Registration Status – Registered with the SEC on March 11, 20081 Registered with the State of California on May 8, 2002 Principal Owners – Peter M. Burton, through PMB Asset Management Robert D. Enright, through RDE Asset Management Jeremy A. Welch, through JAW Asset Management Benjamin R. Peters, through BRP Asset Management Kelly M. Metzler, through KMRAsset Management Christopher S. Hughes, through CSH Asset Management Assets Under Management – Discretionary: $ 1,023,293,243 (as of December 31, 2023) Non-Discretionary: $ 110,497,469 Total AUM: $ 1,133,790,712 ADVISORY SERVICES INVESTMENT MANAGEMENT SERVICES We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our Firm is a partnership formed in the State of California. We specialize in the following types of services: investment management, financial planning, and retirement plan consulting. As part of our Investment Management service, we generally create a portfolio that consists of among the following: mutual funds, exchange traded funds (ETFs), individual stocks or bonds, options, and other public and private securities or investments or sub-advised investment programs. The client’s individual investment strategy is tailored to their specific needs. Each portfolio will initially be designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. We apply a significant level of discipline in our approach to investing. This discipline allows us to stay true to both our management style and our client’s individual objectives. We begin the investment initiative by conducting a detailed financial analysis that includes gaining an understanding of our client’s risk tolerance. Based on our analysis, we develop an Investment Policy Statement (IPS), which outlines the investment objectives, management policies and portfolio. We usually allow clients to impose reasonable restrictions on investing in certain securities or types of securities. A client retains the authority to make additions to and withdrawals from the client’s custodial account at any time, subject to the Firm’s right to terminate a relationship if the amount of assets under management falls to a level that no longer warrants our services. Clients retain the authority to withdraw account assets with notice to the Firm, subject to the usual and customary securities settlement procedures. However, we design client portfolios as long-term investments and caution 1“Registration” means only that the Firm meets the minimum requirements for registration as an investment advisor and does not imply that the SEC or any other regulator guarantees the quality of our services or recommends them. our clients that ongoing or significant asset withdrawals will impair achievement of the client’s investment objectives. Additions to an account may be in cash or securities. However, a client’s custodian may decline to accept particular securities into a client’s account. Or we may recommend that the security be liquidated prior to transferring it to an account we manage if doing so would benefit the Client. Clients are advised that when transferred securities are liquidated, they will be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. Four Steps to Discipline Our goal is to provide our clients with consistent, competitive investment returns over time. We follow a four-step approach to investment management that removes emotion from the equation and allows us to focus on our client’s future. In this way, we can capture opportunities reflective of client expectations and the ever-changing marketplace. Step 1: Target Allocation We begin with a target asset allocation, which represents a reasonable static asset allocation for a long-term investor. This allocation serves as a frame of reference to help ensure consistent, disciplined decision-making. It also serves as a benchmark against which we measure conviction as well as value added (alpha). Step 2: Active Asset Allocation We adjust the target asset allocation to take advantage of opportunities consistent with a client’s long-term goals. We conduct an in-depth analysis of fundamentals and valuations to identify an undervaluation, or overvaluation, relative to alternative asset classes. We analyze opportunities with an emphasis on the potential risks to client portfolios. Step 3: Active & Passive Management We use a combination of active (no-load funds) and passive (exchange traded funds – ETFs – and index funds) management vehicles. We take into account management experience, possible value add (alpha) and style when pursuing active management. When evaluating passive management, we look at market and cost efficiencies as well as consistency of those vehicles. Depending upon our strategy at a given time, we may under-weight and over-weight passive versus active management. Step 4: Monitoring We review portfolios on an ongoing basis against benchmarks specific to that portfolio. We use a thorough methodology to determine a portfolio’s performance on both an absolute and a relative basis. These benchmarks serve as our report card, which we share with our client’s quarterly through detailed performance reports. FIDUCIARY STATUS When we provide investment advice to you regarding your investment accounts, including your retirement plan account or individual retirement account, we are fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities and Exchange Commission, as applicable. These regulations require us to act in your best interest and not put our interests ahead of yours. FINANCIAL PLANNING AND CONSULTING SERVICES We provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation

for clients based on their financial goals and objectives. Services encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. It should also be noted that when requested by a client, we refer clients to outside accountants, attorneys or other specialists, as necessary for non-advisory related services. Implementation of the recommendations will be at the discretion of the client. For those clients that engage our financial planning services on a stand- alone basis, we require a signed agreement delineating the services to be provided. Burton Enright Welch recommends to its financial planning clients that they retain the Firm as their investment advisor to implement its recommendations. Such recommendation gives rise to a conflict of interest. Financial planning clients are hereby advised that they are under no obligation to act on our investment recommendations. PAST REFERRALS TO THIRD PARTY INVESTMENT MANAGERS In the past when appropriate, we provided clients with a list of investment advisory services of third- party professional management firms for the management of client accounts or portions thereof. Such third-party investment firms assumed portions of the administrative role associated with servicing these client accounts. In these cases, there may be a modified fee schedule and some variation in how these remaining client accounts are billed and serviced. As part of this process, we assisted clients in identifying an appropriate third-party money manager. We provided initial due diligence on third-party money managers and ongoing reviews of their management of your account. In order to assist clients in the selection of a third-party money manager, we typically gathered information from the client about their financial situation, investment objectives, and reasonable restrictions they can impose on the management of the account, which are often very limited. It is important to note that we do not offer advice on any specific securities or other investments in connection with this service. Investment advice and trading of securities is only offered by or through the third-party money managers to clients. We periodically review third-party money managers’ reports provided to the client no less often than on an annual basis. We contact the clients from time to time, as agreed to with the client, in order to review their financial situation and objectives; communicate information to third-party money managers as warranted; and assist the client in understanding and evaluating the services provided by the third-party money manager. The client will be expected to notify us of any changes in his/her financial situation, investment objectives, or account restrictions that could affect their account. The client may also directly contact the third-party money manager managing the account or sponsoring the program. 401(K) CONSULTING SERVICES We offer retirement plan consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting their management and fiduciary obligations to the plan under ERISA. 401(k) consulting services offered by our Firm include, but are not limited to, the following: − Analysis and recommendation of Plan structure − Review of specific Plan requirements − Assessment of the current Plan investment options − Provide specific investment recommendations − Determination of appropriate administrative and recordkeeping solution − Analysis and recommendation of employee education program − Ongoing monitoring of Plan We will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us, the Company will be required to enter into a written agreement with us. This agreement will detail the services to be provided and the relevant fees and fee-paying arrangement. General Notice In performing its services, Burton Enright Welch relies upon the information received from its clients or from its clients’ other professional legal and accounting advisors and is not required to independently verify such information. Clients must promptly notify us of any change in their financial situation or investment objectives that would necessitate a review or revision by our advisors of the client’s portfolio and/or financial plan. The investments recommended to clients may be limited by the knowledge and experience of the personnel of Burton Enright Welch and/or the resources available to it as a result of its relationships with custodians and other providers in the broader financial industry. In addition, as a result of these resources, certain investments may be available to clients of Burton Enright Welch that might not be available to members of the public at large. Burton Enright Welch believes that the breadth of choices available under these limitations is sufficiently wide so as to effectively make available the full range of investment options that might conceivably be important for all but the rarest client. TERMINATION OF AGREEMENT Clients may terminate their investment management agreement at any time upon written notice to the Firm. The Firm does not assess any fees related to termination but will be entitled to all management fees earned up to the date of termination. Any prepaid fees owed to the client will be refunded on a pro rata basis based on the amount of time expired in the billing period. Any fees owed by the client to the Firm will be calculated and deducted from the client’s account on a pro rata basis determined on the amount of time expired in the billing period. If a copy of this Form ADV Part 2A disclosure statement was not delivered to the client prior to or simultaneous with a client entering into a written advisory contract with Advisor, then the client has the right to terminate the contract without penalty within five (5) business days after entering into the contract. For purposes of this provision, a contract is considered entered into when all parties to the contract have signed the contract. If the client terminates the contract on this basis, all fees paid by the client will be refunded. Any transaction costs imposed by the executing broker or custodian for establishing the custodial account or for trades occurring during those five days are non-refundable.