Firm Description Benedetti and Gucer, Inc. dba Benedetti, Gucer & Associates’ (“BGA,” the “Firm,” “we,” “us,” “our”) is an investment adviser providing wealth management services and financial planning services to individuals, high net-worth individuals, trusts, and estates. BGA was founded in 2013. Principal Owners BGA is owned equally by Jaime Benedetti and Bob Gucer. Types of Advisory Services BGA offers the following types of advisory services: Wealth management and financial planning for individuals and/or small businesses. Wealth Management BGA continuously advises its clients regarding investing their funds to meet their individual needs. During detailed personal discussions, BGA helps its clients identify and establish their goals and objectives based on their particular circumstances. BGA then develops the client’s personal investment policy reflecting the client’s goals and objectives and creates and manages a portfolio following that policy. BGA manages advisory accounts on a discretionary basis. In some cases, the firm will offer accounts on a non- discretionary basis. The client’s stated objectives guide BGA’s account supervision (e.g., maximum capital appreciation, growth, income, growth and income, etc.). BGA will create a portfolio consisting of one or all of the following: individual equities, bonds, no-load or load-waived mutual funds, Exchange Traded Funds (ETFs), including managed futures, non-traded REITS, private equity funds, and digital assets. BGA may also recommend other alternative investments. BGA will allocate the client’s assets among various investments considering the overall management style selected by the client. Mutual funds will be selected considering any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the fund manager’s track record; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. Financial Planning BGA offers financial planning services, which may include a review of all aspects of a client’s current financial situation, including the following components: cash management, risk management, insurance, education funding, goal setting, retirement planning, estate and charitable giving planning, tax planning, and capital needs planning. BGA meets with the client to review risk tolerance, financial goals and objectives, and time horizons. Additional meetings may include a review of additional financial information; sources of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax returns, investments, and personal and family obligations. Financial planning services may be comprehensive or may focus on certain components. A client should understand that when BGA is engaged to address only certain components, the client’s overall financial and investment issues may not be taken into consideration. Financial planning services create a potential conflict of interest. The client is under no obligation to utilize additional services of BGA and its representatives and is under no obligation to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Consulting Services – 401(k) Plan Review BGA offers clients a 401(k) Plan Review. This

service includes:
• A personal and independent review by an investment professional
• Professional research on your current 401(k) investment choices
• Suggested fund allocations based on your stated goals, age, and risk assessment The 401(k) Plan Review is not intended to be a comprehensive financial planning tool. It assumes a long-term strategy. Consulting Services - ERISA/ Plan Sponsor Consulting BGA offers ERISA Plan Sponsor Consulting Services. These services include:
• Plan Design Consulting and Review;
• Fiduciary Review;
• Fee Review;
• Investment Review; and
• Educational Planning. Tailored Relationships BGA tailors advisory services to the individual needs of the client. BGA clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to BGA in writing. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs BGA does not refer clients to wrap fee programs. Conflicts of Interest All material conflicts of interest regarding BGA, its Investment Advisor Representatives and any of BGA’s employees which could reasonably expect to impair the rendering of unbiased and objective advice have been disclosed. Client Assets As of December 31, 2023, BGA manages $572,270,903 million in assets, all on a discretionary basis.