FIRM INFORMATION J.P. Davis, Inc. dba NRG Wealth Management (“NRG,” “we,” “us,” “our”), a corporation formed in April 2003, is an SEC-registered investment advisory firm located in Oro Valley, Arizona. PRINCIPAL OWNERS On March 31, 2022, NRG is owned and controlled by John Paul Davis. Mr. Davis is its President and Chief Compliance Officer. INVESTMENT ADVISORY SERVICES Portfolio Management Services: NRG offers ongoing portfolio management services based on the individual circumstances of each client. Based upon the client’s investment risk tolerance, NRG creates an Investment Policy Statement which outlines the client’s Investor Life Cycle, Goal(s), Time Horizon, Liquidity Needs, Tax Constraints, and Unique Circumstances. From this information, NRG constructs a portfolio that matches the client’s specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring NRG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. NRG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels and all suitability information is maintained using online software and will be reviewed at least every two years. NRG seeks to execute portfolio management decisions that are made in accordance with the fiduciary duties owed to its clients and without consideration of NRG’s economic, investment, or other financial interests. To meet its fiduciary obligations, NRG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, NRG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is NRG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Guidance Services: NRG’s Financial Guidance Services are generally delivered through the Blueprint, which includes, but is not necessarily limited to, the following services (not all services are offered or applicable to all clients):  Cash Out! Values exercise. Help create a clearly defined set of priorities focusing on the intent and purpose of client resources, including money. The exercise is designed to help improve financial life decisions. ITEM 4 5 NRG Wealth Management  Lifestyle/Legacy goals. Determine and record a specific set of goals the client would like

to accomplish regarding their financial future and legacy.  Financial goals review and analysis.  Record and deliver projections regarding aspects of the client’s future financial lives, including the viability of financial plan through Monte Carlo simulation, investment withdrawal rate, cash flow tables, investment growth rates, and estate value projections.  A net worth summary.  A portfolio snapshot.  Asset allocation recommendations.  Online portal to access bespoke financial reports and summaries on demand. NRG offers modular planning services designed to meet an individual’s specific needs. Modular planning most often will be charged on an hourly basis. These services may include one or more of the following:  Cash flow management  Investment management recommendations for non-supervised assets (i.e., 401ks)  Retirement planning  Insurance needs analysis  Education cost planning  Estate planning (not including document preparation)  Tax planning (not including tax preparation and filing)  Loss of spouse planning We will summarize our services in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by the client. Implementation of the recommendations will be at the client’s discretion. 6 NRG Wealth Management CLIENT INVESTMENT OBJECTIVES/RESTRICTIONS NRG provides a tailored program for each client. This will include an interview session to get to know the client’s specific needs and requirements, as well as a plan that will be executed by NRG on behalf of the client. NRG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. On a case by case basis, our clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. WRAP FEE PROGRAMS NRG does not participate in, recommend, or offer wrap fee programs. ASSETS UNDER MANAGEMENT As of December 31, 2023, NRG managed $171,384,457 in AUM on a discretionary basis.