A. Description of business Clarity Wealth Development, LLC ("Clarity") is a Registered Investment Advisory Firm based in Oregon since 2010. Kay Dee Cole is the managing principal and owns 75% of the firm. Kay Dee is an Investment Advisor Representative and Compliance Officer of the firm. Kim Hall is the Vice President and owns 25% of the firm. Kim is an Investment Advisor Representative and Director of Financial Planning. B. Description of advisory services Clarity is an independent firm specializing in financial planning and managing client portfolios. We take a comprehensive approach to financial planning in that we want to set up a complete plan for clients in the most holistic path possible. We find this to be the best and most effective approach. Comprehensive Financial Planning Financial planning includes tax planning, insurance planning, retirement planning and estate planning. Financial planning services may include consultations and/or written financial plans. Each plan analyzes clients' financial situation and then makes appropriate recommendations for strategies and methods to implement those strategies. Financial planning may be offered as a standalone, one-time engagement or on an ongoing basis provided the client engages Clarity for investment management services. Plans are more effective if reviewed each year and adjusted accordingly. Upon requesting a comprehensive plan, clients will work with a planner to establish their goals and values around money. Clients will need to provide the information required for the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefit, retirement planning, insurance, investments, college planning and estate planning. Our most common client engagement involves working one-on-one with a planner over an extended period. After a comprehensive financial plan is created, clients may choose to work with a planner on an ongoing basis to implement, monitor and update (as needed) the plan provided they engage Clarity for investment management services. If the client engages Clarity for investment management services, the plan will be monitored throughout the year, and the planner will follow up with the client to confirm that agreed upon action steps have been carried out. The annual review of this plan will be fully reviewed to ensure its accuracy. Any updates needed will be implemented at that time. Meetings may be virtual and in person, and we will meet at the client's convenience. NOTE: Planning only clients are under no obligation to act upon the advisor's investment recommendations. If the client elects to act upon any of the recommendations, the client is under no obligation to affect the transaction through the investment advisor. The advisor is also not obligated to monitor investment accounts held outside the firm; this responsibility is entirely up to the client. Neither the advisor, nor any of its planners, agents, or employees, are authorized or permitted to provide legal or accounting documents or services in connection with any services they provide, including financial planning services. Client should consult with their own personal attorneys, accountants, or tax preparers for this advice independently or in conjunction with implementing the plan. Since the client’s financial plan is written based on data provided by the client under an advisory agreement, the accuracy of any information provided by the client is critical to the accuracy, appropriateness, and recommendations provided in the financial plan. The advisor’s planners rely on the completeness and accuracy of this information and will not verify it independently. Neither the advisor nor the client’s planner has a duty to update a financial plan or make additional recommendations once the financial plan has been delivered to the client. Unless the client engages the advisor for ongoing services, once the plan has been provided, advisor’s planners have no obligation to suggest future revisions to the plan, monitor implementation of the plan or monitor the financial circumstances of the client. Managing Client Portfolios/Investment Advisory Services The client can determine to engage Clarity to provide discretionary investment advisory services based on an annual service cost. Clarity creates investment portfolios for clients based on an

individualized investment strategy that takes into consideration the client's personal financial situation including employment status, cash reserves, retirement account values, current age, anticipated retirement date, other sources of income as well as their personal tolerance for risk and volatility. Client portfolios are monitored and adjusted in accordance with the agreed upon investment strategy. Clarity utilizes general securities (stocks & bonds), mutual funds (including exchange traded funds or ETFs (Exchange Traded Funds)), government securities, and occasionally real estate and metals funds to create diversified portfolios tailored to client's goals and individual risk profiles. In client accounts, we do not typically purchase or manage "alternative investments" (such as commodities, managed futures, private equity, currency, or hedge funds) It remains the client's responsibility to promptly notify the Clarity if there is ever any change in his/her/their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Clarity's previous recommendations and/or services. C. Tailoring of advisory services to individual client needs Clarity clients are each unique, so services are tailored to meet client needs. This process begins with a series of consultations intended to discover individual goals and values. Advisors then analyze clients' financial data and suggest how to best achieve client goals, considering client resources, constraints and values, and evaluations of risk and uncertainty. Recommendations are based on the information provided to Clarity by clients, and any omissions or non-disclosed items become the burden of the client. Advisors strive to match investment portfolios to client objectives. Clients may impose restrictions on investing in certain securities or types of securities (Please refer to Item 16). Note: Retirement Rollovers -Potential Conflict of Interest A client leaving an employer typically has four options (and may engage in a combination of these). 1. Employee may leave the money in the employer plan, if permitted 2. Employee may rollover the assets to their current employer plan, if permitted 3. Employee may rollover the assets to an Individual Retirement Account (IRA) 4. Employee may take a lump-sum cash distribution from the employer plan Clarity may recommend an investor rollover the plan assets to an IRA managed by Clarity (option 3 above). As a result, the advisors may earn an asset-based fee for managing the account. A recommendation that a client or prospective client leave their plan assets with their old employer, or rollover to a current employer plan will result in potentially lower compensation to Clarity advisors. Clarity Wealth Development may have an economic incentive to encourage an investor to roll plan assets into an IRA managed by Clarity Wealth Development. Clarity considers a variety of factors before recommending rollover of a retirement plan, including but not limited to: 1) the investment options available in the plan versus the investment options in an IRA 2) fees and expenses in the plan versus the fees and expenses in an IRA 3) the services and responsiveness of the plan's investment professionals 4) required minimum distributions and age considerations 5) tax consequences and 6) clients' experience with self-directed investment management. No client is under any obligation to rollover plan assets to an IRA managed by Clarity. For insurance products, the company provides access to a platform for insurance products by DPL Financial Partners, LLC ("DPL"). The investor is under no obligation to use DPL's service and may seek insurance advice from any licensed agent. The insurance products and fee structures available from DPL may differ from those available from other third-party insurance agents. The company recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. The company does not receive compensation for insurance products selected by the investor, whether secured through DPL or any other agent. D. Wrap fee programs Clarity does not participate in wrap-fee programs. E. Assets under management As of December 31, 2023, Clarity managed $140,635,576 on a discretionary basis.