A. FIRM DESCRIPTION Paul Winkler, Inc. (“PWI” or the “Firm” or “us” or “we”) is a corporation that was founded in the State of Tennessee in 2000. Paul Winkler, Inc.is a registered investment adviser firm with the Securities and Exchange Commission (“SEC”) since June 01, 2023, and was previously a state-registered investment adviser firm. Paul Winkler is the Owner of Paul Winkler, Inc. Additional information about Mr. Winkler’s background may be found in his Form ADV Part 2B Brochure Supplement. PWI offers a variety of investment advisory and related financial services to our clients. We provide investment advisory services, financial planning services, and retirement plan consulting services, all of which are discussed below in further detail. The products discussed throughout this Brochure are all available on a non-wrap fee basis. Our clients consist of individuals, high net-worth individuals, families, business owners and corporations. B. TYPES OF ADVISORY SERVICES OVERVIEW OF SERVICES Our investment advisory services consist primarily of: (1) assessing client needs and goals; (2) financial planning designed to meet those goals; (2) implementing the asset allocation by recommending or otherwise assisting in the client’s selection of specific investment managers or passive investment vehicles that employ those strategies; and (3) reviewing and reassessing the client’s needs and goals, their investment portfolios, and repeating the process on a regular, ongoing basis. PWI dedicates itself to understanding the intricacies of each client. For all investment advisory and related services described below, we tailor our products in accordance with the client-specific needs obtained from documented discussions, a financial plan and/ or risk assessment. Before providing investment advisory services, PWI takes multiple factors into consideration, including, but not limited to, investment objectives, investment horizon, risk tolerance, as well as any reasonable guidelines and restrictions a client may need or impose. INVESTOR EDUCATION Investor Coaching Workshops – We offer our expertise through educational financial workshops to clients who have engaged for financial planning and coaching services. These workshops are typically presented in groups, usually several times a month. Our presentations focus on a variety of issues, such as investments, financial planning, qualified retirement plans, success coaching and other matters that may be of interest to our clients. The Investor Coaching Show – Our President, Paul P. Winkler, hosts a radio show and is often a guest on radio shows. Other PWI investment adviser representatives may also participate on the show. They discuss educational topics including financial planning, retirement issues, and consumer news. An internet podcast is broadcast with the same or similar educational topics. These shows do not provide individualized investment advice. They are geared towards the public for informational purposes and are not to be construed as a solicitation for the purchase or sale of any security, nor the provision of tax or legal advice. Website, Social Media and Workshops: We also provide blogs, web content and videos on our website and other social media and some educational workshops open to the public which address various issues of a financial nature. These offerings do not provide individualized investment advice. They are geared towards the public for informational purposes and are not to be construed as a solicitation for the purchase or sale of any security, nor the provision of tax or legal advice, and also generate prospective clients for us. Some workshops may be offered at a fee and may include other, unaffiliated persons or entities as a part of the workshops as a service or to provide education or benefits in areas we do not provide, to enrich the experience for our clients or potential clients. Any fee charged will be disclosed in advance. Although we do our best to provide these joint events with providers that are professional and act in the best interest of clients and potential clients, these persons or entities are not affiliated with PWI and we are not responsible for the products or services they provide for their non-investment related services, acts or products. Examples of this may include offering a workshop at a public restaurant, winery, or in conjunction with yoga, travel, etc. Books: Our founder, Paul Winkler, has authored several books, many of which are available for purchase through www.amazon.com or in bookstores. His books include: Confident Investing—Why Blind Trust Is A Poor Strategy , Above The Maddening Crowd, Confident Financial Planning- How to Build, Protect, and Enjoy Your Money and Confident Financial Planning. FINANCIAL PLANNING SERVICES At PWI, we want our clients to understand investing and to learn how to achieve their investment objectives and financial needs. We provide personalized financial planning and coaching, designed to meet a person’s individual needs in one-on-one consultations. We also make recommendations for investing based on a person’s individual needs. Before we enter into an adviser-client relationship, we offer a complimentary consultation to find out what you know about investing and what you need to learn more about. We will review some of your current investments to determine if there are any areas of concern. If there are, we will give you steps you can take to potentially get on the right track. We discuss services available, give you time to review the information we provide, and determine whether a relationship might benefit you. If you decide to engage us, our planning and coaching services include preparing an analysis and recommended actions, an educational workshop, and implementation assistance. If you choose to implement your plan’s investment recommendations through an investment manager recommended by us, you are eligible to participate in ongoing educational workshops that we provide. Services begin only after the relationship is formalized with a properly executed Coaching/Planning Engagement or Wealth Planning Agreement. When we make recommendations for implementing the investment advice we give you, you are under no obligation to act on our recommendations. Moreover, if you elect to act on any of our recommendations, there is no obligation to affect the transaction through any company recommended. Our recommendations are based on your financial situation at the time the analysis is presented and based on financial information disclosed by you. While we do not believe it is prudent to make investment choices based on the past performance of a particular manager’s track record, we do make certain assumptions about interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. We do not offer any guarantees or promises that your financial goals and objectives will be met. If you require only advice on a single aspect of the management of your financial resources, such as a review or recommendation as to your investments in your 401(k) plan, we are available to consult with you in addressing specific areas of concern. Subscription Service To address the needs of those with lower financial assets but who still desire education, coaching and a comprehensive financial plan to better ensure financial success as their assets grow, we offer a subscription- based plan. This plan offers online access to eight virtual workshops with a follow up call each quarter for two years. Also included are unlimited email and phone access with a planner, a comprehensive financial plan which may include cash flow management, debt repayment, education and retirement savings, insurance recommendations, tax strategies, investment and estate planning recommendations, etc. The comprehensive financial plan is developed in 3-6 meetings with the client over the first year and includes a written financial plan deliverable. The plan also includes accountability and progress meetings (no less than twice per year), and annual review and revision meetings to keep the plan up to date. Wealth Management Planning Wealth planning is an evaluation of the investment and financial options available based upon your defined economic criteria and financial goals. Planning includes: (i) attempting to make optimal decisions; (ii) projecting the consequences of decisions in the form of a financial plan; (iii) implementing the protocol to achieve the objectives of the plan; and, (iv) comparing future performance against the plan. A plan can be broad

– a mutually defined review of your personal financial needs; or, segmented – review, analysis and evaluation of a core area of financial need. In general, wealth planning encompasses one or more of the following areas:  Personal – Family records, budgeting, personal liability, estate information and financial goals.  Education – Education IRAs, financial aid, state savings plans including 529 plans, grants and general assistance in preparing to meet dependents continuing educational needs through development of an education plan.  Taxes & Cash Flow – Understanding the impact of various investments on your current income tax and future tax liability.  Death & Disability – Cash needs at death, income needs of surviving dependents, estate planning and income analysis.  Estate – Reviewing estate-planning documents, including wills and trusts, to determine if you should seek the assistance of an estate-planning attorney. Reviewing powers of attorney, nursing home and assisted living agreements, living trusts, and Medicare/Medicaid benefits.  Retirement – Analysis of current strategies and investment plans to help you potentially achieve retirement goals.  Investments – Analysis of investment alternatives and their effect on your investment portfolio(s), including a risk and return analysis. Assessment of your risk tolerance profile.  Insurance – Review of existing policies to potentially ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. First, we make a detailed assessment of what you want to achieve based on personal interviews and profile questionnaires. We meet with you to begin formally documenting goals and objectives. Then, we evaluate your goals and objectives and formulate a plan that you will be comfortable executing. In some cases, the drafting of the plan reveals the need for us to help you reconcile the gap between expectations and financial realities. Once a viable plan has been drafted, it is presented to and reviewed with you. The draft and review process may be repeated until you are satisfied with the plan. We make recommendations for the implementation and monitoring of the plan. We usually suggest that you review the plan at least annually. eMoney or Other Web-Based Platform – In addition to planning and coaching, we may provide our clients a web-based platform for the consolidation and maintenance of personal financial information through eMoney Advisor, LLC (“eMoney”) at no charge to our clients. This personal financial management platform helps clients to understand the impact of financial decisions, easily view progress towards their goals, and contains an electronic vault for important documents. INVESTMENT ADVISORY SERVICES Depending upon the results of our analysis and your individual situation, we will recommend the investment of your capital through an unaffiliated third-party asset manager (“TPAM”). The purpose of using a TPAM is to invest your assets in portfolios modeled to mirror your investment objectives and financial needs. All recommendations depend on your circumstances, goals and objectives, strategy desired, account size, risk tolerance, or other factors. You are not obligated to take advantage of any of our recommendations. Before making recommendations, we review the TPAM’s backgrounds and consider factors, such as fees, reputation, performance, financial strength, management, price, and reporting capabilities. We will present you our recommendation based on your financial situation, goals, needs, and investment objectives. We recommend Matson Money, Inc. (CRD #110425), who has created model portfolios, managed by them for a wide range of investment choices. At the time of the recommendation, we provide the TPAM’s written disclosures describing its services and fees. Generally, a TPAM is responsible for portfolio management, portfolio design, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. Our agreements with TPAMs usually require us to maintain a relationship with you, either as a referrer or as a co-advisor. If as a co- advisor, the TPAM requires us to ensure that information about your specific goals, financial situation and risk preference remain current, assist you in determining appropriate allocation models, review account activity periodically, contact you to update information or meet with you annually or upon request, and respond to your inquiries. PWI has entered into a Co-Advisor agreement with Matson Money. Matson Money takes responsibility for investment management, portfolio design, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations. PWI’s responsibilities require us to:
• Provide you with Matson Money’s disclosure brochure that describes its services and fees,
• Provide you with a written disclosure statement, titled “Co-Advisor Disclosure Statement,” that describes the fees we receive for referring you to Matson Money,
• Maintain a relationship with you,
• Ensure that information about your specific goals, financial situation and risk preference remain current and advise Matson Money of changes in this information,
• Assist you in determining appropriate allocation models,
• Review account activity periodically,
• Contact or meet with you annually, and
• Respond to your inquiries. If you choose to go forward with these services, you will enter into a written Investment Management Agreement with Matson Money and PWI. Under this agreement, you authorize Matson Money to supervise and direct your investment accounts in accordance with the investment objectives for each account. Matson Money may accept investment restrictions you provide to Matson Money in writing. SELECTION OF OTHER ADVISERS We may recommend that you use the services of a third-party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action appropriate. C. TAILORED RELATIONSHIPS At PWI, we offer the same suite of services to all our clients. The advisory services and recommendations offered by PWI are based on the individual needs of our clients and the suitability of products and services. Specific client financial plans and their implementation are dependent upon the client’s risk assessment which outlines each client’s current situation (income, objectives, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values and beliefs. PWI will make every effort to comply with the wishes of the client but cannot guarantee absolute adherence due to our use of indexed products, funds, and exchange traded funds (“ETF”) that are controlled by custodian and its third-party service providers. D. WRAP FEE PROGRAMS Paul Winkler, Inc. does not participate in and is not a sponsor of wrap fee programs. Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions, and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. E. ASSETS UNDER MANAGEMENT When calculating regulatory assets under management, an investment adviser must include the value of any advisory account over which it exercises continuous and regular advisory or management services. As of December 31, 2023, PWI reports $283,976,191 in client assets on a discretionary basis and $0.00 on a non- discretionary basis.