A. VIA (“VIA”) is an SEC-registered investment advisor under the “Multi-State” registration category as stated in the ADV Part 1A Item 2A(10). VIA has been in the investment advisory business since September 2000. Mr. Howard Rothman and Boshnack Family LLC are principal owners controlling 25% or more of the entity and are listed in the ADV Part 1A Schedule A. the principal owners are not a publicly held companies and their ownership is not through subsidiaries. B. VIA provides general investment advisory services for clients on a discretionary and non- discretionary basis. VIA may recommend a third-party investment advisor to manage all or a portion of a client's account or an independent Commodity Trading Advisor ("CTA") to manage all or a portion of a client's account in managed futures. Individual accounts are managed directly by a specifically named VIA investment advisor. Investment advice is not limited and includes many different types of investments. C. Accounts managed by a VIA Investment Advisor Representative (“IAR”) are tailored to meet the needs of the client by determining those needs through ongoing discussions regarding risk tolerance, investment goals, personal economic facts, personal demographic facts, and other personal preferences of the client. The accounts are managed based on the following clients’ stated investment objectives: (1) preservation of capital, (2) income, (3) capital appreciation, and (4) speculation. Client accounts may be managed independently by an IAR, invested on one of VIA proprietary “portfolios” as described below or invested in a combination of disciplines. IARs may recommend another investment advisor or a commodity trading advisor to manage all or a portion of the assets in the accounts. Clients are also free to impose reasonable restrictions upon investing in certain securities or types of securities. D. VIA no longer offers wrap fee programs but the program is maintained for existing accounts. Information regarding the wrap fee program is described in a separate ADV Part 2A Wrap Fee Program document. As of December 31, 2023, there are 2 4 legacy wrap fee accounts with $21,013,508.33 in assets under management. VIA receives a portion of the wrap fee for its services. E. As of December 31, 2023, VIA has total assets of $106,360,014.27 in total assets under management. Discretionary assets total $103,697,743.79 and non-discretionary assets total $2,662,270.48. Investment Portfolios - Non-Wrap Fee Programs VIA provides discretionary advisory services on a non-wrap fee basis in the Equity, Balanced, Dividend, Fixed Income and Total Portfolios as well as the Stock Put Writing Program and the Stock Put Credit- Spread Option Program to individuals and institutional investors. These investment methodologies have been developed by Mr. Howard Rothman, VIA’s Chief Executive Officer. Mr. Rothman makes the ultimate investment selections and recommendations and monitors each client account that receives discretionary investment advice. A VIA client may establish an account in one or more of VIA’s investment portfolios, each of which consists of accounts with similar investment objectives, portfolio construction, market exposure and risk tolerance. Each client's portfolio is managed specifically for that client based upon the client's individual goals, objectives, restrictions and current market conditions. A client may request, subject to VIA’s approval, to place limited and reasonable restrictions on the specific securities or types of securities that are purchased for their account. VIA may also provide discretionary advisory services not based on any of the portfolios described below. For trade implementation, each VIA client opens a brokerage account with either Vision Financial Markets, LLC (“VFM”), or a third-party brokerage firm. All trades are executed in that brokerage account and client assets are held in custody with that brokerage firm’s custodian. VIA does not execute trades or custody assets. VFM is a affiliated company under common ownership and control with VIA. The Equity Portfolio (The E-Portfolio) VIA’s principal objective in its Equity Portfolio is to seek returns from a diversified group of large cap U.S. traded equities that it believes have the potential to outperform the S&P 500 Index over time. The Equity Portfolio is primarily composed of a diversified portfolio of large-cap stocks that currently exhibit a high degree of financial strength and potential for growth. The total amount of diversification is a function of the total amount of the individual client's funds invested in the E-Portfolio. An account with a smaller amount invested generally will incorporate fewer stocks and therefore be less diversified. VIA’s research efforts focus on identifying companies that have sustainable gross revenue (“topline”) and earnings or net income (“bottom-line”) growth, competitive advantages and strong returns on equity. VIA selects and purchases stocks based upon its research and evaluation of a given company. During this process, the advisor will review a given company's past revenue and earnings growth, current cash flow status, debt factors, financial ratios such as the price-earnings ratio ("PE") and additional ratios and factors we deem to be relevant. Securities in the Equity Portfolio may represent several sectors of the economy but generally will not be concentrated in any one sector or constitute more than 15% in any one issuer. Securities are sold when VIA deems that the ownership of that company is no longer attractive, or to replace that security with another security that is more attractive. Considerations to sell a security may include deceleration in sales or earnings growth or expected future growth, a high stock price based on PE ratio or key management changes, among other factors. VIA also believes that it makes sound economic sense to employ, from time to time, a strategy of writing covered call positions against some or all of the stocks in the Equity Portfolio. The primary purpose of option writing is to earn additional income through premiums received from the buyers of the call options. By monitoring the volatility, delta and time to expiration, VIA works to optimize the tradeoff between receiving option premium income and the possibility of forgoing future price appreciation on the underlying stock above the written strike price of the option until the option expires. At the same time, the account receives a small measure of downside protection to the extent of the net option premium received should the price of the stock decline. By adding a covered call position to an existing long stock position, VIA will attempt to enhance the potential overall return in the portfolio. The goal of a covered call position is for the short option value to decay over time and allow the account holder to realize a gain up to the total net option premium received should the option position expire worthless. In order to calculate the gain or loss on the overall covered call position, VIA will measure the profit or loss realized during the period the covered call option position was open against the profit and loss of the open securities position during the same time period. In addition to covered calls, VIA may, from time to time purchase out-of-the-money put options to further add to the level of downside protection. The ratio of purchased put options may be less than the number of long shares of stock in the account. This strategy of employing puts to help protect the stocks; value in an account is likely to temper total returns (due to the premium paid to purchase the put options) but does provide some downside protection against declines in the value of the underlying stocks in the account. The Balanced Portfolio (The B-Portfolio) The principal objective of the Balanced Portfolio is to provide income and capital gains from a combination of stocks (common and preferred), bonds, notes, cash, cash equivalents and option premium income. The equity portion of the Balanced Portfolio is managed using the methods employed to manage the Equity Portfolio accounts. Within the fixed income portion, securities are evaluated and selected based upon VIA’s interest rate assumptions, the U.S. Treasury yield curve, credit risk and a number of macroeconomic variables that may affect the relative performance of the specific bonds. Fixed income holdings can include preferred stocks, municipal bonds, corporate bonds, U.S. Government agency debt securities and other debt instruments. VIA also believes that it makes sound economic sense to employ, from time to time, a strategy of writing covered call positions against some or all of the stocks in the Balanced Portfolio. The primary purpose of option writing is to earn additional income through premiums received from the buyers of the call options. By monitoring the volatility, delta and time to expiration, VIA seeks to optimize the tradeoff between receiving option premium income and the possibility of forgoing future price appreciation on the underlying stock above the written strike price of the option, until the option expires. At the same time, the investor receives a small measure of downside protection, to the extent of the net option premium received, should the price of the stock decline. By adding a covered call position to an existing long stock position, VIA attempts to enhance the potential overall return in the portfolio. The goal of a covered call position is for the short option value to decay over time and allow the account holder to realize a gain, up to the total net option premium received should the option position expire worthless. In order to calculate the gain or loss on the overall covered call position, VIA will measure the profit or loss realized during the period the covered call option position was open against the profit and loss of the open securities position during the same time period. In addition to covered calls, VIA may, from time to time, purchase out-of-the-money put options to further add to the level of downside protection. The ratio of purchased put options may be less than the number of long shares of stock owned in the account. This strategy of employing puts to help protect the stocks in an account is likely to temper total returns (due to the premium paid to purchase the put options) but does provide some downside protection against declines in value of the underlying stocks. The Dividend Portfolio (The D-Portfolio) VIA’s principal objective in its equity-based Dividend Portfolio is to provide returns from a diversified group of companies that have an attractive dividend rate but still maintain many growth characteristics. Accordingly, the Dividend Portfolio is composed of mid-cap and/or large-cap stocks that maintain a targeted minimum dividend yield of at least 1.50% and exhibit a high level of financial strength coupled with a historical above average return on equity. Mid-cap stocks represent companies that have a total market capitalization between $1 billion and $5 billion. Mid-cap stocks tend to have a higher risk/reward ratio than large-cap stocks. Large-cap stocks represent companies that have a total market capitalization over more than $5 billion. Based on market conditions, this portfolio may have less diversification at times and may be more exposed to sector trends than a more diversified portfolio. VIA employs technical screening methods to forecast revenue and earnings over the next one to two years. Upon identifying a number of issuers, the selection is further narrowed by applying other investment rules and financial ratios such as PE ratio to evaluate future price projections. In addition to financial strength, dividend yield and return on equity, VIA also examines the dividend payout, the debt equity ratio and forward-looking PE ratios. Finally, VIA looks at companies that may also have an established history of buying back their stock and raising their dividend payments. Although certain industries tend to offer higher yielding stocks, the additional factors employed tend to screen out many less-desirable stocks in certain industries. From time to time VIA also utilizes a strategy of writing covered call positions against some or all of the stocks in the Dividend Portfolio. The primary purpose of option writing is to earn additional income through premiums received from the buyers of the call options. By monitoring the volatility, delta and time to expiration, VIA seeks to optimize the tradeoff between receiving option premium income and the possibility of forgoing future price appreciation on the underlying stock above the written strike price of the option, until the option expires. At the same time, the investor receives a small measure of downside protection, to the extent of the net option premium received should the price of the stock decline. By adding covered call positions to an existing long stock position, VIA works to enhance the potential overall return in the portfolio. The goal of a covered call position is for the short option value to decay over time and allow the account holder to realize a gain, up to the total net option premium received should the option position expire worthless. In order to calculate the gain or loss on the overall covered call position, VIA measures the profit or loss realized during the period the covered call option position was open against the profit and loss of the open securities position during the same time period. In addition to covered calls, VIA may, from time to time, purchase out-of-the-money put options to add downside protection. The ratio of purchased put options may be less than the number of long shares of stock owned in the account. that the strategy of employing puts to help protect the account is likely to temper total returns (due to the premium paid to purchase the put options) but does provide some downside protection against declines in the underlying stocks. The Fixed Income Portfolio (The I-Portfolio) A more conservative strategy is the Fixed Income Portfolio. A client can choose a taxable Fixed Income Portfolio, which seeks to provide returns from U.S. government agency securities, corporate debt and/or preferred stocks, or a non-taxable Portfolio, which seeks to provide returns from municipal bonds. Fixed income securities are selected using the same methodology as the fixed income segment in the Balanced Portfolio. The fixed income portfolio seeks to produce total returns over complete market cycles that exceed returns that may be expected from random trading and passive management strategies. At the discretion of the advisor, the taxable and/or non-taxable fixed income portfolios may consist entirely of one type of security, such as, for example, government agency securities or municipal bonds. Stock Put Writing Program (“SPWP”) and the Stock Put Credit-Spread Option Program (“SPCSOP”) VIA provides its clients with an alternative trading strategy that is designed for investors seeking aggressive returns. It is suitable only for those investors who can bear a high risk of loss, and who are suitable for active and short-term option trading, which includes the use of leverage in holding short put option positions and short put option credit-spread positions. For these investors, VIA offers the SPWP and the SPCSOP. Clients in these portfolios must have "Speculation" or "Capital Appreciation" as their primary objective and their risk tolerance must be "Aggressive" or "Speculative". It is advised that clients allocate no more than 20% of their total investable assets into these portfolios. (VIA has additional portfolios that could be utilized for the balance of a client's investable assets.) It is advised that clients who are age 65 or older do not allocate more than 15% of their investable assets into these portfolios. VIA seeks to achieve an aggressive return for investors in the SPWP, by employing a strategy of writing (selling) put options on a group of common stocks. A client enters a typical trade by selling an out-of-the- money put on a given stock and receiving a premium in exchange for agreeing to purchase 100 shares of that stock at the strike price any time before the expiration date of the option. If the underlying stock price does not drop below the strike price of the option, the option will generally decay in value over time and expire worthless on the expiration date. The premium collected for writing the option becomes the short- term profit for that trade. If the stock price drops below the exercise price, then the option is subject to being exercised. In that case, the stock would have to be purchased at the strike price, which would be higher than the current market price of the stock. A client is not required under applicable margin rules to maintain in his/her account sufficient equity to fund

assignments on all the client's short option positions. However, should the client be exercised on a short-put position, the cost of funding the resulting assignment of the stock may exceed the account's free available margin and result in a margin call, which would likely result in liquidating the stock position at a loss. The SPWP is a leveraged investment and should only be considered by investors with a high-risk tolerance. VIA seeks to achieve an aggressive return for investors in the SPCSOP by writing (selling) put credit-spread options on a group of common stocks or on a stock index. By entering into a spread position, under applicable margin rules, the initial margin that is required will be less than the total maximum potential loss on the spread position. Therefore, the SPCSOP is a leveraged investment and should only be considered by investors with a high-risk tolerance. Clients in both of the above programs will be required to open margin accounts with VFM, or with another qualified custodian. Margin accounts allow for substantial leverage and clients will therefore be responsible for maintaining adequate levels of margin. If the market moves unfavorably, clients may be required to deposit additional margin on short notice to maintain their open positions. Also, clients need to be aware that they will have limited ability to withdraw amounts deposited as margin while option positions in their accounts remain open. Clients in both of the above programs will be required to be approved for writing uncovered options. Clients will need to be approved for Level 3 options trading in order to write puts and for Level 4 options trading to write uncovered puts. Clients who utilize puts on indexes must be approved for Level 5 options trading. Those clients who open option accounts will be provided with a copy of the brochure Characteristics and Risks of Standardized Options (and any supplements) prior to being approved to trade options. Clients will also receive margin and uncovered options disclosure forms. Please note: Options involve risk and are not suitable for all clients. VIA will first identify companies that it believes have a strong tendency to trade at or above their current market price (these may be the same stocks that VIA uses in its other portfolios). The portfolios seek to achieve trading profits by entering into the short-put options trades at higher prices than when the positions are liquidated (closed) or the option positions expire worthless. It is important for an investor to fully understand that a drop (especially a sudden large drop) in the respective stock price will cause losses on the stock option position and at times those losses could be greater than the total potential profit on the option transaction. Leverage is a significant part of the investment strategy and creates the risk that a declining stock price, in the case of writing puts, may result in a loss greater than the amount deposited as margin. Moreover, a stock that is trading below the strike price, in the case of a short put, can and may incur potentially substantial losses in a short period of time. The price of a stock may fall to zero, and the loss in the client's account will be the cost of purchasing the stock at the strike price (far surpassing the value of the margin deposited in the account and the premium income received). If a client purchases a put, it gives the client the right to sell the underlying stock on or before the expiration date at the strike price. If a client sells a put, the client is obligated to buy the underlying stock at the strike price if the client is assigned. As a writer (seller of a put) the client has no control over whether the option will be exercised. Either type of position may be closed out before the expiration date thereby ending any right or potential obligation. A credit spread is the simultaneous initiation of a short put option in combination with the purchase of put option at a lower strike price with the same expiration date. One side of the transaction is writing a put on the stock and receiving a premium, in exchange for agreeing to purchase the stock at the strike price at a future date. The other side of the spread is buying a put option. The buyer pays a premium for the right to sell the stock at the strike price at a future date. There are different kinds of spreads that can be used, each having different objectives. VIA seeks to maintain a diversified portfolio of short options on various stocks that it believes will be more beneficial than limiting the option positions to just one or a few stocks. In the SPWP, if a client desires to own shares of stock but also believes that the ownership of that stock should take place at a price that is lower than the current market price and is willing to wait until a future date, an option strategy can be employed. By writing a put option at a strike price below the current market price, it will offer the opportunity to potentially own the stock at a lower price by the designated expiration date of the option. The put writer receives the premium since the account has now assumed the risk of loss if the stock moves below the strike price. If the stock price drops and the option is exercised, the net put premium will be used to lower the net cost on the stock when it is purchased at the strike price. If the stock does not trade below the strike price by expiration, the option will ultimately expire as worthless and the net put premium will be the profit on the trade. The put writer will be writing uncovered puts and will not own the actual stocks. It is not the intention of this type of portfolio to hold any stocks. If an option position is exercised and stock is purchased, it would most likely be promptly liquidated. In the SPCSOP, VIA will engage in writing put credit spreads. In this spread transaction, both the profit and loss are limited. The spread is the difference between the higher and the lower strike price. This strategy is used when one anticipates that the price of the underlying stock is likely to move higher or remain in a sideways trading range but remaining above the strike prices of the spread transactions, which will give it the opportunity to decay over time and result in a profitable trade. The reason the transaction is structured as a short credit spread instead of a naked put is to limit the potential of a loss on the transaction. Having a limited-loss feature also restricts the potential profit and adds transaction costs because there are two option positions rather than just one. The opportunities of the SPWP and SPCSOP Programs are:  The potential to profit from natural time decay of out-of-the-money short put options;  The potential to profit from an upward stock trend and/or from a sideways stock trend;  Access to investment methodologies developed by Mr. Rothman who will make the investment selections or recommendations and actively manages each of the portfolios; and  Portfolios also offer the ability to trade Exchange Traded Funds ("ETFs") and Indexes. If puts are sold on an index, the client would have to be approved for Level 5 options trading. The Total Portfolio (The T-Portfolio) VIA offers the Total Portfolio in which it may employ any of the strategies that it uses in managing the other portfolios offered, such as the Equity and Balanced Portfolios and the SPCSOP. In addition, VIA may engage in various option strategies including writing naked call options, entering into credit call spreads, entering into short stock positions and/or other decisions in a client's account including using margin to leverage the assets in a client's account. This portfolio entails a HIGH DEGREE OF RISK and requires a higher-level option trading approval, as detailed below, along with margin leverage. Clients in this portfolio must have "Speculation" or "Capital Appreciation" as their primary objective and their risk tolerance must be "Aggressive" or "Speculative." It is advised that clients allocate no more than 20% of their total investable assets into this portfolio. (VIA has additional portfolios that could be utilized for the balance of a client's investable assets). It is advised that clients who are age 65 or older should not allocate more than 15% of their investable assets into this portfolio. In this portfolio, the manager is seeking aggressive market returns. Please note that VIA will have broad discretion to employ many aggressive market strategies in order to seek profits. VIA believes that this portfolio has the flexibility to engage in activities that are specifically geared to events (either short-term or long-term) that are taking place in the market. For example, VIA may employ a "tactical tilt" to exploit a current situation in the market or utilize a complex options strategy due to a severe move in an underlying stock or the market in general. VIA may use various strategies, including but not limited to the following:  All of the strategies detailed in the SPWP and the SPCSOP listed above;  Selling a short (i.e., uncovered) call position providing an opportunity for profit but also involving unlimited risk of loss as the underlying stock price can rise substantially above the option strike price; and  A short straddle, which is a non-directional options trading strategy that involves simultaneously selling a put and a call of the same underlying security, strike price and expiration date. The profit is limited to the premiums of the put and call, but the straddle has substantial risk of loss if the underlying security either drops substantially below the strike price of the put or soars above the strike price of the call. This strategy is called non-directional because the short straddle may be profitable when the underlying security only has a small change in price direction before the expiration of the straddle. These strategies involve the use of leverage and margin. Please review the following important risk disclosure statement regarding the use of margin in a client's account. Clients in the Total Portfolio will also have to be approved for writing uncovered options. Clients will need to be approved for Level 3 options trading in order to write puts and for Level 4 options trading to write uncovered puts. Clients who utilize puts on indexes must be approved for Level 5 options trading. Those clients who open option accounts will be provided with a copy of the brochure Characteristics and Risks of Standardized Options (and any supplements) prior to being approved to trade options. Clients will also receive margin and uncovered options disclosure forms. Please note: Options involve risk and are not suitable for all clients. Non-Wrap Fee Accounts Managed Independently by an IAR Clients may elect to have an IAR individually manage their accounts. Each IAR has his/her own methods of providing investment advice. VIA does not select or recommend an IAR for a client and does not select client investments for the IARs. Each IAR acts independently, makes his/her own investment recommendations and is responsible for those recommendations. The IAR managing a client's account will create a portfolio consisting of one or more of the following: individual equity securities including exchange-traded funds (“ETFs”), preferred stocks, mutual funds, fixed income securities (such as corporate bonds, government securities and municipal securities), unit investment trusts, real estate investment trusts and options on securities. Clients will generally be invested in publicly traded securities. IARs may also invest in portfolios offered by VIA. IARs may not invest client assets in penny stocks or securities that do not have a readily available market price. IARs typically will open new accounts with a third-party broker/custodian. (Please see Appendix 1.) IARs will allocate the client's assets among various investments taking into consideration the objectives, risk tolerance and time horizon of each individual client. The portfolios weighting between funds and market sectors will be determined by each client's individual needs and stated investment objectives. Clients will have the opportunity to place reasonable restrictions on the types of investments made on their behalf if they provide the restrictions in writing. IARs may also engage third-party money managers, with whom VIA has a selling agreement, to manage a portion or all of the client's account. Fees for such management will vary from manager to manager and will be in addition to the fees paid to VIA (Please see Appendix 1). An IAR may recommend a third-party CTA to a client to manage an appropriate portion of the client's account. Any such allocation to managed futures must be based on the suitability of the respective client and the details of the proposed investment (including size of the allocation, etc.). The IAR may include such allocated assets in the total amount on which they are advising the client and on which the investment management fee is charged. There are costs involved in a managed futures account including commissions, exchange/clearing fees and regulatory fees. These costs are in addition to any fees charged by VIA for allocating and supervising the assets. In addition, there may be instances when an IAR is also registered as an Associated Person with an Introducing Broker firm that is a member of the National Futures Association that may be affiliated with VIA. In such instance, it is possible that an investment in a CTA program can be made through the Introducing Broker firm and that the IAR may then share in a portion of the commissions generated in the futures account. Since this is a potential conflict of interest, the IAR is required to disclose such affiliation to the client and obtain the client's affirmative consent to function as the Introducing Broker of the futures account in addition to their role allocating assets as an IAR. IARs may utilize various data sources in gathering historical information, as well as annual and quarterly reports. IARs may use various investment disciplines such as technical, fundamental, cyclical and charting analysis. However, IARs will continuously monitor and evaluate securities relative to market and industry conditions. IARs may use money market funds to "sweep" unused cash balances. Clients who open margin accounts need to be aware that margin involves the use of leverage, and clients may lose more money than they deposit in the margin account. IARs may use certain strategies that are viewed as riskier including, but not limited to, short-term trading (securities sold within 30 days) and short sales and/or naked option writing. Because these investment strategies involve certain additional degrees of risk, they will only be recommended when consistent with the client's stated objectives and tolerance for risk. There also are certain risks associated with option strategies. In a rising market, a call option written to protect the portfolio or an individual stock position within the portfolio may reduce upside potential above the strike price of the option. As options expire or experience increased market volatility, it may be more difficult to manage the covered call positions for maximum economic advantage. Likewise, market volatility may drop around the time of the expiration resulting in lower premium income attainable when "rolling over" an options position. Option execution charges have a much greater impact on smaller accounts than they do on larger accounts. All clients engaging in options transactions, regardless of the portfolio they select, will receive a copy of the brochure Characteristics and Risks of Standardized Options (and any supplements) at, or prior to opening an options account. Clients whose accounts are using options strategies, in addition to covered calls, will also receive the margin and uncovered options disclosure forms. Margin Disclose Statement Clients who open margin accounts will be provided with the full regulatory margin disclosure documents. Margin clients need to be aware of the following: They may lose more funds than are deposited in the margin account; The client’s brokerage firm, whether VFM, or third-party brokerage firm, can liquidate any position to cover a margin debit; The client’s brokerage firm, whether VFM, or third-party brokerage firm, can liquidate positions without first contacting the client; Clients are not entitled to choose which securities or other assets in their account(s) are liquidated or sold to meet a margin call; The loss on a given short spread is limited to the difference between the two strike prices less the net premium received, after execution charges and any other transaction costs; VFM, or third-party brokerage firm can increase its "house" maintenance margin requirements at any time and are not required to provide advanced written notice to clients; and Clients are not entitled to an extension of time to meet a margin call.