Secure Investment Management, LLC (“SIM” or the “Firm”) is a limited liability company formed in 2012 in the State of Arizona. Prior to reorganizing as SIM, Secure Investment Management operated under the name Joshua David Mellberg, LLC since its inception as a registered investment adviser in August, 2006. SIM is owned by Joshua D. Mellberg. The Firm’s business model is based on a decentralized network of Investment Adviser Representatives (“IARs”) doing business in disparate offices located in numerous states and cities. Although all IARs are registered with, and subject to oversight by the Firm, they operate their businesses independently. In addition, the majority of the IAR’s are also independent insurance agents affiliated with JD Mellberg Financial (“JDM”), Insurance Marketing Solutions, LLC ("IMS”), Retirement Income, LLC ("RI”), Ursus Financial Group, LLC ("UFG”), or Secure Income Management, LLC, (“Secure”), all of which are independent marketing organizations for insurance agents. JDM is not affiliated with SIM or Secure, but Josh Mellberg maintains a personal ownership interest. Secure, IMS, RI, and UFG are affiliated with SIM along with another affiliate, SIM Asset. SIM offers a variety of investment advisory services, consulting, and investment management services, to individuals, business entities, trusts, and estates. SIM provides investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative (“IAR”) will ascertain each client’s investment objective(s). Thereafter, SIM shall make recommendations for an appropriate allocation of investment assets consistent with the designated investment objective(s). The client can impose reasonable restrictions on SIM’s services at any time. Types of Advisory Services Offered Financial Planning Services Our IARs can provide financial planning services, including preparing and providing clients with a focused, general, or comprehensive financial plan, based on an analysis of the client’s current financial circumstances, goals and objectives. For this service, clients will need to provide the IAR with personal data such as family financial records, budgeting, personal liability, estate information and additional financial information. Implementation of financial planning recommendations is entirely at the client’s discretion. The Firm is not qualified to, and does not, offer legal, tax, or accounting advice. Generally, SIM first conducts an initial consultation during which pertinent information about the client’s financial circumstances and objectives is collected. For more comprehensive services, the Firm reviews and analyzes the information provided by the client and then provides a written financial analysis that contains recommendations designed with the intention of achieving the client’s stated financial goals and objectives. Financial plans are based on the client’s financial situation at the time the plan is presented and are based on the information disclosed by the client to SIM. Clients are advised that certain assumptions are made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. SIM cannot offer any guarantees or promises that the client’s financial goals and objectives will be met. As the client’s financial situation, goals, objectives, or needs change, the clients are strongly urged to promptly notify the Firm. For more information on the risks associated with investing, please refer to Item 8, below. If the client decides to follow the recommendations, the client has the option, but is under no obligation, to request that SIM implement such recommendations through the Firm’s Investment Management Services. Should a client request SIM to implement such recommendations, the client will receive the services outlined in our Investment Management section below. Furthermore, certain IARs of SIM sell insurance products when the client and IAR believe it to be in the client’s best interest. Insurance products are sold by IARs in their separate capacity as an independent insurance agent with one of our affiliated carriers or with appointed carriers not affiliated with the SIM. If the IAR implements insurance or insurance transactions in this separate capacity, he/she earns a sales commission but does not also charge investment management fees on those investments. This could present a conflict of interest since the IAR is incentivized and earns insurance and/or commission(s) for implementing insurance product recommendations made as part of the Firm’s Financial Planning Services. This conflict is mitigated by the IARs zealously attempting to always act in the best interest of all clients. Please see Items 5, 10 and 14 below for additional information concerning such conflicts. Model Portfolios through Dimensional Fund Advisors SIM is a Dimensional Fund Advisors (“DFA”) approved investment adviser enabling it to offer DFA’s institutional class, open ended, no-load mutual funds to Clients. DFA was founded in 1981 as an institutional fund manager and since the early 1990’s has been allowing selected advisors (approved by DFA through a screening and training process) to use their funds in client portfolios without the usual $20 million institutional investment. DFA authorized advisors must be fee based and adhere to a long-term, disciplined investment approach. SIM receives no financial compensation from DFA. SIM advisors do receive occasional, on-going training and practice management support from DFA associated with the proper use of DFA Funds in client portfolios. SIM does not believe this support materially affects the objectivity of its investment recommendations and remains free to offer non- DFA investment vehicles to Clients whenever deemed appropriate. SIM does not receive any compensation from DFA for using their funds. Orion Portfolio Solutions TAMP SIM offers SMAs through Orion Portfolio Solutions turnkey asset management program (TAMP) that focuses on modern portfolio theory on asset allocation as well as focusing on three major sections. Type of strategy and asset manager chosen will depend on individual client circumstances, goals and needs considering Market Cycle Mandates. Market cycle changes are unpredictable, yet inevitable. Through recognition of their impact, the potential negative effects may be minimized. Market Cycle Mandates seeks to address this challenge by delivering a commonsense approach to managing portfolios regardless of external market variables. Market Cycle Mandates allows you to focus on things within your control by:
• Setting clear expectations and replacing emotion with discipline
• Recognizing the biggest driver of return and risk
• Identifying dedicated investment strategies to properly diversify portfolios History shows that the market typically moves in cycles. Investment strategies that work

in bull markets may not be effective in flat or bear markets. Orion Portfolio Solutions and SIM are not related. See below for additional information on the portfolios available under this program. Investment Advisory Services The client can engage SIM to provide discretionary investment advisory services on a non-wrap fee basis. SIM manages the investment accounts of its clients in accordance with the objectives established by each client, by developing an investment policy statement (“IPS”) or an asset allocation plan. SIM will direct at its sole discretion, the investment and reinvestment of the assets in client accounts. Clients can place reasonable restrictions on assets or investments and will be documented in the IPS. The firm’s philosophy centers on long-term investing and the use of the analysis of past performance of various asset classes to build diversified, low cost, passive, and active portfolios. Investment portfolios will be tailored to the individual needs and desires of each client. SIM currently creates portfolios for separately managed accounts utilizing open-end mutual funds created and managed by Dimensional Fund Advisors (“DFA”) (the “SAM Accounts”). The DFA funds are low-cost, no-load, institutional asset-class funds. DFA is only available to institutional investors or through approved investment advisers. Some of SIM’s legacy clients are managed on a non-discretionary basis in accordance with the agreement entered into at the beginning of their engagement. However, SIM no longer offers non- discretionary services to new clients. Transferring to the SIM Asset Management Platform from the SIM Fund Platform SIM Clients that executed an Investment Advisory Agreement prior to February 28, 2022 must execute a new Client Agreement to invest in SAM Accounts. In addition to updating the Clients’ Investment Objective, the new client Investment Advisory Agreement discloses conflicts of interest as well as the advisory fee to be charged on the SAM account. REITs and Real Estate Partnerships SIM provides advice regarding legacy real estate investment trusts (REITs) and real estate partnerships which are no longer available to current clients. Some of the REITS that are the subject of SIM’s advisory services are not publicly traded. In other words, the lack of an active secondary market for the sale of such REITs can limit a client’s ability to dispose of such investments in a timely manner and/or at an advantageous price. Consequently, a client should exercise caution to avoid over- concentration of their assets in these illiquid investments. It is likely the price of a REIT listed on your account statement provided by a custodian only reflects the original purchase price and does not reflect any price or value from a secondary market, a repurchase offered by the sponsor or the book value. It is possible that the actual value of the REIT on a secondary market or through a repurchase by a sponsor is significantly higher or lower than the original purchase price shown on the account statement provided by the custodian. To the extent that an alternative investment such as a non-traded REIT is included in your portfolio, the alternative investment is subject to an asset management fee by SIM, which will be based upon the current valuation set by the product sponsor, as reflected on the custodian’s account statement. Since certain alternative investments, such as non-traded REITs, are illiquid, the value is not easily or readily ascertainable or reported. As a result, we believe the value shown on the account statement provided by the custodian is the most reliable method for determining the present value of the investment. Currently, SIM does not charge advisory fees for these legacy real estate investments. Amount of Client Assets Managed As of March 30, 2024, the following represents the amount of Client assets under management by SIM on a discretionary and non-discretionary basis: Type of Account Assets Under Management (“AUM”) Discretionary $ 32,406,000 Non-Discretionary $ 0 Total: $ 32,406,000 As a registered investment adviser subject to Section 206 of the Advisers Act, SIM acts as a fiduciary related to the provision of investment advisory services. As such, SIM has an obligation to act in the best interest of its clients, guided by the core fiduciary duties of loyalty and care. IRA Rollovers The Firm provides, as part of its investment advisory services, recommendations for clients to withdraw the assets from an employer's retirement plan (e.g., 401(k)/403b/457 plans) and roll the assets over to an individual retirement account ("IRA") that the Firm will manage for a fee. This is deemed a conflict of interest as we have an incentive to recommend a rollover to the Firm. Compliance with Prohibited Transaction Exemption PTE 2020-02 In December 2020, the DOL adopted a new exemption under ERISA (“PTE 2020-02”), which specifically covers three activities prohibited under Section 406(a). These activities are self-dealing, receiving compensation from third parties in connection with any transactions involving an ERISA plan, and principal transaction activity. PTE 2020-02 can be relied upon by, among others, SEC registered investment advisers and their investment professionals that are deemed investment advice fiduciaries, so long as all the exemption’s requirements are met, as applicable. There are five main components to PTE 2020-02, which are designed to safeguard against the conflicts of interest that apply to the prohibited activities covered by the exemption. These include:
• Adhering to specific Impartial Conduct Standards
• Providing specific disclosure to each ERISA Plan client
• Maintaining applicable written policies and procedures
• Performing and documenting a retrospective review
• Having a senior officer make certain written certifications. SIM is deemed to be an investment advice fiduciary. At all times, the Firm will act in the client’s best interest in making any recommendations related to assets covered by ERISA. SIM will comply with all applicable rules in order to maintain this exemption. Miscellaneous Advisory Services If requested by the client, SIM can recommend the services of other professionals for certain implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain of SIM’S investment adviser representatives in their separate capacities as discussed in Item 10 Other Financial Industry Activities and Affiliations. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from SIM. Client Obligations In performing its services SIM shall not be required to verify any information received from the client, or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify SIM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, and revising SIM’s previous recommendations or services.