A. Strategic Wealth Advisors (“SWA” or Strategic Wealth Advisors) is a limited liability company formed on December 24, 1998 in the state of Arizona. SWA became registered as an Investment Adviser Firm with the State of Arizona in January 1999 and with the Securities Exchange Commission in March 2004. The firm is owned by The John and Laurie Bagley Family Trust. Laurie B. Bagley is the firm’s Manager. B. As discussed below, Strategic Wealth Advisors offers to its clients (individuals, business entities, trusts, estates and pension and profit sharing plans, etc.) investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES Strategic Wealth Advisors provides discretionary investment advisory services on a fee-only basis. The firm’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Strategic Wealth Advisors’ management and usually ranges between 0.25 and 1.00% annually (Specific Fee Schedule is outlined in Item 5, Fees and Compensation). FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) To the extent requested by a client, Strategic Wealth Advisors may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Neither Strategic Wealth Advisors, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of Strategic Wealth Advisors’ services should be considered as such. Planning and consulting fees are negotiable, but generally range from $200 to $500 on an hourly rate basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging Strategic Wealth Advisors to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with SWA setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to commencing services. If requested by the client, SWA may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Strategic Wealth Advisors. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Important Note: It is the client’s responsibility to promptly notify Strategic Wealth Advisors of any change in his/her financial situation or investment objectives so that we can review, evaluate or revise any previous recommendations and/or services. WEALTHBUILDER PROGRAM For young adults who do not meet the firm’s minimums but are affiliated with existing clients or who meet select criteria based on savings potential and willingness to engage in the financial planning process, the firm offers a modified service level with a tiered flat fee schedule, which is provided upon the onset of the engagement and outlined in the client Agreement. MISCELLANEOUS Other Types of Investment Services. When specifically requested by a client, SWA may review a client’s existing position or a potential investment in various non-traditional investments including but not limited to limited partnerships, oil and gas interests, options contracts, futures contracts, real estate and hedge funds. This review is limited to a broad overview of the investment’s line of business, business model and sample projections. Quotes may be obtained for purchases or sales of partnership interests in the secondary market, however, all purchase/sale decisions are made by the client. All transaction costs and risks are borne by the client. If Strategic Wealth Advisors provides investment advice relative to private investment funds, the following disclosure is applicable: Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike other liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that SWA references private investment funds owned by the client on any supplemental account reports prepared by SWA, the value(s) for all such private investment

funds shall reflect either the initial purchase and/or the most recent valuation provided by the fund sponsor. If the valuation reflects the initial purchase price (and/or a value as of a pervious date), it is important to understand that the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. Please Note: Non-Discretionary Service Limitations. Clients that request to engage Strategic Wealth Advisors on a non-discretionary investment advisory basis must be willing to accept that Strategic Wealth Advisors cannot effect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, Strategic Wealth Advisors will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s verbal consent. Retirement Rollovers-No Obligation/Conflict of Interest: A client leaving an employer typically has four options (and may engage in a combination of these options): 1) leave the money in his former employer’s plan, if permitted, 2) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, 3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Strategic Wealth Advisors may recommend an investor roll over plan assets to an IRA managed by Strategic Wealth Advisors. As a result, Strategic Wealth Advisors may earn an asset-based fee; however, a recommendation that a client or prospective client leave their plan assets with their old employer could result in no compensation. Strategic Wealth Advisors may have an economic incentive to encourage an investor to roll plan assets into an IRA that Strategic Wealth Advisors will manage. There are various factors that Strategic Wealth Advisors may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus those of Strategic Wealth Advisors, iv) required minimum distributions and age considerations, and v) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by Strategic Wealth Advisors. When Strategic Wealth Advisors provides investment advice to you regarding your retirement plan account or individual retirement account, SWA is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The manner in which SWA is compensated creates some conflicts with your interests. As such, SWA operates under a special rule that requires the firm to act in your best interest. Under this special rule’s provisions, SWA must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put SWA’s financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that SWA gives advice that is in your best interest;
• Charge no more than is reasonable for the firm’s services; and
• Give you basic information about conflicts of interest. Client Obligations. In performing its services, SWA shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely upon the information provided. Each client is responsible for promptly notifying Strategic Wealth Advisors of any change in his/her financial situation or investment objectives so that SWA can review, evaluate and if necessary, revise previous recommendations and/or services. Disclosure Statement. A copy of Strategic Wealth Advisors’ written Brochure (Part 2A of Form ADV) shall be provided to each client prior to, or simultaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. Any client who has not received a copy of our written Brochure at least 48 hours prior to executing the Investment Advisory Agreement or Financial Planning and Consulting Agreement shall have five business days subsequent to executing the agreement to terminate Strategic Wealth Advisors’ services without penalty. C. Strategic Wealth Advisors shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Strategic Wealth Advisors shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Strategic Wealth Advisor’s services. D. Strategic Wealth Advisors does not participate in a wrap fee program. E. As of December 31, 2023, Strategic Wealth Advisors had $288,610,925 in assets under management, $266,996,850 on a discretionary basis and $21,614,075 on a non-discretionary basis.