Sowell Management is a fee-based investment adviser located in North Little Rock, Arkansas. Sowell Management also does business as Trek Wealth Solutions. Sowell Management provides investment portfolios for individuals, retirement plans, corporations, registered investment advisers and institutions. The firm has many branch office locations located in various states operating under a variety of names. In most cases, each name is a separately incorporated business owned by an investment advisor representative (“IAR”) or multiple IAR’s. The firm has an independent contractor model where IAR’s are generally not Sowell Management employees but rather independent contractors whose services, including portfolio management, can vary significantly from one another. In addition to this independent contractor model, Sowell Management also provides services such as portfolio management, trading, compliance consulting, marketing, outsource financial planning, and technology to certain IAR’s and unaffiliated registered investment advisors (“RIAs”). The firm was established in 2001 by Sowell Management, Inc. and Cindy Sowell. Sowell Management Inc. is owned by William Sowell and his family. As of December 31, 2023, Sowell Management had $ 3,329,402,135 in assets under management, $ 3,328,990,627 of which was managed on a discretionary basis and $ 411,508 of which was managed on a non-discretionary basis. Sowell Management is committed to helping clients build, manage, and preserve wealth, and to provide assistance to clients to help achieve their stated financial goals and investment objectives. Sowell Management offers a variety of advisory services, which include financial planning, financial consulting, and investment management services. Prior to Sowell Management rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Sowell Management setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). While this brochure generally describes the business of Sowell Management, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, independent contractors or any other person who provides investment advice on Sowell Management’ behalf and is subject to the Firm’s supervision or control. Investment Management Services Sowell Management manages client investment portfolios on a discretionary or non-discretionary basis. Sowell Management primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with their stated investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage Sowell Management to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and variable annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Sowell Management directs or recommends the allocation of client assets among the various investment options available within the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. Sowell Management typically begins its investment management services by using a client profile or similar document that provides questions regarding a client’s time horizon, long-term goals and expectations, and short- term risk attitudes. This will help clients identify their most comfortable style of management. Clients may also indicate any special instructions or limits in managing assets. Those instructions must be in writing. Through continuous monitoring of asset class segments’ return and risk factors, the Firm may change portfolio asset mixes in an effort to help meet objectives. The specific percentages allocated to each asset class may vary due to the nature of asset performance and/or the strategy selected. It is the Firm’s intent to maintain a risk exposure commensurate with each client’s objectives by using the various investment portfolio choices available under the strategy selected by that client. The advisory services provided by each Sowell Management IAR may vary. Sowell Management IAR’s tailor advisory services to meet the needs of their individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Sowell Management IAR’s consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. When acting as a sub-advisor for other registered investment advisers, the Firm relies upon this information to be provided by that investment adviser and the Firm does not work directly with the individual client. Clients are advised to promptly notify Sowell Management if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Sowell Management determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Third Party Investment Advisory Services We also provide individualized client services through the selection of a suitable third-party money manager, or sub-advisor. Factors considered in the selection of a third-party manager include, but may not be limited to, an IAR’s preference for a particular third-party manager, client risk tolerance, investment timeframes, goals, and objectives, as well as investment experience, and the amount of assets available for investment. We receive compensation for introducing clients to third-party asset managers and for certain ongoing services provided to clients. These arrangements create a potential conflict of interest because we may have an incentive to refer a client to these third-party asset managers. All third-party asset managers to whom we refer clients are licensed as investment advisers by their resident states and any applicable jurisdictions or by the Securities and Exchange Commission. Sub-Advisory Services Under separate agreement we will have the authority to allocate and reallocate client assets among various investment managers and will allocate assets to Sub-advisors based on that authority. Sub-advisors are licensed as investment advisers by their resident states and other applicable jurisdictions or with the Securities and Exchange Commission. The Sub-advisor will have the power and authority to supervise and direct all investment decisions for those accounts designated by the Firm on a discretionary basis, including the purchase and sale of securities and any other transactions unless specifically directed otherwise in writing. The Sub-advisor will have discretionary authority to aggregate (combine) purchases and sales of securities with similar orders of other clients and proportionately divide up securities if unable to fill all orders. An account will be deemed to have purchased or sold its proportionate share of the securities at the average price determined for the overall transaction when transactions are aggregated. More information on the Sub-advisor’s aggregation policies are shown in each Sub-Advisor’s brochure. Sowell Affinity Sowell Management has entered into a sub-advisory agreement with Affinity Investment Advisors, LLC (“Affinity”) to offer investment management services to clients of Sowell Management. Clients of Sowell will not pay additional fees for use of Affinity services; Sowell pays Affinity a portion of the client’s management fee. Affinity also acts as the sub-advisor to the Affinity World Leaders Equity ETF (“ETF”, WLDR). The ETF may be recommended to the client portfolios sub-advised by Affinity if such investments are consistent with the investment objectives of the client. If Affinity makes such an investment, those clients will be responsible, indirectly (as investors in the ETF) for a portion of the operating expenses and investment advisory fees, in addition to the management fee charged by Sowell and Affinity. Flex Accounts The Sowell Flex program offers unified managed account (UMA) platforms that allow the firm and our IARs the ability to open an account and utilize multiple third-party investment strategies as well as individual securities. To open a Flex account your IAR will obtain the necessary financial data from you to assist with setting appropriate investment objectives, determining the suitability of the program, and in opening your account. The IAR assists the client with selecting a model portfolio of securities designed and managed by a third-party investment adviser available through the Flex platform. The third-party investment advisors typically construct various model investment portfolios that are managed according to specific investment strategies associated with the respective models, and that are not generally customized for individual clients. Generally, you may request reasonable investment restrictions on investing in securities. Sowell, Sowell Affinity, or other third-party investment advisors are granted client authority by you in client and custodian agreements, to purchase and sell securities on a discretionary basis pursuant to investment objectives identified by you. The services provided by each third-party investment advisor in the Flex program are unique; you should request and carefully review the applicable Brochure for each third-party investment advisor for information about the services provided by the third-party investment adviser, including a description of the third-party investment advisers background, investment strategies, conflicts of interest, and other relevant information regarding the third-party investment adviser. Sowell utilizes the services of the GeoWealth, Adhesion Wealth, and SmartX Advisory Solutions platforms to deliver its Flex account services to you. Since the services provided by GeoWealth, Adhesion Wealth platform, and SmartX Advisory Solutions are unique, you should request and review the Brochure for each firm for more information about the services provided by each company. Clients may request a copy of the Brochure for any third-party adviser or GeoWealth, Adhesion Wealth, and SmartX from their IAR or by visiting www.adviserin.sec.gov.

Financial Planning and Consulting Services The Firm’s investment management services may include the analysis of a client’s situation and assistance in identifying and implementing appropriate financial planning and investment management techniques to help meet specific financial objectives. Sowell Management’ financial planning and consulting services may include any or all of the following functions:
• Determination of appropriate income planning strategies for both pre- and post-retirement.
• Review of existing and proposed investment asset mixes.
• Calculation of pre-retirement savings and investing needs.
• Assessment of overall financial position including net worth, cash flow, and debt.
• Comprehensive analysis of IRA-related issues.
• Estimates of federal estate taxes and a suggested plan of action to help meet estate planning objectives.
• Review and determination of life and disability insurance needs.
• Suggestions for minimizing federal and state income tax obligations.
• Development of investment strategies consistent with business ownership succession and transition planning. In performing these services, Sowell Management is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Sowell Management may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Sowell Management or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Sowell Management under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Sowell Management’ recommendations and/or services. Subscription Self-Directed Financial Planning Tools and Assistance Certain IARs may offer self-directed financial planning tools through a website portal. These tools include but are not limited to budgeting, debt reduction, insurance planning, college planning, and may include access to a financial planner / IAR for consultation. Additional comprehensive financial planning services are available depending upon your needs. Retirement Plan Advisory Services Retirement Plan Advisory Services consists of helping employer plan sponsors to establish, monitor and review their company's retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment selection and monitoring, plan structure, and participant education. Sowell Management offers management of 401(k), 457, and 403(b) accounts both on a plan level and on the individual participant level. At the plan level the Firm manages the investment line-up making changes as necessary as well as providing risk-based investment models for the participants. On the individual participant level, the Firm manages risk-based models using the current investment lineup based on risk tolerance of the individual investor. Plan Level Sowell Management will establish the plan’s needs and objectives through an initial meeting to collect data, review plan information, and assist in developing or updating the plan’s provisions. Ongoing services may include recommendations regarding the selection and review of unaffiliated mutual funds that, in the Firm’s judgment, are suitable for plan assets to be invested. The Firm periodically reviews the investment options selected and makes recommendations to keep or replace plans investment options as appropriate. Sowell Management performs a comprehensive review of Investment options and will assist with converting from incumbent service providers to a new service provider if appropriate. Sowell Management will provide periodic recommendations for the plan’s investment allocation. Upon receipt the Firm will review the investment options and provide positions for accounts in accordance with the management style chosen by the client. The analysis with specific fund positions will be sent to the client. Clients are responsible for making the fund changes within the account. Participant Level The Firm can also be engaged to provide financial education to plan participants. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA and participant education will relate to general principles for investing and information about the investment options currently in the plan. Sowell Management may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. Conflict of Interest – IRA Rollover Recommendations When recommending that a client rollover his or her account from current retirement plan to an IRA, Sowell and its investment adviser representatives have a conflict of interest. Sowell and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, Sowell and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan (unless a client retained the firm to provide advice about the client’s retirement plan account or the retirement plan has retained the firm to provide advice at the plan level). Thus, Sowell and its investment adviser representatives have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest. Sowell has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA. Sowell and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in the firm receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by Sowell and its supervised persons and any material conflicts of interest related to Sowell recommending the rollover of funds from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our 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 we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. RIA Co-Brand- Business Entities of Investment Advisor Representatives Investment Advisor Representatives may have their own legal business entities whose business names and logos may appear on marketing materials approved by RIA firm, or client statements as approved by the Custodian. The Client should understand that the businesses are legal entities of the Investment Advisor Representative and not the RIA Firm, nor the Custodian. Additionally, the business entity may provide services other than as an Investment Advisor Representative as disclosed herein such as CPA, attorney, insurance, broker dealer, as well as other non-investment related services; however, Investment Advisory Services of the Investment Advisor Representatives are provided through RIA Firm. Additional information about the aforementioned arrangement the RIA Firm has with an Investment Advisor Representative can be found within the respective ADV part 2B, also referred to as the brochure supplement which contains information about the educational background, business experience, and disciplinary history (if any) of the IARs who provide advisory services to the client. Signals Sowell Management has entered into agreements with various third parties that provide investment guidance regarding when to buy or sell certain securities (“Signal Providers”) that Investment Advisor Representatives and other unaffiliated Registered Investment Advisors who utilize our services may consider in managing some or all of their accounts. The Signal Providers will not manage or exercise investment discretion or trading authority over any client account and have no duty to client, fiduciary or otherwise. Sowell Management retains exclusive responsibility for making the determination of whether to implement any of the signals in client accounts. Signal Provider has no contractual or advisory/fiduciary relationship. Ancillary Services Sowell Management also provides additional ancillary services to IAR’s in order to support the IAR’s business operations. These ancillary services are needed because IAR’s operate under a separate legal entity as an independent business model which is separate and distinct from Sowell Management. Those ancillary consulting services may include compliance consulting services as well as consulting services for billing, technology, back- office support, portfolio management, trading, onboarding and creative design. Some or all of these ancillary consulting services are available for use by the respective IAR’s based on its particular business needs regarding its day-to-day operations. The ancillary consulting services being provided could create a conflict of interest for the Firm. Given Sowell Management’s independent business model, Sowell Management IAR’s are not obligated to use all ancillary services offered through Sowell Management. For example, IAR’s may conduct their own portfolio management and trading or use separate technology systems.