A. Description of the Advisory Firm BDT & Associates, Inc. d/b/a Invicta Financial Group (hereinafter “BDT”) is a Corporation organized in the State of Arizona and formed in September 2007. BDT became an RIA in June 2017. BDT is a privately-owned entity. B. Types of Advisory Services Financial Planning Services BDT provides ongoing financial planning services based on a client’s individual values, goals, objectives, time horizon, assets available, and risk tolerance. BDT will meet with a prospective client, free of charge, to review the individual’s financial situation and determine with the prospective client whether BDT’s services would be a fit for each party. If the parties decide to pursue a working relationship, then the client would pay BDT’s fee (see Item 5) for BDT to work with the client in providing a detailed financial plan and implementation strategy. This financial plan may include, but is not necessarily limited to:
• Portfolio Review and Evaluation
• Investment Planning
• Risk Management
• Tax Projection, Planning and Integration
• Retirement Planning
• Education Planning
• Cash Flow Analysis
• Budgeting
• Debt/Credit Management BDT seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of BDT’s economic, investment or other financial interests. To meet its fiduciary obligations, BDT does not carry commissionable investment licenses, reducing potential conflicts of interest. It is BDT’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 Advisory Services via Selection of Other Advisers For ongoing management of investment portfolios, BDT directs clients to third-party investment adviser(s). BDT works in conjunction with the third-party adviser(s) to find

a portfolio that meets the client’s values, goals, objectives, time horizon, assets available, and risk tolerance. Before selecting other advisers for clients, BDT will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where BDT is recommending the adviser to clients. Services Limited to Specific Types of Investments BDT may recommend various securities to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Clients may impose restrictions in financial planning in certain securities or types of securities in accordance with their values or beliefs. BDT reserves the right to end the relationship. BDT will tailor a program for each individual 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 BDT on behalf of the client. BDT may use model allocations, together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BDT from properly servicing the client account, or if the restrictions would require BDT to deviate from its standard suite of services, BDT reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. BDT does not participate in any wrap fee programs. E. Assets Under Management BDT’s does not provide direct portfolio management and thus does not have regulatory advisory assets under management for purposes of Form ADV reporting. Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 $ 250,954,763.00 December 2023