OurAdvisoryBusiness Howard Bailey Securities, LLC (“Howard Bailey”, “us”, “we”, “our”) is a Registered Investment Adviser (“Adviser”) with the Securities and Exchange Commission (“SEC”). The Adviser offers investment advice regarding securities and other financial services to clients. We provide investment advice through Investment Adviser Representatives (“Advisors”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. Howard Bailey was founded in 2016. Casey Weade serves as the firm’s CEO. Howard Bailey provides management services to individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments, corporations, small businesses and churches. We are committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business. Services We provide various asset management and financial planning services, with an emphasis on retirement planning services. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We do not participate in wrap fee programs. AssetManagement Asset management is the professional management of securities (stocks, bonds and other securities) and assets (e.g., real estate) in order to meet your specified investment goals. With an Asset Management Account, you engage us to assist you in developing a custom-tailored portfolio designed to meet your unique investment objectives. The investments in the portfolio account may include mutual funds, stocks, bonds, etc. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management are based upon your investment goals and objectives, risk tolerance, and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in periodic reviews, which usually take place on an annual basis at a minimum. These reviews will be conducted in person, by telephone or video conference, and/or via a written Howard Bailey ADV Part 2A March 2024 Page 5 of 22 inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. We will:
• Review your present financial situation
• Monitor and track assets under management
• Provide portfolio statements, periodic rate of return reports, asset allocation statement, rebalanced statements as needed
• Advise on asset selection
• Determine market divisions through asset allocation models
• Provide research and information on performance and fund management changes
• Build a risk management profile for you
• Assist you in setting and monitoring goals and objectives
• Provide personal consultations as necessary upon your request or as needed. You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. You shall not have the ability to impose restrictions on the management of your account. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that doing so is in your best interests. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We utilize Fidelity Brokerage Services LLC as our third-party custodian. You will enter into a separate custodial agreement with the custodian. This agreement, among other things, authorizes the custodian to take instructions from us regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. Your statement may be in either printed or electronic form based on your preferences. You will at all times maintain

full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We manage assets on a discretionary basis, which means you have given us the authority to determine the following with/without your consent:
• Which securities to be bought or sold for your account Howard Bailey ADV Part 2A March 2024 Page 6 of 22
• Amount of securities to be bought or sold for your account Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. ThirdPartyMoneyManagers We may determine that opening an account with a professional third-party money manager is in your best interests. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may:
• Assist in the identification of investment objectives
• Recommend specific investment style and asset allocation strategies
• Assist in the selection of appropriate money managers and review performance and progress
• Recommend reallocation among managers or styles within the program
• Recommend the hiring and firing of money managers utilized by you. You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur. Sub-Adviser Howard Bailey has elected to utilize the investment management services of AE Wealth Management LLC (“AEWM”) and its platform provider, Orion Advisor Services, LLC (“Orion”), to assist in the provision of Investment management services for the client. The client will be provided the Brochure Documents of AEWM and Orion at the time of application. Unless otherwise notified, the Advisor is appointed as his/her agent to receive the delivery of the Brochure Documents of AEWM and Orion, and the Advisor will provide, upon request, copies of any applicable Brochure Documents of AEWM and Orion to the client. The client may also, at any time, change his/her mind and request, for no additional cost, the Brochure Documents of AEWM and Orion to be delivered to the client directly. Howard Bailey ADV Part 2A March 2024 Page 7 of 22 FinancialPlanning/Consulting We provide services such as comprehensive financial planning, estate planning, business planning, educational planning, and financial consulting. Fee based financial planning and consulting is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets specific goals and objectives. The financial planning and/or consulting relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning and/or consulting services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. AssetsUnderManagement As of March 29, 2024, Howard Bailey Securities, LLC has approximately $ 463,303,000 of assets under management. $ 431,716,000 of these assets is managed on a discretionary basis and $ 31,587,000 is managed on a non-discretionary basis.