Firm Description Strategent Financial, LLC (“Strategent”) was founded in July 2008 by Dale S. Lam who is Strategent’s principal owner and Chief Compliance Officer. Strategent primarily provides wealth management services to individuals and families as described below. Strategent also provides advice to other entities such as pension and profit sharing plans, trusts, estates, and corporations. Strategent is a fee-only financial services firm. Strategent does not make commissions from selling annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. Strategent is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Types of Advisory Services Strategent offers the following types of advisory services: Wealth Management Strategent’s primary service offering, “wealth management,” combines discretionary portfolio management and financial consulting about a broad range of topics such as: financial planning, tax efficiency, charitable gifting, estate considerations, college planning, risk / insurance management, wealth transfer and other special needs. This process includes development of a long-term financial strategy through the continuing, collaborative relationship with the client. This service is generally targeted towards accounts with a minimum of $800,000 in assets under management with Strategent and fees are based on a percentage of the assets under management. When engaging Strategent to provide wealth management services, clients enter into an agreement setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fee that is due from the client. Strategent’s portfolio management is tailored to the individual needs of the client developed through personal discussions to establish short and long-term goals and investment objectives. Strategent develops each client’s personal investment plan and creates and manages a portfolio based on that policy. Strategent manages wealth management accounts on a discretionary basis only. Account supervision is guided by the agreed upon investment plan. Strategent does not provide custody or other administrative services in connection with its wealth management services, except as indicated in Item 15 below. All client assets will be managed within their designated brokerage account or pension account held with a qualified custodian. Financial Planning On a limited basis, Strategent will agree to provide financial planning services to clients that are not wealth management clients according to the terms and conditions of a financial planning agreement. Financial planning services address the specific needs of 4 Strategent Financial, LLC the client and may include any or all of the following areas of concern: personal financial planning, education planning, income tax and cash flow analysis, death and disability analysis, retirement planning, investment review, estate planning, and insurance analysis. Depending on the service being provided, financial planning clients may receive a written report, providing a detailed financial plan designed to achieve their stated financial goals and objectives. If a client chooses to implement the recommendations of the financial planning service, Strategent suggests that clients work closely with their attorney, accountant, insurance agent, or other designated professionals. Implementation of the recommendations is entirely at the client’s discretion. Retirement Plan Advisory Services Strategent offers retirement plan advisory services to company retirement plan sponsors organized under the Employee Retirement Income Security Act of 1974 (“ERISA”). Strategent offers to provide the following services in an ERISA Section 3(21) capacity to those plan sponsors under the terms and conditions of the retirement plan advisory agreement:
• Development and Updates to Investment Policy Statement (“IPS”)
• Investment Recommendations
• Investment Monitoring and Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance o Menu Diversification o Selection of Qualified Default Investment Alternative
• Communication and Education o Education Services to Plan Committee o Informational Meetings and Participant Education Portfolio Construction Overview Strategent will typically create a portfolio consisting of some combination of the following, depending on the particular needs of the client: no-load or load-waived mutual funds, exchange traded funds (“ETFs”), individual equities, bonds, certificates of deposit or other investment products. Strategent will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Mutual funds and ETFs will be selected on the basis of any or all of the following criteria: the asset class targeted by the fund, the fund’s adherence to the stated investment goals, the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; 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. Clients will have the opportunity to place reasonable restrictions on

the types of investments which will be made on the client’s behalf. Clients will retain individual ownership of all securities. 5 Strategent Financial, LLC Wrap Fee Programs Strategent does not participate in a wrap fee program. Assets Under Management As of December 31, 2023, Strategent managed $262,816,045 in client assets on a discretionary basis. Miscellaneous Disclosures ERISA / IRC Fiduciary Acknowledgment. When Strategent provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary 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. Because the way Strategent makes money creates some conflicts with client interests, Strategent operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Strategent must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that Strategent gives advice that is in the client’s best interest; charge no more than is reasonable for Strategent’s services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of Interest. An investor leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Strategent recommends that a client roll over their retirement plan assets into an account to be managed by Strategent, such a recommendation presents a conflict of interest if Strategent will earn a new (or increase its current) advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to an account managed by Strategent. Limitations of Financial Consulting Services. Strategent does not serve as a law firm, accounting firm, or insurance agency, and no portion of Strategent’s services should be construed as legal, accounting, or insurance implementation services. Unless specifically agreed in writing, Strategent and representatives are not responsible to implement any financial plans or financial planning advice, provide ongoing financial planning services, or provide ongoing monitoring of financial plans or financial planning advice. Strategent’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the written financial plan, or upon termination of the applicable agreement. Clients retain absolute discretion over all financial planning and related implementation decisions and are free to accept or reject any recommendation from Strategent and its representatives in that respect. Upon specific request, Strategent may recommend the services of other professionals for 6 Strategent Financial, LLC certain non-investment implementation purposes (e.g., attorneys, accountants, or insurance agents). Clients are not obligated to engage any recommended professional to provide services, who are responsible for the quality and competency of the services they provide. Dimensional Fund Advisors: Strategent may allocate client investment assets to mutual funds and ETFs issued by Dimensional Fund Advisors (“DFA”), some of which are generally only available through selected registered investment advisers. Therefore, upon the termination of Strategent’s services, a client may experience restrictions on the transfer, additional purchases, or reallocation among DFA funds. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, Strategent will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when Strategent determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, Strategent is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Strategent if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Strategent’s services or previous recommendations, or if they are not receiving at least quarterly statements from their account custodian. 7 Strategent Financial, LLC