Item 5 Additional Compensation ............................................................................................................................ 17 Item 6 Supervision ........................................................................................................................................................ 17 Firm Description Paladin Wealth, LLC dba Paladin Financial (“PW”) was founded in 2017. Jeffrey Foley is majority owner and Managing Member. PW is a fee based financial planning and investment management firm. PW does not act as a custodian of client assets. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the client on an as-needed basis and may charge fees of their own. Conflicts of interest will be disclosed to the client in the event they should occur. Types of Advisory Services ASSET MANAGEMENT CO-ADVISOR PW has entered into a Co-Advisor relationship with Gradient Investments, LLC (GI). PW will provide information to each client regarding the services offered by GI as the portfolio manager. PW will assist the Client to determine the appropriate model selection based on the Client’s investment objectives and risk tolerance. PW will have full discretion on an ongoing basis to select suitable models to maintain client’s risk tolerance. PW will share in the management fees charged by GI as described in Item 5 of this brochure. CLIENT DIRECTED ACCOUNTS PW will assist in the opening, closing and transferring of accounts. PW will not have discretion at any time on these accounts. The Client is responsible for the assets held within the accounts and their values which could increase or decrease (potential loss of principal). PW will not execute trades in client directed accounts unless direction is initiated by the Client. PW will not provide performance reporting on these accounts and can furnish third party analysis reports per the client’s request. Similar services may be available through other sources for a lower fee. ERISA PLAN SERVICES PW provides services to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. PW will act as a 3(21) advisor: Limited Scope ERISA 3(21) Fiduciary. PW typically acts as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor, PW has a fiduciary duty to act in the best interest of the client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using PW can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: ➢ Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. ➢ Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt

and amend the IPS. ➢ Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. 2. Non-fiduciary Services are: ➢ Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Advisor’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Advisor is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. ➢ Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. ➢ Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. ➢ Meet with Client on a periodic basis to discuss the reports and the investment recommendations. PW may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between PW and Client. 3. PW has no responsibility to provide services related to the following types of assets (“Excluded Assets”): 1. Employer securities; 2. Real estate (except for real estate funds or publicly traded REITs); 3. Stock brokerage accounts or mutual fund windows; 4. Participant loans; 5. Non-publicly traded partnership interests; 6. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or 7. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in the calculation of Fees paid to Advisor under this Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, the client will compensate PW on an hourly fee basis or fixed fee basis described in detail under the “Fees and Compensation” section of this brochure. Services include but are not limited to a thorough review of all applicable topics including Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance. If a conflict of interest exists between the interests of the investment advisor and the interests of the client, the client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through PW. Financial plans will be completed and delivered inside of ninety (90) days. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Wrap Fee Programs PW does not sponsor any wrap fee programs. Client Assets Under Management Discretionary AUM: Non-Discretionary AUM: Date Calculated: $113,046,086 $0 December 31, 2023