A. Description of the Advisory Firm Delta Wealth Advisors, LLC (hereinafter “Delta Wealth Advisors”) is a Partnership organized in the State of Indiana. The firm was formed in October 2017, and the principal owners are Dino Nikolas Efthimiou and Nicholas Gerald Christ Finnigan. B. Types of Advisory Services Investment Advisory Services Delta Wealth Advisors offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Delta Wealth Advisors 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. Investment advisory services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Delta Wealth Advisors evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Delta Wealth Advisors 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. Delta Wealth Advisors seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Delta Wealth Advisors’ economic, investment or other financial interests. To meet its fiduciary obligations, Delta Wealth Advisors attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Delta Wealth Advisors’ 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 Delta Wealth Advisors’ policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Investment advisory services offered by Delta Wealth Advisors are available to clients in the AUM Model and Net Worth Model. These services are specifically tailored to meet the needs of each client. Prior to delivering investment advisory services, the Adviser will ascertain each client’s specific investment objective. Then Delta Wealth Advisors will allocate or recommend that the client allocate their investment assets consistent with the designated investment objective. Clients may impose reasonable restrictions on any of the Adviser’s investment advisory services at any time, but restrictions must be delivered to the Adviser. More specifically, Delta Wealth Advisors will assist Clients in determining the appropriate allocation of the Clients’ invested assets among different asset classes. In addition, the Adviser also provides active trading models to Clients consisting mostly of stocks and ETFs. Clients in the Adviser’s active trading model must authorize the Adviser to exercise discretionary trading authority over the assets dedicated to the client’s recommended investment strategy, which includes the initial allocation and ongoing rebalancing. The discretionary authority allows Delta Wealth Advisors to buy, sell or otherwise trade the assets in the client’s account without prior approval of each transaction. Financial Planning Services Delta Wealth Advisors includes financial planning services to clients participating in their Net Worth Model at no additional cost or obligation. Delta Wealth Advisors begins with an intensive fact-finding session which helps the Adviser become totally familiar with the client’s current financial situation (including among other things, income taxes, investments, insurance, estate affairs and family circumstances), as well as their personal goals and priorities for the next several years. Then, working from this comprehensive information, the Adviser prepares a detailed financial plan which documents the client’s situation, identifies all areas which will be impacted, and makes specific goal-oriented recommendations. The Adviser’s specific goal-oriented recommendations are designed to educate and allow a client to coordinate his/her financial affairs more efficiently, increase cash flow, prudently reduce income taxes, and attempt to improve his/her overall net worth. Once this written document has been discussed with the client, the recommendations that the client feels comfortable with are scheduled for implementation with specific deadlines to be met. Delta Wealth Advisors continues to assist the client based on a quarterly review of services in all applicable areas of financial planning including estate, retirement, cash flow and tax planning. Please Note: * It is always the client’s responsibility to promptly notify Delta Wealth Advisors if there is any change in their financial situation or investment objective. This notification of change allows the Adviser an opportunity to review, evaluate, or revise our previous recommendations or services. * Financial Planning is not available in the AUM Model. Service Models Delta Wealth Advisors offers two service models for their clients to best meet their individual needs. AUM Model The AUM model is a traditional investment management where the Adviser bases its annual investment management fee for managed discretionary assets upon a percentage (%) of the market value

of the assets and the specific types of investment management services provided. In this model clients receive an individually tailored plan addressing the following: Client Goals Risk Tolerance Personal Tax Situation Horizon Liquidity Net Worth Model The Net Worth Model is a full spectrum of financial planning, asset management and tax services to align assets to goals with tax efficiency. In this model client’s receive an individually tailored plan addressing the following: Client Goals Life Insurance Review Personal Tax Situation Long Term Care Insurance Review Liquidity Umbrella Liability Insurance Review Risk Tolerance Property & Casualty Insurance Review Time Horizon Health Insurance Review Business Successions Corporate Retirement Plan Guidance Trust Services Annuities Personal Financial Statement Identity Theft Prevention Planning Income Tax Planning Asset Protection Planning Budgeting and Cash Management Charitable Intent Evaluation Retirement Funding Charitable Giving Strategies Education Planning Debt Management Social Security Planning Employee Benefit Planning Wealth transfer preferences Estate Documentation Review Asset Titling Confirmation Beneficiary Designation Planning End of Life Planning Disability Insurance Review 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 1 of the Employee Retirement Income Act (ERISA) and 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 out 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 a level fee that is reasonable for our services; and
• Give you basic information about conflicts of interest. Private Alternative Investments and Other Types of Investments Offered to Clients From time-to-time Delta Wealth Advisors may offer net-worth clients that meet the definition of “accredited investors” opportunities that may include private investments, unsecured promissory notes, private equity funds, private business, venture capital and/ or private equity fund advisers. Delta Wealth Advisors does not receive a fee from the issuers of these offerings when clients enter into these investment deals. Delta Wealth does not charge origination, acquisition, monitoring or disposition fees on these Private Alternative Investments. Delta Wealth’s standard net worth advisory fee does apply to these investments. Delta Wealth does not charge an additional investment management fee for these private investment opportunities. Delta Wealth works to follow industry best practices in vetting Private Alternative Investment opportunities. Standard vetting techniques include review of Operating Memorandum, Private Placement Memorandum, and other available documents. Delta Wealth is responsible for reviewing and regularly communicating with General Partner, portfolio company and investment partners on private investment opportunities. For example, Delta Wealth regularly attends quarterly calls, summarizes key findings, and distributes updates to clients invested in the deal. Services Limited to Specific Types of Investments Delta Wealth Advisors generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds, private equity and private placements, although Delta Wealth Advisors primarily recommends ETF. Delta Wealth Advisors may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Delta Wealth Advisors will tailor a program for each individual client through its use of model portfolios. 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 Delta Wealth Advisors on behalf of the client. Delta Wealth Advisors 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 reasonable restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Delta Wealth Advisors from properly servicing the client account, or if the restrictions would require Delta Wealth Advisors to deviate from its standard suite of services, Delta Wealth Advisors 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, transaction costs, and certain other administrative fees. Delta Wealth Advisors does not participate in wrap fee programs. E. Assets Under Management Delta Wealth Advisors has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $101,050,662 $ 1,128,845 December 2023