A. Portfolio Strategies, Inc. is a corporation formed on December 14, 1982, in the State of Washington. The Registrant became registered as an Investment Adviser Firm in March 1983. The Registrant is owned, in equal part, by John Williamson and David Jajewski. David Jajewski is the Registrant’s Chief Executive Officer and Managing Partner. B. As discussed below, the Registrant offers to its clients (individuals, business entities, investment companies, pension and profit sharing plans, trusts, estates, charitable organizations, etc.) investment advisory services. The Registrant does not hold itself out as providing financial planning, estate planning, or insurance planning services. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary investment advisory services on a fee basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management, generally between 0.80% and 2.50%. The Registrant does not determine the percentage advisory fee payable except to the extent that the current maximum annual advisory fee is 2.50%. The referring broker-dealer and/or investment adviser determines whether the client will pay the maximum or some lesser fee percentage. The client remains free to negotiate the advisory fee with the referring broker-dealer and/or investment adviser. The Registrant shall pay a portion of the advisory fee to the referring broker-dealer and/or investment adviser. See further discussion below regarding fees. Registrant manages investment advisory accounts not involving Investment Supervisory Services. Each investment program managed by the Registrant has been devised to meet a particular investment strategy applicable to an individual client’s investment objective(s). Each investment program is continuously managed based on the program’s strategy, rather than based upon each client's individual needs. However, each client will have the opportunity to place reasonable restrictions on the types of investments to be held in his/her/their/its account. Before engaging Registrant to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Registrant offers investment programs using the following model portfolios: Index Plus, All Seasons, L/O Opportunity, Quantitative Income, Equity Alternative, Inflexion Points, Inflexion Points Nitro, Tactical High Yield, Ultra Select, Tactical Equity, Tactical Equity Moderate, Tactical Evolution, PSI Equity Advantage, Aggressive Growth, Absolute Return, PSI Liberty Tactical Income Solutions, PSI Liberty Tactical Growth Solutions, PSI Liberty Opportunity, PSI Liberty Smart, PSI Liberty Capstone and PSI Liberty Spectrum, each of which programs is more comprehensively discussed in the Registrant’s program brochures which are provided to all prospective clients. Some program strategies are also available within specific variable annuities and 401(k) programs obtained through various insurance companies and custodians. Because of trading restrictions and fund limitations imposed by certain custodians, some programs (Index Plus) may be substantially modified to meet these more stringent requirements, which may affect performance results. The modifications are solely a function of the custodian designated by the client, of which the client is made aware prior to participating in a particular program. The Registrant does not determine or recommend the custodian; the Registrant is custodian neutral. The Registrant currently maintains relationships with Axos Clearing and Charles Schwab and Co, Inc. (“Schwab”). The choice of custodian is the decision of the client in conjunction with the client’s chosen referring broker-dealer/ investment adviser. The Registrant has no economic incentive relative to the client’s choice of custodian. The Registrant can manage the assets in the same manner at any such custodian. Fees will differ depending upon the custodian chosen. Higher custodian fees will adversely impact account performance. The client should address custodian choice with the referring broker-dealer/ investment adviser. See disclosure below Registrant’s investment programs do not follow a buy-and-hold strategy but trade in-and- out of positions on a frequent basis (which could be two to three times a week). The strategies used by Registrant can incorporate the purchase of inverse index mutual funds and other mutual funds that invest in leveraged instruments, such as futures contracts and options on securities, both on a long and short basis. Because of this leverage, the value of an individual program may fluctuate substantially from day to day. However, Registrant's goal in the use of these funds is to mitigate market exposure, thereby attempting to decrease overall program downside risk. MISCELLANEOUS No Financial Planning or Non-Investment Consulting/Implementation Services. The Registrant does not provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Please Note: Registrant does not serve as an attorney, accountant, or insurance agency, and no portion of our services should be construed as legal, accounting, or insurance implementation services. Accordingly, we do not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). including representatives of Registrant in their separate individual capacities as registered representatives of GWN Securities, an SEC registered and FINRA member broker-dealer, or as licensed insurance agents You are 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 made by Registrant or its representatives. Please Note: If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and competency of the services provided. Please Also Note-Conflict of Interest: The recommendation by Registrant that a client purchase a securities or insurance commission product through one of Registrant’s representatives in their separate and individual capacity as a registered representative of GWN Securities, and/or as an insurance agent, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment or insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission products through such a representative. Clients are reminded that they may purchase securities and insurance products recommended by Registrant through other non- affiliated broker-dealers and/or insurance agencies. Retirement Rollovers - Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Registrant is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant, whether it is from an employer’s plan or an existing IRA. The Registrant’s Chief Compliance Officer, David Jajewski, remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such rollover recommendation. Please Note: Generally, the Registrant does not recommend rollovers. Rather, the rollover recommendation, if made, is made by the client’s introducing broker-dealer or investment adviser. In such event, the introducing broker-dealer or investment adviser shall have the responsibility for compliance with the above disclosure obligation and the fiduciary requirements applicable to recommending rollovers. The Registrant shall confirm, in writing, with the client’s introducing investment professional (i.e., the professional that maintains the day-to-day relationship with the client), that the introducing professional has undertaken a review of the client’s current retirement plan, and has determined that a rollover is in the best interest of the client. 12b-1 Compensation. Certain affiliated and unaffiliated mutual funds pay marketing, distribution, and/or shareholder servicing fees, commonly known as 12b-1 fees. Although Registrant will first seek to invest a client in mutual fund share classes that do not pay 12b- 1 fees, if such share class is unavailable on a particular mutual fund, Registrant may invest clients in shares classes of the same fund which pay 12b-1 compensation. Where the client is invested in fund(s) that pay 12b-1 fees, the 12b-1 compensation will be collected directly by the account custodian and no portion shall be retained by Registrant. Fund share classes that pay 12b-1 compensation generally have higher internal expense ratios, which adversely impacts performance. The Registrant’s Chief Compliance Officer, David Jajewski, remains available to address any questions that a client or prospective client may have regarding the above arrangement. Please Note: Inverse/Enhanced Market Strategies. The Registrant may utilize long and inverse mutual funds and/or exchange traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices (at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no assurance that any such strategy will prove profitable or successful. In light of these enhanced risks/rewards, a client may direct the Registrant, in writing, not to employ any or all such strategies for his/her/their/its accounts. Mutual Fund/Exchange Traded Fund Fees. While the Registrant may recommend allocating investment assets to mutual funds that are not available directly to the public, the Registrant may also recommend that clients allocate investment assets to publicly available mutual funds and exchange traded funds that the client could obtain without engaging Registrant as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly available mutual funds and exchange traded funds without engaging Registrant as an investment adviser, the client or prospective client would not receive the benefit of Registrant’s initial and ongoing investment advisory services. In addition to Registrant’s investment management fee, brokerage commissions, and/or transaction fees, the client will also incur, relative to all mutual fund and exchange traded funds, charges imposed at the fund level (e.g., management fees and other fund expenses). Commission/Transaction Fees. Broker-dealers/custodians that execute investment transactions generally charge brokerage commissions, transaction fees, and/or custodial fees for effecting securities transactions. These charges, as well as the charges imposed at the mutual fund and exchange traded fund level, are in addition to Registrant’s advisory fee referenced in Item 5 below. Custodian Charges-Additional

Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that Axos Clearing (“Axos”) or Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Axos and Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions. The fees shall differ depending upon the broker-dealer/custodian. These fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below. Registrant does not receive any portion of these fees/charges. See additional disclosure at Item 5 below. ANY QUESTIONS: Registrant’s Chief Compliance Officer, David Jajewski, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: As set forth below at Item 5, transaction fees for clients of Registrant are generally assessed as an annual asset-based fee, rather than on a transaction-by-transaction basis. Research Services. The Registrant engages unaffiliated investment providers to provide research services and/or investment signals to assist the Registrant with management of one or more if its investment strategies. Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non- public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Registrant has established its procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Registrant does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cash Sweep Accounts. Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, Registrant shall generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless Registrant reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within the Registrant’s actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any of the Registrant’s unmanaged accounts. Asset-Based Pricing Arrangements and Limitations. Registrant may recommend that clients enter into an “Asset-Based” pricing agreement with the account broker- dealer/custodian. Under an asset- based pricing arrangement, the amount that a client will pay the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the account, generally expressed in basis points and/or a percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1.00%, or 0.01% (0.0001). This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. Under either the asset-based or transaction-based pricing scenario, the fees charged by the respective broker-dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to Registrant per Item 5 below. Registrant does not receive any portion of the asset- based transaction fees payable by the client to the account custodian. The client is under no obligation to enter into an asset-based arrangement, and, if the client does so, the client can request at any time to switch from asset- based pricing to transactions- based pricing, However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to transaction- based pricing could prove to be economically disadvantageous. Data Aggregation Platforms. Registrant may provide its clients with access to an online platform hosted by Orion, Envestnet, or other providers (the “Platforms”). The Platforms allow a client to view their complete asset allocation, including those assets that Registrant does not manage (the “Excluded Assets”). Registrant does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Registrant shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Registrant, shall be exclusively responsible for such investment performance. The client may choose to engage Registrant to manage some or all of the Excluded Assets pursuant to the terms and conditions of the IAA between Registrant and the client. The Platforms also provide access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Registrant. Finally, Registrant shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the Platforms without Registrant’s assistance or oversight. Use of Unaffiliated Broker-Dealers and Investment Advisers. The Registrant primarily manages accounts referred to it by unaffiliated broker-dealers and investment advisers, pursuant to which the Registrant generally pays a portion of its management fee to the referring broker-dealer or investment adviser in accordance with the parameters of SEC Rule 206(4)-3. The referring broker-dealers and investment advisers maintain both the initial and ongoing day-to-day relationship with the client, including initial and ongoing determination of client suitability for the Registrant’s designated strategies. The Registrant does not maintain physical possession of client funds or securities. Accounts are primarily maintained at the custodian designated by the referring broker- dealer/investment adviser. Other than the advisory fees earned by the Registrant from the referred account, the Registrant does not derive any economic benefit from the referring investment adviser or broker-dealer. See Items 13A and 14B below. Model Provider. In the event that an unaffiliated registered investment adviser firm desires to utilize Registrant’s models and/or strategies on the Envestnet and/or FTJ FundChoice platforms, the Firm will receive a platform fee payable by the investor. The platform fee payable to the Firm is separate, and in addition to, any advisory fee payable to the underlying investment manager. Thus, in addition to the platform fee payable to the Firm, the investor will also incur an investment management fee payable to the unaffiliated investment manager for the selected strategy. If the Adviser, on behalf of its investor client, determines to utilize one of the Firm’s models, the Firm, in lieu of an investment management fee payable directly to the Firm by the investor, shall receive only its management fee In addition to platform and management fees, the investor will also incur custodial fees, no portion of which shall be received by the Firm. The unaffiliated investment adviser maintains both the initial and ongoing day-to-day relationship with the client, including initial and ongoing determination of client suitability for the Firm’s models. The Firm does not have any relationship with the adviser’s clients Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, market conditions, style drift, and/or if the Registrant is informed of a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Please Note: Cash Positions. The Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Registrant’s Chief Compliance Officer, David Jajewski, remains available to address any questions that a client or prospective may have regarding the above fee billing practice. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/ revising Registrant’s previous recommendations and/or services. Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2 of Form ADV, along with the Form CRS Relationship Summary, shall be provided to each client prior to, or contemporaneously with, the execution of the IAA. C. The Registrant shall provide investment advisory services specific to needs of each client. Prior to providing investment advisory services, an investment adviser representative will discuss with each client, his/her/their/its particular investment objective(s). The Registrant shall allocate each client’s investment assets consistent with his/her/their/its designated investment objective(s). Client may, at any time, impose restrictions, in writing, on the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $59,547,202 in assets under management on a discretionary basis.