A. Description of the Advisory Firm APS Management Group, Inc. dba Advanced Portfolio Strategies and Advanced Portfolio Strategies Insurance & Financial Services (hereinafter “AMGI”) is a Corporation organized in the state of California. The principal owners are Daniel Roy Bennett, Glen Alan Michel and Daniel Mason Hart. The firm was formed in 2014 and became licensed as an investment adviser in 2016. AMGI is also a licensed insurance agency. B. Types of Advisory Services Portfolio Management Services AMGI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AMGI 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 AMGI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AMGI will request 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. AMGI may also direct clients to third-party investment advisers. Before selecting other advisers for clients, AMGI will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where AMGI is recommending the adviser to clients. AMGI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AMGI’s economic, investment or other financial interests. To meet its fiduciary obligations, AMGI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, AMGI’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 AMGI’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. AMGI may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, AMGI will always ensure those other advisers are properly licensed or registered as an investment adviser. AMGI then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third-party adviser on behalf of AMGI's client. AMGI may also allocate among one or more private equity funds or private equity fund advisers. AMGI will not review the ongoing performance of the third-party adviser as a portion of the client's portfolio. AMGI has entered into a relationship with UPTIQ, an unaffiliated internet-base lending platform providing a large network of lenders who can assist AMGI’s clients with a variety of different types of personal and business loans (i.e., mortgage, home equity, auto, commercial, working capital, etc.). UPTIQ’s platform seeks to match the client with those lenders who can best fulfill the client’s borrowing needs. Once matched with a lender, UPTIQ’s platform serves to help facilitate the loan application and fulfillment process. UPTIQ is compensated only by the lender. Please Note: No portion of any loan proceeds will be knowingly accepted by AMGI for investment purposes. No Obligation:

No client is under any obligation whatsoever to utilize UPTIQ’s services. There can be no assurance that the lending terms obtained via the UPTIQ platform will be more favorable than those available from non-platform lenders. The client remains free to consider/evaluate/utilize other lenders and platforms, and, to the extent reasonably requested, the AMGI shall remain available to help assist the client with such evaluation process. Recourse: It shall remain the client’s exclusive obligation to repay the loan. The lender shall have recourse against the client in the event that the client fails to meet repayment obligations, including, depending upon the type of loan, recourse to the client’s personal or business property, or investment accounts. Licensing/Registration: Neither UPTIQ, nor AMGI, serves as a lender. Neither UPTIQ, nor AMGI, is registered or licensed as a lender or lending broker with any state or federal regulatory agency or authority. AMGI does not provide any services on behalf of UPTIQ. Acknowledgment: In the event that a client desires to utilize the UPTIQ platform, the client will receive a separate Acknowledgement from AMGI for review and execution. Pension Consulting Services AMGI offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. 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. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Services Limited to Specific Types of Investments AMGI generally limits its investment advice to mutual funds, real estate, fixed income securities, insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. AMGI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions AMGI 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 AMGI on behalf of the client. AMGI may use “model portfolios” 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 AMGI from properly servicing the client account, or if the restrictions would require AMGI to deviate from its standard suite of services, AMGI reserves the right to end the relationship. AMGI will segment various types of advisory services and planning strategies (i.e. retirement, estate planning) that will be determined based upon thorough fact-finding and needs based analysis. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. AMGI does not participate in any wrap fee programs. E. Assets Under Management AMGI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 112,768,941 $ 14,976,381 December 2023