TruWealth offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to TruWealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with TruWealth setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). TruWealth filed for registration as an investment adviser in June 2020 and is principally owned by Charles Simmons and Christy Lynn Neal Simmons. As of December 31, 2023, TruWealth had $2,106,194,250 in assets under management, all of which was managed as a discretionary basis. While this brochure generally describes the business of TruWealth, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on TruWealth’s behalf and are subject to the Firm’s supervision or control. Financial Planning Services TruWealth offers clients a broad range of financial planning services, which include any or all of the following functions:
• Retirement Planning
• Trust and Estate Planning
• Business Planning
• Insurance Planning
• Cash Flow Analysis
• Investment Planning
• Long-Term Care Planning
• Workplace Benefit Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment management services under a comprehensive wealth management engagement. In performing these services, TruWealth is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. TruWealth recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage TruWealth or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by TruWealth under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising TruWealth’ recommendations and/or services. Page | 6 TruWealth Advisors 2024 Investment Management Services TruWealth manages client investment portfolios on a discretionary or non-discretionary basis. While these services are available on a stand-alone basis, they can also be rendered in conjunction with financial planning services under a comprehensive wealth management engagement. In managing client investment portfolios, TruWealth primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), custom structured products, individual debt and equity securities and independent investment managers (“Independent Managers” or “Separate Account Managers”) in accordance with their stated investment objectives. Clients can engage the Firm to provide advice about any type of legacy position or other investment held in client portfolios, including investment products that are always maintained at their primary custodian, such as self-directed brokerage accounts, variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). With respect to such variable life insurance and annuity contracts, TruWealth 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. TruWealth 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. TruWealth 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 promptly notify TruWealth 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 TruWealth determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services TruWealth provides various consulting 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 includes any or all the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education Page | 7 TruWealth Advisors 2024 As disclosed in the Advisory Agreement, certain of the foregoing services are provided by TruWealth 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 TruWealth’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, TruWealth selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. TruWealth 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, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. TruWealth also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. TruWealth continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. TruWealth seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Insurance Consulting Services As further described in this Brochure, a number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance products on a fully disclosed commissionable basis. In addition, the Firm may utilize the service of DPL Financial Partners, LLC (“DPL”), Lincoln Financial Group (“Lincoln”), or other approved platforms to offer the Firm’s clients fee-only variable annuity and commission free variable life insurance. TruWealth will receive a management fee for advising clients on the subaccounts of these products. Neither TruWealth, nor its Supervised Persons receive any commissions on these variable products, but there is a conflict of interest in recommending the DPL, Lincoln or other platform which allows the Firm to provide these products to clients. Page | 8 TruWealth Advisors 2024