COMPANY HISTORY AND PRINCIPALS Simplicity Solutions, LLC’s (hereafter, “Simplicity Solutions” or the “Firm”) status as a Registered Investment Adviser was granted by the SEC as of February 27, 2015. The predecessor entity to Simplicity Solutions, Sawtooth Asset Management, Inc., was registered with the SEC as an investment adviser since 2009. Simplicity Solutions and its affiliates, Simplicity Wealth, LLC, an investment adviser registered with the SEC, Simplicity Financial Investment Services, Inc., a broker-dealer registered with the SEC, and LifePro Asset Management, LLC, an investment adviser registered with the SEC are under common control of Simplicity Financial Marketing Holdings, Inc. Simplicity Solutions provides investment advisory services, portfolio management and back-office services from its principal place of business in Minneapolis, Minnesota. However, the Firm does not offer tax, accounting, regulatory, or legal advisory services. You should seek outside counsel for these services. SIMPLICITY SOLUTIONS’ MANAGED ACCOUNT PROGRAM The Firm’s focus is on the provision of a Turnkey Asset Management Program (“TAMP”) to independent third-party investment advisers, broker/dealers, insurance companies, banks, and trust companies (individually, an “Adviser” and collectively, the “Advisers”). The investment management and investment advisory services provided by Simplicity Solutions as described herein are primarily offered through its Managed Account Program (the “Program” or “TAMP”). Through the Program, Simplicity Solutions provides Advisers with access to the model portfolios of a wide variety of third- party investment managers (the “Model Managers”) selected by Simplicity Solutions as well as access to supporting operational services. Each model portfolio is designed to meet a particular investment goal. Under a written agreement between the Model Manager and Simplicity Solutions (the “Model Manager Agreement”), the Model Manager constructs a model portfolio based on an asset allocation risk profile and selects the underlying investments for each portfolio that is based upon a particular investment strategy and/or philosophy. The Model Manager will provide the buy and sell recommendations to Simplicity Solutions for the Model Portfolios. Simplicity Solutions provides ongoing due diligence and review of the Model Managers available through its Program. Simplicity Solutions may at any time hire or terminate a Model Manager at its complete discretion. In the event a Model Manager is terminated or departs from Simplicity Solutions’ Program, in coordination with the Client’s Adviser, an appropriate replacement may be recommended for a Client’s account. Simplicity Solutions cannot guarantee the availability of a particular model portfolio or particular Model Manager. Simplicity Solutions' model portfolio offerings are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding exchange-listed securities, like stocks and ETFs, foreign issuers, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, mutual funds, United States governmental securities, option contracts on securities and the model portfolios of a variety of Model Managers. Based on the individual needs and circumstances of the Client, the Client’s Adviser will determine the allocation of assets in the Client’s account among the various investment options and model portfolios available, as deemed appropriate. Simplicity Solutions will provide advice regarding specific investments for a Program account, and will manage or effect purchases, sales, or other transactions for an account. In addition, Simplicity Solutions will have the authority and discretion to manage the account in the event a Model Manager ceases to act as manager for the account, in which event Simplicity Solutions will manage account investments not allocated to an existing Model Manager until a new Model Manager is retained or manage account investments in their entirety in the event no new Model Manager is recommended. In managing the (Page 5 of 20) account assets, Simplicity Solutions is specifically permitted to retain all or part of the existing investments or to liquidate such investments, at Simplicity Solutions’ discretion. However, the decision regarding the selection of investment options, including model portfolios, to be held in a Client’s account is made by the Client’s Adviser based, in part, on Simplicity Solutions’ evaluation of the investment styles, strategies, risks, and potential benefits of each investment option and each Model Manager. At or before entering into the Investment Management Agreement, the Client’s Adviser will be available to discuss the Model Manager’s Disclosure Documents and answer any questions the Client may have regarding the Program and the Model Managers. Because the Model Managers may change from time to time, Clients and prospective Clients should consult directly with their Adviser to discuss the currently available selection of Model Managers. Certain Model Managers may not be available to all Clients. Simplicity Solutions also provides an overlay management service for the model portfolios selected by an Adviser for a Client’s account, which includes executing instructed trades and rebalancing the account at the Adviser’s request or as necessary to conform to the recommended asset allocation for the model portfolio as directed by the Model Manager. The suitability of a transaction for the Client is assessed and determined as of the date the transaction was executed for the Client’s account by the Client’s Adviser. All transactions effected for the Client’s account will be deemed to be suitable based on and in reliance on the Client’s Adviser’s assessment of the Client’s financial situation, investment objectives, risk tolerance, and investment time horizon, unless written notice to the contrary is received by the Simplicity Solutions team within 10 business days following the Client’s receipt of the custodian’s statement reflecting such transactions. Although the Client’s Adviser maintains discretion over the Client’s account, Simplicity Solutions maintains discretion for timing of transactions as well as the holdings of model portfolios when a specific security may not be available or advantageous to a Client. SUB-ADVISORY AND OPERATIONAL SERVICES Simplicity Solutions also provides sub-advisory and operational services to Clients through sub-advisory relationships with other third-party Advisers. In these arrangements, an Adviser executes a Sub-advisory Agreement or an Operations Service Agreement (collectively “Service Agreements”) with Simplicity Solutions, in which Simplicity Solutions agrees to provide the Adviser with investment management, investment advisory and/or operational services on behalf of such Adviser’s Clients. As per the terms of the Service Agreements, the Client will enter into a written agreement with the Adviser pursuant to which the Client will authorize the Adviser to utilize the services of a third-party sub-advisor such as Simplicity Solutions. When servicing a Client’s account in coordination with a third-party Adviser, the Service Agreements will specify those services to be provided by Simplicity Solutions internally versus those services to be provided by the third-party Adviser as well as any fees to be charged and collected for the specified services. In general, Simplicity Solutions provides these services through Simplicity Solutions’ Managed Account

Program as described in this Disclosure Brochure. As described above, these subadvised clients will enter into an advisory agreement directly with the third-party Adviser, and we will have no direct client relationship with the Adviser’s Clients. The third-party Adviser is responsible for providing Clients with a copy of the Firm’s brochure and establishing the fee that Clients pay, which will be specified in the signed advisory agreement. The Firm receives a portion of the total advisory fees for its advisory services, as agreed upon in the Service Agreement we have with the third-party Adviser. An investment advisor representative affiliated with the third-party Adviser will assist Clients in selecting from the Firm’s managed portfolio and specialty solution offerings that align with the Client’s investment objectives, risk tolerance, and time horizon. This investment advisor representative will also provide Clients with initial and ongoing information and education concerning the investments selected. As a subadvisor, the Firm generally maintains discretionary authority to determine the timing of transactions as well as the holdings of model portfolios when a specific security may not advantageous to a Client. The third party Adviser should meet with Clients periodically to discuss these allocation changes and, at all times, maintains discretion in the selection of Client’s investments or model portfolios. (Page 6 of 20) TAX OVERLAY SERVICES Simplicity Solutions offers optional Tax Loss Harvesting Services and Tax Transition Services (collectively “Tax Overlay Services”) to assist in mitigating the impact of taxes on certain Client accounts. The primary source of taxes in Client portfolios is from realized short-term capital gains. Simplicity Solutions’ Tax Loss Harvesting Service seeks to minimize or, if possible, eliminate realization of short-term capital gains. When rebalancing Client accounts, Simplicity Solutions weighs the tax impact of transactions against the risk of not complying with the Model Manager’s sell recommendations. If selling a security based on a Model Manager’s recommended model portfolio change will result in a substantial short-term capital gain, Simplicity Solutions will typically seek to offset that gain with existing realized short-term losses, harvest new short- term losses, or potentially defer the sale of the security until it either reaches long-term capital gains status or until an offsetting short-term capital loss can be harvested. Simplicity Solutions maintains discretion for this service in the selection of investments, timing, and execution of transactions. Simplicity Solutions may provide Tax Transition Services to minimize the impact of taxes on certain Client accounts as an existing Client portfolio is transitioned into the Program. Simplicity Solutions offers customizable solutions to manage potential realization of large, unrealized capital gains that may be embedded in a Client’s portfolio in addition to customizable strategies that provide for tax-efficient diversification of Client portfolios with asset concentration. SOCIALLY RESPONSIBLE INVESTING SERVICE Simplicity Solutions offers an optional Socially Responsible Investing (“SRI”) screening service designed for Clients who wish to integrate Environmental, Social and Governance factors into their investments. SRI overlay screens can be applied to an existing account and has the ability to be customized to exclude investments within certain segments. This service is subject to a client account minimum of $250,000. Simplicity Solutions maintains discretion for this service in the selection of investments, timing and execution of transactions. INDEX REPLICATION SERVICE Simplicity Solutions offers a replicated index solution, which can give Clients direct, index-like exposure through recommendation of a sub-set of securities that are representative of a particular index with similar risk characteristics. This service is subject to a client account minimum of $250,000. Simplicity Solutions maintains discretion for this service in the selection of investments, timing and execution of transactions. DATA AGGREGATION Simplicity Solutions offers optional Data Aggregation Services which enables Clients to monitor accounts that are not managed by Simplicity Solutions. Using Data Aggregation Services, Clients can examine their holdings, allocation of assets and portfolio performance across the full spectrum of a specific Client’s in-house and held away accounts. Through use of a data aggregation system, Simplicity Solutions has the ability to generate performance reporting which is calculated according to industry standards and can be applied to each account or combination of several related accounts on a household or family level. SOFTWARE TOOLS Simplicity Solutions provides a customizable asset management software program through a web-enabled platform ("Platform") primarily to other Advisers, who in turn, provide the Platform to their investment adviser representatives. Simplicity Solutions may also license the Platform to certain Advisers. The Platform is typically customized and may be private labeled in the name of the applicable Adviser. Advisers can provide the Platform to investment advisor representatives, who can use the Platform to manage the accounts of their respective Clients, which typically includes individuals and their related trusts or estates. The Platform provides Advisers the ability to offer their Clients a separate accounts program, various asset allocation programs and account reporting services. Simplicity Solutions also allows Advisers to combine these programs to suit the needs of their Clients. (Page 7 of 20) BACK-OFFICE PROCESSING/BILLING SERVICES Simplicity Solutions provides back-office functions on behalf of Advisers including daily account reconciliation and asset transfers. Simplicity Solutions uses electronic data feeds from trading/clearing/custodial firms to streamline the account reconciliation process. Simplicity Solutions uses billing software to automate billing for Advisers, which can accommodate a billing structure to include house-holding of accounts to capture scaling rates, several layers of combined accounts and assets, flat fee billing, credits, advance or arrear billing, daily weighted average billing and event triggered billing. INVESTMENT ADVISORY SERVICES In general, Simplicity Solutions and its Advisers provide services to their Clients through Simplicity Solutions’ Managed Account Program as described in this Disclosure Brochure. As of January 1, 2023, Simplicity Solutions ceased offering clients direct investment advisory accounts and only provides sub-advisory and “TAMP” services to institutional firms. However, Simplicity Solutions maintains a limited number of legacy advisory accounts, in which the Client has entered into a written Investment Management Agreement (the “Agreement”) with Simplicity Solutions. The Agreement describes the nature and extent of Simplicity Solutions’ services, the terms and conditions applicable to such services, and the fees to be charged. It should be noted that the services and fees described in this Disclosure Brochure may not all be applicable to a Client’s specific Agreement. Clients will receive a copy of this Disclosure Brochure prior to the execution of the Agreement. ASSETS UNDER MANAGEMENT As of December 31, 2022, Simplicity Solutions was providing investment advisory and/or portfolio management services for $3,392,815,637 on a discretionary basis and $64,976,867 on a nondiscretionary basis.