Firm information Full Sail Capital, LLC (“Full Sail Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Oklahoma. Full Sail Capital has been registered as an investment adviser since February 2018 and is principally owned by David Stanley (Chief Executive Officer), Zachary Reynolds (Chief Investment Officer), and Scott Cravens (Chief Operating Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Full Sail Capital. Advisory Services Offered Full Sail Capital offers a variety of advisory services, which include financial planning, consulting, and investment management services to individuals, high net worth individuals, trusts, estates, retirement plans, charitable organizations, corporations, and business entities (each referred to as a “Client”). Clients are required to enter into one or more written agreements with Full Sail Capital setting forth the relevant terms and conditions of the advisory relationship. Full Sail Capital serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Full Sail Capital’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation, or Interest in Client Transactions, and Personal Trading. Wealth Management Services Full Sail Capital provides Clients with wealth management services which include the financial planning and consulting services described above, as well as discretionary and/or non-discretionary management of investment portfolios. Investment Management Services Full Sail Capital primarily allocates Client assets among various exchange-traded funds (“ETFs”), mutual funds, and individual debt and equity securities in accordance with their stated investment objectives. Less frequently, Full Sail Capital also recommends that certain eligible Clients invest in privately placed securities, which may include debt, equity, and/or interests in pooled investment vehicles (e.g., private equity, real estate, and hedge funds). The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Where appropriate, the Advisor also provides advice about any type of legacy position or other investment held in Client portfolios. Clients can engage Full Sail Capital to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Full Sail Capital directs or recommends the allocation of Client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Full Sail Capital tailors its services to meet the needs of its individual Clients and seeks to ensure, on a continuous basis, that Client portfolios are managed in a manner consistent with those needs and objectives. Full Sail Capital consults with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios. Clients are advised to notify Full Sail Capital if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Full Sail Capital determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Advisor’s management efforts. Under certain circumstances, Full Sail Capital may accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is 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. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers - In limited cases, Full Sail Capital will recommend independent investment managers (“Independent Managers”), to actively manage a portion of its Clients’ assets in accordance with stated investment objectives. The Advisor is given discretion to hire and fire the Independent Managers without the Client’s prior consent. The specific terms and conditions under which a Client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, Clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Full Sail Capital evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third party analyses it believes are reputable. To the extent possible, Full Sail Capital seeks to assess the Independent Managers’ investment

strategies, past performance and risk results in relation to its Clients’ individual portfolio allocations and risk exposure. Full Sail Capital also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Full Sail Capital continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, Full Sail Capital monitors the performance of those accounts being managed by Independent Manager. Full Sail Capital seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. Financial Planning and Consulting Services Full Sail Capital offers Clients a broad range of financial planning and consulting services, which includes retirement planning, education planning, estate planning, tax planning, and cash flow planning. These services are generally only rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In addition, Clients may engage the Advisor, through its wholly-owned subsidiary, FSC Realty, LLC, to consult regarding real estate deals or other investments that are sourced by the Client and not an Advisor recommendation. A financial plan developed for, or financial consultation rendered to the Client may include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Full Sail Capital may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Estate Plan Consulting Services Full Sail Capital offers estate plan consulting services as part of the Advisor’s wealth management services. Full Sail Capital’s services may include the Advisor’s licensed attorneys working with Clients’ estate planning attorneys to ensure documents remain effective legally and function practically. Family Office Services Full Sail Capital offers family office services as part of the Advisor’s wealth management services. Full Sail Capital’s services may include bill pay services, consolidated reporting, cash flow analysis, family financial literacy, and wealth transfer planning. Under these services, Full Sail will accept or maintain custody of Client’s funds or securities. Please see Item 15 – Custody for more information. Retirement Plan Advisory Services Full Sail Capital provides various retirement plan advisory services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing, and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services: 3(21) Services Plan Design and Strategy Investment Recommendations & Monitoring Plan Review and Evaluation Plan Fee Benchmark Executive Planning Plan Fee Cost Analysis Co-Fiduciary Services Plan Committee Consultation Compliance Assistance Participant Education 3(38) Services Plan Design and Strategy Discretionary Investment Management Plan Review and Evaluation Plan Fee Benchmark Executive Planning Plan Fee Cost Analysis Fiduciary Services Plan Committee Consultation Compliance Assistance Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by the Advisor as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Client Account Management Prior to engaging Full Sail Capital to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services provided by the Advisor may include:  Establishing an Investment Strategy – Full Sail Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.  Asset Allocation – Full Sail Capital will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.  Portfolio Construction – Full Sail Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – Full Sail Capital will provide investment management and ongoing oversight of the Client’s investment portfolio. Wrap Fee Programs Full Sail Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Full Sail Capital. Assets Under Management As of December 31, 2023, Full Sail Capital manages $1,831,472,226 in Client assets, $1,733,699,747 of which are on a discretionary basis and $97,772,479 on a non-discretionary basis. Furthermore, Full Sail Capital has an additional $40,335,215 of assets under advisement. Clients may request more current information at any time by contacting the Advisor.