A. Firm Information and Background Risk Paradigm Group, LLC (“RPg” or the “Advisor”) is an investment management firm specializing in the design, delivery, and management of tactical investment strategies that primarily use exchange traded funds (“ETFs”) for their underlying holdings. These strategies are commonly referred to as “Managed ETF Strategies” or “Tactical ETF Strategies” and are powered by policy based, quantitatively driven methodologies and/or a combination of fundamental top down quantitative bottom up analyses (the “Model Methodology[ies] or ”Model[s]”). RPg also offers the Principal Protected Investment Strategy designed to provide a stable, protected investment. RPg primarily serves Financial Intermediaries (the “Intermediary[ies]”) and their End Client (the “End Client[s]”), as well as individuals and institutions seeking portfolios that provide exposure to a variety of different market segments, including: US equities, US fixed income, International equities, and alternative asset classes. More specifically, RPg focuses on downside protection using a repeatable investment process that is either quantitative or a blend of quantitative and a combination of fundamental top down quantitative bottom up analyses. Financial Intermediaries include: broker-dealers, registered investment advisors (“RIAs”), and other Advisory Persons serving both institutional and individual End Clients and qualified & non-qualified plans. RPg was founded in October 2010, and is a wholly-owned subsidiary of Risk Paradigm Group Holdings, LLC, a privately held Limited Liability Company (“LLC”) that is organized under the laws of the State of Delaware. RPg is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”) and is organized under the laws of the State of Texas. RPg is a related advisor due to common control with its affiliate, RPg Family Wealth Advisory, LLC (Please see Item 10). David M. Gatti (Chief Executive Officer, Chief Investment Officer) is the principal officer of RPg. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by RPg. Please contact Robert McCauley, RPg’s Chief Compliance Officer (“CCO”), with any questions regarding this Disclosure Brochure. Mr. McCauley can be reached at (866) 726-5150 or via email at [email protected]. B. Advisory Services Offered The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. RPg’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Tactical Investment Strategy Products The most prominent expression of RPg’s expertise is through Tactical Investment Strategies (“Tactical Strategy[ies]”), that are selected and/or otherwise recommended in conjunction with an Intermediary dispensing advice to an End Client. The “RPg” Tactical Strategies use a quantitative formulaic process to select sectors and asset classes, while the “TAG” Strategies use a global macro process supported by a micro process to adjust asset allocations to our forward view of the relative risk and returns of various asset classes. Additionally, RPg offers a stable protected investment strategy (the “Products” or “Strategies”) The Strategies currently offered by RPg include the following: RPg ActiveParadigm Strategies RPg Tactical U.S. Equity Strategy RPg Tactical U.S. Equity FT Strategy RPg Tactical Global Balanced Strategy TAG Tactical Strategies TAG Tactical Income TAG Tactical Conservative TAG Tactical Moderate TAG Tactical Growth TAG Tactical Equity For a detailed description of these Strategies, please see Item 8 below. RPg does not typically have an advisory relationship with the Intermediary’s End Client and does not typically provide tailored advice to the End Client nor assist the End Client in determining if any Product is suitable to meet their goals and objectives. The Intermediary is solely responsible for understanding and evaluating each End Client’s identity, circumstances, financial condition, portfolio holdings, tax situation, regulatory status, financial

needs and goals, and for making determinations as to whether a Product provided by RPg is appropriate for each potential End Client. The Intermediary is responsible for reporting and communicating with the End Clients as to the status and performance of their individual investments. At no time will RPg accept or maintain custody of an End Client’s funds or securities. The Strategies offered to Intermediaries for their End Clients are made available through individual separately managed accounts (“SMAs”), or through agreements of RPg products administered through Model Manager Accounts or Unified Managed Accounts (“MMAs” or “UMAs”) Sponsored by third parties (“Sponsor Platform[s]”). Delivery through Separately Managed Accounts: Our Products are typically selected and/or otherwise recommended for End Clients through Financial Intermediaries such as broker-dealers and RIAs, and their respective Advisory Personnel. To administer the Tactical Strategies listed above, RPg will manage the selected Product through the SMA on a discretionary basis. At no time will RPg accept or maintain custody of an End Client’s funds or securities. All End Client assets will be managed within their designated brokerage account[s] or pension account[s] pursuant to the RPg investment management agreement executed by the Intermediary or the Intermediary’s End Client. Delivery through Platform Agreements in Model Manager Accounts, including Unified Managed Accounts: For Intermediaries who utilize MMAs and UMAs, RPg may provide its Tactical Strategies to RIA firms via Turnkey Asset Management Programs (commonly referred to as “TAMPs”) and UMA Platform Sponsors (“Sponsor[s]”) through platform level licensing agreements (“Platform Agreements”). Customized Investment Management Services RPg may provide customized investment management services (“Customized Strategies”) to individuals, institutions such as endowments or foundations, and qualified & non-qualified plans through separately managed accounts (“SMAs”) or through Platform Agreements as described above. With respect to any Customized Strategy managed by RPg, the investment guidelines will be administered in accordance with a documented investment mandate provided by the End Client’s Intermediary or Platform Sponsor and delivered to RPg. At no time will RPg accept or maintain custody of an End Client’s funds or securities, except for the authorized deduction of RPg’s investment management fees. All End Client assets will be managed within their designated brokerage account[s] or pension account[s] pursuant to the RPg investment management agreement, executed by the End Client. Please see Item 5 below for more details. Sub-Advisory Relationships RPg does not engage a sub-advisor. RPg reserves the right to enter into sub-advisory relationships in the future. C. Client Account Management Pursuant to the delivery of investment management services associated with RPg’s Products, the Methodologies and Tactical Strategies generally are not administered to the specific needs or circumstances of an Intermediary or their End Client. RPg does not typically have the direct advisory relationship with the End Client, but may at times. RPg does not typically tailor its investment services for the Intermediary’s End Client, or for determining if any RPg Product is appropriate for the End Client. The Intermediary is solely responsible for understanding and evaluating each End Client’s identity, circumstances, financial condition, portfolio holdings, tax situation, regulatory status, financial needs and goals, and for making determinations as to whether a Product provided by RPg is appropriate for each potential End Client. The Intermediary is responsible for reporting and communicating with the End Clients as to the status and performance of their individual investments. At no time will RPg accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. D. Wrap Fee Programs RPg does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by RPg. E. Assets Under Management As of December 31, 2023, RPg manages $81,481,650 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.