Advisory Firm Pacific Wealth Management (“PacWealth”) has been providing investment advisory services since 2001. PacWealth is owned by Justin and Montana Kuntz. Justin C. Kuntz is the company’s managing director. He has been in the financial services industry since 2011. Advisory Services PacWealth offers the following advisory services, where appropriate, to individuals, corporations, and other business entities. Asset Management Services Financial Planning Consulting As of December 31, 2023, PacWealth has $263,706,905 assets under management on a discretionary basis, $6,233,786 of assets under management on a non-discretionary basis. ASSET MANAGEMENT SERVICES PROGRAM PacWealth offers asset management services. In this program, investment adviser representatives (“IARs”) of PacWealth will manage client portfolios based on the individual needs of the client. At the time of the clients' initial investments in the program, the IAR will assist the client in determining the client's current financial situation, financial goals, attitudes towards risk, investment objective, and give the client the opportunity to impose reasonable restrictions on the management of the account. Clients have the ability to leave standing instructions with the IAR to refrain from investing in particular securities, types of securities, or invest in limited amounts of securities. The above determination will allow the IAR to review the client's situation and determine an appropriate asset allocation. The investment objective selected by the client, which could range from conservative to aggressive growth, will guide the IAR in managing the client’s account. Once an appropriate asset allocation is determined with a client, the IAR will manage the client accounts on a discretionary or non-discretionary basis. PacWealth will create a portfolio consisting of one or more of the following: individual equities (with the exception of foreign issuers), warrants, corporate debt securities, commercial paper, CDs, municipal securities, mutual funds, exchange traded funds (“ETFs”), variable annuity subaccounts, structured products, U.S. Government securities and option contracts on securities. PacWealth will allocate the client's assets among various investments taking into consideration the objectives of the client. The mutual funds will be selected on the basis of any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. PacWealth's IARs will implement or make recommendations with respect to changes to a client's account based on market, economic, and political circumstances, and the individual characteristics of securities. Portfolios will be rebalanced on a periodic basis, typically quarterly. PacWealth also provides discretionary asset management services with respect to certain 529 plan portfolios. PacWealth will assist the client in selecting an investment strategy for the 529 plan portfolio taking into consideration the objectives of the client and recommend and/or make changes to the investment strategy over time if appropriate. The 529 plan sponsor will rebalance the account consistent with the selected investment strategy. Clients are free to consult with their IARs at PacWealth at any time concerning their portfolios. Should the client's individual situation change, the client should notify their IAR, who will assist the client in revising the current portfolio and/or prepare a new questionnaire to determine if a different portfolio would be appropriate to the client's new situation as well as modify or impose account restrictions. PacWealth will contact clients at least annually to review the client's personal financial circumstances. For PacWealth to manage client assets, the client will typically be required to establish an account in his/her name at Charles Schwab & Co., Inc. (“Schwab”) by completing an account application. Schwab is a registered broker/dealer and qualified custodian (holder of account assets). Client retains all rights of ownership on the account regardless of the custodian, including the right to withdraw securities or cash, vote proxies, and receive transaction

confirmations. In addition, client will also have the ability to impose restrictions on investing in certain securities or types of securities at the time the account is opened. In some instances, PacWealth manages assets for accounts that are not able to select Schwab as the custodian (e.g., some 529 plan and retirement accounts). When this is the case, PacWealth is not involved in establishing the account and the client is responsible for the selection of the custodian. In order to hire PacWealth to provide management services, the client will be asked to enter into a written investment advisory agreement with PacWealth. This agreement will set forth the terms and conditions of the relationship, including the amount of the investment advisory fee. Clients with at least $1,000,000 in assets under management with PacWealth may receive up to $1,000 paid toward the cost of basic estate planning services through estate planning attorney Charles J. Ingber, subject to advance approval by PacWealth. Basic estate planning services include but are not necessarily limited to; the creation of a living trust, will, health care directive and/or financial power of attorney. This service is provided as a courtesy, is contingent upon the client engaging Mr. Ingber for services, and may be altered or discontinued at PacWealth’s sole discretion. Please refer to Item 10 of this brochure for further information. No agency cross transactions or principal transactions may be affected in program accounts. COMPREHENSIVE FINANCIAL PLANNING PacWealth also provides advice in the form of Comprehensive Financial Planning. Clients purchasing this service will receive a written financial plan or report(s), providing the client with detailed financial planning services designed to achieve their stated financial goals and objectives. In general, the financial planning services will address any or all of the following areas of concern:
• Consultation and recommendations for cash flow strategies including budgeting, savings, and debt management.
• Determining cash flow strategies for planned cash flow needs including major purchase(s), college funding, emergency reserve accounts(s), and retirement distribution planning.
• Retirement goal accumulation and distribution scenario planning. This includes analysis to assess the levels of risk in plans and the probability of attaining goals given certain assumptions.
• Create and periodically update a financial needs analysis, a process that evaluates the likelihood of meeting stated goals based on the client assets, liabilities, and relevant economic assumptions.
• Needs analysis for life, disability and long term care protection; recommendations regarding types of policies, limits, deductibles and appropriate coverage.
• Consultation regarding estate planning issues and asset protection strategies.
• Consultation regarding current and prospective health insurance programs.
• Dependent care and special needs planning for disabled and elderly family members.
• Guidance and consultation for college funding. In addition, PacWealth may provide consultation upon request for the following:
• Current investment holdings
• Strategies for philanthropic gifting and family foundations
• Small business planning issues PacWealth gathers required information though in-depth personal interviews. Information gathered includes a client's current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire completed by the client, and a written report is prepared. Should a client choose to implement the recommendations, PacWealth suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. CONSULTING Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. PacWealth also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, PacWealth provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance planning, and budgetary planning.