General Information Vista Investment Partners II, LLC d/b/a Vista Investment Partners was formed in 2017 and provides financial planning and portfolio management services to its clients. Brett D. Guiley is the principal owner of Vista. At the outset of each client relationship, Vista spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, Vista generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments Vista will make on behalf of the client in order to meet those goals. The Financial Profile and the Investment Plan are discussed regularly with each client but are not necessarily written documents. Portfolio Management As described above, at the beginning of a client relationship, Vista meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Vista based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, Vista will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, Vista will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on Vista in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Vista. Separate Account Managers Vista may utilize one or more Separate Account

Managers (each a “Manager”), when appropriate and in accordance with the Investment Plan for a client. Having access to various Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. Vista will usually select the Manager(s) it deems most appropriate for the client. Factors that Vista considers in recommending/selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. The Manager(s) will generally be granted discretionary trading authority to provide investment advisory services for the portfolio. Pursuant to the Manager(s)’ investment authority, the Manager(s) may select one or more of Vista’s investment strategies described in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss in varying combinations over time for a given client, depending upon the client’s individual circumstances. Under certain circumstances, Vista retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent. In other cases, the client will ultimately select one or more Managers recommended by Vista. In any case, with respect to assets managed by a Manager, Vista’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio. Financial Planning Vista also offers financial planning services, as described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning may include advice that addresses one or more areas of a client’s financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client’s particular situation and the client’s specific needs, financial planning may include some or all of the following:
• Gathering factual information concerning the client’s personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client’s present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Estate planning strategies;
• Assessing risk and reviewing basic health, life, and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have Vista implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by Vista under a financial planning engagement and/or engage the services of any recommended professional. Type and Value of Assets Currently Managed As of September 15, 2023, Vista managed $0 on a discretionary basis and $0 on a non-discretionary basis.