A. Ownership/Advisory History Trek Financial, LLC dba Trek Financial (“Trek” and/or “the firm”) is a privately held, employee owned, independent registered investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”) since January 1996. The principals of the firm are Justin Young, Chief Executive Officer; and Ben Bimson, Chief Investment Officer. Our firm offers services through our network of investment adviser representatives (“Adviser Representatives”). Adviser Representatives may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the Adviser Representative and not of our firm Trek Financial, LLC. The Adviser Representatives are under the supervision of our firm Trek Financial, LLC, and the advisory services of the Adviser Representative are provided through our firm Trek Financial, LLC. For additional information, please refer to Schedule D of Part 1 of our Form ADV or ask your Adviser Representative. A complete list of approved doing business as names came be found by searching for Trek Financial, LLC, CRD# 109376 on the Internet at www.adviserinfo.sec.gov. The investment advisory services of Trek are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Trek. Your investment adviser representative may either be an employee of Trek or an independent contractor. Investment adviser representatives are able, within the parameters set by Trek (as disclosed in Item 5 –Fees and Compensation), to negotiate the asset management, financial planning, and service fees charged to clients for the services provided and/or to waive, at the Adviser Representative’s expense, clients’ operational and custodian fees. It is possible that different investment advisor representatives may charge different fees for providing the same service to clients. The specific level of services you will receive, and the fees you will be charged, by Trek will be specified in your advisory services agreement. B. Advisory Services Offered Discretionary Asset Management Services For its discretionary asset management services, Trek receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. Trek’s discretionary asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. Trek will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. Investment Management Services Trek may recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent third-party managers or sub- advisors based on the stated investment objectives of the client. The terms and conditions under which the client is to engage the independent manager(s) will be set forth in separate written agreements between (i) the client and Trek and (ii) the client and the designated independent manager(s). Trek will continue to render advisory services to the client relative to the ongoing monitoring and review of account performance, for which Trek will receive an annual advisory fee. Payment of this fee will be described in the Trek Schedule of Services and Fees document. Factors that Trek will consider in recommending independent manager(s) include the client's stated investment objective(s) and the independent manager(s) management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated independent manager(s) and the corresponding designated broker-dealer/custodian of the client's assets may be exclusive of, and in addition to, Trek’s investment advisory fee set forth in Item 5 of this brochure. In addition to Trek’s written disclosure statement, the client will also receive the written disclosure statement of the designated independent manager(s). Certain independent manager(s) may impose more restrictive account requirements and varying billing practices than Trek. In such instances, Trek may alter its corresponding account requirements and/or billing practices to accommodate those of the independent manager(s). Model Portfolios Trek offers various model portfolios that are managed by Trek or selected third parties. We offer models with additional costs that range from 0.00% to 0.75%. The following is a list of some of the model portfolios offered by Trek. This is not a comprehensive list and the client has access to other model portfolios that are not otherwise listed here. The additional model portfolio fees are listed in Item 5. Trek offers the Trek Custom Strategic Portfolios that are based on a disciplined approach using research and data from BlackRock. These are a series of portfolios that are designed for different risk profiles and investment objectives ranging from conservative to moderate to aggressive and they are managed with a goal of tax efficiency through careful selection of underlying investments and low portfolio turnover. The NDR Dynamic Allocation Strategy trades 13 highly liquid ETFs based on an objective, weight-of-the- evidence model designed to minimize drawdowns. The model portfolio can make allocations to six equity ETFs, six fixed income ETFs, as well as a cash ETF. The top-level macroeconomic model determines the appropriate allocation to equity and fixed income. Then, within the equity and fixed income sleeves, independent indicator models determine the ETF allocations. Each indicator within the equity and fixed income sub-models has an equal weighting that contributes to its relative position and allocation within the sleeve. The tactical weight recommendations are unconstrained at both levels. The NDR Tactical Allocation Strategy is an evidence based multi-factor model using internal and external market indicators to drive key stock/bond allocations leading to 0/100, 60/40 or 100/0 monthly allocations. It is designed to maximize growth and minimize drawdowns with the ability to allocate to long-term treasuries when equity markets are struggling and/or cash when rising rates are a risk. This strategy has multiple layers of monthly indicator testing for Tactical Allocation using ETFs. The NDR Tactical Dynamic Allocation Strategy is a combination of the NDR Dynamic Allocation Strategy and the NDR Tactical Allocation Strategy on a 50% / 50% basis. The NDR Dynamic Allocation Strategy ESG trades 13 highly liquid ETFs based on an objective, weight-of- the-evidence model designed to minimize drawdowns. The model portfolio can make allocations to six equity ETFs, six fixed income ETFs, as well as a cash ETF. The top-level macroeconomic model determines the appropriate allocation to equity and fixed income. This strategy uses ESG ETFs for asset classes that are sensitive to those looking for ESG goals, and where ESG ETFs are available to substitute. The NDR Sector Allocation Strategy is a systematic, evidenced-based approach to sector allocation in an attempt to capture the majority of major upside market moves while avoiding major downside moves. Each month, sector-specific indicators are modelled to evaluate the relative attractiveness of eleven equity sector ETFs within the U.S. large-cap space. The model output results in the allocating of assets from sectors with unfavorable characteristics to sectors with favorable characteristics and providing downside protection to the portfolio by allocating to defensive sectors during large market declines. The NDR Fixed Income Allocation Strategy is a systematic, evidenced-based approach to fixed income allocation in an attempt to capture the majority of major upside market moves while avoiding major downside moves. Each month, macroeconomic and technical indicators are combined to evaluate the relative attractiveness of nine fixed income ETFs across sectors and geographies, reallocate assets from sectors and geographic regions with unfavorable characteristics to areas with favorable characteristics, and provide downside protection to the portfolio by lowering duration and reducing credit risk during weak economic environments. The Quality Selection Strategy uses BCA Research to implement this multifactor quantitative strategy that identifies high-quality macro-resilient stocks. The strategy relies on 30 factors that can be broken down into seven broad categories and aggregated into a final measure called the “BCA Score.” The bias of the BCA Score is to favor high quality, strong momentum, and low volatility factors that have produced a reliable performance over different phases of the economic cycle. Each month, the strategy defines its universe as the top 1,000 U.S. stocks based on market cap and selects the top five stocks per GICS sector based on the BCA Score. The portfolio is equal weighted within each sector and sector neutral relative to the 1,000-stock universe. At each rebalancing period, the strategy will recommend buying or selling positions based on the BCA Score as well as a quantitative macro-overlay. This strategy has a $100,000 minimum investment. The Value Selection Strategy grades each stock in the universe based on several factors we believe contain information crucial in predicting future returns. Stocks are selected from NDR’s Multi-Cap Value universe using data from Compustat. The universe is typically made up of around 400 U.S. domiciled constituents from small to large cap that are also considered to have adequate trading liquidity. The top 60 graded stocks are considered the buys. Factors employed by the Value strategy are selected as a result of how well they perform in a back-test environment where returns from known historical data are used. This strategy has a $100,000 minimum investment. The Growth Selection Strategy grades each stock in the universe based on several factors we believe contain information crucial in predicting future returns. Stocks are selected from NDR’s Multi-Cap Growth universe using data from Compustat. The universe is typically made up of around 400 U.S. domiciled constituents from small to large cap that are also considered to have adequate trading liquidity. The top 60 graded stocks are considered the buys. Factors employed by the Growth strategy are selected as a result of how well they perform in a back-test environment where returns from known historical data are used. More specifically the factors used are price momentum, analyst forecast of earnings growth, short interest, operating cash flow, asset turnover, cash position, gross profit margin, earnings/enterprise value, and shareholder yield. This strategy has a $100,000 minimum investment. The MacroQuant Strategy is an ecosystem of quantitative factor models. for each factor model, MacroQuant examines the relationship between the factors and the asset being modeled (e.g., US equities) and provides a bullish or bearish signal. These individual signals are combined to create an overall recommendation and allocation based on the existing economic and financial conditions. MacroQuant’s methodology provides a flexible, transparent framework. The resulting tactical model has flexible allocations to equities, bonds, and cash. The Bulwark Tactical Trend Strategy follows a proprietary algorithm developed by Ascent Systematic Advisors to trade US listed stocks. The strategy's investment objective is to maximize risk-adjusted absolute returns over a full market cycle through the use of a First Principles Based Process focused on preservation of capital and on profiting from timeless features of the stock market. The systematic methodology seeks to achieve this objective by:
• Applying a proprietary quantitative selection process designed to systematically capture idiosyncratic trends
• Following a strict systematic portfolio construction and risk management approach that aims to eliminate human bias in the investment management process.
• Increasing the allocation to Cash when the model deems appropriate The Qualified Navigator Strategy trades 13 highly liquid ETFs based on an objective, weight-of-the evidence model designed to minimize drawdowns. The model portfolio can make allocations to six equity ETFs, six fixed income ETFs, as well as a cash ETF. The top-level macroeconomic model determines the appropriate allocation to equity and fixed income. Then, within the equity and fixed income sleeves, independent indicator models determine the ETF allocations. Each indicator within the equity and fixed income sub-models has an equal weighting that contributes to its relative position and allocation within the sleeve. The tactical weight recommendations are unconstrained at both levels. This model anticipates trades that are bi-monthly compared to the NDR Dynamic Allocation Model and is more suitable for non-taxable or tax-deferred accounts. The Conservative Dynamic Allocation Strategy trades 13 highly liquid ETFs based on an objective, weight- of-the evidence model designed to minimize drawdowns. The model portfolio can make allocations to six equity ETFs, six fixed income ETFs, as well as a cash ETF. The top-level macroeconomic model determines the appropriate allocation to equity and fixed income. Then, within the equity and fixed income sleeves, independent indicator models determine the ETF allocations. Each indicator within the equity and fixed income sub-models has an equal weighting that contributes to its relative position and allocation within the sleeve and is interpreted with a more conservative bias than the NDR Dynamic Allocation Strategy. The tactical weight recommendations are unconstrained at both levels. The Aggressive Dynamic Allocation Strategy trades 13 highly liquid ETFs based on an objective, weight- of-the evidence model designed to minimize drawdowns. The model portfolio can make allocations to six equity ETFs, six fixed income ETFs, as well as a cash ETF. The top-level macroeconomic model determines the appropriate allocation to equity and fixed income. Then, within the equity and fixed income sleeves, independent indicator models determine the ETF allocations. Each indicator within the equity and fixed income sub-models has an equal weighting that contributes to its relative position and allocation within the sleeve and is interpreted with a more Aggressive bias than the NDR Dynamic Allocation Strategy. The tactical weight recommendations are unconstrained at both levels. The Global Allocation Model combines trend, sentiment, fundamental, and macroeconomic indicators in a weight-of-the-evidence approach to assign tactical weights versus a fixed benchmark of 55% stocks, 35% bonds, and 10% cash. This allocation uses both country specific ETFs and broad market ETFs for US equity exposure. Bonds are represented by an ETF indexed to the Barclays Aggregate Bond Index. Tactical shifts are made based on indicators as well as portfolio optimization. Tactical weight recommendations are unconstrained at all three levels. The Global Quads is a risk managed global macro portfolio designed to perform over the full market cycle with an overarching theme of protecting principal and compounding returns. We use two factors to forecast future financial market return: economic growth and inflation. Based upon their respective rate of change, we weight 4 possible outcomes of growth slowing/accelerating and inflation slowing/accelerating

and the typical government policy response in each combination. Holdings are screened through a risk range strategy for additional risk management and for building and exiting positions. The Macro Navigator is a risk managed global macro portfolio designed to perform over the full market cycle with an overarching theme of protecting principal and compounding returns. We use two factors to forecast future financial market return: economic growth and inflation. Based upon their respective rate of change, we weight 4 possible outcomes of growth slowing/accelerating and inflation slowing/accelerating and the typical government policy response in each combination. By implementing signals on positions, to screen allocations, risk can be dramatically reduced over time. Trading may occur more frequently or less frequently depending on market conditions. The Macro Growth Navigator is a risk managed global macro portfolio designed to perform over the full market cycle with an overarching theme of growth and compounding returns. We find two factors to be most consequential in forecasting future financial market return: economic growth and inflation. Based upon their respective rate of change, we weight 4 possible outcomes of growth slowing/accelerating and inflation slowing/accelerating and the typical government policy response in each combination. We then select the assets based upon back-testing of their relative performance in each of the 4 quadrants. It differs from the Macro Navigator by not de-risking based on asset class volatility. Equity typically will range from 40-80% depending on model readings. Signals are used to screen holdings quarterly to determine which asset classes need adjustment. The Viking US Quality Equity model portfolio invests in large cap equities listed on US exchanges. The strategy seeks to identify both stability in earnings and fundamental quality. The strategy allocates to companies that have demonstrated good return on capital and good earnings yield. The strategy selects from a universe of stocks Large Cap US equities with market capitalization over $30B. It excludes the Utilities Sector, carries equal weighting among the equites and aims to have approximately 30 stocks in the portfolio. The factors on the portfolio and investment universe are re-run quarterly. This benchmarks to the S&P 500 Index. The Viking Quality ADR model portfolio invests in large cap ADRs from global developed markets. The strategy seeks to identify both stability in earnings and fundamental quality. The strategy thesis has a foundation in a belief that companies that have good return on capital and good earnings yield are likely to perform better over the long term. The strategy considers stability of earnings, stability of earnings and analyst estimates of dividends to select approximately 30 stocks quarterly from listed US ADRs. The benchmark for this strategy is the MSCI EAFE Index. The Viking US Quality Dividend model portfolio invests in large cap equities listed on US exchanges. The strategy seeks to identify firms that demonstrate both historical dividend growth and analyst expectations of future dividends. The goal is to simplify the process of selecting a basket of equities that have historically shown certain dividend characteristics that investors may view as an attractive theme for investment. The strategy process selects equities that are biased towards above average dividend yield, as well as improved valuations and lower debt to equity. The strategy uses various factors to screen from US Large Cap stocks and benchmarks to the S&P 500. Individual Security Selection Clients can also choose to have a portion of their assets managed by Trek on an individual basis, taking into account a client's personal financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). Trek’s engagement with a client will include, as appropriate, the following:  Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to Trek in response to a questionnaire and/or in discussions with the client and reviewed in meetings with Trek.  Analyzing the client's financial circumstances, investment holdings and strategy, and goals.  Providing assistance in identifying a targeted asset allocation and portfolio design.  Implementing and/or recommending individual equity and fixed income securities, mutual funds, and ETFs.  Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk. In addition to providing Trek with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Trek will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Consulting and Financial Planning Services Trek gathers information through in-depth personal interviews and/or questionnaires. Information gathered includes your objectives, goals, risk tolerance, other personal and financial circumstances, time horizon, tax returns, wills or estate plans, powers of attorney, insurance policies, employee benefits and retirement benefits information, and other documents as we may reasonably request in order to permit a complete evaluation and preparation of recommendations to you. The work will include written review, analysis and preparation of the recommendations and findings we provide you. While financial planning services are prepared with the intention of the client implementing recommendations made within the plan through Trek, clients are not obligated to do so. Clients may select any investment advisor, broker/dealer, or financial institution to implement Trek recommendations. Financial planning fees are negotiable. In addition, Trek may waive, reduce or credit the amount of the financial planning fee charged to a client when additional advisory fees or commissions are earned. The decision to waive or reduce an advisory fee is at the sole discretion of the investment advisor representative. Use of Other Investment Advisory Firms as Sub-Advisors At its discretion Trek can decide to utilize affiliated or unaffiliated investment advisory firms as sub advisors to provide asset management services according to the terms and conditions of a written Sub-Advisor Agreement. With respect to sub-advisory services, Trek will maintain both the initial and ongoing day-to- day relationship with the underlying client, including initial and ongoing determination of client suitability for the Sub-Advisor’s separately managed accounts. In a sub-advisory relationship, Trek is responsible for the recommendation and selection of the Sub-Advisor on behalf of the client and can remove the client’s assets from the Sub-Advisor’s management at Trek’s discretion. Use of Other Investment Advisory Firms as Trade Signal Providers At its discretion Trek can decide to utilize affiliated or unaffiliated investment advisory firms as trade signal providers to assist us with the development and recommendation of appropriate investment options for our Model Portfolios and separately managed accounts. Trek will have final authority and responsibility to accept or reject all investment recommendations provided by the signal providers. The unaffiliated signal providers will not have access or have any responsibility to make investment changes to or place trades in the Model Portfolios or client accounts. Accounts Managed by Third-Party Money Managers Trek typically does not refer clients managed accounts to other investment advisory firms; however, certain clients that decide to have Trek manage a portion of their portfolio may have established prior relationships with another Third-Party Money Manager. For assets that it is determined that it would be in the client’s best interest to leave a portion of their assets in the Third-Party Money Manager program, the third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. As a result of the ongoing relationship, we are paid a portion of the total fee charged to your account by the third-party manager. Under this program, we are available to answer questions that you have regarding your account and act as the communication conduit between you and the third-party money manager. The third-party money manager might take discretionary authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. Workshops and Seminars Trek may conduct periodic financial educational sessions for those desiring general advice on personal finance and investing. Topics may include issues related to financial planning, college funding, estate planning, retirement strategies, or various other economic and investment topics. Our workshops are educational in nature and do not involve the sale of insurance or investment products. Information presented will not be based on any one person’s need nor do we provide individualized investment advice to attendees during our general sessions. CAIS Platform Trek has contracted with Capital Integration Systems, LLC (CAIS) for use of its alternative investment platform, software, and services. CAIS sources and selects new funds for its platform through a due diligence process conducted by Mercer Investment Consulting (Mercer). The process typically includes discussions among CAIS, prospect funds, their managers, Mercer and other relevant third parties experienced with the managers. Products that are appropriate and desirable for the platform are subject to internal committee reviews by CAIS and full, independent diligence review by Mercer. Product onboarding occurs only following the successful completion of these processes. Following onboarding, a regular dialogue and review is maintained with respect to each fund so long as it remains on the platform. Use of the CAIS platform enables our clients to have access to alternative investments at meaningfully lower dollar amounts, often starting at $100,000 minimum investments, than the funds usually require. The management fees and the carried interest vary at the fund level. iCapital Network Trek has contracted with Institutional Capital Network, Inc. “(iCapital Network”) and their affiliates to provide Advisors with access to the iCapital Network alternative investment platform, software and services. iCapital Network and/or its affiliates conduct due diligence (investment and operational) on private equity and hedge fund offerings available on their platform. Privately Offered Securities valuations can lag a month or more and are received from the issuer’s third- party administrator to the alternative investment vehicle, for directly offered investments or from iCapital Network’s fund administrator for those available on the iCapital Network platform. The fee calculation uses the data to calculate the fee. ERISA Retirement Plan Non-Fiduciary Services Trek provides non-fiduciary services for retirement plans, which include the following:  Assist in the education of the participants about general investment principles and the investment alternatives available under the plan. This shall include education in these four types of investment information:
• Information about the terms of the plan and the benefits of participating in the plan.
• General information about financial and investment concepts.
• General information about the asset allocation models offered by the plan, without recommending any specific model to the participant.
• Tools that a participant can use to determine risk tolerance, perform gap analysis and other similar interactive investment materials.  Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.  Support plan sponsor’s human resources department and coordinate their integration with the plan’s record keeper and other related administrative service needs.  Assist the plan sponsor with plan benchmarking.  Assist the plan sponsor with review and understanding of plan investment monitoring and selection process.  Provide a plan fiduciary review.  Provide the plan sponsor periodic retirement industry updates and education on topics relevant to plan sponsor’s role as a fiduciary.  Educate all plan fiduciaries on the use of tools and checklists to help them better monitor and manage their fiduciary responsibilities. ERISA Retirement Plan Fiduciary Services Trek provides fiduciary services for retirement plans, which include the following:  Provide ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the Plan in accordance with the Plan’s investment policies and objectives.  Select a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder.  Develop an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan.  Monitor investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and determine whether to maintain or remove and replace investment options.  Meet with Client on a periodic basis to discuss the reports and the investments decisions.  Select a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election. Client acknowledges that it is responsible for determining whether the Plan should have a QDIA and deciding upon the type of investment that will serve as a QDIA (e.g., target date fund, balanced fund or managed account). Once Client has made that determination, Adviser will select the investment to serve as the QDIA. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).  Provide, where the plan recordkeeper capabilities exist, unitized asset allocation model(s). Use of these models by participants will incur an additional advisory fee (paid by the participant from their plan assets).  Provide, where the plan recordkeeper capabilities exist, core (non-unitized), risk-based asset allocation models for participants. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Trek recommends clients to the Betterment wrap fee program. While Trek does not sponsor a wrap fee program, it may recommend third-party wrap fee programs depending on the needs of a particular client. (Wrap fee programs offer services for one all-inclusive fee.) E. Client Assets Under Management As of December 31, 2023, Trek manages $2.260 Billion of discretionary assets, which includes $574,812of Betterment program assets.