through discussion with the client and/or questionnaires, we will collect pertinent data, identify goals, objectives, financial concerns and potential solutions. We will present the client with a written analysis. Following the conclusion of the consulting services, we may make recommendations regarding implementation of the financial strategies discussed. Clients are not obligated to follow any recommendations we may make or to implement any recommendations through us. ii. BUSINESS CONSULTING SERVICES We provide business consulting services to our clients who have family or closely held businesses. This service entails one or more of the following: review financial statements to look for cost saving opportunities; review employer hiring strategies; review worker’s compensation insurance; assisting hiring CPAs and corporate attorneys; real estate transaction reviews and due diligence; assistance with structuring the transfer of the business from one generation to the next; and other services as negotiated with the client. iii. PORTFOLIO MANAGEMENT SERVICES We manage individualized portfolios for our clients. We work with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. We use marketable securities that may include bonds, common stock

(equities), and treasury bonds. (Additional information about securities used their risks can be found under Item 8.) Our investment philosophy is to use principals of value, safety and quality to seek investment options globally. We place heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. We offer this service on an ongoing basis or as a one-time service. With the one-time service we work with the client to create a portfolio, but implementation of the portfolio will be handled by the client. iv. SELECTION OF THIRD-PARTY INVESTMENT ADVISERS After an initial meeting with the client and when deemed appropriate, we may recommend the services of an independent investment adviser (“Third Party Adviser”). The recommendation will depend on the client’s circumstances, goals and objectives, strategy desired, account size, risk tolerance, or other factors. Working with the client we determine which Third Party Adviser may be appropriate. We will review Third Party Advisers prior to making a recommendation to the client. We will consider the following factors during its review: whether it is registered in California, fees, reputation, performance, financial strength, management, price, reporting capabilities, client’s financial situation, client’s goals, client’s needs, and client’s investment objectives. After its review we will present the client with one or more recommendations. If the client wishes to proceed with the recommendation, we will enter into a Co-Adviser relationship with the recommended Third-Party Adviser. The Co-Adviser relationship means our firm and the Third-Party Adviser will have separate rolls while serving the client. In effect, the client will engage both us and the Third-Party Adviser to serve his/her accounts and we and the Third-Party Adviser will provide separate services to the Client. Under this arrangement, the Third-Party Adviser will be responsible for portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. While we will maintain our relationship with the client by monitoring the status of the client’s accounts with the Third Party Adviser, make recommendations about the Third Party Adviser that could include changing to a different Third Party Adviser, meeting the client at least annually and acting as the client’s primary financial adviser. All questions regarding the Third-Party Adviser’s services and performance shall be directed to us. As a result of us and the Third-Party Adviser having different roles, the client will engage each separately. The client will sign a Selection of Third-Party Adviser Service Agreement with us. This agreement outlines our services provided to the client and the fees associated with those services. It will also allow us the ability to monitor performance of the Third-Party Adviser on behalf of the client. The client will also sign a separate agreement with the Third-Party Adviser that will detail its services and fees. When using the services of a Third-Party Adviser, clients will be given a copy of its Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. C. TAILORED SERVICES Our financial planning and portfolio management services are individualized to each client. A client may impose restrictions on investment in certain securities or types of securities. Any restrictions must be provided in writing. D. WRAP PROGRAM We do not sponsor or use wrap programs. E. CLIENT ASSETS MANAGED As of February 6, 2024, we manage $154,000,000 in client assets on a discretionary basis. We also manage $7,000,000 in client assets on a non-discretionary basis.