Lee Financial Group Hawaii, Inc. (“LFG”) was organized on May 13, 1988 and its sole owner is Terrence K.H. Lee. As of December 31, 2022 LFG, managed $334,649,839 of client assets on a discretionary basis. Wealth Management Services LFG provides investment supervisory services (giving continuous advice as to the investment of funds on the basis of the individual needs of each client) to individuals, trusts, estates, charitable organizations, corporations and other business entities, pension and profit sharing accounts (“Wealth Management services”). These Wealth Management services include, but are not limited to, one or more of the following services: providing investment advice, selecting investments and providing reports to clients. These services are provided pursuant to a discretionary agreement between LFG and the client. Horizon Program (“HP”) LFG offers an automated investment program, HP, through which clients can be invested in a range of investment strategies which LFG has constructed and manages, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The client may exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened online by the client at Charles Schwab & Co., Inc. (“CS&Co”). LFG uses the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the HP. LFG is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). LFG and not Schwab, is the client’s investment advisor and primary point of contact with respect to the HP. LFG is solely responsible, and Schwab is not responsible, for determining the appropriateness of the HP for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. LFG has contracted with SPT to provide LFG with the Platform, which consists of technology and related trading and account management services for the HP. The Platform enables LFG to make the HP available to clients online and includes a system that automates certain key parts of LFG’s investment process (the “System”). The System includes an online questionnaire that helps LFG determine the client’s investment objectives and risk tolerance and to select an appropriate investment strategy and portfolio. LFG will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio. LFG then makes the final investment decision and selects a portfolio based on all the information the client has provided to LFG. The System also includes an automated investment engine through which LFG manages the client’s portfolio on an ongoing basis through automatic rebalancing and, if the client is eligible and elects, tax-loss harvesting. LFG charges clients a fee for its HP services as described below under Item 5 Fees and Compensation. LFG’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the HP. Schwab does receive other revenues from LFG in connection with the HP. LFG does not pay SPT fees for the Platform. These services are provided pursuant to a discretionary agreement between LFG and the

client. Communication is primarily conducted with clients through electronic channels. Clients must agree to accept electronic delivery of documents, including, but not limited to: Form ADV, disclosure documents, prospectuses, statements, confirmations and other materials. LFG makes hard copies available if requested. Wealth Managers are also available to discuss servicing matters with clients. The client, not LFG decides whether to enroll in the HP; however LFG works with clients to help them determine which services are the best fit for them. In general, those clients who have less investment complexity and are seeking a more digital experience may benefit from LFG’s HP. Clients who have investible assets of $250,000 or more, more investment complexity, or a desire for one-on-one services with a Wealth Manager may benefit from LFG’s Wealth Management Services. Investment Management Services LFG provides investment management services (the investment and reinvestment of assets) to a mutual fund series (the “Fund”) of a registered investment company, Lee Financial Mutual Fund, Inc. (“Lee Financial Fund”), subject to the supervision and direction of Lee Financial Fund Board of Directors. These services include selecting investments and providing reports to the Lee Financial Fund Board of Directors. These services are provided pursuant to a Management Agreement between LFG and Lee Financial Fund in respect of the Fund. LFG asks clients to complete an investment risks data sheet that includes, among other things, information on the client’s investment goals, risk tolerance, asset inventory and investment experience, in order to tailor its advisory services to the individual needs of the client. LFG manages its client assets in accordance with such investment restrictions as the client may, from time to time, furnish to LFG in writing. With respect to the Lee Financial Fund, LFG manages the Fund’s assets in accordance with the Fund’s investment objectives, policies, and restrictions as described in the Fund’s prospectus. Benefit Plans and IRAs – Our Fiduciary Acknowledgment When LFG and our individual Wealth Managers 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 of 1974 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 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. Under this special rule, covered “plans” include employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as well as tax-qualified solo 401(k) and Keogh plans for self-employed individuals and partners. “IRAs” include individual retirement accounts, individual retirement annuities, health savings accounts, Archer medical savings accounts and Coverdell education savings accounts.