A. DESCRIPTION OF THE ADVISORY FIRM Vivid Wealth Management, LLC (hereinafter “VWML”) is a Limited Liability Company organized in the State of Iowa. The firm was formed in July 2021, and the owner is Vivid Tax Advisory Services, LLC. The principal owner of Vivid Tax Advisory Services, LLC is Cameron Dale McCarty. B. TYPES OF ADVISORY SERVICES Portfolio Management Services VWML offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VWML creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Portfolio management services include, but are not limited to, the following: – Investment strategy – Asset selection – Risk tolerance – Personal investment policy – Asset allocation – Regular portfolio monitoring VWML evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. VWML will request discretionary authority from clients in order 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, which is given to each client. VWML seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VWML’s economic, investment or other financial interests. To meet its fiduciary obligations, VWML attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VWML’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 VWML’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. 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 debt/credit planning. Services Limited to Specific Types of Investments VWML generally limits its investment advice to mutual funds, fixed income securities, insurance

products including annuities, and treasury inflation protected/inflation linked bonds, although VWML primarily recommends ETF (including ETFs in the gold and precious metal sectors) and equities. VWML may use other securities as well to help diversify a portfolio when applicable. 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 Form ADV 2A 09/23 Page 5 of 15 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. C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS VWML will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by VWML on behalf of the client. VWML may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may request specific restrictions within their accounts. These requests will be reviewed on an individual basis to determine if they will impede VWML’s ability to implement the selected strategy. D. 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. VWML does not participate in any wrap fee programs. E. ASSETS UNDER MANAGEMENT VWML has the following assets under management: Discretionary Amounts Non-discretionary Amounts Date Calculated $ 171,948,835 $0 December 2023 Form ADV 2A 09/23 Page 6 of 15