A. Oregon Pacific Wealth Management, LLC (“OPWM”) is a limited liability company formed in 2016 in the State of Oregon. OPWM is owned by Oregon Pacific Banking Company, which is wholly owned by Oregon Pacific Bancorp. B. As discussed below, Oregon Pacific Wealth Management offers to its clients (individuals, high net worth individuals, pension and profit-sharing plans, business entities, trusts, and estates), investment advisory services, and related consulting services. INVESTMENT ADVISORY SERVICES The client may engage OPWM to provide discretionary and/or non-discretionary investment advisory services on a wrap or non-wrap fee basis. (See discussion below). If a client engages OPWM on a wrap fee basis, the client will pay a single fee for bundled services (i.e. investment advisory, trade execution, custody). The services included in a wrap fee agreement will depend upon each client’s particular need. If the client engages OPWM on a non-wrap fee basis, the client will select individual services on an unbundled basis, paying for each service separately (i.e. investment advisory, trade execution, custody). The client can agree to have OPWM provide discretionary and/or non-discretionary investment advisory services on a fee basis. Generally, OPWM’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under OPWM’s management. Please Note: Non-Discretionary Service Limitations. Clients that determine to engage OPWM on a non-discretionary investment advisory basis must be willing to accept that OPWM cannot affect any account transactions without obtaining prior verbal or written consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, OPWM will be unable to affect any account transactions (as it would for its discretionary clients) without first obtaining the client’s verbal or written consent. OPWM constructs globally diversified risk-based portfolios that provide proper diversification across asset classes, and risk metrics. The portfolios are designed to help clients achieve their long-term goals through a research-driven, risk managed process. The portfolios are tailored to the client’s risk tolerance, and long-term goals based on a detailed Investment Policy Questionnaire, and suitability review. Client portfolios can be further customized to their needs based on a comprehensive financial plan. Depending on the circumstances, and suitability review, in some cases OPWM can manage client portfolios around restrictions. This is limited to equity only portfolios, where the restrictions can be implemented without diverging from the client’s risk profile, and long-term goals. The majority of OPWM’s portfolios are designed around ETFs and Mutual funds, which are managed funds and restrictions cannot be imposed on their holdings. OPWM does not limit its advice to any specific securities or investment strategies. As part of its investment advisory service, OPWM may recommend certain managed model portfolios offered by a third-party investment manager to new and existing clients and may allocate current client assets to those managed models. At all times, OPWM will ensure that client assets are allocated in a manner that is consistent with their risk tolerance. NON-WRAP FEE BASIS The client can agree to have OPWM provide discretionary and/or non-discretionary investment advisory services on a fee basis. Generally, OPWM’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under OPWM’s management. FINANCIAL PLANNING SERVICES Financial plans and financial planning may include but are not limited to reviewing and prioritizing client goals and objectives; developing a summary of client’s current financial situation; including a net worth statement cash flow summary; insurance analysis. OPWM will review a client’s current investment portfolio, develop an asset management and financial management strategy, including financial projections and analysis. OPWM will complete a retirement planning assessment, including financial projections of assets required at estimated retirement date, and assess estate net worth and liquidity. OPWM will identify tax planning strategies to optimize financial position. OPWM will present a written financial plan that will be reviewed in detail with the client. The plan will contain recommendations designed to meet the client’s stated goals and objectives, supported by relevant financial summaries. OPWM will develop an action plan to implement the agreed upon recommendations. Referral to other professionals, as required, to assist with the implementation of the action plan. Assisting clients with the implementation of the financial plan. Determining necessity to revise the financial plan. ONLINE INVESTMENT ADVISORY SERVICES OPWM also offers an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash allocation. The client may instruct OPWM to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). OPWM uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. OPWM is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). OPWM, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. OPWM is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. OPWM has contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables OPWM to make the Program available to clients online and includes a system that automates certain key parts of the investment process (the “System”). The System includes an online questionnaire that helps OPWM determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that OPWM will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but OPWM then makes the final decision and selects a portfolio based on all the information about the client. The System also includes an automated investment engine through which OPWM manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). OPWM charges clients a fee for services as described below under Item 5 - Fees and Compensation. OPWMs’ fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues in connection with the Program, including (i) the profit earned by Charles Schwab Bank, SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that

we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab receives from the market centers where it routes ETF trade orders for execution. OPWM does not pay SPT fees for the Platform so long as OPWM maintains $100 million in client assets in accounts at CS&Co. that are not enrolled in the Program. If OPWM does not meet this condition, then OPWM pays SPT an annual licensing fee of 0.10% (10 basis points) on the value of clients’ assets in the Program. This fee arrangement gives OPWM an incentive to recommend or require that clients with accounts not enrolled in the Program be maintained with CS&Co. The terms and conditions for client participation in the Program are set forth in detail in the Wrap Fee Program Brochure. MISCELLANEOUS ADVISORY SERVICES DISCLOSURE If requested by the client, OPWM may recommend the services of other professionals for certain noninvestment implementation purposes (i.e., attorneys, accountants, insurance, etc.), including certain of OPWM’s investment adviser representatives in their separate registered/licensed capacities as discussed below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from OPWM. Clients have the option to purchase investment products that OPWM recommends through other brokers or agents that are not affiliated with OPWM. Please Note: If the client engages any such recommended professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify OPWM if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising OPWM’s previous recommendations and/or services. Please Note: Fee Differentials. As indicated in Item 5 below, OPWM shall price its services based upon various objective and subjective factors. As a result, OPWM’s clients could pay diverse fees based upon the market value of their assets, the complexity of the engagement, geographic differences, and the level and scope of the overall consulting services to be rendered. The services to be provided by OPWM to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Sub-Advisory Agreement with Investment Adviser: Under its Investment Advisory Agreement, OPWM has discretionary authority to hire and fire Sub-Advisor(s), which can manage the investments in the client’s designated account on a discretionary basis in accordance with the client’s stated investment objectives. Independent Managers: OPWM may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. OPWM shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which OPWM shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, and reporting. Trade Errors: OPWM has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with our fiduciary duty, it is the policy of OPWM to correct trade errors in a manner that is fair to the client. In cases where the client causes the trade error, the client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client will be made whole and any loss resulting from the trade error will be absorbed by OPWM if the error was caused by the firm. If the error is caused by the broker-dealer, the broker-dealer will be responsible for covering all trade error costs. The trade will be moved to an error account and will be dealt with at the discretion of the broker dealer. Client Obligations: In performing its services OPWM shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify OPWM if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising OPWM’s previous recommendations and/or services. Written Acknowledgement of Fiduciary Status: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Disclosure Statement: A copy of OPWM’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, simultaneously with, the execution of the Investment Advisory Agreement. C. OPWM shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, OPWM shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on OPWM’s services. D. There is no significant difference between how OPWM manages wrap fee accounts and non- wrap fee accounts. However, as stated above, if a client engages OPWM on a wrap fee basis, the client will pay a single fee for bundled services (i.e. investment advisory, trade execution, custody) (See Item 4.B). The services included in a wrap fee agreement will depend upon each client’s particular need. If the client determines to engage OPWM on a non-wrap fee basis the client will select individual services on an unbundled basis, paying for each service separately (i.e., investment advisory, trade execution, custody). E. As of December 2022, Oregon Pacific Wealth Management had $ 135,000,000in assets under management on a discretionary basis and $0 in assets under management on a non- discretionary basis. As of December 2022, Oregon Pacific Wealth Management had $ 99,766,543.00 in trust assets under advisement.