A. Description of Firm Spectrum Strategic Capital Management, LLC (“Spectrum”) is an Oregon-based investment management firm, founded in 2001. We primarily offer services covering the areas of financial planning, portfolio construction, and asset management. We are currently registered with the Securities and Exchange Commission (“SEC”) as an investment adviser and with the State of Oregon as a Limited Liability Company (“LLC”). We conduct business in a number of states, which are reflected in Part 1 of our Form ADV, a copy of which can be found on www.adviserinfo.sec.gov. Currently, the principal owners (each owning between 14% to 43%) of the firm are, Greg Bachman, CFA & CFP®, Nichols Cutting, CPA, and Scott Meeker, CPA. They are all part of senior management and are considered control persons of the firm. B. Types of Advisory Services Offered Our advisory services fall into two broad categories: Financial Planning and Investment Management. Our financial planning services are available on a stand-alone basis or as part of our investment management services. Clients that request financial planning services only are under no obligation to have any recommendations contained in the written plan implemented by us. 1. Financial Planning Spectrum’s approach to financial planning is to (1) obtain significant financial and other information from the client, including attitudes, goals, and objectives; (2) analyze the information obtained in order to develop alternatives for consideration; and (3) explain the implications and potential outcomes of selecting a particular alternative. Based upon the client’s objectives, Spectrum will prepare a written financial plan addressing the stated financial goals. This plan may be comprehensive in nature, or modular, as directed by the client. The client is not under any obligation to implement any of the recommendations outlined in the financial plan at any time either with Spectrum or with any other firm. Clients always have the right to decide whether to act upon any recommendations and may follow or disregard, wholly or in part, any information, recommendation or advice provided by Spectrum. Should the Client decide to follow our recommendations, typically the investment services are offered through Spectrum pursuant to a client’s request for investment management services outlined in Item 4.B.2 below. Clients should know that Spectrum has conflicts of interest when making certain recommendations since Spectrum will receive fees, compensation and/or other concessions should the client implement such recommendations. More specifically, Spectrum will receive investment management fees should a client implement investment recommendations through us. In addition, certain advisory representatives of Spectrum also are licensed insurance agents with various unaffiliated insurance companies and their affiliated insurance agency, Spectrum Insurance Services, LLC. When the advisory representatives implement insurance transactions in this separate capacity, they receive normal and customary commissions for doing so. There exists a conflict of interest because there is an incentive for such advisory representative to recommend investment products for which they receive compensation. Clients always have the right to select any advisory firm or insurance agency or similar sales agency or representative to implement the advice and recommendations provided by Spectrum and/or our advisory representatives. Importantly, as part of Spectrum’s fiduciary duty to clients, the firm and our representatives endeavor at all times to put the interests of the clients first, and recommendations will only be made to the extent that they are reasonably believed to be in the best interests of the client. Additionally, the conflicts related to these services are disclosed by us to new clients through the delivery of the firm’s disclosure brochures (Form ADV Part 2A and Part 2Bs) and are outlined in the written agreement entered into by the client with Spectrum (“Client Agreement”). Please refer to Item 10 for further information on our financial affiliations. Financial plans are based on the client’s financial situation at the time of creation and are based on financial information disclosed by the client to Spectrum. Clients are advised that certain assumptions are made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance cannot be relied on as an indication of future performance. We cannot offer guarantees or promises that the client’s financial goals and objectives will be met. Further, Spectrum generally reviews and updates the plan based upon changes in the client’s financial situation, goals, or objectives or changes in the economy. Should the client’s financial situation, goals, objectives or financial needs change, the client is responsible for notifying us promptly of the changes. The following list represents the types of financial plans that we offer our clients: a. Investment Planning Profile When compiling an Investment Planning Profile, Spectrum will build a customized investment portfolio designed with a goal toward increasing returns and reducing risk. This model will be based on the client’s time horizon, risk tolerance level, tax situation, future income needs, and goals and objectives. We will generally perform a complete analysis of the client’s current portfolio and then compare it to our recommended investment portfolio. We will then suggest how the investments should be reallocated over various asset classes and the specific investment selection to implement our recommendations. We will provide a customized report that will define and assign the responsibilities of all involved parties and establish a clear understanding of the investment goals and objectives for the assets covered by the Investment Planning Profile. b. Cash Management Profile When constructing a Cash Management Profile, Spectrum will identify the client’s sources of income and expenses. This profile will evaluate cash flow based on how income is currently being spent. We will then examine and itemize total income versus total expenses including taxes, to determine whether there is a surplus or deficit at the end of the year. We will use this information to make prudent recommendations regarding short-term and long-term financial goals (including debt restructuring). c. College Planning Profile For College Planning Profiles, Spectrum will help determine the estimated future cost of a college education and provide the client with various funding methods available. The College Planning Profile will also take into consideration whether financial aid will be available and potential tax implications. We will then review assets currently available and examine the specific dollar amounts that will be required on a monthly or lump sum basis. We will also project the estimated future cost of any specific university. d. Risk Management and Survivors’ Needs Profile For those clients desiring Risk Management and Survivors’ Needs Profiles, Spectrum will evaluate and project the estimated future financial needs of the surviving spouse and other dependents. We will then review available resources for income, including current insurance programs, and the economic loss associated with a death, disability, or long-term illness of either spouse. We will also identify strategies to mitigate the identified risks. e. Accumulation Profile When compiling an Accumulation Profile, Spectrum will evaluate current and future estate accumulation and/or savings goals and the dollar amounts required for funding. We will review assets currently available and factor in time horizon, possible returns, and shortfalls, if any. f. Estate Planning Profile For clients desiring an Estate Planning Profile, Spectrum will calculate and evaluate the impact of estate taxes. We will assist the client in his/her goal of preserving assets today and in the future, as the client accumulates a greater amount of wealth. Specific tax savings and wealth transfer strategies will be provided in an effort to help assist the client in minimizing estate liabilities and to help ensure the client preserves his/her estate for the benefit of its intended beneficiaries. Other areas of consideration will include:  Maximizing the Unified Credit;  Uses of Various Wills and Trusts;  Methods of Providing Estate Liquidity; and  Future Growth of the Estate. g. Retirement Planning Profile Spectrum’s Retirement Planning Profiles identify a client’s retirement goals and estimates of future income and expenses. This profile will provide the client with helpful guidance in planning for a comfortable and possibly early retirement. We will review and examine the client’s current situation and the assets that will be available, including Social Security and/or other sources of income. Spectrum will determine the adequacy of future income and provide specific recommendations if there are any shortfalls. We will also run future growth projections, including the impact of inflation, to help increase the likelihood that the client does not outlive his/her income. Retirement Planning Profiles can also include: Social Security benefits strategies, complete investment analysis, and the impact of lifestyle choices on income requirements. h. Comprehensive Financial Plan When compiling a Comprehensive Financial Plan, Spectrum will prepare a complete financial plan that is designed to give clients a comprehensive financial analysis and evaluation, and a detailed roadmap to help them understand and work toward their goals. This plan is a compilation of some, or all of the financial profiles listed above, as appropriate for each client. It is our goal to become the client’s chief financial adviser and to coordinate the efforts of their other advisers for their best interests. If the client wishes, we will proceed to implement the alternatives selected; and periodically update the adopted plan as needed. 2. Investment Management There are three key elements to Investment Management: portfolio construction, implementation, and monitoring. Portfolio construction is based on the asset allocation model that has been determined to be appropriate for the client. In this phase, the client’s investment objectives, constraints, and preferences are identified and specified. The result is the determination of the percentages of a client’s total portfolio that should be allocated to each particular asset class. Implementation and monitoring is an ongoing process by which:  Strategies are developed and implemented through investments in a combination of financial assets;  Capital market conditions and client circumstances are monitored; and  Portfolio adjustments are made as appropriate to reflect significant changes in any or all of the above relevant variables. Spectrum managed account portfolios usually consist of, but are not limited to, a combination of some or all of the following: money market funds, mutual funds, stocks, bonds, unit investment trusts, exchange traded funds (“ETFs”), certain limited private offerings, and certificates of deposit. Per the Client Agreement, the client’s managed account will be a discretionary account for which Spectrum need not seek client approval prior to purchasing or repositioning assets. For more information on our discretionary authority,

please refer to Item 16, below. Clients, with assistance from Spectrum, will fully and accurately complete a questionnaire (“Client Profile”) in the form provided by us describing the client’s financial situation, investment objectives, time horizon, risk tolerance and investment preferences. We will utilize the Client Profile in rendering services to each client. Upon completion of a Client Profile, Spectrum and client will determine the appropriate portfolio investment strategy based on results of the Client Profile. Under all circumstances, clients are responsible for promptly notifying us of any material changes in the information furnished by the client in the Client Profile or information that is otherwise material to client’s financial situation, investment objectives, time horizon, risk tolerance and investment strategy. Clients will be provided with a written Investment Policy Statement (IPS) based on the results of the Client Profile. Clients and/or Spectrum can choose to exclude certain asset classes or specific securities from their managed account portfolio or modify the risk level for the portfolio type indicated. These exclusions and/or modifications will be included in the IPS. Currently, Spectrum offers the following investment strategies:  Investment Management Services Strategy  Enhanced Index Strategy The Investment Management Services Strategy’s investment objective allocations are designated as Ultra-Conservative, Conservative, Moderate, Moderate Growth, Growth, and Aggressive Growth. The Enhanced Index Strategy’s investment objective allocations are designated as Income, Growth and Income, or Capital Appreciation. Please refer to Item 8 below for details regarding the types of investments utilized for these two strategies. From time to time, we may change or create new portfolio investment strategies. Each client’s managed account portfolio can be invested similarly to, or different from, other clients with the same or similar objectives. Spectrum will monitor market conditions and the performance of each client’s portfolio, reposition assets as needed, and communicate any changes to clients in a timely manner. In the event that a client notifies Spectrum of changes to the information in their Client Profile, we will review such changes and recommend appropriate changes to the client’s IPS, if any. Once the amended IPS has been finalized, Spectrum will proceed in an orderly manner to make the necessary changes to transition to the client’s redesigned portfolio strategy. A client’s managed account portfolio can either be a cash account or a margin account. Unlike a cash account, a margin account allows the client to buy securities or withdraw cash by borrowing the money against the portfolio assets. While we do not encourage clients to borrow money for the purpose of building an investment portfolio, there are situations where the use of margin can offer the potential to take advantage of a buying opportunity. In those situations, we suggest that clients apply for margin privileges on their accounts in order to obtain this flexibility. However, in accordance with our fiduciary duty to our clients, we only suggest the use of margin in cases where we believe it is within the client’s overall investment goals and in the client’s best interest. Clients should be aware that the use of margin creates a conflict of interest between us and our clients since our fees are based on the full value of the assets under management including any assets purchased using margin. In order to mitigate that conflict, it is our goal to work with our clients to pay off the margin balance as quickly and efficiently as possible. Buying securities on margin subjects client to additional costs and risks that should be carefully considered before opening a margin account. We provide clients who wish to have margin accounts with a separate information sheet on such risks. For more information regarding the risks of loss in general, please refer to Item 8, below. For certain qualifying clients, Spectrum will recommend that a portion of such client’s assets be invested in one or more private investments. These can include, without limitation, hedge funds, real estate funds, private equity funds, venture capital funds, private placements, Delaware Statutory Trusts (“DST”) and other types of private pooled investment vehicles (collectively “Private Funds”). When determining which clients should receive a recommendation to invest in a Private Fund, Spectrum considers a number of factors, including but not limited to a client’s sophistication, risk tolerances and qualifications, investment objectives, and the amount of available assets in the client’s account(s). Spectrum’s goal is to allocate in a fair and balanced manner; however, given these differing factors, the allocation of investment opportunities in Private Funds to clients is mainly subjective and not all qualifying clients will be provided an investment opportunity. Clients that receive a recommendation to invest in Private Funds will be provided with a copy of each fund’s offering documents, which should be read in their entirety prior to investing in order to understand the investment objectives, fees, risks and conflicts pertaining to such investments. Please refer to Items 5 & 8 for further information. 3. Retirement Plan Investment Advisory Services Spectrum offers investment advisory services to defined contribution plans, defined benefit plans, and 401k retirement plans. Each plan sponsor will select whether they want us to serve as a Section 3(21) or Section 3(38) adviser. In providing services as a Section 3(21) adviser, Spectrum will: (i) assist the plan fiduciary in creating and/or updating the plan’s written Investment Policy Statement; and (ii) formulate model portfolios based on those investment options available to the plan, recommend investment options for the plan, periodically reviews the plan’s investment options, and meet with the client periodically in order to discuss. As a 3(21) adviser, Spectrum will not have discretion over a plan’s investments and assets. In providing services as a Section 3(38) adviser, Spectrum shall service as the investment manager for the plan and shall have (i) discretion over the establishment of the plan’s IPS; and (ii) discretion over the selection, monitoring, removal and replacement of the plan’s investments. Also, dependent on client needs, Spectrum will provide training and education and answer general questions from plan participants relating to the characteristics of and considerations for the plan’s investment selections. Educational seminars for plan participants generally cover the following areas: (1) financial planning, (2) risk management, (3) types of investments, (4) estate planning, and (5) taxes. If the Plan is participant-directed, Spectrum will, if requested, provide advice to any individual plan participant as to the participant’s investment in securities made available by the plan. In doing so, the Firm will take into account a participant’s specific needs, age, investment horizon, and other relevant factors. However, such services do not include discretionary asset management by Spectrum of investments made by participants. Also, Spectrum will not receive any fees directly from plan participants for the performance of this service. C. General Information about Spectrum’s Services 1. Gathering Individual Client Information As explained above, services provided by Spectrum are customized to meet the individual needs, objectives, and other financial goals of the client. Early on in the relationship, we will typically memorialize each client’s investment objectives, risk tolerance, time horizons and other important and necessary information, including any investment guidelines, in the client’s Client Profile and IPS. We will use this information, together with any other information relating to the client’s overall financial circumstances, to determine the most appropriate asset allocation and investment strategy that we believe best meets each client’s financial goals. There may be times when certain restrictions are placed by a client which prevents us from accepting or continuing to service the client’s account. Spectrum reserves the right to not accept and/or terminate a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting and/or maintaining the objectives covered in the IPS. 2. Responsibility for Accuracy Spectrum will not assume any responsibility for the accuracy of the information provided by the client. We are not obligated to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and are expressly authorized to rely on the information as provided. Under all circumstances, clients are responsible for promptly notifying us in writing of any material changes to their financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies Spectrum of changes in their financial circumstances, we will review such changes and when warranted, recommend that updates be made to the client’s financial plan, IPS and/or managed account portfolio. 3. Advisory Agreements Prior to engaging Spectrum to provide advisory services, each client will be required to enter into one or more written Client Agreements with us, setting forth the services to be provided, the fees to be charged and the terms and conditions under which we will render our services. Spectrum will provide a Brochure (Form ADV Part 2A) and the applicable Brochure Supplements (Form ADV Part 2B) to each client or prospective client prior to or upon execution of our written Client Agreement. The advisory relationship will continue until terminated by the client or Spectrum in accordance with the provisions of the executed Client Agreement(s). D. Assets Under Management As of December 31, 2023, the following represents the amount of client assets managed by Spectrum on a discretionary and non-discretionary basis: Type of Account Assets Under Management (“AUM”) Discretionary $203,587,998 Non-Discretionary $6,170,572, Total $209,758,570 E. Education and Business Standards of Spectrum’s Representatives Spectrum generally requires its Investment Adviser Representatives to successfully complete university study and/or its educational or business equivalent. We select those persons who have demonstrated knowledge of the financial and economic principles needed in providing sound investment and financial planning advice. These skills are demonstrated by their business background, education, passing of FINRA securities examinations, or professional designations such as Certified Financial Planner (CFP®), Certified Financial Analyst (CFA®) or Certified Public Accountant (CPA). We also expect everyone associated with us to conduct business according to the highest standards of honesty and fairness, and that they render services to their customers in a manner that they would apply to or demand for themselves. Spectrum’s Investment Adviser Representatives should have no securities related disciplinary history. Each Spectrum investment advisory representative’s education and business history is outlined in their respective Form ADV Part 2B, a copy of which is provided to all clients and can be requested by contacting us.