Daniel Krug & Associates is a state-registered investment adviser firm located in Clarkston, Michigan. The firm is legally formed as a corporation under the laws of the State of Michigan.  Daniel Krug is the Chief Executive Officer (CEO) and sole owner of Daniel Krug & Associates. Full details of the education and business background of Daniel Krug are provided at Item 19 of this Disclosure Brochure.  Daniel Krug & Associates filed its initial application to become registered as an investment adviser in December 2018. Introduction The investment advisory services of Daniel Krug & Associates are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Daniel Krug & Associates (referred to as your investment adviser representative throughout this brochure). Daniel Krug & Associates is registered as an investment adviser firm and licensed as an insurance agency. As a client of Daniel Krug & Associates your investment adviser representative will also serve as an insurance agent of Daniel Krug & Associates. This means your investment adviser representative, acting as an insurance agent, will recommend you place your assets in insurance products and annuities when he or she believes it is your best interest to do so. Daniel Krug & Associates has taken steps to manage this conflict of interest by requiring that each investment adviser representative (i) only recommend insurance and annuities when in the best interest of the client and without regard to the financial interest of Daniel Krug & Associates and its investment adviser representative or its insurance agents, (ii) not recommend insurance and/or annuities which result in your investment adviser representative acting as an insurance agent and/or Daniel Krug & Associates receiving unreasonable compensation related to the recommendation and (iii) disclose in writing to a client any material conflicts of interest related to insurance or annuity recommendations. Description of Advisory Services The following are descriptions of the primary advisory services of Daniel Krug & Associates. Please understand that a written Investment Management Agreement, which details the exact terms of our services, must be signed by you and Daniel Krug & Associates before we can provide you the services described below. Daniel Krug & Associates offers investment management services, which involves Daniel Krug & Associates providing you with continuous and ongoing supervision over your specified accounts. We make available to clients access to an account aggregator in which clients will input all of their assets, liabilities, income and expenses. Our investment adviser representatives will discuss and help to identify client’s financial needs and objectives based upon the general background and financial information the client provides to us to develop investment guidelines (“Investment Guidelines”) for the client. We will not consider any cash, securities, or other assets unless the client tells us about them and they are included in the planning process. Simultaneous with the execution of the Daniel Krug & Associates Investment Management Agreement, the client signs the Client Services Agreement (“CSA”) among AssetMark, Inc. (“AssetMark”), the client and Daniel Krug & Associates. By entering into this agreement, the client is participating in a wrap fee program sponsored by AssetMark (“AssetMark Platform”). The AssetMark Platform makes available investment strategies including model portfolios. AssetMark may also provide discretionary management of the client’s account if selected by the client. We will recommend the investment strategies and subadvisors available on the AssetMark Platform. The subadvisor will be responsible for recommending the securities in the account. Daniel Krug & Associates will be responsible for monitoring the sub-advisors and recommending changes to the sub-advisors or model portfolios. Whether or not Daniel Krug & Associates has discretionary authority to select the sub-advisor, the sub- advisor will have discretionary authority to manage the portion of the client’s assets allocated by the us to such sub-advisor. In addition, you must appoint our firm as your investment adviser of record on specified Accounts (collectively, the “Account(s)”) at your custodian. We may request additional information from time to time to assist us in managing your Account(s). We rely upon the information you provide; we do not independently verify the accuracy or completeness of any of your information. We will review the Investment Guidelines with you on an annual basis. Based upon the Investment Guidelines, we will develop and will periodically update your investment strategy. You will be responsible for notifying us, in writing, of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. 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. It is important that you understand that we manage investments for other clients and can 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 taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we can buy, sell or recommend for any other clients or for our own Accounts. Conflicts can arise in the allocation of investment opportunities among Accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your Account(s) and other Accounts advised by our firm among such Accounts equitably and consistent with the best interests of all Accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be 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 any client or use it for any client's benefit. Selection of Sub-Advisers As stated above, Daniel Krug & Associates will provide recommendations to the client to utilize one or more specific sub-adviser(s) (individually "Sub-Adviser" and collectively "Sub-Advisers") to manage the Account or a portion of the assets of the Account. When a Sub-Adviser is selected, the Sub-Adviser will have discretionary authority on your Account to place trades and make changes to the Account or the portion of your Account the Sub-Adviser is authorized to manage. Daniel Krug & Associates will conduct due diligence of any recommended Sub-Adviser and monitor the performance of Sub-Adviser with respect to the Sub-Advisor's management of the designated assets of Account relative to appropriate peers and/or benchmarks. Daniel Krug & Associates will be available to answer questions a client has regarding any portion of client's Account managed by a Sub-Adviser and will act as the communication conduit between Client and the Sub-Adviser. The recommendation of Sub-Advisers, or other products and funds, can be done on a discretionary or non-discretionary basis with the specific terms outlined in your Advisory Agreement. When a client authorizes Daniel Krug & Associates to have the ability to select Sub- Advisers or other products and funds on a discretionary basis, Daniel Krug & Associates will have the authority to select and terminate Sub-Advisers, products or funds without the client's specific approval. A complete description of the Sub-Adviser's services, practices and fees will be disclosed in the Sub- Adviser's Form ADV Part 2A that will be provided to client. Financial Planning Services - Daniel Krug & Associates offers Financial Planning Services, which involves ongoing financial planning and consulting to our existing clients. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Financial Planning Services can cover specific or multiple topics. We provide "holistic" financial plan consultations, which typically address the following topics:  Asset Allocation  Budgeting  Buy / Sell Analysis of Assets and Impacts on Cash Flow & Net Worth Projections  Cash Flow Analysis & Budgeting  College/Education Planning  Estate and Tax Planning  Investment Planning  Retirement Planning  Risk Management We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer "as-needed" consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an "as-needed" consultation, it will be incumbent upon you to identify those particular issues for which you are seeking my

advice or consultation on. Referrals to Third-Party Money Managers - Daniel Krug & Associates offers advisory services by referring clients to independent, third-party investment advisory firms providing Turn-Key Asset Management Programs (“TAMP”) and other advisory services. Third-party investment advisory firms are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. As a result of the referral, the firm is paid a portion of the fee charged and collected by the third-party investment advisory firm in the form of referral and consultation fees. Each referral arrangement involving U.S. resident clients and/or U.S. based third-party investment advisory firms is performed pursuant to a written promoter agreement (previously referred to as a solicitor agreement) and is in compliance with SEC Rule 206(4)-1 and applicable state securities rules and regulations. Under this program, we assist you with identifying your risk tolerance and investment objectives. Third- party investment advisory firms are recommended in relation to your stated investment objectives and risk tolerance. You must enter into an agreement directly with the third-party investment advisory firms who provide your designated account with asset management services. We are available to answer questions that you have regarding your account and act as the communication conduit between you and the third-party investment advisory firm. The third-party investment advisory firm will typically take discretionary authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account(s) managed by a third-party investment advisory firm. You are never required or obligated to work with a third-party investment advisory firm we recommend and may work with the financial professional of your choice. However, please understand if you choose not to utilize an investment advisory firm we recommend and/or not provide your personal and financial information to the third-party investment advisory firm in order to receive advisory services, then we are unable to assist you with your advisory needs through this service. No guarantees can be made that a client's financial goals or objectives will be achieved by a third-party investment advisory firm recommended by our firm. Further, no guarantees of performance can ever be offered by our firm. Please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for more details. Newsletters - Daniel Krug & Associates occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Newsletters are provided to clients and prospective clients free of charge. Seminars - Daniel Krug & Associates provides class seminars taught throughout the year. Seminar topics focus on retirement planning issues but can also include other general financial planning topics. Seminars are always offered on an impersonal basis and do not focus on the individual needs of participants. Seminars are offered to clients and prospects free of charge. Limits Advice to Certain Types of Investments Daniel Krug & Associates provides investment advice on the following types of investments:  Mutual Funds  Exchange Traded Funds (ETFs)  Equity Positions (i.e., individual stock positions)  Fixed Income Securities (e.g., individual bond positions)  Securities Traded Over-the-Counter  Municipal Securities  Variable Annuities  Variable Life Insurance  US Government Securities  Fixed Indexed Annuities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that can be suitable for each client's specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we can increase cash holdings as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Participation in Wrap Fee Programs Daniel Krug & Associates offers investment management services through the AssetMark Platform. This platform is a wrap fee program which bundles various services together and charges an all- inclusive fee, named a “wrap fee” because it wraps around all services rather than charging a separate fee for each service. A description of the AssetMark Platform practices, fees and conflicts will be disclosed in AssetMark’s Appendix 1 of Form ADV that will be provided to clients prior to or at the time of entering into an agreement with AssetMark and Daniel Krug & Associates. Tailor Advisory Services to Individual Needs of Clients Daniel Krug & Associates' advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our financial planning services are always provided based on your individual needs. When providing financial planning services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser 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. Retirement Plan Rollover Recommendations To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account ("Rollover IRA"), managed by our firm please know that we and our investment adviser representatives have a conflict of interest. Daniel Krug & Associates and our investment adviser representatives can earn investment advisory fees by recommending that you roll over your account at the retirement plan to a Rollover IRA managed by our firm. However, we will not earn any investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by our firm. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm may be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Daniel Krug & Associates receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by Daniel Krug & Associates and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. To the extent we provide you investment advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the retirement plan to a Rollover IRA or make a distribution from the retirement plan, Daniel Krug & Associates hereby acknowledges our fiduciary obligations to you with regard to our investment advice about whether to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement plan, Our investment advisor representatives shall act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client's needs, without regard to the financial or other interests of Daniel Krug & Associates or our affiliated personnel. Client Assets Managed by Daniel Krug & Associates As of April 30, 2024, Daniel Krug & Associates had $116,610,899 in client assets managed on a discretionary basis.