Since 2004, Wealthstream has been in business as a registered investment adviser, which specializes in providing financial planning and investment management services to individuals, and high net worth clients Wealthstream is driven by its mission to meet the high standard of quality and service that its clients deserve and expect. Wealthstream is owned by a select group of its employees including Michael Goodman, President who owns greater than 25% of the Firm. Financial Planning Services Wealthstream may provide its clients with a broad range of financial planning services, which may include advice on non-investment related matters. Wealthstream crafts a personal financial profile for its clients, illustrating their financial goals and assets. Generally, these financial plans address a broad range of personal matters, including cash flow needs, investment growth, savings strategies, personal investment preferences, individual risk tolerance, as well as retirement, estate, tax, debt, educational and insurance planning. While certain of Wealthstream’s financial planning services may be rendered as part of a wealth management arrangement (in conjunction with portfolio management, as explained below), Wealthstream may also provide financial plans as a standalone service offering. In performing its services, Wealthstream is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. Wealthstream may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Wealthstream recommends its own services. The client is under no obligation to act upon any of the recommendations made by Wealthstream under a financial planning engagement or to engage the services of any such recommended professional, including Wealthstream itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Wealthstream’s recommendations. Clients are advised that it remains their responsibility to promptly notify Wealthstream if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the firm’s previous recommendations and/or services. Investment Management and Wealth Management Services Clients can engage Wealthstream to manage all or a portion of their assets on a discretionary basis, which may include a broad range of financial planning services. Wealthstream primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), individual debt and equity securities and/or options, as well as the securities components of variable annuities in accordance with the investment objectives of the client. In addition, Wealthstream may render investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that may not be held by the client’s primary custodian. In so doing, Wealthstream either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Tailored Relationships Wealthstream tailors its advisory services to the individual needs of clients. Wealthstream consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. Clients are advised to promptly notify Wealthstream if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon Wealthstream’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets are invested in sustainable funds) if, in Wealthstream’s sole discretion, such conditions would not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Retirement Rollovers-Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Wealthstream recommends that a client roll over their retirement plan assets into an account to be managed by Wealthstream, such a recommendation creates a conflict of interest if Wealthstream will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by Wealthstream. Wealthstream Advisory team remains available to address any questions that a client or prospective client may

have regarding the potential for conflict of interest presented by such rollover recommendation. Retirement Plans Wealthstream will provide consulting services to qualified retirement plans and their fiduciaries based upon an analysis of the needs of the plan. In general, these services may include an existing plan review, assistance in the development of a retirement plan, evaluation of retirement plan vendors, asset allocation advice, communication, and education services to plan participants, investment performance monitoring, and/or ongoing consulting. Wealthstream will provide consulting services to the plan fiduciaries as described above. Typically, the named plan fiduciary must make the ultimate decision as to retaining the services of such investment advisers as Wealthstream recommends. The plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan. Use of Independent Managers As mentioned above, Wealthstream recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms, compensation, and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between the client and the designated Independent Managers. Wealthstream renders services to the client relative to the discretionary and/or non- discretionary selection or recommendation of Independent Managers. Wealthstream also monitors and reviews the account performance and the client’s investment objectives. When recommending or selecting an Independent Manager for a client, Wealthstream reviews information about the Independent Manager such as its disclosure statement and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that Wealthstream considers in selecting or recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, Wealthstream’s investment advisory fee. In addition to Wealthstream’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than Wealthstream. In such instances, Wealthstream may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Wealthstream does not participate in a Wrap Fee Program. Client Assets As of December 31, 2023, Wealthstream had $1,347,237,878 in assets under management, all of which are managed on a discretionary basis.