Ownership Spectrum Financial Alliance, Ltd., L.L.C. (“Advisor”, “SFA”, “Spectrum” or “we”) is an investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”) from January 2005 to June 2012, then with the State of Kentucky from June 2012 to March 2014, and reregistered with the SEC in March 2014. We are a Delaware limited liability company, and our sole member (owner) is C. Kelly Buckley. General Description of Primary Advisory Services We offer personalized advisory services including financial planning and asset management services. The following are brief descriptions of our primary services. A detailed description is provided in Item 5, Fees, and Compensation, so that clients and prospective clients (“clients” or “you”) can review the services and description of fees more thoroughly. Financial Planning Services (Plans and Consultations) We offer advisory services in the form of financial planning and consultations. Comprehensive planning services focus on your overall financial situation. Modular planning services and consultations (both one- time and on-going) focus on specific areas of concern to you. Our financial planning services can be in the form of written or verbal financial plans that can be comprehensive or segmented (modular) in format. Plans can include, but are not limited to, the topics of estate planning, investments, taxes, and insurance. Asset Management Services We offer asset management services to provide you with continuous and on-going supervision over your accounts. This means that we continuously monitor your account and make trades in that account when necessary. Our clients engage us to provide “fee-only” asset management services where we make investment recommendations and also make changes to the managed account. If you elect to engage us for this service, we will develop an individualized investment program for your account(s). We provide various investment strategies through our management services; a specific investment strategy and investment policy is crafted for you and focuses on your specific goals and objectives. Asset management services are separate from and in addition to the financial planning services previously discussed. To provide these services, we need to obtain certain information from you to determine your financial situation and investment objectives. At least annually, we contact you to determine whether your financial situation or investment objectives have changed, or if you want to impose and /or modify any reasonable restrictions on your managed accounts. Our representative is always reasonably available to consult with you relative to the status of your accounts. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. Your beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account. A separate account(s) is maintained for you with the custodian, and you retain the right of ownership of the account (e.g., the right to withdraw securities or cash, exercise, or delegate proxy voting, and receive transaction confirmations). It is important that you understand we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. Conflicts may arise in allocating investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by us equitably and consistent with the best interests of all accounts involved. However, there is no assurance that a particular investment opportunity that comes to our attention is allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to you or any other client or use it for any client’s benefit. Charles Schwab & Co., Inc. We recommend that your assets be maintained in a brokerage account with Charles Schwab Institutional, a division of Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer and member of SIPC. See Item 12, Brokerage Practices, for additional

discussion on our recommendation and use of Schwab. However, you are free to select any account custodian you wish. Any direction to use a specific broker/dealer or account custodian must be in writing, and we reserve the right to decline the instructions if we believe it would result in operational difficulties. We assist you in establishing a managed account at Schwab or another qualified custodian that you select. The qualified account custodian maintains custody of your funds and securities. We do not act as custodian and do not have direct access to your funds and securities except to have advisory fees deducted from your account with your prior written authorization. Our minimum accepted household account is $500,000 of investable assets. We also consider any pro bono activities that may be required or requested, such as a church donation liquidation or military spouse assistance. There is no charge for these types of pro bono activities. You authorize us to have trading authorization on your accounts and we provide management services on a discretionary basis only. This means we make all decisions to buy, sell or hold securities, cash, or other investments in your managed account in our sole discretion without consulting with you before making any transactions. You must provide us with written authorization to exercise this discretionary authority and you can place reasonable restrictions and limitations on the discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary authority. Annuity, Retirement Plan Management, and Outside 529 Account Management We also offer management services relative to: (1) variable life/annuity products (2) individual employer- sponsored retirement plans (i.e., 401(k) plan, pension plan, profit sharing plan, etc.) and (3) College 529 account management through Brighter Future. The managed assets are maintained at either the specific insurance company that issued your variable life/annuity product or at the custodian designated by the sponsor of your retirement plan. When managing these assets, we either recommend or implement the allocation of product or the retirement plan portfolio. If we implement transactions, you must provide us with trading authority, including any access to accounts using assigned identification numbers and/or passwords, and discretionary authority. See Item 16, Investment Discretion, for additional discussion on discretionary authority. Any authorizations we have are strictly limited in order to avoid having custody of your accounts (as determined by applicable state and federal rules and regulations). Specifically, we do not have the authority to open an account on your behalf, to designate or change your address of record with a qualified custodian, or to withdraw funds or securities or transfer them to an account not in your name at a qualified custodian. Limits Advice to Certain Types of Investments We provide advice to the following types of investments:  Exchange-listed securities  Securities traded over-the-counter  Foreign issues  Warrants  Corporate debt securities (other than commercial debt)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  Exchange-traded funds (ETFs)  United States government securities  Option contracts on securities and commodities While we generally limit our advice to the investment products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. We also provide advice about any type of investment held in a client’s portfolio at the beginning of the advisory relationship. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. Tailor Advisor Services to Individual Needs of Clients Our services are always provided based on your specific needs. You have the ability to impose reasonable restrictions on your accounts, including specific investment selections and sectors. However, we reserve the right to not enter into an investment advisor relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Advisor The amount of assets managed by Advisor totaled approximately $292,780,848 as of March 30, 2024, all on a discretionary basis.