A. Description of the Advisory Firm Kinetic Wealth Investment Advisors, LLC (hereinafter “KWIA”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in October 2020, and the principal owner is Richard M. Packer. B. Types of Advisory Services Portfolio Management Services KWIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KWIA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) 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, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring KWIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KWIA will require 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. KWIA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KWIA’s economic, investment or other financial interests. To meet its fiduciary obligations, KWIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KWIA’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 KWIA’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. Small Market Solutions (SMS) Program KWIA may direct clients to the Small Market Solutions Program offered by LPL Financial, LLC. Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus. The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. In addition to the services described above, Plan Sponsor may also select from a number of consulting services available under SMS that are provided by KWIA. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting

services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets. Financial Planning Financial plans and financial planning may include, but are not limited to: retirement planning, education planning, estate planning, cash flow/budget planning, risk management planning, personal wealth planning, tax planning, business planning, investment planning/asset allocation, or such other financial planning or consulting services. The scope of services is determined between KWIA and client and will be outlined in the client financial planning agreement. Consulting Services KWIA provides consulting services to registered investment advisers concerning investment strategies and counseling on financial planning advice to clients of those investment advisers. Our consulting services will be limited to investment strategies involving mutual funds, ETFs and insurance products, when appropriate. Services Limited to Specific Types of Investments KWIA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs and non-U.S. securities, although KWIA primarily recommends U.S. stocks, ETFs, and mutual funds. KWIA 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 KWIA 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 KWIA on behalf of the client. KWIA 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 KWIA from properly servicing the client account, or if the restrictions would require KWIA to deviate from its standard suite of services, KWIA 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. KWIA does not participate in wrap fee programs. E. Assets Under Management KWIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $124,045,477 $0 November 2023