Item 5 Additional Compensation ............................................................................................................................ 18 Item 6 Supervision ........................................................................................................................................................ 18 Firm Description Paladin Capital, LLC (“PC”) was founded in 2017. Jeffrey Foley is majority owner and Managing Member. PC is a fee based financial planning and investment management firm. PC 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 PC has entered into a Co-Advisor relationship with Gradient Investments, LLC (GI). PC will provide information to each client regarding the services offered by GI as the portfolio manager. PC will assist the Client to determine the appropriate model selection based on the Client’s investment objectives and risk tolerance. PC will have full discretion on an ongoing basis to select suitable models to maintain client’s risk tolerance. PC will share in the management fees charged by GI as described in Item 5 of this brochure. CLIENT DIRECTED ACCOUNTS PC will assist in the opening, closing and transferring of accounts. PC 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). PC will not execute trades in client directed accounts unless direction is initiated by the Client. PC 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 PC 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. PC will act as a 3(21) advisor: Limited Scope ERISA 3(21) Fiduciary. PC 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, PC 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 PC 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. PC may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between PC and Client. 3. PC 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 PC 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 PC. Financial plans will be completed and delivered inside of ninety (90) days. REFERRAL ARRANGEMENT – (Legacy Clients Only) When deemed appropriate for the client, we may recommend that clients utilize the services of a Third Party Manager (“TPM”) to manage a portion of, or your entire portfolio. All TPMs that we recommend must either be registered as investment advisers with the Securities and Exchange Commission or with the appropriate state authority(ies). After gathering information about your financial situation and objectives, an Associated Person of our firm will make recommendations regarding the suitability of a TPM or investment style based on, but not limited to, your financial needs, investment goals, tolerance for risk, and investment objectives. Upon selection of a TPM(s), we will monitor the performance of the TPM(s) to ensure their performance and investment style remains aligned with your investment goals and objectives. In such circumstances, we receive referral fees from the TPM. We act as the liaison between the client and the TPM in return for an ongoing portion of the advisory fees charged by the TPM. We help the client complete the necessary paperwork of the TPM, provide ongoing services to the client, will provide the TPM with any changes in client status as provided to us by the client and review the quarterly statements provided by the TPM. We will deliver the Form ADV Part 2, Privacy Notice and the Disclosure Statement of the TPM. Clients placed with TPMs will be billed in accordance with the TPM’s Fee Schedule which will be disclosed to the client prior to signing an agreement. This is detailed in Item 10 of this brochure. 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 PC does not sponsor any wrap fee programs. Client Assets Under Management Discretionary AUM: Non-Discretionary AUM: Date Calculated: $2,975,271 $0 December 31, 2023