BACKGROUND WealthSource Partners, LLC is a Nevada limited liability company that was organized on November 2, 2015 in the state of California, and subsequently became registered as an investment adviser on February 18, 2016. WealthSource was created from the merger of the assets of Vellum Financial, LLC, formerly a California limited liability company, and Avant- Garde Advisors LLC, formerly a Delaware limited liability company, both of which were originally formed in 2009. WealthSource is a wholly owned subsidiary of WealthSource Holdings, Inc., a Nevada corporation (“WHI”). WHI is controlled by a Board of Directors that consists of A. Bryan Sullivan, President; Eric Patton, Secretary and Treasurer; and Jon Dubravac. Mr. Sullivan is the only shareholder who owns, directly or indirectly, 25% or more of WHI’s outstanding voting securities. With respect to WealthSource, Mr. Patton serves as Chief Financial Officer, Jason Mirabella serves as Chief Operating Officer, Christopher Shea serves as Chief Investment Officer, Ryan Mannen serves as Chief Technology Officer, Natalia Autenrieth serves as Chief of Staff and David Ito serves as Chief Compliance Officer and General Counsel. On December 1, 2023, WealthSource entered into definitive agreements with OneDigital Investment Advisors LLC (“ODIA”), a registered investment adviser, pursuant to which certain assets of WealthSource were sold to ODIA (“Acquisition”). As a result of the Acquisition, many of WealthSource’s investment adviser representatives have now also become investment adviser representatives of ODIA and WealthSource anticipates that it will withdraw its registration as an investment adviser on or before August 27, 2024. WealthSource offers advisory services, which generally consist of (1) financial planning (level of detail and any written work product will vary by client engagement), (2) the provision of discretionary or non-discretionary investment recommendations relating to the purchase or sale of securities and/or the selection of third-party investment managers who are responsible for making portfolio management decisions (“Sub-Advisers”), (3) the ongoing monitoring of clients’ securities portfolios, and (4) non-discretionary recommendations regarding the purchase, exchange or surrender of insurance products. WealthSource’s advisory services are tailored to the specific needs of each client based on their investment objective(s), financial circumstances, and risk tolerance as conveyed to or assessed by an investment adviser representative of WealthSource (“IAR”). All clients can impose reasonable restrictions, at any time, on the securities or types of securities to be held in their portfolios. Restrictions, however, are deemed “unreasonable” (1) if they would interfere with the ability of WealthSource or a Sub-Adviser to make investment decisions in a timely manner, (2) if they would compel WealthSource to make investment decisions that would WealthSource® Partners, LLC Page 6 of 48 Form ADV, Part 2A be inconsistent with the client’s investment objectives, financial circumstances and/or risk tolerance, or (3) with respect to assets managed by a Sub-Adviser, if the Sub-Adviser prohibits clients from imposing the requested restriction. Any investment restrictions or changes to such restrictions must be provided to WealthSource in writing and signed by the client. Please note that the imposition of one or more investment restrictions could result in investment returns that are less optimal than the investment returns that would have been achieved if no investment restrictions were imposed on WealthSource. As of March 22, 2024, WealthSource had $2,116,238,123 in assets under management, of which $2,020,531,070 was managed on a discretionary basis. INVESTMENT ADVISORY SERVICES WealthSource offers a variety of investment advisory services on a discretionary or non- discretionary basis through its IARs. These services include, but are not limited to, the creation of investment and/or asset allocation strategies that are customized by the IAR for the client and/or the creation of customized portfolio allocations to model portfolios managed by WealthSource under the direction of its Chief Investment Officer (hereafter, “WSP Models”) or model portfolios managed by the IAR. The types of investments held in client accounts will vary depending on the investment/asset allocation strategy and/or model portfolio utilized in the management of the client’s account and can include, but are not limited to, exchange-traded funds (“ETFs”), mutual funds, exchange traded notes (“ETNs”), variable annuities, real estate investment trusts, equities, fixed income securities, options contracts, levered ETFs, structured products and other non-publicly-traded securities such as private investment funds (e.g., private equity funds, hedge funds). WealthSource may also utilize margin and/or engage in short selling in the management of client accounts. Clients should be aware that the market value of a client’s account and corresponding fee payable by the client to WealthSource is generally increased as a result of the use of leverage and, consequently, a conflict of interest exists when

WealthSource recommends the use of margin or short selling to clients. Client accounts are generally rebalanced or reallocated periodically in order to reestablish the targeted percentages of the initial asset allocation. This rebalancing or reallocation will generally be performed quarterly but may be performed more or less frequently. Third-Party Investment Managers In providing investment advisory services, WealthSource may also recommend the portfolio management services of other unaffiliated, independent investment advisers based on the needs of the client. When recommending third-party investment managers on a discretionary basis, WealthSource is responsible for performing due diligence on the third-party investment manager, hiring one or more third-party investment managers on behalf of the client, monitoring each third-party investment manager’s performance and adherence to its stated investment strategy and, if necessary, terminating the third-party investment manager on the client’s behalf. WealthSource® Partners, LLC Page 7 of 48 Form ADV, Part 2A Such third-party investment managers are hereafter referred to as “Sub-Advisers”. When recommending third-party investment managers on a non-discretionary basis, WealthSource will refer one or more third-party investment managers to the client for the client’s consideration. If the client elects to utilize a referred third-party investment manager, the client will enter into an investment management agreement directly with such investment manager and, consequently, WealthSource will not have the authority or ability to hire or terminate the third- party investment manager on the client’s behalf. Such third-party investment managers are hereafter referred to as “TPIMs”. Clients should be aware that when WealthSource refers a TPIM, WealthSource will be acting as a solicitor for such investment managers. Under this arrangement, the client will not pay any investment advisory fees to WealthSource with respect to assets placed under the TPIM’s management. Instead, WealthSource will be compensated through the receipt of solicitation fees paid by the TPIM. Please see the “Item 5 – Fees and Compensation” and the “Item 10 – Other Financial Industry Activities and Affiliations” sections below for important information regarding conflicts of interest relating to WealthSource’s activities as a solicitor. In light of the breadth of investment strategies that are available through Sub-Advisers and TPIMs and the unique combination of investment risks associated with each type of investment strategy, clients who are recommended the services of a Sub-Adviser or referred to a TPIM should carefully review the Form ADV, Part 2A (i.e., disclosure brochure), applicable Part 2Bs (i.e., brochure supplements), and Part 3 (i.e., Form CRS or client relationship summary) of the Sub-Adviser and/or TPIM for important information concerning the Sub-Adviser and/or TPIM and their investment strategies, including any associated risks and conflicts of interest. PENSION CONSULTING SERVICES WealthSource also offers fee-only, non-discretionary pension consulting services primarily to corporate retirement plans. Such services typically include the provision of investment advice about asset classes and investment alternatives, assistance in the selection of investment options to be made available by the retirement plan to its participants, monitoring of investment options that have been selected, periodic onsite meetings with responsible plan fiduciaries and providing general education to the plan’s participants. FINANCIAL PLANNING SERVICES (STAND-ALONE) WealthSource offers stand-alone financial planning services on an ad hoc, project or ongoing basis, which generally involves an analysis of the client’s current financial situation, goals, and objectives in order to provide advice and/or guidance on a range of topics that may include: Investment Analysis and Planning, Retirement Planning, Charitable Planning, Education Planning, Real Estate Analysis, Mortgage/Debt Analysis and/or Insurance Analysis. INSURANCE PLANNING SERVICES WealthSource® Partners, LLC Page 8 of 48 Form ADV, Part 2A WealthSource offers discretionary and non-discretionary insurance planning services limited to insurance products recommended and/or sold by DPL Financial Partners, LLC (“DPL”) to clients. As part of these services, WealthSource provides non-discretionary advice regarding the advisability of DPL’s insurance recommendations in relation to the client’s overall financial planning objectives or plan, which include recommendations to purchase a new insurance product; adding on or forgoing a rider to a new insurance product; retaining, annuitizing, exchanging, surrendering, lapsing or withdrawing from an existing insurance product; taking out a loan from an existing insurance product and/or entering into a life and/or viatical settlement with respect to an existing insurance product as well as discretionary advice regarding the allocation of investments between variable insurance product sub-accounts, changing indices for interest-crediting rates, and/or changing an insurance product’s indexing method. Please see the