A. Description of the Advisory Firm Silicon Private Wealth, LLC (hereinafter “SPWL”) is a Limited Liability Company. The firm was formed in April 2016, and the principal owners are Patricia Gail Williams, Calum Cunningham, Scott Smith, and Peter Verbica. B. Types of Advisory Services Portfolio Management Services SPWL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SPWL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring
• Third Party arrangements SPWL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. SPWL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SPWL’s economic, investment or other financial interests. To meet its fiduciary obligations, SPWL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SPWL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is SPWL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; educational planning; and debt/credit planning. In offering financial planning, a conflict exists between the interests of the investment adviser and the interests of the

client. The client is under no obligation to act upon the investment adviser's recommendation, and, if the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. This statement is required by California Code of Regulations, 10 CCR Section 260.235.2. Services Limited to Specific Types of Investments SPWL generally limits its investment advice to mutual funds, fixed income securities (including treasury inflation protected/inflation linked bonds), real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), options, non-U.S. securities, venture capital funds or private placements. SPWL may use other securities as well to help diversify a portfolio when applicable. Selection of Other Advisers SPWL may direct clients to third-party investment advisers. Before selecting other advisers for clients, SPWL will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where SPWL is recommending the adviser to clients. C. Client Tailored Services and Client Imposed Restrictions SPWL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by SPWL on behalf of the client. SPWL may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SPWL from properly servicing the client account, or if the restrictions would require SPWL to deviate from its standard suite of services, SPWL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. SPWL does not participate in any wrap fee programs. E. Assets Under Management SPWL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 1,306,164 $ 116,013,777 December 2023