A. Opes Wealth Management, LLC (“OWM”) is a corporation formed on November 6, 2018 in the State of California. OWM became registered with the United States Securities and Exchange Commission (“SEC”) as an Investment Adviser Firm in December 2018. OWM is principally owned by Mark Duvall, Erin Whalen, Tracie Southerland, and Louis Odette. OWM operates out of Menlo Park, California and Ashland, Oregon. B. As discussed below, OWM offers to its clients (individuals, business entities, and trusts) discretionary investment advisory services, and, to the extent specifically requested by a client financial planning services and related consulting services. INVESTMENT ADVISORY SERVICES The client can determine to engage OWM to provide discretionary investment advisory services on a fee‐only basis. All investment advice provided is customized to each client’s investment objectives and financial needs. OWM tailors its advisory 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. OWM 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. Opes Premier Services Clients may choose to engage OWM to provide combined financial planning and investment management services relative to investment accounts under the “Opes Premier Services” program (“Opes Premier Program”). To commence the Opes Premier Program engagement, clients are required to enter into a Financial Counseling and Investment Advisory Agreement with OWM setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. An investment adviser representative will then meet with the client to ascertain investment objectives, risk tolerances, restrictions, and to create a balance sheet analysis report. Once defined and agreed upon, OWM will prepare the client’s Financial Assessment and Recommendations analysis and review it in detail with the client. Thereafter, OWM will allocate investment assets consistent with the designated investment objectives and the Financial Assessment and Recommendations analysis. OWM primarily allocates investment assets among mutual funds and exchange traded funds (“ETFs”) generally following the parameters of one or more similarly managed asset allocation models described in Item 8.C. below. Under the Opes Premier Program, OWM may adjust its trading strategies within the similarly managed investment allocation models on an individualized client basis depending upon each client’s investment objectives and/or tax consequences. When consistent with client investment objectives, OWM may also allocate all or a portion of their investment assets among Separately Managed Account programs sponsored by Charles Schwab & Co., Inc. (Charles Schwab & Co., Inc. and its affiliates including but not limited to Schwab Wealth Investment Advisory, Inc. are collectively referred to as “Schwab”) OWM is not owned by, affiliated with, or sponsored or supervised by Schwab. (Please refer to the “Separately Managed Account Program” disclosure below). After OWM allocates Opes Premier Program investment assets, OWM continues to provide ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, provides tax loss harvesting and related consultation services as may be applicable, and rebalances the portfolio on a discretionary basis as applicable. OWM also offers to review the Opes balance sheet analysis report on an annual basis with the client to address any changed circumstances, and to evaluate whether the financial plan is still appropriate based upon the client’s individual investment objectives. OWM will also modify the balance sheet analysis report on an annual basis or upon a client’s specific request based upon a change in financial circumstances without additional charge. However, in the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of OWM), OWM may determine to charge for such additional, the dollar amount of which shall be set forth in separate written notice. Opes Select Services Clients may choose to engage OWM to provide combined financial planning and investment management services relative to investment accounts under the “Opes Select Services” program. To commence the Opes Select Program engagement, clients are required to enter into a Financial Counseling and Investment Advisory Agreement with OWM setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. An investment adviser representative will then meet with the client to ascertain investment objectives, risk tolerances, restrictions, and to create a balance sheet analysis report. Once defined and agreed upon, OWM will prepare the client’s Financial Assessment and Recommendations analysis and review it in detail with the client. Thereafter, OWM will allocate investment assets consistent with the designated investment objectives and the Financial Assessment and Recommendations analysis. OWM primarily allocates investment assets among mutual funds and exchange traded funds (“ETFs”) generally following the parameters of one or more similarly managed asset allocation models described in Item 8.C. below. The Opes Select program differs from the Premier program in that there is no “location optimization” (tax optimization strategy that strategically allocates taxable and tax deferred investments), fewer and different Alternative Investments, no Separate Account Managers. Under the Opes Select Program, OWM may adjust its trading strategies within the similarly managed investment allocation models on an individualized client basis depending upon each client’s investment objectives and/or tax consequences. After OWM allocates Opes Select Program investment assets, OWM continues to provide ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives, provides tax loss harvesting and related consultation services as may be applicable, and rebalances the portfolio on a discretionary basis as applicable. OWM also offers to review the Opes balance sheet analysis report on an annual basis with the client to address any changed circumstances, and to evaluate whether the financial plan is still appropriate based upon the client’s individual investment objectives. OWM will also modify the balance sheet analysis report upon a client’s specific request based upon a change in financial circumstances without additional charge. However, in the event that the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of OWM), OWM may determine to charge for such additional, the dollar amount of which shall be set forth in a separate written notice to the client. Opes Access Services Clients may choose to engage OWM to provide investment management services utilizing the Institutional Intelligent Portfolios® Program, under the “Opes Access Services” program. OWM may choose to accept accounts into the program that may be higher or lower than this threshold, in its sole discretion. The Institutional Intelligent Portfolios® Program is an automated investment program through which clients are invested in a range of investment strategies OWM has constructed and manages, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash allocation. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). OWM uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate Opes Access Services. OWM is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (collectively, “Schwab”). OWM, and not Schwab, is the client’s investment adviser and primary point of contact with respect to Opes Access Services. As between OWM and Schwab, OWM is solely responsible for determining the appropriateness of Opes Access Services for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals. OWM has contracted with SPT to provide OWM with the Platform, which consists of technology and related trading and account management services for Opes Access Services. The Platform enables OWM to make Opes Access Services available to clients online and includes a system that automates certain key parts of its investment process (the “System”). The System includes an online questionnaire that helps OWM determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that OWM will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but OWM then makes the final decision and selects a portfolio based on all the information it has about the client. The System also includes an automated investment engine through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). OWM charges clients a fee for its services as described below under Item 5, Fees and Compensation. OWM’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Schwab as part of Opes Access Services. OWM does not pay SPT fees for the Platform so long as it maintains $100 million in client assets in accounts at CS&Co that are not enrolled in Opes Access Services. If Opes does not meet this condition, then it must pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of its clients’ assets in Opes Access Services. This arrangement presents a conflict of interest, as it provides an incentive for Opes to recommend that clients maintain their accounts at Schwab. Clients enrolled in Opes Access Services are limited in the universe of investment options available to them. For example, the investment options available are limited to ETFs, whereas OWM recommends various other types of securities in its other services. Opes Access Services is designed to provide guidance and professional assistance to individuals who are beginning the process of accumulating wealth. Clients will have access to their accounts

and a financial interface online but will also have the opportunity to confer with OWM with respect to their account. Rebalancing The System will rebalance a client’s account periodically by generating instructions to CS&Co to buy and sell shares of ETFs and depositing or withdrawing funds through the “Sweep Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an ETF varies by a set parameter established by OWM, (ii) OWM decides to change the ETFs or their percentage allocations for an investment strategy or (iii) OWM decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Accounts below $5,000 may deviate farther than the set parameters as well as the target allocation of the selected investment profile. Rebalancing below $5,000 may impact the ability to maintain positions in selected asset classes due to the inability to buy or sell at least one share of an ETF. For example, withdrawal requests may require entire asset classes to be liquidated to generate and disburse the requested cash. Sweep Program Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 1% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program, a program sponsored by Schwab. By enrolling in Opes Access Services, clients consent to having the free credit balances in their brokerage accounts at CS&Co swept into deposit accounts (“Deposit Accounts”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of Opes Access Services. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of ETF positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with CS&Co, Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Financial Planning Services For Select and Premier clients, OWM offers personal comprehensive financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. For certain Access clients, planning is conducted only as mutually agreed. Depending upon individual client requirements, the comprehensive financial plan will include recommendations, which many include the following areas: Retirement Planning, Cash Flow Forecasting, Estate Planning, Charitable Giving, Tax Planning, and Insurance Planning. OWM prepares and provides the financial planning client with a written comprehensive financial plan and performs quarterly, semi-annual or annual reviews of the plan with the client, dependent on the client’s needs Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. MISCELLANEOUS Non-Investment Consulting/Implementation Services. To the extent requested by the client, OWM may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, expert witness, etc. Neither OWM, nor any of its representatives, serves as an attorney, accountant, or licensed insurance agent, and no portion of OWM’s services should be construed as same. To the extent requested by a client, OWM may recommend the services of other professionals for certain non- investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from OWM. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify OWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising OWM’s previous recommendations and/or services. Separately Managed Account Programs. In the Opes Premier Services program, OWM may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated Separately Managed Account programs sponsored by Schwab and/or its affiliated entities in accordance with the client’s designated investment objective(s). In such situations, the Separately Managed Account Manager shall have day- to-day responsibility for the active discretionary management of the allocated assets. OWM shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which OWM shall consider in recommending Separately Managed Account programs include the client’s designated investment objective(s) as applied to the Separately Managed Account program: management style, performance, reputation, financial strength, reporting, pricing, and research. In the event that OWM is engaged to provide investment advisory services as part of an unaffiliated Separately Managed Account program, OWM will be unable to negotiate commissions and/or transaction costs. Held Away Assets. We implement investment advice on behalf of certain clients in held- away accounts that are maintained at independent third-party custodians. These held- away accounts are often 401(k) accounts, 529 plans, and other assets that are not held at our primary custodian(s). We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our primary custodian(s). Further information about this service is available in Item 5. Use of Mutual Funds. Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by OWM independent of engaging OWM as an investment advisor. However, if a prospective client determines to do so, he/she will not receive OWM’s initial and ongoing investment advisory services. In addition to OWM’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Portfolio Activity. OWM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, OWM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when OWM determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by OWM will be profitable or equal any specific performance level(s). Client Obligations. In performing its services, OWM shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify OWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising OWM’s previous recommendations and/or services. Fiduciary Acknowledgment. When OWM provides investment advice to you regarding your retirement plan account or individual retirement account, OWM is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way OWM makes money creates some conflicts with client interests, so OWM operates under a special rule that requires the Firm to act in the clients’ best interest and not put OWM interest ahead of the clients.’ C. OWM shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, OWM shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). Clients may impose reasonable restrictions on the management of their accounts if OWM determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for OWM’s management efforts. D. OWM will not assume any responsibility for the accuracy or the information provided by clients. OWM is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and OWM is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying OWM in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. In the event that a client notifies OWM of any changes, OWM will review such changes and implement any necessary revisions to the Client’s portfolio. OWM does not sponsor a wrap fee program for its investment advisory services. E. As of December 31, 2023, OWM had $589,916,182 of Assets under management on a discretionary basis.