A. Strategic Wealth Capital, LLC Strategic Wealth Capital, LLC (“SWC,” or the “Adviser”) is a California limited liability company formed on August 15, 2019. The Adviser is an investment adviser registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”). The principal owner of SWC is Adrianne Yamaki. B. Types of Advisory Services Offered Financial Planning The Adviser’s financial planning process begins with an intensive fact-finding session which helps the Adviser become familiar with the client’s current financial situation (including among other things, higher education planning, investments, insurance, estate affairs and family circumstances), as well as their personal goals and priorities for the next several years. Then, working from this comprehensive information, the Adviser makes specific goal-oriented recommendations. The Adviser’s specific goal- oriented recommendations are designed to educate and allow a client to coordinate his/her financial affairs more efficiently, increase cash flow, prudently reduce income taxes, and attempt to improve his/her overall net worth. Once this has been discussed with the client, the recommendations that the client feels comfortable with are scheduled for implementation with specific deadlines to be met. The Adviser continues to assist the client based on an annual review of services in all applicable areas of financial planning including estate, retirement, cash flow and tax planning. Investment Consulting The Adviser works to provide institutional retirement plans and the plan sponsors with diversified investment options for plan participants to choose from. In addition, as requested by the plan sponsor, the Adviser shall provide plan participants with general information seminars and/or educational materials that describe the various investment alternatives available under the plan, information about investing in general, including information about several types of investments, such as allocation strategies, and historical returns. Interactive materials designed to help participants identify an appropriate investment strategy are provided. Investment Management We offer discretionary and non-discretionary investment management services. Investment management services offered by the Adviser are specifically tailored to meet the needs of each client. Prior to delivering investment advisory services, the Adviser will ascertain each client’s specific investment objective. The Adviser will allocate, or recommend that the client allocate, their investment assets consistent with the designated investment objective. Please note: It is always the client’s responsibility to promptly notify the Adviser if there is any change in their financial situation or investment objective. This notification of change allows the Adviser an opportunity to review, evaluate, or revise the previous recommendations or services. Managed Discretionary Assets If you engage our firm on a discretionary basis, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow our Investment Advisor Representatives (“IAR’s”) to weigh the Client’s objectives with current market conditions and act on a client’s account without further authorization. Managed Non-Discretionary Assets In addition to providing investment management of client assets on a discretionary basis, the Adviser, for a separate and additional fee, provides certain limited services to clients with respect to “Managed Non-Discretionary Assets.” These services consist solely of the following: o The Adviser is available to consult with the client on a semi-annual basis (or more often if requested by the client) regarding Managed Non-Discretionary Assets. However, the client is solely responsible for all decisions and consequences on the client’s Managed Non-discretionary Assets, including decisions on whether to retain or sell all or a portion of the Managed Non-Discretionary Assets. This responsibility remains solely with the client regardless of whether any security is reflected on account reports prepared by the Adviser. o The Adviser is available to service Managed Non-Discretionary Assets, such as setting up and monitoring regular distributions and special one-time distribution requests. o The Adviser can process any trades on the Managed Non-Discretionary Assets, but only when requested to do so by the client. Upon receipt of any client’s request, The Adviser will endeavor, but cannot guarantee, that any such transaction will be affected on the day received or at any specific time or price. Limitations for Non-Discretionary Assets Clients that engage the Adviser on a non-discretionary investment advisory basis must be willing to accept that the Adviser cannot affect any account transactions

without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, Strategic Wealth Capital will be unable to affect any account transactions (as it would for its discretionary accounts) without first obtaining the client’s consent. Third-Party Money Mangers After the Adviser has gathered information about the client’s specific investment objective, the Adviser will assist the Client in selecting a Third-Party Money Manager (“TPMM”) to deliver an investment model (“strategy”) or manage a separate account for the Client. IAR’s utilize multiple factors in selecting a prudent TPMM to recommend to a client, including but not limited to performance, investment objectives, and fees. These factors are considered in relation to the Client’s specific investment objective to help determine the suitability of the TPMM. When a client engages a TPMM we recommend, we do not directly manage that portion of the Client’s portfolio assets and are not involved in selecting the securities to be bought and sold, or the timing of the same. The day-to-day portfolio management decisions are provided by the TPMM, and then executed by us at the Client’s custodian or executed directly by the TPMM if managed in a separate account. In the event that the use of multiple TPMMs is recommended to a client, each TPMM has differing minimum account requirements as well as a variety of fee ranges. If a client uses a TPMM in a separate account, we periodically review the Client’s financial situation, objectives, and restrictions; and communicate relevant information to the TPMM and assist the client in understanding and evaluating the services provided by the TPMM. Some TPPMs maintain their own separate execution, clearing, and custodial relationships. If we determine that a selected TPMM is not managing the Client’s portfolio in a manner consistent with the Client’s IPS and investment objectives, or if the financial situation of the Client changes, we recommend a new TPPM. Additional Services The Adviser may furnish advice on matters not involving securities, such as:
• Retirement Income Planning Withdrawal Rate Analysis
• Insurance Review & Planning Corporate Retirement Plan Guidance
• Estate & Charitable Gift Planning
• Business Successions
• Personal Financial Planning
• Education Planning
• Cash Flow & Budgeting
• Employee Benefits & 401(k) Guidance
• Tax Planning C. Tailored Relationships At the Adviser, advisory services are tailored to the specific needs of each Client. Prior to providing advisory services, the Adviser will ascertain each Client’s investment goals and objectives. The Adviser then allocates and/or recommends that the client allocate investment assets consistent with the designated investment objective. The client may, at any time, impose reasonable restrictions on the Adviser’s services, but restrictions must be delivered to the Adviser in writing and must be signed by the Client. In performing services for the Client, the Adviser is not required to verify any information it received from the client or from the Client’s other professionals and the Adviser is expressly authorized by the Client to rely on this information. Each client is advised that it remains the Client’s responsibility to promptly notify the Adviser if there is ever any change in the Client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Adviser’s previous recommendations or services to the Client. D. Participation in Wrap Fee Programs The Adviser offers services through both wrap fee programs and non-wrap fee programs. Certain other fees are not included in the wrap fee and are paid for separately by the client. Clients may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from the custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap-fee you are charged by our firm. Please refer to the Adviser’s Wrap Fee Brochure for additional information. Generally, we consider wrap fee programs through which investment advisory services and execution of your transactions are provided for specified fees that are not based directly upon transactions in your account. Our firm and our investment team do not manage wrap fee accounts differently from other programs. E. Client Assets The Adviser manages $178,930,539 of client assets exclusively on a discretionary basis. SWC Assets Under Management (AUM) is calculated as of 12/31/2023.