Paratus Financial, Inc. was founded by Bonnie Free Chadwick in 2003. Paige E. Boyer, and Olivia S. Kriscunas were appointed directors in 2017. Our current directors’ biographies can be found under Educational Background. Paratus Financial, Inc. provides comprehensive financial planning services in the areas of tax, investments, risk management, estate planning, and retirement. Fees are based on hourly rates and incorporated into annual fixed fee contracts prior to engagement. Paratus Financial, Inc. provides custom financial planning services to high-net-worth individuals, families, trusts, estates, retirement plans, endowments, corporations and charitable organizations. These services include making specific investment recommendations, reviewing performance compared to a predetermined benchmark, analyzing risk compared to a predetermined benchmark, reviewing other investment managers, prioritizing and quantifying clients’ financial goals and objectives, optimizing investment strategies with respect to taxes and account styling, retirement planning and long-term cash flow analyses, debt management, employee benefits, income tax planning, and estate planning. Paratus Financial, Inc. reviews the client’s financial objectives, recent statements for brokerage and retirement accounts, annual income including earned income and passive income, annual spending, tax returns and charitable objectives, and estate documents and gifting goals. We aid the client to develop a strategy through which Paratus Financial, Inc. can assist the client in managing their investment portfolio, tax planning, and estate planning. Particular services are in an annual contract signed by each Account Manager and client. Financial exhibits, asset allocations, investment performance, statements of investment policy, and other various reports will be utilized and provided to the client depending on the description of services summarized in the contract. Specific Investment Recommendations Paratus Financial, Inc. identifies each individual’s risk tolerance and establishes a target portfolio asset allocation. We implement and monitor investments review risks within the target. Specific Fixed Income Recommendations To implement a secure strategy using mutual funds, Paratus Financial, Inc. monitors performance, credit risk, interest rate risk (duration) and fee structure. Paratus Financial, Inc. reviews the appropriateness of these funds at least monthly. Paratus Financial, Inc. also recommends use of professional third-party bond managers. We recommend bond managers to buy individual bonds in clients’ portfolios when appropriate. We review a clients’ duration and credit risk across their entire portfolio to recommend a bond investment strategy. We do not receive any compensation for recommending these 3rd party managers. We have discretion over the assets when they are managed by 3rd party managers. Paratus Financial recommends clients diversify risk assets among securities, among markets, among sectors and among management styles. Specific Equity Investment Recommendations The investments we recommend are mutual funds and ETFs. These funds are publicly traded, liquid, and transparent. The funds are reviewed quarterly for appropriateness in our clients’ portfolios. The criteria we use for passive funds are market liquidity and correlation to the fund’s target index. For actively managed funds, we evaluate manager tenure, long term performance, fee structure, risk adjusted returns, and return and style consistency. Appropriate investment recommendations are based on a buy and hold strategy, rather than market timing, daily trading, or a revolving door of new investments. We recommend investment strategies that reflect current market conditions and long-term market trends. We offer unbiased advice on investment strategies since we are not compensated by investment managers. We have discretion over some of our clients’ assets and are responsible for all trades and account management. Further, a client may self-direct or hire a third party to manage a portion of their portfolio. We incorporate these assets into our overall investment recommendations. We consider a clients’ entire portfolio, including those assets not under our discretion. Mutual funds have shares classes with varying fee structures. We do not differ in share class recommendation among clients and client may purchase our recommended funds directly (or through their retirement plans). We do not accept referral fees or commissions from our recommendations. All client fees are negotiated in an annual contract with each client to determine what services each client needs for the next year. Performance: Paratus Financial, Inc. provides portfolio returns and compares the returns to a specific and predetermined benchmark. We review with clients the dollar and percentage returns, how it relates to the rest of the investment market, what investments in their portfolio contributed to performance. Portfolio Risk: Paratus Financial, Inc. reviews a portfolio’s risk by analyzing the standard deviation of the portfolio and specific funds over a long period (10 years) compared to the benchmark. We also evaluate a portfolio’s value-at-risk. Other Investment Managers: Some Paratus Financial, Inc. clients retain other investment managers. Paratus Financial, Inc. does not have discretion over these accounts. We will, at the clients request and per our annual contracts, evaluate the managers performance, risk, style drift. We will review investment proposals from other managers to ensure it complements the client’s overall portfolio and financial objectives. Financial Goals and Objectives: Paratus Financial, Inc. assists clients with quantifying and prioritizing financial goals and objectives. These are typically noted in a statement of investment policy and the portfolio will be managed with these goals in mind. Some financial goals may include funding education, paying off debt, optimizing yield in a portfolio to provide living expenses, charitable objectives, and gifting goals. Optimizing Investment Strategies with Respect to Taxes and Account Styling: Investment recommendations consider tax implications such as deferred tax on qualified retirement accounts and realizing gains in after-tax accounts. To the extent possible and without impeding on sound economics, we strive to minimize tax implications in a portfolio. This includes recommending tax-exempt municipal bonds in after-tax portfolios for clients in higher tax brackets, rebalancing in retirement accounts, prioritizing qualified dividends in after-tax accounts and non-qualified dividends in retirement accounts. We also consider asset ownership during portfolio construction. Paratus Financial, Inc. works with

clients to ensure assets held jointly, separately, in retirement accounts, or invested for the next generation are invested appropriately. Retirement Planning and Long-Term Cash Flow Analyses: Paratus Financial, Inc. assists clients with evaluating if they are financially independent to pursue retirement, or when they will become financially independent. We use a Monte Carlo analysis for these discussions. Account Managers emphasize the variables in the Monte Carlo are sensitive and that results are not guaranteed. We provide multiple reports showing slight changes in expectations (life expectancy, market returns, spending) to illustrate how sensitive the analysis is. During this process, we assist clients in determining their annual spending and expected spending in retirement and establish a reasonable target rate of return in relation to their risk tolerance. Debt Management: Paratus Financial, Inc. will review clients’ debt and assist with prioritizing paying off debt to maximize tax deductions and minimize cash outflow. We advise on optimal mortgage strategies, such as paying off a mortgage, refinancing, or recasting, when appropriate. Employee Benefits: Paratus Financial, Inc. assists with client’s evaluation of employee benefits, such as 401(k) participation and investments, supplemental retirement plans, cash balance plans, deferred compensation, and stock awards. We optimize savings with respect to a client’s tax situation. We review clients’ restricted stock awards and stock options as a piece of their portfolio and on their asset allocation. We do not advise on exercising stock options as we do not advise on individual stock positions. For clients who have material inside information or stock holding requirements, we monitor clients’ trading with respect to corporate governance requirements. Income Tax Planning: Since our firm typically prepares and files income tax returns for our clients, we are also involved in income tax planning. This includes calculating and managing retirement distributions, monitoring capital gains, recommending timing and source of charitable contributions, staying apprised of changes in income tax laws, and other income tax items. Estate Planning: Paratus Financial, Inc. recommends 3rd party attorneys for clients to update their estate plan, wills, and ancillary documents to reflect changes in estate tax laws, changes in portfolios, and interpersonal changes. We will advise on estate tax strategies, given our knowledge of a client’s portfolio and income tax situation. Retirement Plan Rollover Recommendations - When Paratus Financial, Inc. provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that Paratus Financial, Inc. is a “fiduciary” 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. The way Paratus Financial, Inc. makes money creates conflicts with your interests so Paratus Financial, Inc. operates under a special rule that requires Paratus Financial, Inc. to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, Paratus Financial, Inc. must as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of Paratus Financial, Inc. ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Paratus Financial, Inc. gives advice that is in your best interest;
• Charge no more than is reasonable for the services of Paratus Financial, Inc.:
• Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Paratus Financial, Inc., please know that Paratus Financial, Inc. and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Paratus Financial, Inc. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Paratus Financial, Inc. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Paratus Financial, Inc. receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Paratus Financial, Inc. and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Paratus Financial, Inc. or our affiliated personnel. Client Assets Under Management As of December 31, 2023, Paratus Financial, Inc.’s assets under management totaled $619,615,968. $202,365,327 are managed on a discretionary basis and $417,250,641 are managed on a non- discretionary basis.