A – Spectrum Financial, Inc. (a sub-s corporation) was formed in 1986 and registered with the SEC in 1988. The majority interest in the firm is held by Ralph J. Doudera who serves as CEO. The primary objective of Spectrum Financial, Inc. (Spectrum Financial) is to achieve consistent rates of return that are in excess of a buy/hold strategy over a complete market cycle and provide liquidity by preserving the purchasing power of the assets under management. Strategies designed and implemented strive to avoid declining markets and strive to participate in rising markets. B – Spectrum offers three types of services (Programs): SecurityMaxx℠, AssetMaxx℠, and WealthMaxx℠ (currently inactive). These services all provide the same underlying philosophies Spectrum strives to provide its clients. The description of these services and related information is outlined below: SecurityMaxx℠ (Separately Managed Accounts) This program aids clients in effecting buy/sell transactions between defensive (money market) funds and aggressive (bond or stock) funds in the same mutual fund family, variable life or annuity contract, or custodian/platform. Exchanges may result in short-term capital gains or losses and dividends may vary depending on investment strategies. Large quick profits are not the primary goal of these investment strategies 3rd Party Custodians: Certain strategies of Spectrum Financial may only be offered through specific custodians. Spectrum Financial has arrangements with third party custodians that allow Spectrum Financial to choose between several fund families on a non-commission basis. Spectrum Financial has discretion over the fund(s) purchased or sold without obtaining the consent of the client and may also recommend the sale or redemption of fund shares other than for exchange, if, in its opinion, the fund shares are not conducive to management. Statements usually are generated from the custodian monthly but will not be generated less than quarterly. There may be transaction charges involved when purchasing or selling funds as well as other custodial fees payable to the third-party custodian. Spectrum Financial does not participate in these fees. Contract Processing: A client should understand that Spectrum Financial might require 2-4 weeks to establish an account, i.e., review the documents for proper form, setup computer records, and implement other procedural tasks. Delays may occur due to an improper account number, spelling of name or other matters. If a signal is generated during the initial processing, a client may or may not be moved into the signaled position and thus possible losses may occur during this period for which Spectrum Financial assumes no responsibility in the implementation of these initial trades. After the initial set up period, Spectrum Financial attempts to process all trade orders within 24-hours of generating a buy/sell signal. If a Spectrum Financial administrative error occurs, and it is not corrected within the 24-hour period, Spectrum Financial will evaluate the error as follows: 1. Accounts with actual losses above 25 basis points, a credit will be applied to future management fees. 2. Accounts with lost opportunity above 25 basis points, a credit will be applied in the amount of an annualized rate of 6% of the account value and will be based on the number of days the error was not corrected outside the 24-hour period. 3. Accounts that benefit from the error will not be adjusted. If a client cancels all management, the offset of fees would be negotiated.

If resolution is not obtained, the arbitration clause in the contract would apply. Delays could occur due to circumstances beyond Spectrum Financial’s control, such as restrictions imposed by funds or custodians, natural disasters, internet interruptions, etc. In such event, Spectrum Financial assumes no responsibility for any possible losses. Spectrum Financial will not honor any request to move an account contrary to its current recommended signal position unless the client terminates the contract and provides specific instructions to Spectrum Financial. The client agrees not to cause or permit any exchange to be made in the account that is inconsistent with a recommendation of Spectrum Financial. Any acts inconsistent with the foregoing shall relieve Spectrum Financial of any liability. Clients should carefully review the prospectus for possible fund restrictions on exchanges, as Spectrum Financial will not be responsible for losses resulting from any such restriction. AssetMaxx℠ (Allocation Program using actively managed mutual funds) In this program, Spectrum Financial builds client’s portfolios using actively managed mutual funds. The active management is done internally within the funds giving the client the benefits of a managed risk investment philosophy. Spectrum Financial will aid the client in determining a portfolio mix of these mutual funds based on their client profile. The client’s mix of mutual funds is designed and intended to be held long-term with periodic rebalancing among the client’s holdings. Annual reporting of the assets held and ongoing servicing for the account will be provided under this service. This service is entered in to by a Letter of Engagement (LOE). Funds available under this program are sub-advised by both the applicant Spectrum Financial and an SEC affiliated adviser Hundredfold Advisors LLC (owned by Simply Distribute Foundation). WealthMaxx℠ (currently inactive) In this service, Spectrum Financial creates a portfolio of alternative investments for qualified or accredited investors only. The investor must provide information which will then verify what type of investor they will be classified. The service includes alternative investment research, client risk analysis and annual performance reviews but primarily provides a liaison service between the investor and individual alternative investments. This will give the client consolidated information for their portfolio on a quarterly basis. Recommended alternative investments will likely invest in a wide range of investment vehicles and strategies, which may involve a high level of risks. Spectrum Financial will provide an annual review to determine if the portfolio is in line with the client’s objectives. Recommendation for changes in allocation may be made by Spectrum Financial; however, the client must provide written consent to implement changes. Spectrum Financial or its officers or directors do not manage the alternative investments used in building the clients portfolio. Clients are encouraged to understand the risks involved in alternative investment investing. C- The strategies utilized are based on the client’s objectives and risk tolerance. Both SecurityMaxx℠ and AssetMaxx℠ programs are used to diversify a client’s portfolio if necessary. There is no provision for clients to restrict funds used by either program. D-N/A: Spectrum Financial does not participate in wrap fee programs. E-Assets under management FYE 12-31-2023 Discretionary Amount $292,322,759 Discretionary Accounts 243