Bellatore Financial, Inc. (“Bellatore” or the “Firm”) is located in Pleasant Hill, California and provides asset management services to select financial advisory businesses across the U.S. Bellatore is principally owned by Bellatore Holdings, Inc. (formerly known as Bella Fund Holdings, Inc.), which is primarily owned by Larry A. Harvey. A complete listing of Bellatore’s ownership can be found on the Firm’s ADV Part 1A. Bellatore has provided investment advisory services since 2007. As of December 31, 2023, Bellatore managed $513,325,252 in assets under management, $17,009,523 on a discretionary basis and $496,315,729 on a non-discretionary basis. Bellatore was founded with a central purpose: to empower advisors through higher quality solutions. Bellatore provides turn-key asset management programs to independent registered investment advisors to help provide those advisors with more time for what truly matters—enhancing their businesses and servicing client relationships. Bellatore also provides customized outsourcing centered on business management, back-office support, investment solutions and wealth planning. Bellatore provides its advisory firm clients with consultative advice regarding the design of investment advisory products and services including positioning, strategy and efficacy of plans, programs and products. Additionally, Bellatore provides investment management and model portfolio solutions to the clients of the advisory firms that partner with Bellatore. Bellatore's Management Authority All portfolios are maintained as separate accounts in the client's name with a qualified independent custodian. The managed portfolio consists of all assets held in the client’s account. Bellatore exercises its power and authority under the terms of the relevant program agreement. Bellatore does not maintain custody or possession of client assets or funds. Bellatore provides ongoing investment supervision of the portfolios and provides quarterly reporting to clients regarding their accounts. UNIFIED MANAGED ACCOUNT PROGRAM The Unified Managed Account Program (“UMAP”) provides clients investment advisory services through an open-architecture structure that combines a variety of securities and strategies. Under the terms of the UMAP client agreement, Bellatore provides asset allocation guidance and strategies, portfolio construction, trading, rebalancing, performance reporting, account monitoring and administration. CAPITAL ALLOCATION & MANAGEMENT PROGRAM The Capital Allocation & Management Program (the “CAM Program”) is a discretionary investment management offering in which Bellatore constructs and manages portfolios that consist of mutual funds and/or exchange traded funds (“ETFs”), or a combination of mutual funds and ETFs. These portfolios are designated in varying degrees from conservative, to moderate, to aggressive. In consultation with their independent advisor, clients can choose from a group of portfolios that most closely match their investment objectives and risk tolerances. Bellatore manages the portfolios to respond to changing capital market conditions and periodically rebalances the portfolios as needed. Clients may change the portfolio type if their circumstances change. The portfolio implementation options consist of: Tax Efficient Portfolios for taxable accounts; Tax Deferred Portfolios for qualified accounts, Exchange Traded Fund Portfolios for tax efficiency; Exchange Traded Funds for qualified accounts; and Hybrid Portfolios of mutual funds and exchange traded funds. The Hybrid portfolios may be used for taxable accounts but will not be managed for tax efficiency. For tax deferred portfolios, the Firm has Tax Advantage Portfolios of Variable Annuities from either Security Benefit Corporation

or Jefferson National Life Insurance Company. CAM Program Sub-Advisory Services Bellatore provides sub-advisory services on managed money platforms, and as such, provides investment advisory services to certain clients of these firms. Bellatore constructs and manages mutual funds and/or ETF portfolios, as well as hybrid portfolios consisting of combinations of such instruments, which have varying degrees of risk ranging from conservative to aggressive. The investment and reinvestment of client's assets are in accordance with the specific investment styles, risk tolerances and the investment objectives and policies set forth in the appropriate client agreement, as updated periodically by the client. ALTIUS SELECT INVESTMENT PORTFOLIOS The Altius Select Investment Portfolios Program (the “Altius Program”) provides investment advisory services designed to meet individual clients’ investment objectives through investments in mutual funds, based on information clients prepare with the assistance of their investment advisor. Clients participating in the Altius Program enter into an agreement with Bellatore and their advisor. The Altius Program client agreement grants Bellatore the authority to: change or modify the Portfolios, asset allocation percentages, and selection of investments; effect transactions in client accounts without seeking approval or discussing investments decisions with clients first; periodically rebalance client assets; and manage client assets for compliance with the portfolios’ investment objectives. The Altius Program consists of portfolios of mutual funds that correspond to specific investor profiles, ranging from conservative to aggressive, with suggested asset allocations developed by Bellatore’s investment committee. Each portfolio is comprised of mutual funds that represent the various asset class allocations included in the corresponding investor profile. Bellatore selects and monitors the mutual funds included in the portfolios. With the assistance of their Advisor, clients may select the portfolio that may best fit their current investment objectives. Altius Program Sub-Advisory Services Bellatore provides sub-advisory services on managed money platforms, and as such, provides investment advisory services to certain clients of these firms. Bellatore constructs and manages mutual fund portfolios, which have varying degrees of risk ranging from conservative to aggressive. The investment and reinvestment of client's assets are in accordance with the specific investment styles, risk tolerances and the investment objectives and policies set forth in the appropriate client agreement, as updated periodically by the client. DOL Disclosure 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.