Orgel Wealth Management is an independent SEC-registered investment advisory firm that provides advisory and wealth management services to individuals, families, high net worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Its services primarily include investment management, financial planning and consulting, and retirement plan consulting. Orgel Wealth Management was established in October 2013 as a limited liability company and, together with its predecessor practices, has served clients since 1984. Orgel Wealth Management is 100% owned by its principals with no employee owning 25% or more of the firm. Orgel Wealth Management offers a variety of wealth management services, including financial planning, retirement plan consulting, and portfolio management. Prior to rendering services, clients enter into a written agreement with Orgel Wealth Management that sets forth the terms and conditions of the advisory relationship. Investment Management Services Orgel Wealth Management provides investment management services to clients primarily on a discretionary basis under a wrap-fee program (also see Item 16, Investment Discretion). Orgel Wealth Management individually tailors its services and works closely with the client upon engagement to determine the client’s investment objectives, risk tolerance, investment time horizon, and liquidity needs. Orgel Wealth Management then determines a portfolio investment strategy for each client designed to achieve the client’s objectives. While Orgel Wealth Management’s disciplined asset allocation strategies focus primarily on the long-term view, Orgel Wealth Management also incorporates a pragmatic approach that makes provisions for events along the way. Client portfolios consist primarily of mutual funds, exchange-traded funds, bonds, and cash, but may also include individual stocks, privately placed investments, such as private debt, private equity, and hedge funds, collective investment trusts, structured notes, annuities, alternative investments, and real estate investment trusts. Investment decisions are not limited to any specific security or product. Clients may request, in writing, to impose reasonable restrictions or mandates on the management of their accounts. Before agreeing to implement any requested restrictions or mandates, Orgel Wealth Management, in its sole discretion, will determine if the requested restrictions or mandates would materially affect the performance of a management strategy or prove overly burdensome to the management efforts. Clients are responsible for notifying Orgel Wealth Management if there are changes in their financial situation. Orgel Wealth Management’s fee-based comprehensive wealth management services are provided primarily through a wrap-fee program with a fee that is generally based on a percentage of assets under management. A wrap-fee program is a type of investment program that provides clients with investment management and brokerage services for one all-inclusive fee. As described further below, Orgel Wealth Management generally imposes fees that are based on the percent of assets under management and that typically cover the discretionary investment management of client portfolios, execution services, custodial services, and the range of consulting services provided by Orgel Wealth Management, which may include financial planning, business consulting and transition services, and other services. Orgel Wealth Management’s fee arrangement generally is designed to provide clients with the ability to trade in certain investment products without incurring separate costs for execution services or custodial services. Orgel Wealth Management is both the sponsor and investment manager to the wrap-fee program. Clients who participate in the wrap-fee program pay Orgel Wealth Management a single fee, which covers Orgel Wealth Management’s advisory fees, certain transaction costs, and custodial and administrative costs. Clients are not charged separate fees for the respective components of the total services. Orgel Wealth Management receives a portion of the wrap fee for our services after paying other service providers. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. Additionally, there are no material differences between the investment or management strategies employed by Orgel Wealth Management for clients who participate in the wrap-fee program and clients who do not participate in the program. The terms and conditions of the wrap program engagement are more fully discussed in Orgel Wealth Management’s Wrap Fee Program Brochure. Because wrap program transaction fees and commissions are paid by Orgel Wealth Management to the account custodian/broker-dealer, Orgel Wealth Management could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in a client's account. In an attempt to mitigate or eliminate this conflict of interest, Orgel Wealth Management has entered into an asset-based pricing arrangement with Pershing LLC (Pershing) to provide custody and execution services. Under an asset-based pricing arrangement, the amount that Orgel Wealth Management will pay to Pershing for transaction fees and commissions is based upon a percentage of the market value of Orgel Wealth Management’s wrap fee client accounts. This differs from transaction-based pricing, which assesses separate transaction fees and commissions for each transaction. Such asset-based pricing arrangement was instituted in an effort to mitigate Orgel Wealth Management’s economic incentive to minimize trading in client wrap fee accounts by establishing a fixed cost for custody and execution services regardless of the level of trading activity in wrap fee accounts. Financial Planning and Consulting Services Either as part of its investment management services or on a stand-alone basis, Orgel Wealth Management offers clients a range of financial planning and consulting services, which may include any or all of the following:  Investment planning  Budget planning  Education expense planning  Tax planning  Retirement planning  Estate planning assistance  Business consulting and transition services Limitations on Financial Planning and Consulting Services. Financial planning and consulting services are provided to the extent specifically requested by the client and may be provided either as a part of the client’s ongoing investment management service or, in limited situations, for a separate and additional fee per the terms and conditions of a separate agreement. In performing financial planning and consulting services, Orgel Wealth Management may rely on information obtained from the client or from the client’s other professionals. Orgel Wealth Management is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys or accountants) and fully relies on such information. At the request of a client, Orgel Wealth Management may provide tax planning and advice, including, for example, the creation of tax projections to facilitate tax estimates, assistance with individual and corporate forward tax planning, searching for unused tax credits or deductions, and identification of tax efficient charitable gifting strategies. Orgel Wealth Management is not an accounting firm, does not prepare tax returns, and no portion of our services should be construed as legal or accounting advice. At all times, clients should defer to their separately engaged attorney or tax professional when making legal or tax decisions. Orgel Wealth Management may also provide estate planning assistance at the request of a client. For example, estate planning assistance services may include educating clients on estate planning methods, collaborating with a client’s attorney in an effort to design estate plans that efficiently transfer wealth, working with trustees regarding the management and distribution of managed trust assets, and assisting with the formation of business succession strategies. Orgel Wealth Management does not serve as an attorney for clients and does not prepare estate planning documents. No portion of our services should be construed as legal advice and the services are not a substitute for receiving legal advice from a qualified attorney; at all times, clients should defer to their separately engaged attorney when making legal decisions. In addition, at the request of a client, Orgel Wealth Management may also provide advice on types and levels of insurance coverage or may review insurance products from unaffiliated insurance companies. Orgel Wealth Management is not an insurance company and does not maintain any affiliation with a licensed insurance provider. Clients remain responsible for seeking insurance coverage from a licensed insurance professional. Orgel Wealth Management may recommend the services of itself or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Orgel Wealth Management to provide additional fee-based services. Clients retain full discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Orgel Wealth Management as part of the financial planning or consulting services or to engage the services of any recommended professionals, including Orgel Wealth Management itself. If the client engages any professional (e.g., attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the engaged professional shall remain exclusively responsible for resolving any such dispute with the client. At all times, the engaged licensed professional (e.g., attorney, accountant, insurance agent, etc.), and not Orgel Wealth Management, shall be responsible for the quality and competency of the services provided. Clients are advised that it remains their responsibility to promptly notify Orgel Wealth Management of any change in their financial situation or investment objectives in writing so that Orgel Wealth Management may review, and if necessary, revise its previous recommendations or services. Retirement Plan Management and Consulting Services Orgel Wealth Management provides various management and consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing, and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized and may include any or all of the following services:  Plan design and strategy  Plan review and evaluation  Investment advice and review  Plan fee and cost analysis  Administrative/record keeping review  Fiduciary and compliance assistance  Fiduciary education  Participant education Certain retirement plan services are provided by Orgel Wealth Management as a fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Orgel Wealth Management’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation Orgel Wealth Management reasonably expects under the engagement. In addition, Orgel Wealth Management and its advisors act as fiduciaries under ERISA and the Internal Revenue Code, as applicable, with respect to investment advice provided to a retirement plan, plan participant or beneficiary account, subject to any limitations included in the written agreement with the client. Assets Under Management As of December 31, 2023, Orgel Wealth Management had $7,104,580,359 regulatory assets under management, of which $7,102,327,562 were managed on a discretionary basis and $2,252,797 were managed on a non-discretionary basis. Miscellaneous Disclosures Retirement Rollovers Conflict of Interest. A client or prospective client 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 another employer’s plan, if one is available and rollovers are permitted, (iii) roll over the assets 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). If Orgel Wealth Management recommends that a client roll over their retirement plan assets into an account to be managed by Orgel Wealth Management, such a recommendation creates a conflict of interest if Orgel Wealth Management will earn new (or increase its current) compensation as a result of the rollover. Whether Orgel Wealth Management provides a recommendation as to whether a client should engage in a rollover or not, Orgel Wealth Management is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Orgel Wealth Management. Orgel Wealth Management’s Chief Compliance Officer, Troy Mertens, remains available to address any questions that a client or prospective client may have regarding the potential conflict of interest presented by such rollover recommendation. Use of Mutual Funds and Exchange Traded Funds. Orgel Wealth Management utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Orgel Wealth Management’s investment advisory fee and any transaction and/or custodial fees discussed below, clients will also incur charges imposed at the fund level (e.g., management fees and other fund expenses) for investments in mutual funds and exchange traded funds. Use of Collective Investment Trusts. Orgel Wealth Management utilizes collective investment trusts when appropriate for its retirement plan clients. In addition to Orgel Wealth Management’s investment advisory fee and any relevant custodial or record keeping fees applicable for the retirement plan, investors will also incur charges imposed by the collective investment trust (e.g., management fees and other fund expenses). Use of Alternative Investments. Where appropriate, Orgel Wealth Management may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage

of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of the enhanced risks of interval funds, a client retains the ability to separately direct Orgel Wealth Management, in writing, at any time in the future not to purchase interval funds for the client’s account. Annuities. Orgel Wealth Management may provide advice concerning annuity assets and may manage annuity assets on a discretionary basis. In addition to Orgel Wealth Management’s investment advisory fee, annuity assets are also subject to charges imposed by the annuity issuer (e.g., management fees and other expenses associated with the annuity asset). Structured Notes. Orgel Wealth Management may purchase structured notes for client accounts. A structured note is generally a financial instrument that combines two elements, a debt security component and a component that provides exposure to an underlying asset or assets. The debt security component of a structured note can provide principal protection and carries counter party risk based on the issuer. The component of a structured note that provides exposure to an underlying asset or assets can link the return on the note to the return of an underlying asset or assets (such as the S&P 500 Index or commodities) which can be used to provide some degree of leveraged returns (but usually with some cap on the maximum return) and be tailored to a specific market or economic view. With structured notes, investors may also receive long-term capital gains tax treatment if certain underlying conditions are met, and the note is held for more than one year. Finally, structured notes have liquidity constraints that limit the ability to sell the note before maturity. In the event that the client seeks to prohibit or limit the purchase of structured notes for the client’s account, the client can do so, in writing. In the event that a client has any questions regarding structured notes, Orgel Wealth Management’s Chief Compliance Officer, Troy Mertens, remains available to address them. See Risks Associated with Structured Notes at Item 8 below. Unaffiliated Private Investment Funds. Orgel Wealth Management provides investment advice regarding private investment funds. Orgel Wealth Management, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which, including the terms, conditions, risks, conflicts and fees (including incentive compensation), is set forth in the fund’s offering documents. Orgel Wealth Management’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Orgel Wealth Management calculating its investment advisory fee. Orgel Wealth Management’s fee shall be in addition to the fund’s fees. Orgel Wealth Management’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s). Please Note: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please Also Note: Valuation. In the event that Orgel Wealth Management references private investment funds owned by the client on any reports prepared by Orgel Wealth Management, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor, if an updated valuation has been provided. The updated value will continue to be reflected on the report until the fund provides a further updated value. If subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. Please Also Note: As a result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, Orgel Wealth Management shall calculate its fee based upon the latest value provided by the fund sponsor. Portfolio Activity. Orgel Wealth Management has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Orgel Wealth Management will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when Orgel Wealth Management determines that changes to a client’s portfolio are neither necessary nor prudent. Orgel Wealth Management remains entitled to any advisory fees it earns regardless of trading activity within the client’s account. In addition, there can be no assurance that investment decisions made by Orgel Wealth Management will be profitable or equal any specific performance level(s). Securities-Based Loans – Margin Accounts and Pledged Assets. A client who has a need to borrow money could choose to do so by using:  Margin Loan: With a margin loan, the account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,  Pledged Assets Loan: In consideration for a lender (e.g., a bank, etc.) making a loan to the client, the client pledges investment assets held at the account custodian as collateral. The above-described securities-based loans (collectively, SBLs) are generally utilized because the loans typically provide more favorable terms (e.g., interest rates, flexible repayment, and minimal paperwork) compared to standard commercial loans. SBLs can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. Such securities-based loans, however, are not without potential material risk to a client’s investment assets. The lender (e.g., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Orgel Wealth Management does not recommend such borrowing unless it is for specific short-term purposes (e.g., a bridge loan to purchase a new residence). We also do not recommend such borrowing for investment purposes (e.g., to invest borrowed funds in the market). If a client chooses to utilize margin or a pledged assets loan, Orgel Wealth Management would benefit in several ways. If a client takes a loan rather than liquidating assets in the client’s account, Orgel Wealth Management continues to earn a fee on such account assets. In addition, if a client invests any portion of the loan proceeds in an account to be managed by Orgel Wealth Management, Orgel Wealth Management will receive an advisory fee on the invested amount. Furthermore, because Orgel Wealth Management’s advisory fee is based upon the higher margined account value, Orgel Wealth Management will earn a correspondingly higher advisory fee, which could provide us with a disincentive to encourage the client to discontinue the use of margin. Please Note: clients who choose to utilize securities-based loans must accept the above risks and potential corresponding consequences. Cryptocurrency. Cryptocurrency is a digital currency that can be used to buy goods and services and uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand in their market. Because cryptocurrency is currently considered to be a speculative investment, Orgel Wealth Management will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: At this time, Orgel Wealth Management does not recommend or advocate the purchase of, or investment in, cryptocurrencies. We consider such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, and complete loss of principal. Socially Responsible Investing Limitations. Socially Responsible Investing (SRI) involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process. There are potential limitations associated with allocating a portion of an investment portfolio in SRI securities (e.g., securities that have a mandate to avoid, when possible, investments in products such as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of SRI securities may be limited when compared to the universe of securities that do not maintain such a mandate. SRI securities could underperform broad market indices. Investors must accept these limitations, including the potential for underperformance. Correspondingly, the number of SRI mutual funds and exchange-traded funds is significantly limited compared to the universe of mutual funds that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Orgel Wealth Management), there can be no assurance that investment in SRI securities or funds will be profitable or prove successful. Non-Discretionary Service Limitations. Clients who determine to engage Orgel Wealth Management on a non-discretionary investment advisory basis must be willing to accept that Orgel Wealth Management cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Orgel Wealth Management would like to make a transaction for a client’s account, and the client is unavailable, Orgel Wealth Management will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Cash Positions. Orgel Wealth Management continues to treat cash as an asset class. As such, unless determined to the contrary by Orgel Wealth Management, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Orgel Wealth Management’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Orgel Wealth Management may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss participating in market advances. Depending upon current yields, at any point in time Orgel Wealth Management’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Orgel Wealth Management’s Chief Compliance Officer, Troy Mertens, remains available to address any questions that a client or prospective may have regarding the above billing practice. Client Obligations. In performing its services, Orgel Wealth Management will not verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. It remains each client’s responsibility to promptly notify Orgel Wealth Management if there is ever any change in their financial situation or investment objectives so that Orgel Wealth Management can review, and if applicable, revise its previous recommendations or services. We mitigate each of the conflicts of interest identified above by disclosing them to clients and prospective clients and maintaining policies and procedures designed to make sure our employees render appropriate advice. In addition, our Chief Compliance Officer, Troy Mertens, remains available to address any questions that a client or prospective client may have regarding these disclosures and conflicts of interest.