A. Description of our advisory firm, including how long we have been in business and our principal owners. Blum Financial L.P. d/b/a Strategic Wealth Planning is dedicated to providing individuals, families, businesses and other types of clients with a wide array of investment advisory services. Our firm is a Texas Limited Partnership and has been in business as an investment adviser since 2009. The firm’s General Partner is Blum Management Group, Inc. and our principal owner is Stephen J. Blum who holds the professional designations of CFP®, ChFC, CLU and AEP. B. Description of the types of advisory services we offer. (i) Non-Discretionary Asset Management: We offer continuous supervision for those clients who choose to open non-discretionary advisory accounts with our firm. We communicate with these clients on an as-needed basis and suggest an investment strategy and individual investments that will meet their goals and objectives. The final investment decision is made by the client. We review non-discretionary portfolios at least monthly. (ii) Strategic Wealth Planning Discretionary Managed Account Program: Our firm offers a discretionary Managed Account Program (“MAP”) whereby we manage client accounts for a single fee that includes both management services and the transaction costs. The MAP is designed to assist our clients meet their stated investment goals and to obtain professional asset management for a convenient single “wrap” fee. We construct an individualized portfolio based on the initial and ongoing information our clients provide to us. Once we establish the initial portfolio, we review the discretionary portfolio at least monthly and rebalance the portfolio based upon a client’s individual needs, stated goals and objectives and any changes in circumstances that are provided to us. We do not allow MAP clients to place restrictions on the types of investments to be held in the portfolio unless the client has an employment- related restriction. Additionally, we may make individual investment recommendations to our discretionary MAP clients for their consideration and approval. (iii) Pension Consulting: We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. All pension consulting services are in compliance with the applicable state laws regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA, but only with respect to the provision of services described in our Advisory Agreement. (iv) Financial Planning and Consulting: Strategic Wealth Planning provides a variety of financial planning, consulting and management services to individuals, families, businesses and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan, providing a financial consultation for clients based on the client’s financial goals and objectives and/or supervision and/or management of non-publically traded securities and other investments. This planning or consulting may 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 2024 ADV 2A | FIRM BROCHURE | Page 5 Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations provided to our clients may include general recommendations for a course of activity or specific actions to be taken by the clients, some of which will be effected by SWP. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, establish education or charitable giving programs and/or buy or sell non-publically traded securities or other investments. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary, for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the client’s discretion. (v) Referrals to Third Party Money Managers: The services of a

Third Party Money Manager (“TPMM) are not generally available to an individual investor and Adviser’s access to these financial services provides our clients with additional investment opportunities not available to the general public. When appropriate, Adviser may recommend that a Client use the investment advisory services of a TPMM for all or a portion of Client assets. All TPMMs recommended to the Client by SWP must be registered as investment advisers with the SEC or with appropriate state authorities. Adviser provides the initial due diligence in the selection of the TPMMs and conducts ongoing reviews of TPMM management of Client accounts. SWP will make recommendations regarding the suitability of a TPMM based on, but not limited to, the Client’s financial needs, investment goals, tolerance for risk and investment objectives. Once SWP places Client assets with a TPMM, Advisor does not offer further advice or recommend any specific securities or other investments for assets placed with a TPMM. Adviser reviews TPMM portfolios at least twice each month. Adviser may also review the TPMM quarterly reports. As necessary, SWP contacts our Clients 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. Clients agree to notify Adviser of any changes in his/her/their financial situation and/or investment objectives that could affect their investments, and this information, once received, is shared with a client’s TPMM. A client may also directly contact the TPMM managing the account or sponsoring the program. Client authorizes Adviser to provide information requested by the TPMM and authorizes the TPMM to answer Advisor questions regarding Client accounts with TPMM. Except as otherwise provided by Federal or state securities laws, the Adviser, acting in good faith, shall not be liable for any action by TPMMs recommended to the Client by the Adviser. SWP advises and Client understands and agrees that TPMMs charge a separate fee which is in addition to SWP Advisory Fees listed on Exhibit A. SWP may share in the fee paid by Client to the TPMM. Clients who are referred to TPMMs will receive full disclosure, including services rendered, fee schedules and account minimums at the time of referral. The Adviser’s annual fee for investment management services provided under this Agreement shall be a percentage (%) of the market value of all Client Assets under management, including all assets placed with a TPMM, in accordance with the fee schedule and procedure the SWP Discretionary Investment Advisory Services Agreement. In the event Adviser is dissatisfied with the performance or services of a TPMM for any reason, or feels that they are not meeting SWP clients’ goals and objectives, Client grants SWP the authority to terminate all TPMM services with or without client consultation and consent. In the event Client decides to terminate a TPMM, Client shall provide written notice to SWP. Upon termination of TPMM services for any reason, SWP will close the TPMM account(s) and direct TPMM to transfer all Client assets in TPMM accounts to SWP. Thereafter, SWP will manage Client Assets according to the Client Profile. 2024 ADV 2A | FIRM BROCHURE | Page 6 (vi) Professional Services and Consulting SWP offers services to other registered advisers in such areas as office management, client communication, document preparation and compliance, and SWP contracts with other registered advisers to act as the adviser’s agent in a non- fiduciary capacity. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients and whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing our firm’s Managed Account Program and to those clients who choose non-discretionary investment services. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting, Pension Consulting and Referrals to Third Party Money Managers. More details about how we individualize our investment services for each client are found in (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing their accounts. D. Participation in wrap fee programs. SWP offers a wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) to our Firm Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts differently than other accounts. As further described in our Wrap Fee Program Brochure, our firm receives a portion of the wrap fee for its services. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis. As of December 31, 2023, SWP manages $164,400,000.00 in client assets. We manage1 $133,000,000.00 on a discretionary basis and $31,400,000.00 on a non-discretionary basis.