Page 4 A. Description of Your Advisory Firm HD Money, Inc. (“HDM” or the “firm”) is a Florida corporation. The firm was formed in 2013 and is owned by Margaret Hixon, Stuart Dickson, and Phillip Dickson. B. Advisory Services Offered HDM provides personalized, confidential financial planning and retains subadvisers for services to individuals, businesses, and charitable organizations. Advice is provided through consultation with the client and may include one or more of the following services: determination of financial objectives, identification of financial concerns, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. HDM is a fee-based financial planning and investment management firm. HDM limits its investment advice to limited types of investments and strategies available from third-party managers, which include mutual funds, ETFs, stocks, and bonds. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement or risk analysis. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Investment Management Services HDM’s discretionary investment management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. HDM will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. In addition, HDM may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. For discretionary investment management services, HDM receives a limited power of attorney to effect securities transactions on behalf of its clients. Clients may grant HDM limited discretionary authority with respect to advisory client assets, including discretion to select third-party managers on behalf of such HDM advisory clients. HDM recommends securities transactions to its clients that include securities and strategies as described in Item 8 of this Brochure. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. HDM will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. HDM will also contact clients at least annually to determine Page 5 whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Independent Account Managers With respect to the discretionary services clients engage us to provide, HDM may recommend the use of independent account managers (“subadvisers”) to manage all or a portion of client assets. The client authorizes HDM to delegate the performance of the discretionary services to subadvisers. Under such authority, the client authorizes us to allocate assets into, or recommend, portfolios of investments constructed, monitored, and modified from time to time by one or more subadvisers. While such subadvisers

will manage accounts on an ongoing basis, the subadvisers will not provide clients with advice based on their circumstances—HDM will recommend how client assets should be allocated among the subadvisers and their strategies. HDM will provide clients with the ADV Part 2A Brochure of any subadvisers. Certain subadvisers we utilize may require the client to separately enter into a services agreement with that subadviser as a condition to participate in all or certain investment programs offered by such subadviser, and the client may be required or complete a separate trading authorization form required by a qualified custodian. Any subadviser we retain or engage will have the same discretionary authority to buy, sell, or hold investments for the account(s) the client grants to us by giving instructions to brokers and dealers and the account’s qualified custodian(s). Currently, HDM has an agreement with its affiliate, Vimvest Securities, LLC (“Vimvest”), to provide HDM with access to portfolios developed and monitored by Vimvest (the “Vimvest Portfolios”) to recommend to its clients. Either HDM or the client determine the amounts to be invested in the Vimvest Portfolios, and thereafter, Vimvest has limited discretion to rebalance the client’s account within the Vimvest Portfolios. Consulting and Financial Planning Services HDM provides review and analysis in many areas including, but not limited to risk vs. reward analysis, income analysis, insurance policy review, investment allocation review, legacy analysis and social security analysis. HDM gathers required information through in-depth personal interviews and questionnaires. Information gathered includes a client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report is prepared covering one or more of the above-mentioned topics as directed by the client. Managers, members, and registered personnel of HDM are licensed insurance agents. In implementing the financial plan, the firm may recommend insurance products in which it has an economic interest. Please be advised of the following: ▪ A conflict exists between the investment adviser and the client. ▪ The client is under no obligation to act upon the firm’s recommendation. ▪ If the client elects to act on the firm’s recommendations, the client is under no obligation to effect the transaction through the firm. Page 6 Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by HDM under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising HDM’s recommendations and/or services. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account. For example, other than for Vimvest Portfolios, clients may restrict the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs HDM does not participate in wrap fee programs, where certain brokerage commissions and transaction costs are included in the asset-based fee charged to the client. HDM does recommend the wrap fee program of its affiliate, Vimvest. E. Client Assets Under Management As of December 31, 2023, HDM managed $225,890,000 of client assets, all on a discretionary basis.