Vigilare Wealth Management, LLC is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of the State of Arizona. Vigilare Wealth Management, LLC has been registered as an Investment Advisory Firm since June 7, 2011, and is jointly owned and managed by Jason S. Polit and Zeljko J. Zdrale. General Description of Primary Advisory Services Vigilare Wealth Management, LLC is an independent fee-based Registered Investment Advisor. We designed Vigilare Wealth Management, LLC with a single goal in mind: To protect and grow our clients’ wealth to the best of our ability. Vigilare Wealth Management, LLC (“VWM”) offers clients a comprehensive range of services (each a “Service” and collectively the “Services”) that support both short and long-term goals. VWM acts as the central point of contact for the various Services in carrying out the objectives of the Client. Upon execution of a power of attorney (“POA”), VWM may engage, hire, retain, and employ, in the name and for the Account of Client, such lawyers, accountants, and other professionals as are necessary in the ordinary course of performing Services on behalf of Client. Depending upon the needs and objectives of the Client, VWM’s Services may include some or all of the following Services: Financial Oversight and Recordkeeping Services i. Expense Oversight: This Service includes gathering agreements, contracts, and invoices that require regular payment and organizing these invoices into payment schedules, establishing checking accounts and other types of accounts needed to pay these invoices and coordinating payment. These payments may include quarterly tax payments, insurance payments, distributions to shareholders, mortgage payments, management fees and other payments. ii. Cash Flow Oversight: This Service includes developing twelve (12)-month cash flow projections, updating cash flow projections on a monthly basis, and the validation of cash inflow and outflows against supporting documentation. iii. Record Management and Retention: This Service includes creating the documents and files necessary to support the operation of a family office as required including maintaining a general ledger and account records and other files as needed. Integrated Wealth Management Services With a comprehensive view of your financial and lifestyle requirements, we work with you to establish wealth transfer and tax minimization plans to help assure family continuity and governance, address executive compensation and benefits issues, and formulate a strategic financial plan and other wealth management strategies. Client acknowledges that he/she/it is under no obligation to implement any recommendations made by VWM as part of a financial plan, either independently or through VWM or its affiliates. If Client wishes to implement any such recommendations, Client may select any brokerage firm, private investment firm, insurance agency, broker, or carrier, bank, or any other financial Service institution to implement Client’s decisions. Should Client choose to implement such recommendations through VWM and/or its affiliates, Client should realize that this presents a conflict of interest in that VWM will charge separate fees for implementing such recommendations (see “Investment Oversight Services” below), and consequently, the objectivity of the advice rendered to Client could be biased. Furthermore, Client understands that investment adviser representatives (“IARs”) of VWM and/or its affiliates sell insurance products in their separate capacities as independent insurance agents for firms not affiliated with VWM. When these IARs implement insurance transactions in these separate capacities, they earn additional compensation. This presents a conflict of interest since IARs could earn fees and commissions for implementing recommendations made as part of a financial plan. Client understands that he/she/it is free to select any insurance agent or insurance provider they wish to implement any recommendations. We may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit or restrict our trading in these positions. Investment Management Services Our Investment Management Services are based on a dynamic asset allocation strategy. Through this service, VWM implements a customized and individualized investment program for clients by applying our investment philosophy with ongoing discretionary supervision over client accounts. This means that we will continuously monitor your account and make trades in your account when necessary. When discretionary authority is provided by the client, we will not be required to contact you prior to making investment decisions. Third-Party Investment Managers We may utilize unaffiliate, independent third-party investment managers (“TPIMs”) to manage some or all of Client assets if we determine such action to be in the best interest of the Client. When recommending Client to a TPIM, the Firm will (i) gather such information as investment objectives, risk tolerance, investment guidelines, time horizons and other important and necessary information relating to the Client’s assets; (ii) based upon such information, determine appropriate allocations of Client’s assets; and (iii) recommend one or more TPIMs whose management style and strategies are consistent with Client’s objectives and financial profile. Clients may be required to enter into an advisory agreement with a TPIM, which will be in addition to and, and distinct from the agreement with VWM. TPIMs will typically have discretionary authority over the assets allocated for management and are authorized to buy, sell, and trade in securities in accordance with the Client’s investment objectives and/or selected investment strategy. VWM shall provide information and/or documentation to the TPIM relative to the Client’s investment objective(s), initially when the Client account is opened, and anytime the Client informs the Firm of any change to their investment objectives. VWM’s fees typically include those fees associated with allocating Client assets to designated TPIMs. Please refer to the “Fees” section in Item 5 below for important fee information. Trustee Services Upon client request, VWM provides Trustee services, including Personal CFO/Executive Services, Tax and Accounting Services, Real Estate Services, Executive and Family Assistance, Philanthropic Support, Estate and Gift Planning and Trustee Services. These services are offered under separate engagement and Clients will need to enter into separate agreements for these services. Disclosure Regarding Rollover Recommendations We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i)

the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective client has regarding the oversight. General Information About Your Account Prior to engaging VWM to provide investment management services, the client will be required to enter into a formal investment advisory agreement setting forth the terms and conditions, including the amount of the investment management fee, under which we shall manage the client’s assets. Clients will also need to enter into a separate custodial/clearing agreement with a broker/dealer and/or custodian selected by Vigilare Wealth Management, LLC. Our discretionary asset management services will only be provided through accounts at broker/dealer(s) selected by VWM. The selected broker/dealer(s) provide custody, clearing, and other brokerage services including regular basic statement reporting. Clients will be required to establish a brokerage account(s) through this broker/dealer for all discretionary asset management services. VWM will be granted limited power-of-attorney over all discretionary accounts in order to effect trades and, when agreed upon by the client, to deduct advisory service fees. A separate account is always maintained for each client and the client retains all rights of ownership to their accounts (e. g. right to withdraw securities or cash, exercise, or delegate proxy voting, and receive transaction confirmations). Please refer to Item 12 – Brokerage Practices for further information on VWM’s relationship with Custodians. Description of Investment Types We provide investment advice on the following types of investments.
• Exchange-listed securities (i.e., stocks and exchange-traded funds)
• Securities traded over the counter
• Foreign issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial Paper and Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities
• Option and derivative contacts on securities, commodities, or currencies
• Interests in partnerships investing in real estate, oil, and gas interests. We may also periodically invest in leveraged ETFs. Leveraged ETFs seek a multiple of the return of a benchmark for a single day only. Leveraged ETFs are riskier than other alternatives that do not use leverage. We invest in leveraged ETFs in order to magnify the performance of an index, and thus, seek greater profits (of course, losses are magnified too). These positions will be actively monitored and rebalanced on a regular basis to maintain consistent exposure. Rebalancing does not guarantee specific future results and may result in investment losses. We have indicated the types of investments we typically provide advice on, but we reserve the right to advise clients on any other type of investment that we deem appropriate based on the client’s stated goals and objectives. We may also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment on which the client requests advice. We do not provide advice on Variable Life Insurance, Variable Annuities or futures contracts on tangibles or intangibles. Portfolios managed under our advisory services will typically be constructed using national market listed cash, stocks, exchange traded funds, closed ended funds, individual bonds, open-ended mutual funds. We may increase cash holdings, deploy short selling strategies or alternative investments as deemed appropriate, based on a client’s indicated tolerance for risk, our expectations of market behavior, and/or for risk management purposes. Conflicts may arise in the allocation of investment opportunities among accounts managed. We strive to allocate investment opportunities deemed appropriate for your account(s) and other accounts advised by the firm equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity will be shared in any particular manner. If VWM obtains material, non-public information about a security or its issuer that may not lawfully be used or disclosed, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Advisory Services Tailored to Individual Needs of Clients Our services are provided based on the individual needs of each client. We work with each client on a one- on-one basis using interviews and data gathering forms to determine a client’s investment objectives, financial resources and constraints, potential adverse tax consequences, attitudes towards market volatility, tolerance for potential market losses, and other suitability information. Clients are given the ability to request restrictions or preferences on the accounts we manage; including but not limited to, cash management needs, tax sensitivity, coordination with held-away assets, restrictions, or preferences for specific companies and/or sectors. While our advisory services are tailored to you as an individual, recommended products may use a multi- fund manager approach which makes it difficult to ensure that your portfolio will not invest in a particular industry or security. However, we are happy to discuss your preferences and will effort to accommodate them. Clients are responsible for timely notification to VWM of any changes to their financial situation or investment objectives and if the client would like to impose and/or modify any reasonable restrictions on the management of his/her accounts. Administrative Services Provided by Black Diamond Our Firm has contracted with Black Diamond to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, client database maintenance, quarterly performance evaluations, payable reports, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Black Diamond will have access to client information, but Black Diamond will not serve as an investment adviser to our clients. Our Firm and Black Diamond are non-affiliated companies. Black Diamond charges our Firm an annual fee for each account administered by Black Diamond. Please note that the fee charged to the client will not increase due to the annual fee our firm pays to Black Diamond, the annual fee is paid from the portion of the management fee retained by our Firm. There may be a possibility for price or account value discrepancies due to quarter-end transactions in an account. Dividends or trade date settlements may occur and our third-party billing software may report a slight difference in account valuation at quarter end compared to what is reported on your Statement from the Custodian. Our firm has the ability to produce billing summaries, which can be provided upon request. Nitrogen (Formerly RISKALYZE) To further fine-tune our understanding of a client’s risk tolerance, our Firm utilizes Nitrogen, a third- party vendor tool, to assist in identifying the client’s risk tolerance. Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and investment volatility (investment variance), which uses past data to calculate expected variance. Wrap Fee Programs We do not place client assets into a wrap fee program. Assets The number of clients’ assets managed by Vigilare Wealth Management; LLC totaled $ 291,005,199 as of December 31, 2023. $279,326,298 are managed on a discretionary basis and $11,678,901 are managed on a non-discretionary basis.