A. Description of the Advisory Firm Significant Wealth Partners, LLC (hereinafter “SWPL”) is a Limited Liability organized in the State of Illinois. The firm was formed in January 2018, and the principal owners are Brian William Atkins and Stephen Richard Smith. B. Types of Advisory Services Portfolio Management Services SWPL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWPL 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 SWPL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWPL 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. SWPL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWPL’s economic, investment or other financial interests. To meet its fiduciary obligations, SWPL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWPL’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 SWPL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. SWPL may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, SWPL will always ensure those other advisers are properly licensed or registered as an investment adviser. SWPL conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. SWPL then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of SWPL's client. SWPL may also allocate among one or more private equity funds or private equity fund advisers. SWPL will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Selection of Other Advisers SWPL may direct clients to third-party investment advisers. Before selecting other advisers for clients, SWPL will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where SWPL is recommending the adviser to clients. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; debt/credit planning and profit sharing. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse or other relatives, and assessing

appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Financial planning to address retirement entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debt/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Educational Seminars/Workshops SWPL provides periodic educational seminars and workshops to prospective clients. Services Limited to Specific Types of Investments SWPL generally limits its investment advice to mutual funds, fixed income securities, real estate funds, insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and private placements. SWPL may use other securities as well to help diversify a portfolio when applicable. Brian is also principle owner of Atkins & Associates, LLC and any recommendations made to clients regarding insurance products will be offered by Mr. Atkins and any commissions paid for those services and products are made to Atkins & Associates, LLC. Please see item 10.C for more detail. 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 SWPL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWPL from properly servicing the client account, or if the restrictions would require SWPL to deviate from its standard suite of services, SWPL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SWPL does not participate in any wrap fee programs. E. Assets Under Management SWPL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 210,000,000.00 $ 0.00 March 2024