Description of Advisory Firm Van Hulzen Asset Management’s registration was granted by the U.S. Securities and Exchange Commission on March 14, 2003. Craig Dennis Van Hulzen (CRD Number 2468474) is the Executive Chairman, Chief Investment Officer and Founder of Van Hulzen Asset Management. Mr. Van Hulzen owns the majority of the equity in Van Hulzen Asset Management. Bradley Robert Nicholson (CRD Number 4846561) is the President of Van Hulzen Asset Management and owns a minority interest in Van Hulzen Asset Management. Wedbush Capital, owns a minority interest in Van Hulzen Asset Management. Paul Nederveld is the Chief Compliance Officer of Van Hulzen Asset Management. Van Hulzen Asset Management is not publicly owned or traded. As of December 31, 2023, Van Hulzen Asset Management managed on a discretionary basis $1,983,123,187 and $10,696,624 on a non-discretionary basis. Client assets are managed on an individualized basis. Clients may impose restrictions on their accounts. Types of Advisory Services Van Hulzen Asset Management, a California Limited Liability Corporation, provides investment advisory services to clients, including individuals, pension and profit-sharing plans, trusts, estates, small business owners, foundations, charitable organizations, private investment vehicles and corporations on a discretionary and non-discretionary basis. Wealth Management Services Van Hulzen Financial Advisors offers a broad-based financial solution for clients who are seeking advice on their total financial situation. This is an advisory service that includes analysis and recommendations on the client’s entire balance sheet including investment portfolios, real estate, private investments, debts, and other items. Wealth management also includes (as applicable) financial planning, estate planning, tax strategies, asset allocation services, asset management, reporting, position monitoring, cashiering, and support of a dedicated team. Asset Management Services We have numerous investment strategies that include US Covered Call Strategy, US fixed income, US equity, global equity, tactical asset allocation, ETF (including commodity funds, precious metal funds, and agricultural funds) and “no-load” or “load-waived” mutual funds, and balanced investment styles, alternative investments (including publicly traded and non-traded real estate funds and privately traded business development companies), variable annuities, and options. Asset Management Services is for investors who hire Van Hulzen Asset Management to solely manage an allocation of their overall portfolio and not for the broad-based wealth management solution. Assets managed by Van Hulzen Asset Management are predominantly made up of individual securities such as US equities, American Depository Receipts, exchange-traded funds, and bonds. On occasion, mutual funds may also be appropriate for diversification or asset class allocation. In these cases, there are two levels of fees involved, that is, one fee payable to Van Hulzen Asset Management and a second fee payable to the mutual fund. All mutual funds (including no-loads) have embedded fees (as represented by the funds’ published “expense ratios”) that the mutual fund company automatically extracts from the fund’s return. The client does not receive an explicit invoice for the mutual fund’s expenses, even though the client pays the mutual fund expenses through the fund’s returns. In addition, the client’s brokerage firm may charge the client a “transaction fee” on the purchase of some no-load mutual funds. Wetsel Financial Model Wealth Portfolios Wetsel Financial Model Wealth Portfolios (“WFMWP”) advisory program offers a unique solution for those clients desiring a dynamic long-term asset management program. The WFMWP program may use individual securities, preferred stock, bonds, mutual fund shares and exchange traded funds (“ETFs”) to create one or more model portfolios based on a client’s investment objective. Our models include an income with capital preservation portfolio, income with moderate growth portfolio, growth with income portfolio, growth portfolio and aggressive growth portfolio. Van Hulzen Asset Management has discretion to buy and sell securities in the client’s account in accordance with the guidelines and asset allocation thresholds set forth in accordance with the model portfolio(s) selected. Schreur Financial Model Wealth Portfolios Schreur Financial Wealth Portfolios (“SFWP”) advisory program offers a unique solution for those clients desiring a dynamic long-term asset management program. The SFWP program uses individual securities such as US equities, American Depository Receipts, exchange-traded funds and bonds. On occasion, mutual funds may also be appropriate for diversification or asset class allocation. Van Hulzen Asset Management has the discretion to buy and sell securities in the client’s account in accordance with the guidelines and asset allocation thresholds set forth in accordance with the asset allocation selected. Consulting Services We offer research and consulting services on a contractual basis. The services offered include technical research analytics, financial modeling, business valuation, private fund review and recommendation, and transactional analysis. Van Hulzen Asset Management also provides advice regarding hedging of concentrated positions and manages accounts which seek to trade in volatility strategies, including the use of

index and single stock options. Asset Allocation Services We offer a strategic asset allocation program for clients seeking guidance on the allocation of capital between various asset classes, managers or commingled funds. The Asset Allocation services include:
• Complete Evaluation of Client’s Current Investments, including investments held at other custodians and variable annuities.
• Assisting Client in Quantifying and Prioritizing their investment and other financial goals
• Developing a Cohesive Investment Strategy for managing the client’s portfolio
• Establishing and/or Consolidating the Client’s Investment Accounts
• Manager, asset and security research and selection (as appropriate)
• Implementation of the agreed-upon allocation, including purchasing, selling existing and new securities to arrive at the recommended asset allocation.
• Risk Analysis of personal balance sheet holdings (private, public, real estate, debt)
• On-Going Monitoring of the positions for continued suitability
• On-Going Adjustments and Rebalancing of the investment portfolio
• Quarterly Investment Performance Reports
• On-Going Meetings to Review Strategy and Progress toward client’s goals
• Retirement Planning, Cash Flow Analysis and Planning, Stock Option Planning, College Planning
• Assistance with Tax, Estate, Insurance and Real Estate issues All work is customized for each client relationship and fees are negotiated based on the services provided on a case-by-case basis. Clients or Van Hulzen Asset Management may terminate the contracted services by providing written notice. One-Time Investment Analysis and Planning Consultation A thorough assessment is performed of the client’s financial goals, objectives, existing investments, and risk tolerance in order to provide sound investment analysis and recommendations. A customized investment strategy and asset allocation plan will then be developed for the client to implement. The advice and recommendations will include specific adjustments to be made to the current assets if appropriate, and recommendations on investments to be added. Portfolio recommendations are composed primarily of no-load mutual funds readily available through discount brokerages of the client’s choice. If the client already owns a variable annuity, we will research and recommend the sub-account fund choices most appropriate for the client’s goals and objectives. The client is responsible for maintaining their investment accounts and for the on-going implementation and maintenance required by the portfolio. Financial Planning Services Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals;
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis;
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals;
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio;
• Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. ERISA Services We offer ERISA 3(21) and 3(38) services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include:
• Provide the Sponsor and the Plan with the recommended diversified investment options for the Plan from which Plan participants may choose. May also create specific asset allocation models (the “Models”) comprised of any and/or all of the designated investment alternatives.
• Recommend a qualified default investment alternative (“QDIA”)
• Revise existing (and/or develop and maintain) an Investment Policy Statement establishing the investment policies and objectives for the Plan, setting forth the asset classes and investment categories to be offered under the Plan, and providing the criteria and standards for selecting and monitoring such assets.
• Provide Plan participants with informational seminars, to include materials which describe the various investment alternatives available under the Plan, information about investing generally, including information about different types of investments, information about different investment allocation strategies, including information about historical returns, and interactive materials designed to help participants identify appropriate investment strategy. Wrap Fee Programs Van Hulzen Asset Management does not participate in wrap fee programs.