A. Description of the Advisory Firm Whalen Wealth Management DBA Whalen Financial (hereinafter “Whalen Financial”) is a Corporation organized in the State of Nevada. The firm was formed in November 2020, and the principal owner is Andrew Joseph Whalen. B. Types of Advisory Services Portfolio Management Services Whalen Financial offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Whalen Financial creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 Whalen Financial evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Whalen Financial will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Whalen Financial seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Whalen Financial’s economic, investment or other financial interests. To meet its fiduciary obligations, Whalen Financial attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Whalen Financial’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 Whalen Financial’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. Held Away Assets – Pontera We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary,

Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Selection of Other Advisers Whalen Financial may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, Whalen Financial will always ensure those other advisers are properly licensed or registered as an investment adviser. Whalen Financial conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. Whalen Financial then makes investments with a third-party investment adviser by referring the client to the third-party adviser. Whalen Financial will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments Whalen Financial generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs (including ETFs in the gold and precious metal sectors). Whalen Financial may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Whalen Financial offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. 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. Whalen Financial does not participate in any wrap fee programs. E. Assets Under Management Whalen Financial has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 157,855,321.00 $ 0.00 December 2023