A. Description of the Advisory Firm Sand Creek Capital, LLC, dba Cordingley & Parkinson Wealth Management (hereinafter “C&PWM”) is a Limited Liability Company organized in the State of Idaho. The firm was formed in February 2023, and the principal owner is Robert Garry Parkinson. B. Types of Advisory Services Portfolio Management Services C&PWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. C&PWM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 C&PWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. C&PWM 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. C&PWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of C&PWM’s economic, investment or other financial interests. To meet its fiduciary obligations, C&PWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, C&PWM’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 C&PWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Strategic Wealth Management Platform (SWM) SWM offers clients an asset management account that allows the IAR to direct and manage specified client assets. On the SWM platform clients pay an asset based management fee and separate transaction costs. C&PWM employs a Portfolio Analyst who is responsible for the review, analysis and due diligence of various investment vehicles. The Portfolio Analyst presents information on these investment vehicles to the C&PWM’ Investment Committee. The Investment Committee has created different models to be used by the IARs depending on the client’s investment objective. The Investment Committee meets monthly, or more frequently as needed, to review the models and determine what, if any, changes may be needed based on market conditions, performance, etc. The IARs can choose to use these models within the SWM platform; however, they still have the flexibility to deviate from the model to suit the individual client’s needs. Pension Consulting Services C&PWM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve

objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators, and broker-dealers These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Educational Seminars C&PWM offers educational seminars led by experienced financial advisors. C&PWM attends plan meetings for new employees where they can enroll into retirement plans. Advisors explain benefits and advise on investments options when asked. Advisors also attend benefit fairs/open houses where participants can stop by and receive education on their portfolios and review their performance. C&PWM do not charge separately for these seminars. Services Limited to Specific Types of Investments C&PWM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs, treasury inflation protected/inflation linked bonds, alternative assets, and private placements. C&PWM may use other securities as well to help diversify a portfolio when applicable. 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 C&PWM 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 not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. C&PWM does not participate in wrap fee programs. E. Assets Under Management C&PWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 129,919,379 $0 December 2023