Firm Description Sundvold Capital Management LLC, (Sundvold Financial) was founded in 1997 as a fee-only financial planning and investment advisory firm. Sundvold Financial provides personalized confidential financial planning and investment management to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, insurance review, investment management, education funding, retirement planning and estate planning. Sundvold Financial believes that objectivity is the single most important quality a consulting firm can bring to the client, so we have structured our firm to minimize potential "conflicts of interest". It is for this reason we do not accept soft dollar payments of any form, we do not sell proprietary products and we do not accept payment from money managers. Sundvold Financial also operates as an independent insurance agent representing numerous companies. We may offer health and life insurance from these companies and receive commissions as a result of such purchases. A conflict of interest may exist when the representative of Sundvold Financial recommends that a client purchase an insurance product that results in compensations being paid to them as an independent insurance agent. Clients are free to purchase insurance from other firms, if they deem that in their best interest. Our practice begins and ends with the needs of the client. It is process driven. Solutions can be developed only after appropriate data (both quantitative and qualitative) have been gathered and evaluated. Related issues should be identified and clients should be directed to other appropriate professionals for resolution. Implementation, continuous monitoring, and as necessary, modification are an integral part of the process. A written evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. Sundvold Financial also provides investment advice to participants in defined- contribution retirement plans (i.e., 401(k) and 403(b) whose employers (i.e. plan sponsors) have contracted with Sundvold to provide such services, or in the case where Sundvold has been appointed as an ERISA 3(38) investment fiduciary by a named ERISA 3(21) fiduciary. Principal Owners Jon Sundvold is principal owner. Types of Advisory Services Sundvold Financial provides investment supervisory services, also known as asset management services, manages investment advisory accounts not involving investment supervisory services and furnishes investment advice through consultations. Sundvold Financial also furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues and trust services that often include estate planning. As of December 31,2023, Sundvold Financial manages approximately $_482,000,000 in assets under advisement with $209,000,000 being regulatory assets recognized by the Securities Exchange Commission. 100% of assets under management are managed on a non-discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without client consent. Types of Agreements The following agreements define the typical client relationships. Financial Planning Agreement A financial plan is generally designed to help the client with all aspects of financial planning without ongoing investment management after the financial plan is completed. At Sundvold Financial the focus is on the implementation of that plan and the ongoing accountability we expect from our clients pertaining to the financial plan. The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations,

debt management and reduction planning, savings strategies and direction. Detailed investment advice and specific recommendations are provided as part of a financial plan. The fee for a financial plan is predicated upon the facts known at the start of the engagement. The minimum fee is $1,500. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. In the event that the client’s situation is substantially different than disclosed, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. Advisory Service Agreement Most clients choose to have Sundvold Financial manage their assets in order to obtain ongoing in-depth advice and life planning. All aspects of the client’s financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the start of the relationship. An Advisory Service Agreement can include: cash flow management; insurance review; investment management (including performance reporting); education planning; retirement planning and estate planning, as well as the implementation of recommendations within each area. The annual Advisory Service Agreement fee is based on a percentage of the investable assets according to the following schedule: 1.00% on the first $1 million 0.80% on the next $4 million; 0.60% on the next $5 million: 0.40% on the next $10 million; and 0.30% above $20 million. Current client relationships may exist where the fees are higher or lower than the fee schedule above. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client, or the investment manager, may terminate an Agreement by written notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination. Retainer Agreement When it is more appropriate to work on a fixed-fee basis, a Retainer Agreement is executed in lieu of an Advisory Service Agreement. The minimum annual fee for a Retainer Agreement is $ 1,500. Investment Management Agreement An Investment Management Agreement may be executed when financial planning is not provided as part of the relationship. The minimum annual fee for an Investment Management Agreement is $1,500. Hourly Planning Engagements Sundvold Financial provides hourly planning services for clients who need advice on a limited scope of work. The minimum hourly rate for limited scope engagements is $200. Asset Management Assets are invested primarily with institutional money managers, from Sundvold Financial research, and in no-load and exchange-traded funds. This is done through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds. Stocks and bonds may be purchased or sold through a discount brokerage account when appropriate. The discount brokerage firm charges a transaction fee for stock and bond trades. Sundvold Financial does not receive compensation, in any form, from fund companies or brokerages. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, futures contracts, and interests in partnerships. Initial public offerings (IPOs) are not available through Sundvold Financial. Termination of Agreement A Client may terminate any of the aforementioned agreements, at any time, by notifying Sundvold Financial in writing. The client will pay the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Sundvold Financial will refund any unearned portion of the advance payment. Sundvold Financial may terminate any of the aforementioned agreements, at any time, by notifying the client in writing. If the client made an advance payment, Sundvold Financial will refund any unearned portion of the advance payment.