The Stanich Group, LLC (“Cultivating Wealth” or “CW”) offers investment advisory services in the form of financial planning, discretionary investment management, and consulting services. Sara Stanich is the sole owner. Our firm is a limited liability company founded and headquartered in the State of New York and registered with the Securities and Exchange Commission (SEC). Registration of an investment adviser does not imply a certain level of skill or training. As of 12/31/2023, CW had $131,187,017 in discretionary assets under management (AUM). Investment Management with Financial Planning CW provides discretionary investment management services. Our investment management service focuses on allocating assets among various asset classes, portfolio diversification, managing portfolio risk, while considering other general economic and financial factors. CW offers financial advice and guidance to our clients and reviews existing and potential investments from a strategic and tactical asset allocation approach. Investments are chosen and structured based on the individual client needs. During our discovery process, we listen actively to the client's known and unknown goals and objectives, review current investments, time horizons, risk tolerance, and liquidity needs. We also review and discuss the client's prior investment history, as well as family composition and investing background. We then assist clients with the management of their investments on a discretionary basis. CW 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. Investment management services include, but are not limited to, the following:
• Investment strategy.
• Personal investment policy.
• Asset allocation.
• Asset selection.
• Risk tolerance.
• Regular portfolio monitoring. CW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CW will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Account supervision and structure is guided by a client’s objectives (i.e. capital appreciation, growth, income, or growth and income), as well as their specific tax situations and potential implications. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors on assets managed on a discretionary basis. Our investment recommendations are not limited to any specific security or industry. Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended when consistent with a client's stated investment objectives, risk tolerance, liquidity needs, comfort level and suitability. CW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of CW’s economic, investment or other financial interests. To meet its fiduciary obligations, CW attempts to avoid, among other things, investment or trading practices that systematically advantage

or disadvantage certain client portfolios, and accordingly, CW’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 CW’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 and Consulting Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Business and Personal Financial Planning. Financial plans and consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. CW also provides consulting for small business owners to assess the current value of their business, develop strategies to increase business value, and understand the role of the business as an asset in the client’s personal financial plan. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Divorce Financial Planning CW will also work with clients going through divorce to prepare detailed budgets, analyze the long‐ term implications of multiple settlement options and produce the financial statements needed to make informed decisions relating to the divorce process. Client Tailored Services and Client Imposed Restrictions CW will tailor a financial plan, which includes an investment strategy, for each client. This process starts with an initial discovery session to get to know the client, the client’s specific needs and requirements. CW will then create an investment portfolio for the client with a specific set of recommendations based on the client’s personal needs, investment objectives, to include any personal and specific tactical restrictions which may be imposed by the client. Clients may impose certain restrictions on investing in specific securities and/or types of securities in accordance with their legal status, values and/or beliefs. However, if the requested restrictions prevent CW from properly servicing the client’s account, or the restrictions would require CW to deviate from its standard service model, CW reserves the right to decline these requests and/or end the relationship.