Business Description Our advisory firm is an SEC registered investment advisory firm. Registration with the SEC does not imply a certain level of skill or training. We provide investment advisory services to individuals, high-net-worth individuals, corporations, and pension and profit-sharing plans concerning various securities, including mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, structured notes, options, commodities and non-U.S. securities. As a registered investment advisor, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our clients’ interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities and all transactions are sent to qualified custodians which execute, compare, allocate, clears, and settles them. Qualified custodians maintain our clients’ accounts and may grant clients access to them. A. Description of the Advisory Firm Singer Wealth Advisors LLC. (Herein after “SWA”) is a corporation organized in the State of Florida. We may market under the name Singer Wealth. The Singer Wealth Advisors, Inc, an S Corp, was formed in January 2014. In April 2021 Singer Wealth Advisors, Inc. became Singer Wealth Advisors, LLC. Singer Wealth Advisors, LLC became registered with the SEC November 2021. Registration with the SEC does not imply a certain level of skill or training. The principal owner is Keith Singer. B. Types of Advisory Services Portfolio Management Services SWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. SWA 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 SWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. SWA will request discretionary authority from clients 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. SWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of SWA’s economic, investment or other financial interests. To meet its fiduciary obligations, SWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, SWA’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 SWA’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. Third Party Platforms Singer Wealth Advisors offers advisory and sub-advisory services to other investment advisory firms, (RIA Clients). RIA clients use models offered by Third Party Money Managers for the allocation of their client (End Clients) portfolios. Model Managers/Sub-Advisors As part of our Asset Management Services, we are able to select or recommend the use of unaffiliated, third-party investment advisors serving as “Sub-Advisors” to manage all or a portion of your assets. Through these relationships we can direct the use of tactically managed strategies or managed models on their platform. The selection of Sub-Advisors is affected on a discretionary basis. This means we can “hire and fire” the Sub-Advisors from your account without consulting with you in advance. Any Sub-Advisor recommended by us shall be registered or exempt from registration in your home state of residence. The decision to use a Sub-Advisor is always based on each client’s individual needs. A complete description of the third-party investment advisor’s services acting as Sub-Advisor, fee schedules and account minimums are disclosed in the third party investment advisor’s Form ADV Disclosure Brochure which will be provided to clients at the time an agreement for services is executed and account is established with the Sub-Advisor, (if hired on a non-discretionary basis), or when we add or remove a Sub-Advisor from your account, (if selected on a discretionary basis). Assignment of SWA Investment Advisory agreement may be made after investor’s receipt of notification from Singer Wealth Advisors to investors identifying the proposed transaction. If notification is not received from investors within 60-days of receipt, SWA will presume no response is negative consent and will proceed with the transaction as described in notification sent. We are always available to answer questions you may have regarding the portion of your account managed by the Sub-Advisor, and act as the communication conduit between you and the Sub- Advisor. Sub-Advisors will take discretionary authority to determine the securities to be purchased and sold for your accounts managed by the Sub-Advisor. We will not utilize trading authority with respect to your Accounts(s) and/or assets managed by a Sub-Advisor. Annuities Variable Annuities offered with Charles Schwab as agent of record. SWA holds limited power of attorney on clients’ variable annuity accounts, allowing for the deduction of management fees as well as choosing and/or changing investment sub accounts. Fixed annuities are held directly with the carrier; Singer Wealth Advisors is the agent of record. Singer Wealth Advisors will recommend Advisory Fixed Income Annuity Indexes which are subject to advisory fees. Clients should be aware that non-fee-based index annuities are available as an alternative. Clients should compare fee-based index annuities to similar commissionable products to determine what is in their best interest. Private Placement Life Insurance (PPLI) and Private Placement Variable Annuities (PPVA) We can manage or provide consulting services on PPLI & PPVA, which includes:
• Conducting due diligence on PPLI and PPVA offerings to identify suitable options for clients.
• Advising on the structure and allocation of PPLI and PPVA within client portfolios.
• Providing ongoing monitoring and management of PPLI and PPVA investments to align with client goals and risk tolerance.
• Offering guidance on the tax implications, fees, and risks associated with PPLI and PPVA. PPLI and PPVAs are specialized financial products offering unique benefits for tax-efficient investing and estate planning for high-net-worth individuals. However, they come with complex features, fees, and risks that should be carefully considered. Investors are advised to work closely with their financial advisor, tax and legal professionals to understand these products fully. Before investing in PPLI or PPVA, investors should review the offering documents, understand the risks, and assess suitability for their financial goals and risk tolerance. Initial Public Offering (IPO) & Pre- IPO A Pre-IPO fund is a type of investment fund that focuses on investing in private companies that are expected to go public through an Initial Public Offering (IPO) in the future. These funds seek to capitalize on the potential for significant returns by investing in promising companies before they list their shares on a public stock exchange. Pre-IPO funds typically invest in companies during their earlier stages of development, often when they are still privately held and looking to grow rapidly. Determining the valuation of private companies can be challenging, but Pre-IPO funds employ various methods to estimate the company's worth before it goes public. 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 debit/credit planning. Services Limited to Specific Types of Investments SWA does not generally limit its investment advice. Investment advice includes blue chip stocks, ETFs (including ETFs in the gold and precious metal sectors), mutual funds, fixed income securities, real estate funds (including REITs), insurance products (including annuities), equities, treasury inflation protected/inflation linked bonds, structured notes, and other alternative investments, commodities and non-U.S. securities, options and private investments. SWA will consider other investments that are not included in our investment models at the request of a client. On occasion, Singer Wealth Advisors will offer non-publicly traded alternative investments to qualified investors. The standard Singer Wealth Advisors management fee will be assessed and will be documented in the advisory contract. On occasion, Singer Wealth Advisors will present a private lending opportunity to accredited investors. Documentation is provided to the potential investor by the mortgage company. This investment is purchased directly with the mortgage company; management fees will be collected from the associated Schwab account under SWA management. Asset will not appear in the Schwab account. The standard Singer Wealth Advisors management fee will be assessed and will be documented in the advisory contract. Cash Management Account Singer Wealth Advisors offers Cash Managed Accounts to investors with a household minimum initial investment of $250,000 in the strategy. Accounts may hold cash equivalent investments defined as: short-term investments with high credit quality and high liquidity including and not limited to cash, money markets, CDs, and short-term treasuries. A separate account will be established to isolate the client’s short-term liquid cash needs. If at any time the client’s cash needs change or there is a change in investment strategy as directed by the client, stating their choice to have SWA directly manage all or some of these assets, they understand and agree that the assets that SWA directly manages are charged at a higher rate as described in Exhibit II of the Investment Advisory + Selection And Monitoring Contract

under SWA Directly Managed schedule of fees. In the event an appropriate investment becomes available, the client is required to acknowledge the probability of a higher fee structure, and sanction and authorize the transfer of funds from the Cash Management Account to fund the new investment. Given Singer Wealth Advisors’ fiduciary responsibility, the investment offered will be appropriate to the investors’ risk tolerance, investment policy, and suitability, and warrant the higher fee schedule. Qualified Retirement Plan Services During the course of the annual service cycle, it is understood that Advisor may not perform each of the below services, as some services are offered on an as-needed basis. Specific services provided are indicated in the Qualified Retirement Plan Consulting Agreement as they relate to the Plan. It is understood that Advisor will be entitled to the full annual service fee regardless of whether all of the selected plan consulting services are needed on an annual basis. Fiduciary Consulting Services Investment Policy Statement Preparation. Advisor will assist Client in the development of an investment policy statement. The investment policy statement establishes the specific asset classes to be offered in the plan, as well as the criteria for selection and performance of each investment option for the Plan. The Client ultimately have the responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. Non-Discretionary Investment Advice. Advisor will provide Client with general, non- discretionary investment advice regarding asset classes and investment options, consistent with the Plan’s investment policy statement. Advisor will not have investment discretion nor any authority to add or remove investment options or trade securities in the Plan. Client will determine whether or not to implement Advisor’s advice. The implementation of any of Advisor’s advice will be solely the responsibility of Client Investment Selection Services. Advisor will provide Client with recommendations of investment options consistent with ERISA section 404(c). Investment Due Diligence Review. Advisor will provide client with periodic due diligence reviews of the Plan’s reports, investment options and recommendations. Investment Monitoring. Advisor will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement. Additionally, the Advisor will make recommendations to maintain or remove and replace investment options. (Only available for assets custodied through Schwab) Default Investment Alternative Advice. Advisor will provide non-discretionary investment advice to assist Client with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). Individualized Participant Advice. Upon request from Client, Advisor will provide one-on- one advice to Plan participants regarding their individual situations. (Subject to suitability assessment and review) Advisor acknowledges that in performing the fiduciary services listed above, that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Advisor will act in a manner consistent with the requirements of a fiduciary under ERISA for all services for which Advisor is considered a fiduciary under ERISA. However, Advisor (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Fiduciary Management Services Discretionary Management Services. Advisor will provide Client with continuous and ongoing supervision over the designated retirement plan assets, as specified in the Agreement. Advisor will actively monitor the designated retirement plan assets and provide advice to Client regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. Advisor has discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in the sole discretion of Advisor without first consulting with Client. Advisor also has the power and authority to carry out these decisions by giving instructions, on behalf of Client, to brokers and dealers and the qualified custodian(s) of the Plan for Advisor’s management of the designated retirement plan assets. Discretionary Investment Selection Services. Advisor will monitor the investment options of the Plan and add or remove investment options for the Plan. Client grants Advisor discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. Default Investment Alternative Management. Advisor will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. Investment Management via Model Portfolios. Advisor manages Model Portfolios which are investment options available to Plan participants. If Client has elected to include Advisor’s Model Portfolios as available options for Client’s qualified retirement plan, then each Plan participant will have the option to elect or not elect the Model Portfolios managed by Advisor and will be allowed to impose reasonable restrictions upon the management of each account by written instructions to Advisor. In all discretionary services listed in this section above, the Advisor will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), and the Advisor hereby acknowledges that it is a fiduciary with respect to the fiduciary management services listed above. Non-Fiduciary Services Participant Education. Advisor will provide educational services to the Plan participants about general investment principles and the investment alternatives available under the Plan. Client understands that Adviser’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Educational presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts. Participant Enrollment. Advisor shall assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Qualified Plan Development. Advisor will assist Client with the establishment of a qualified plan by working with Client and a selected Third Party Administrator. If Client has not already selected a Third Party Administrator, Advisor will assist Client with the review and selection of a Third Party Administrator for the Plan. Due Diligence Review. Upon request, Advisor will provide Client with periodic due diligence reviews of the Plan’s fees and expenses and the Plan’s service providers. Fiduciary File Set-up. Advisor will help Client establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, the investment policy statement, investment committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money managers and monitoring procedures for funds and/or money managers. Benchmarking. Advisor will provide Client with benchmarking services and will provide analysis concerning the operations of the Plan. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. D. Client Tailored Services and Client Imposed Restrictions SWA offers the same suite of services to all its clients (predicated on the client meeting required criteria, if any, including but not limited to accredited investor status). 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 impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent SWA from properly servicing the client account, or if the restrictions would require SWA to deviate from its standard suite of services, SWA reserves the right to end the relationship. E. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. SWA does not participate in any wrap fee programs. F. Assets Under Management SWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated $ 424,595,205.20 $0 December 31 2023