A. GOLDEN STATE ASSET MANAGEMENT, LLC Golden State Asset Management, LLC (“GSAM” and/or “the firm”) is an investment adviser registered under the Investment Advisers Act of 1940. GSAM was initially formed as a Wyoming limited liability company in 2018 and reorganized as a Delaware limited liability company in December of 2021. GSAM is an affiliate of Golden State Wealth Management, LLC, Golden State Equity Partners, LLC, and Redwood Investment Group. See Item 10 of this document for an additional discussion concerning the firm’s affiliates. Golden State Asset Management, LLC’s primary office is located at 201 E Sandpointe Ave, Suite 460, South Coast Metro, CA 92707. B. TYPES OF ADVISORY SERVICES OFFERED As discussed below, GSAM primarily provides discretionary portfolio management and investment services to the clients of other registered investment advisors. Typically, this means that GSAM implements its strategy directly by placing trades in the client’s separate account. 1. Sub-Advisory Services GSAM primarily provides discretionary sub-advisory services to investment advisors. When providing such services, GSAM will enter into a separate, written sub-advisory agreement with each advisor. Subject to GSAM’s written approval, the client may be able to place a variety of restrictions on GSAM’s discretionary investment activity, including restrictions on the term of investments, the types of securities permitted, the credit ratings allowed, and the liquidity of the account. Clients may change these restrictions upon written notice to GSAM and such changes are only effective once acknowledged in writing by GSAM. In providing sub-advisory services to its clients, GSAM employs various proprietary investment strategies (“Investment Strategies”) for the portfolios over which it has been delegated discretionary authority (each, a “Portfolio”). GSAM works with each client to determine

which Investment Strategy or Strategies will achieve the objectives of a particular portfolio. 2. Stella Nova™ GSAM also provides digitally automated portfolio management services directly to retail clients through its Stella Nova advisory program, which the firm began offering in the 4th Quarter of 2020. More detailed information about Stella Nova can be found in the Stella Nova Program Brochure or on the Stella Nova website (http://www.mystellanova.com). 3. Investment Philosophy & Strategies GSAM believes that client investment allocations should change as their life changes. Investment advisers that utilize GSAM as a sub-adviser have a thorough understanding of their 5 GSAM Firm Brochure 3.2024 clients’ personal risk tolerance investment objectives and adjust their allocation to meet the personal needs. GSAM seeks to incorporate a broad range of diversified investment options that will enable it to construct a portfolio with aggregate risk and return characteristics at any point within the client’s desired suitability range (aggressive to conservative). The firm seeks adherence to the specific investment objectives, time frame, and criteria for each client, and evaluates the relevant information over a full market cycle. With these objectives and identified investment categories, the Firm will select investment options to:
• Maximize return within reasonable and prudent levels of risk within portfolio timeframes.
• Provide returns comparable to returns for similar investment options.
• Provide exposure to a wide range of investment opportunities in various asset classes. Client Assets Under Management GSAM has $342,307,815 in regulatory assets under management as of December 31, 2023.