This Disclosure document is being offered to you by ICA Group Wealth Management (“ICA Group” or “Firm”) about the investment advisory services we provide. It discloses information about our services and the way those services are made available to you, the client. Our Firm became a registered investment adviser in April 2021 and is owned by ICA Group Holding Company, LLC. Chad Renner is the President and Chief Executive Officer; Kelly Bauman and Paul Gunderson are Co-Chief Compliance Officers. We are committed to helping clients build, manage and preserve their wealth. Our Firm provides services that help clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however, investment advisory services are initiated only after you and ICA Group execute an Investment Management Agreement. INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts, once we have determined a profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior client consent but within the expected investment guidelines. We may accept accounts with certain restrictions, if circumstances warrant. We primarily allocate client assets among cash, individual stocks, bonds, exchange traded funds (“ETFs”), no-load or load-waived mutual funds, equities, corporate bonds, municipal bonds, U.S. Government Treasuries, certificates of deposit, options and structured products. We generally invest Client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk and conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to this service. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background. Based on client needs, we develop a client’s personal profile and investment plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have changed with respect to their goals. Once we have determined the types of investments to be included in a client’s portfolio and have allocated the assets, we provide ongoing investment review and management services. With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client financial objectives. We trade these portfolios based on the combination of our market views and client objectives, using our investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is managed in a manner consistent with those needs and objectives. Clients have the ability to leave standing instructions with us to refrain from investing in particular industries or invest in limited amounts of securities. MARCH 2024 | PAGE 4 If a non-discretionary relationship is in place, calls will be placed presenting the recommendation made and only upon your authorization will any action be taken on your behalf. In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from clients. Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically, these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Investment Management Platforms Available Through LPL As further described below, many of ICA Group’s IARs recommend investment advisory programs offered through LPL. Below is a description of the platform of advisory products and services available through LPL that are offered by ICA Group. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please refer to the applicable program’s account agreement and LPL’s Form ADV Part 2A and program brochure. i. SWM II Account Although clients do not pay a transaction charge for transactions in a SWM II account, clients should be aware that our Firm pays LPL transaction charges for those transactions. The transaction charges paid by our Firm vary based on the type of transaction (e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges paid by the ICA Group for equities and ETFs are $9. For mutual funds, the transaction charges range from $0 to $26.50. Because our Firm pays the transaction charges in SWM II accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost to ICA Group of transaction charges may be a factor that our Firm considers when deciding which securities to select and how frequently to place transactions in a SWM II account. In many instances, LPL makes available mutual funds in a SWM II account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM II in many cases will not be the least expensive share class that the mutual fund makes available and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM II. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage-related MARCH 2024 | PAGE 5 services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. Our Firm has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline our Firm, consciously or unconsciously, to render advice that is not disinterested. Although the client will not be charged a transaction charge for transactions, ICA Group pays LPL a per transaction charge for mutual fund purchases and sales in the account. our Firm generally does not pay transaction charges for Class A Share mutual fund transactions accounts, but generally does pay transaction charges for Platform Share mutual fund transactions. The cost to our Firm of transaction charges generally may be a factor ICA Group considers when deciding which securities to select and whether or not to place transactions in the account. The lack of transaction charges to our Firm for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, presents a significant conflict of interest between our Firm and the client. In short, it costs our Firm less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should understand this conflict and consider the additional indirect expenses borne as a result of the mutual fund fees when negotiating and discussing with your ICA Group the advisory fee for management of an account. ii. Manager Access Select Program Manager Access Select offers ICA Group’s clients the ability to participate in either the Separately Managed Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”). In the SMA Platform, ICA Group will assist in identifying a third-party asset manager (“TPAM”) from a list of TPAMs made available by LPL. The selected TPAM will manage the client’s assets on a discretionary basis, including the investment and reinvestment of assets as directed by LPL and authorized by the client, in accordance with the selected model. ICA Group will be responsible for providing initial and ongoing assistance regarding the TPAM selection process. iii. Optimum Market Portfolios Program (“OMP”) OMP offers ICA Group’s clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. ICA Group will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. ICA Group will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion and authority to both transact Optimum Funds pursuant to the portfolio selected for the client and to rebalance the account. iv. Model Wealth Portfolios Program (“MWP”) MWP offers ICA Group’s clients a professionally managed mutual fund asset allocation program. ICA Group will obtain the necessary financial data from the client and assist the client in determining the suitability of the MWP program based on the client’s investment objectives. ICA Group will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated MARCH 2024 | PAGE 6 investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Advisor, through its IAR, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to transact in mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. Each client entering into an LPL Program will be provided a written LPL disclosure brochure that outlines in detail the services provided and fees charged, along with other important information about the selected platform. Clients should thoroughly read the brochure upon receipt. The LPL Platforms can or will not be suitable for, and therefore not offered to, all of our clients. Please refer to Item 5 for important information related to fees associated with these platforms. Investment Management Platforms Available Through Charles Schwab & Co., Inc. (“Schwab”) As further described below, ICA Group’s IARs recommend investment advisory programs offered through Schwab. The following Schwab sponsored programs are available to our clients: Managed Account Marketplace (“Marketplace”) The Marketplace program allows the IAR and the client to choose a TPAM from an extensive list that Schwab has compiled; however, neither Schwab nor CSIA screen, evaluate or monitor the TPAMs in the Marketplace program. In each of the above-referenced Schwab Programs, the TPAMs provide discretionary investment advisory services and will manage clients’ assets in the programs in accordance with the investment strategies chosen by the clients. Also, Schwab serves as the client’s custodian and broker in the Schwab Programs. ICA Group provides ongoing investment advisory services, including gathering necessary client financial data and assisting the client in determining an appropriate Schwab Program, including selection of TPAMs, in accordance with the investment strategy or strategies suitable for and in line with each client’s investment guidelines. Each client entering into a Schwab Program will be provided with a written Schwab disclosure brochure that outlines the services provided and fees charged, along with other important information about the selected Schwab Program. Clients should thoroughly read the brochure upon receipt. The Schwab Programs can or will not be suitable for, and therefore are not offered to, all of our clients. Please refer to Item 5 for important information related to fees associated with the platforms. Investment Management Platforms Available Through ICA Group ICA Group offers its Clients a professionally managed asset allocation platform known as “ICAMP.” ICA Group will obtain the necessary financial data from the Client and assist the Client in determining the suitability of the ICAMP program based on the Client’s investment objectives and investment risk tolerance. ICA Group then will initiate the steps necessary to open an ICAMP account and have discretion to select a model consistent with the client’s stated investment objective and investment risk tolerance. MARCH 2024 | PAGE 7 For this investment platform, client authorizes ICA Group to act on a discretionary basis to transact

in mutual funds, ETFs, and other suitable asset classes and to liquidate previously purchased securities. The client also authorizes ICA Group to effect rebalancing for ICAMP accounts according to the designed strategy specifications. Within ICAMP, ICA Group has seven (7) discretionary Model Portfolio strategies that range from Capital Preservation to Aggressive Growth, which include the following: 1. Capital Preservation: A broadly diversified portfolio that aims to manage drawdowns for a client that has a low tolerance for risk and volatility. This strategy is generally suitable for clients with a short-term, medium-term, or long-term investment horizon. 2. Income: A broadly diversified portfolio that aims to manage drawdowns and provide income for a client that has a low to conservative tolerance for risk and volatility. This strategy is generally suitable for clients with a short-term, medium-term, or long-term investment horizon. 3. Conservative Growth: A broadly diversified portfolio that aims to manage drawdowns and provide growth for a client with a low to medium tolerance for risk and volatility. This strategy is generally suitable for clients with a medium-term or long-term investment horizon. 4. Moderate Growth: A broadly diversified portfolio that aims to manage drawdowns and provide growth for a client with medium tolerance for risk and volatility. This strategy is generally suitable for clients with a medium-term or long-term investment horizon. 5. Growth: A broadly diversified portfolio that aims to manage drawdowns and provide capital appreciate for a client with medium to high tolerance for risk and volatility. This strategy is generally suitable for clients with a long-term investment horizon. 6. Growth Plus: A broadly diversified portfolio that aims to manage drawdowns and provide capital appreciation for a client with an above average tolerance for risk and volatility. This strategy is generally suitable for clients with a long-term investment horizon. 7. Aggressive Growth: A broadly diversified portfolio that aims to manage drawdowns and provide the very highest growth potential possible for a client with a high tolerance for risk and volatility. This strategy is generally suitable for clients with a long-term investment horizon. Concierge Model Platform: This platform is for an IAR who has portfolios that they are already using to achieve risk alignment for their client but still wants to take advantage of outsourced model management. FINANCIAL PLANNING Through the financial planning process, our team strives to engage our clients in conversations around the client’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals and circumstances of each client in mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy MARCH 2024 | PAGE 8 objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Our team is not qualified to, and does not, offer legal, accounting or tax advice. Our services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Our specific services in preparing your plan may include:  Review and clarification of your financial goals  Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning  Creation of a unique plan for each goal you have, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals  Development of a goal-oriented investment plan, with input from various advisors to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention  Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits; and  Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax adviser, an estate plan to provide for you and/or your heirs in the event of an incapacity or death. A written evaluation of each client's initial situation or Financial Plan is provided to the client. An annual review will be provided by the Adviser, if indicated by the Client and Adviser per the Agreement. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. If the client decides to follow the recommendations, the client has the option, but is under no obligation, to request that ICA Group implement such recommendations through the Firm’s Investment Management Services. Should a client request ICA Group to implement such recommendations, the client will receive the services outlined in our Investment Management section below. Furthermore, certain IARs of ICA Group sell brokerage and insurance products when the client and IAR believe it to be in the client’s best interest. Insurance products are sold by IARs in their separate capacity as an independent insurance agent with ICAG Insurance Agency, LLC or with appointed carriers not affiliated with the ICA Group. Brokerage products are sold by IARs in their separate capacity as a registered representative with LPL. If the IAR implements insurance or insurance transactions in this separate capacity, he/she earns a sales commission but does not also charge investment management fees on those investments. This could present a conflict of interest since the IAR is incentivized and earns compensation and/or commission(s) for implementing insurance and brokerage product recommendations made as part of the Firm’s Financial Planning Services. This conflict is mitigated by the IARs zealously attempting to always act in the best interest of all clients. Please see Items 5, 10 and 14 below for additional information concerning such conflicts. Retirement Planning Consulting Services ICA Group’s Retirement Planning Services help our clients to determine when they can retire, based on their desired lifestyle. ICA Group provides clients with guidance on what is financially feasible based on current assets, retirement plans and other factors. We will review existing MARCH 2024 | PAGE 9 assets, liaise with your estate planning attorneys, tax and other professional advisors to develop a comprehensive retirement plan to meet your needs. RETIREMENT PLAN SERVICES For employer-sponsored retirement plans with participant-directed investments, our firm provides its advisory services as an investment adviser as defined under Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and Our Firm share fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement between Our Firm and the Plan Sponsor. Under the 3(21) agreement, or Firm provides the following services to the Plan Sponsor:  Screen investments and make recommendations.  Monitor the investments and suggests replacement investments when appropriate.  Provide a quarterly monitoring report.  Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).  Recommend QDIA alternatives.  Recommend non-discretionary model portfolios. We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial education to Plan participants, benchmarking the Plan services, education to fiduciary committee members, and monitoring the service provider. The scope of education provided to participants will not constitute “investment advice” within the meaning of ERISA and participant education will relate to general principles for investing and information about the investment options currently in the Plan. We may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for new participants. When servicing as in a 3(38) fiduciary capacity, our Firm is granted full trading authority over the Plan and have the responsibility for the selection and monitoring of all investment options offered under the Plan in accordance with the investment policy statement and its underlying investment objectives and strategies for the Plan. Plan participants have the ability to exercise control over the investment selection from the plans line up of investments, and we have no authority or discretion to direct the investment of assets of any participant’s account under the Plan. DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, MARCH 2024 | PAGE 10 which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer and remains available to address any questions that a client or prospective client has regarding the oversight. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. CONSULTING SERVICES We also provide clients investment advice on a more-limited basis on one or more isolated areas of concern such as estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or any other business advisory / consulting services for equity or debt investments in privately held businesses. In these cases, clients will be required to select their own investment managers, custodian, and/or insurance companies for the implementation of consulting recommendations. If client needs include brokerage and/or other financial services, we will recommend the use of one of several investment managers, brokers, banks, custodians, insurance companies, or other financial professionals ("Firms"). Consulting clients must independently evaluate these Firms before opening an account or transacting business and have the right to effect business through any firm they choose. Clients have the right to choose whether or not to follow the consulting advice provided. CO-BRANDED INVESTMENT ADVISOR REPRESENTATIVES Our firm offers services through our network of investment advisor representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials and/or disclosure statements and client statements. The Client should understand that the businesses are legal entities of the IAR and not of our firm. The IARs are under the supervision of our firm and the advisory services of the IAR are provided through our firm. A complete listing of the entities is listed on our ADV Part 1. WRAP FEE PROGRAM We also provide services on a wrap fee basis as part of the SWM II wrap fee program. For more detail see description of the SWM II Account above. A wrap fee program is an arrangement where brokerage commissions and transaction costs are absorbed by the Firm. The fee covers transaction costs or commissions resulting from the management of your accounts, however, most investments trade without transaction fees today, so our payment of these and other incidental custodial related expenses should not be considered a significant factor in determining MARCH 2024 | PAGE 11 the relative value of our wrap program. Participants in the Program may pay a higher aggregate fee than if brokerage services are purchased separately. Additional information about the Program is available in ICA Group’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV. Our “wrap” fee may be more or less than the fees and commissions charged by other advisory firms, third-party managers, and brokerage firms if the services were acquired separately. The factors that bear upon the cost of services are the size of the account, type of transaction and whether trades are placed through a brokerage firm other than the custodian resulting in per trade commissions being charged. ASSETS As of December 31, 2023, we manage $1,161,142,958 in discretionary asset under management and no non-discretionary assets under management.