Firm Description Strategic Equity Management, Inc., DBA SEM Wealth Management (“SEM”) was founded in 1992 by Richard Gage, our principal owner, an engineer experienced in the use of statistical design and optimization. Jeff Hybiak, who joined SEM in 1998, is an owner with significant experience in Finance and has earned the Chartered Financial Analyst (CFA) designation. Currently the SEM team includes engineers, finance and business professionals. SEM, with offices in Tucson, AZ and New Kent, VA, serves clients nationwide by working strategically with professional financial advisors assisting their clients achieve their financial goals. In this brochure the words “we”, “our”, “us” and “SEM” refer to Strategic Equity Management, Inc., DBA SEM Wealth Management and the words “you”, “your” and “client” refer to you as either a client or prospective client of SEM. The term Associated Person is used in this brochure, our Associated Persons are our SEM’s officers, employees and all individuals providing investment advice on behalf of SEM. In this brochure the words “mutual funds” or “funds” refer to both mutual funds or exchange traded funds (ETFs). Types of Advisory Services SEM provides investment supervisory services, also known as asset management services, on a discretionary basis. We provide three categories of investment services. TACTICAL Programs Utilize technical analysis and Daily Monitoring of market prices to implement our mechanical investment models in response to changes in global markets. These tactical models are developed using extensive computer back-testing and most often proprietary to SEM. DYNAMIC Programs Utilize economic models and Monthly Monitoring of program allocations in response to global economic indicators. When economic growth is rising these programs are invested offensively and when growth is slowing, they are invested defensively STRATEGIC Programs Utilizes a blend of Strategic and Dynamic models with QUARTERLY Monitoring. These programs often invest in Vanguard and American Funds and some are trademarked AMERIGUARD. When the investment model indicates an allocation change SEM executes the trade in our client accounts. We provide investment supervisory services by establishing accounts in your name with investment companies directly or through trust, brokerage, or insurance firms. The assets are then switched between money market, funds, stocks, and subaccounts, when our investment models indicate. In addition, SEM may propose the Client include, as part of their financial portfolio, one or more types of products that are not part of the discretionary investment advisory services provided by SEM, such as insurance products. If the Client chooses to include such a product in their financial portfolio, SEM recommends the Client work closely with their attorney, accountant, insurance agent, and other related professionals. Incorporation of the non- advisory financial product into the Client’s financial plan is entirely at the Client’s discretion. Individual Portfolio Management SEM provides advisory services tailored to the individual needs of our clients. Our clients most often are referred to us by other financial professionals, generally Registered Investment Advisors or Registered Representatives. The following explains the process that associated persons and other financial professionals utilize: 1. Initially and on an ongoing basis the financial professional will have personal communications designed to understand the client’s goals, objectives and individual situation. Specifically, the client works with the financial professional to complete our New Account Form. This form assesses our client’s investment history, time horizon, risk tolerance and liquidity needs. 2. SEM offers several investment programs, including programs managed by non-affiliated Advisories. Generally, each program targets a different risk level and includes multiple active investment strategies. The client and the financial professional then select a mix of SEM’s investment programs tailored to fit their individual needs. 3. Optionally, the client can complete a questionnaire which provides an output score. This score is an additional guide that can be used to help categorize a client’s major need, i.e. income, conservative, growth etc. Depending on the score we identify a logical allocation to our investment programs. 4. A wide range of individual portfolios can be constructed using a combination of SEM programs. Generally, each investment program requires a minimum investment of $25,000 (although this amount can be higher

or lower depending primarily on the custodian and investment program). All programs may not be available at each custodian. 5. After the program allocation is made by the client and their financial professional the account paperwork is submitted to SEM. If the program allocation seems unsuitable we will contact the financial professional and / or client for clarification. When another financial professional (Advisor) has introduced the client to SEM, it is the responsibility of the client and financial professional to select the appropriate SEM investment program, taking into consideration the objectives, risk tolerance, time horizon, and any other relevant factors. In addition the client’s entire portfolio of investments should be taken into consideration when selecting an SEM investment program. Client is responsible to report any significant changes in their financial circumstances to their advisor immediately. Advisor will then notify SEM and evaluate whether those changes necessitate a change in the investment program. When a client is referred to SEM by an Advisor it is SEM’s responsibility to manage all accounts in each program in the same fashion and to remain consistent to the structure outlined in the individual Program Reports. If SEM makes any material changes to the program SEM will notify the client and investment advisor of the changes. SEM may also suggest changes to the investment program selected based on reported changes in the client’s personal financial situation. In order to participate in our discretionary investment programs we require that you grant us discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with us or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Pursuant to a Model License Agreement with Geneos Wealth Management, a Registered Investment Advisor and wholly owned subsidiary of GWM Holdings Inc. (“GWM”), SEM provides investment advisory services on an investment model level for clients of GWM. GWM compensates SEM quarterly based on the amount of assets in SEM models on GWM’s Axiom platform. SEM participates as a third party investment adviser (“Money Manager”) on Axos Advisor Services Money Manager X-Change (“MMX”) program. SEM makes some investment programs available to non-affiliated Advisor’s (“Advisor”) to select for their clients. The non-affiliated Advisor has the sole responsibility to ensure the Money Manager investment program on the MMX Program meets the needs of, and is suitable for, Clients and Accounts. The Advisor also is and shall remain responsible for all investment activity made by the Money Manager including, without limitation, fiduciary obligations, suitability determinations, disclosure to Clients regarding Money Manager and participation in the MMX Program, and supervision and monitoring of trading and activities by Money Manager. Money Manager bills Advisor directly fees owed to it by Advisor. Advisor shall either pay Money Manager directly or direct that Axos move money from designated Accounts to Money Manager’s fee account. SEM provides some model portfolios on the Orion Portfolio Solutions (“OPS”) platform. SEM’s activities are limited to model portfolio asset allocation changes and does not interact directly with the Client whose assets are invested on the OPS platform. OPS pays SEM monthly based on the assets under management in SEM model portfolios. SEM provides some model portfolios on Centaurus Financial, Inc. (“CFI”) Wealth Management Flex UMA platform. Investment Advisor Representatives (IAR’s) affiliated with CFI select various model portfolios on the Flex UMA platform for their Clients. CFI provides education and compliance for their IAR’s who together are responsible for fiduciary, disclosure and suitability determinations for model portfolios for Flex UMA Clients. CFI via their Overlay Manager Adhesion Wealth Advisor Solutions, Inc. compensates SEM quarterly based on the amount of assets in SEM model portfolios on CFI’s Flex UMA platform. Assets under Management As of January 31, 2024, SEM manages approximately $403,100,000 in assets on a discretionary basis and $181,000,000 assets on a non- discretionary basis.