A. Description of the Advisory Firm DeLarme Wealth Management, Inc (hereinafter “DWM”) is a Corporation organized in the State of California. The firm was formed in May 2016, and the principal owner is Jeffrey “Jeff” DeLarme. B. Types of Advisory Services Portfolio Management Services DWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DWM creates an Investment Policy Statement for each client and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to investment strategy, asset allocation, risk tolerance, asset selection, and regular portfolio monitoring. DWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DWM will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are typically documented in the Investment Policy Statement, which is given to each client. DWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of DWM’s economic, investment or other financial interests. To meet its fiduciary obligations, DWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, DWM’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 DWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Generally, limited financial planning will be provided as part of the portfolio management services at no additional cost. Selection of Other Adviser DWM has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, DWM will always ensure those other advisers are properly licensed or registered as an investment adviser. DWM conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. DWM then makes investments with a third-party investment adviser by investing with the third-party adviser. DWM will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Pension Consulting Services Fiduciary Services DWM may serve as a 3(21) non-discretionary investment advisor to pension or other employee benefit plans (including but not limited to 401(k) plans). These services may include, but is not limited to: • identifying investment objectives and restrictions
• recommend establishing and revising the plan’s investment policy statement
• recommend and monitor the investments
• recommend creating and maintain model asset allocation portfolios (“model portfolios”)
• recommend and monitor qualified default investment alternatives (“QDIAs”)
• recommend and monitor investment managers (third party asset managers)
• provide participant advice • 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 These services are generally based on the goals, objectives, demographics, time horizon, and/or risk

tolerance of the plan and its participants. In some instances, DWM may serve as a 3(38) discretionary investment manager to retirement plan accounts including, but not limited to pension plans, 401k plans, profit sharing, and other benefit plans. In this capacity, DWM may provide the following services:
• select and monitor the plan’s investments
• create and maintain model asset allocation portfolios “model portfolios”
• manage qualified default investment alternatives (“QDIAs”) Non-Fiduciary Services DWM may also provide the following non-fiduciary services:
• plan governance and committee education
• assist client with selecting and reviewing other service providers
• employee/participant investment education and communication
• consulting services to assist with plan design (settlor) decisions 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. Clients are under no obligation to act on our advice. Services Limited to Specific Types of Investments DWM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non- U.S. securities, venture capital funds and private placements, although DWM primarily recommends exchange traded funds. DWM 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 DWM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by DWM on behalf of the client. DWM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent DWM from properly servicing the client account, or if the restrictions would require DWM to deviate from its standard suite of services, DWM reserves the right to end the relationship. 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. DWM does not participate in wrap fee programs. E. Assets Under Management DWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 143,770,162.00 $ 12,783,475.00 February 2024