A Vistica Wealth Advisors, LLC (“Vistica Wealth,” “we,” “our,” “us,” and/or “firm”) is a California limited liability company registered as an investment advisor with the SEC. Our principal place of business is located in Carlsbad, California. The principal owner of Vistica Wealth is the Jeffrey and Lily Vistica Trust. Jeffrey “Jeff” Vistica serves as the Managing Principal and Chief Compliance Officer of our firm. B We offer a wide range of investment advisory services to our clients (“you,” “your,” and “client”). A description of each of our advisory services is set forth below. Investment Management Services: When you engage us for these services, we will provide you with a broadly diversified portfolio that is customized to your unique investment objectives and needs. In designing your portfolio, we focus on achieving optimal asset allocation and providing structured and ongoing portfolio management and supervision to the accounts you designate. Within each asset class, we primarily recommend investments in an assortment of index funds and other “passive” products. Vistica Wealth will work with you to determine your investment objectives and investor risk profile and will prepare a written investment policy statement (“IPS”) which will guide our ongoing management of your account. As part of this process, we will use investment and portfolio allocation software to evaluate alternative portfolio designs which align with your unique investment profile. We will also evaluate your existing investments in view of your IPS and work with you to develop a plan to transition from your existing portfolio holdings to the desired portfolio of investments. Vistica Wealth will then continuously monitor your investments and overall asset allocation strategy and hold review meetings with you periodically throughout our relationship as necessary and appropriate. Vistica Wealth will manage your portfolio on a discretionary basis according to your IPS. This means that you will be required to authorize our firm and our investment advisor representatives to implement our investment recommendations directly within your account without obtaining your specific consent prior to each transaction. We will typically create a portfolio of no-load mutual funds and may implement the desired investment strategy through the use of certain model portfolios which align with your IPS. We will allocate your assets among various investments, taking into consideration the overall management style you have selected for your account. Vistica Wealth primarily recommends securities portfolios consisting of passively managed asset class and indexed mutual funds, such as the mutual funds sponsored by Dimensional Fund Advisors (“DFA”). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Consequently, the DFA fund fees are generally lower than fees and expenses charged by other types of funds. Vistica Wealth may also recommend public real estate investment trusts (“REITs”) and commodities index funds where the client desires to include real estate and/or commodities in their asset allocation strategy. We also offer investment portfolios which take into consideration certain environmental, social, and governance (“ESG”) factors in their construction. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client has specifically requested that they be retained for a particular reason. These situations will be specifically identified in the client’s IPS or otherwise specifically discussed with the client. Vistica Wealth may also recommend fixed income portfolios to investment management clients consisting of managed accounts of individual bonds. Vistica Wealth will request discretionary authority from you to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager to handle related trading functions. Vistica Wealth will prepare a Fixed Income IPS for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, Vistica Wealth will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Fixed Income IPS. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain our consent prior to the sale of any client securities. On an ongoing basis, Vistica Wealth will answer any inquiries you may have regarding the status of your investments and monitor the performance of your accounts. Vistica Wealth will periodically, but at least annually, review your investment policy and risk profile and initiate a discussion with you regarding the re-balancing of your accounts to the extent appropriate. Where a third-party manager is retained, Vistica Wealth will act as a co- advisor, providing the underlying third-party manager with any updated client financial information or account restrictions necessary for the manager to

provide sub-advisory services to your account and monitoring the performance of third-party managed portfolio. In addition to managing your investment portfolio, at your request, we may consult with you and provide you with financial planning services related to various financial topics, including, without limitation, income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, and establishment and design of retirement plans and trust designs. Employee Benefit Plan Services: Vistica Wealth also provides advisory services to participant-directed employee retirement benefit plans. Vistica Wealth will analyze the plan’s current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. Vistica Wealth will recommend investment options to achieve the plan’s objectives, provide participant education meetings, and monitor the performance of the plan’s investment vehicles. Vistica Wealth will recommend changes in the plan’s investment vehicles as may be appropriate from time to time. Vistica Wealth generally will review the plan’s investment vehicles and investment policy as necessary. The client makes all ultimate investment decisions with respect to our investment recommendations and is responsible for investment implementation. For certain retirement plans, Vistica Wealth also works in coordination and support with Buckingham Strategic Partners, LLC (“BSP”), formally known as BAM Advisor Services, LLC. Retirement plan clients will engage both Vistica Wealth and BSP. BSP will provide the client additional discretionary investment management services and will exercise discretionary authority to select the investments made available to plan participants and maintain the plans’ investments according to the goals and investment objectives of the plan. Vistica Wealth will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: Vistica Wealth also provides advice in the form of financial planning services. Clients will receive a written financial plan which includes a set of financial recommendations designed to assist the client in achieving their stated financial goals and objectives. Various types of additional reports or financial analysis may be provided to the client as part of these services. The types of reports provided to clients will vary depending upon the nature of the services requested. In general, the financial analysis or report will address one or more of the following financial topics:
• PERSONAL: Management of family records, budgeting, personal liability, net worth tracking, estate information, and financial goals.
• PROFESSIONAL PRACTICES: Managing cash flow expectations, debt structuring, transition planning, and office space lease vs. buy decisions.
• EDUCATION: 529 plans and planning to meet ongoing educational needs of dependents
• SPECIAL NEEDS: Determining an estimate of lifetime support, document circles of support and letter(s) of intent to protect the financial and life management needs of family members with special needs.
• TAX & CASH FLOW: Income tax, spending analysis, and debt/credit planning.
• DEATH & DISABILITY: Projection of anticipated cash needs at death, disability, and long-term care expenses.
• RETIREMENT: Analysis of strategies and scenarios to help the client meet his or her retirement planning objectives.
• INVESTMENTS: Analysis of investment strategies and their impact on a portfolio. Vistica Wealth gathers required information through in-depth personal interviews. Information gathered includes the client’s current financial status, future goals, and attitude towards risk. Related documents supplied by the client are carefully reviewed and various types of written reports may be prepared by Vistica Wealth. Should a client choose to implement the recommendations in the report(s), we suggest the client work closely with his/her independent attorney, accountant, and/or insurance agent. The client always makes the ultimate investment decision. Where we are not engaged for investment management services, the implementation of our financial planning and consulting recommendations and the monitoring of investment is the responsibility of the client. Clients are never required to engage us for these additional services. C We construct portfolios to match with each client’s unique risk tolerance, financial objectives, and investment needs. We believe that our use of low-fee, tax-efficient funds better enable our clients to meet their financial goals. Once an individual client’s investment policy is established, we are disciplined about rebalancing the investments. D We do not sponsor, recommend to clients, or otherwise participate in any wrap-fee programs. E We manage approximately $103,482,628 of client assets on a discretionary basis and $0 of client assets, on a non-discretionary basis. These amounts were calculated as of December 31, 2023.