A. Vahanian & Associates Financial Planning Inc. (“Vahanian”) is a New York corporation formed on July 14, 1986. Vahanian became registered as an investment adviser in August 1998. Jeffrey C. Vahanian, is Vahanian’s President and principal owner. B. Vahanian offers investment advisory services and financial planning and related consulting services to its clients as described below. INVESTMENT ADVISORY SERVICES Clients can engage Vahanian to provide discretionary investment advisory services on a fee basis. Vahanian’s annual investment advisory fee is based upon a percentage of the market value of the assets placed under Vahanian’s management. Before engaging Vahanian to provide investment advisory services, clients a enter into an Investment Advisory Agreement with Vahanian setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the fee that is due from the client. Vahanian’s investment management services are tailored specifically to the needs of each client. To begin the investment advisory process, an investment adviser representative will collaborate with the client to develop investment objectives based upon an assessment of factors that typically include capital preservation, risk tolerance, income production, liquidity requirements, client preferences, asset and liability levels, and investment restrictions. Once the client’s investment objectives are established, Vahanian will allocate or recommend that the client allocate investment assets consistent with the designated investment objectives. Vahanian primarily allocates client investment assets on a discretionary basis among various mutual funds, exchange traded funds (“ETFs”), individual equity securities, and to a much lesser extent, fixed income securities (bonds), cash and cash equivalents consistent with the client’s designated investment objectives. Once allocated, Vahanian provides ongoing monitoring and review of account performance and asset allocation as compared to client investment objectives and will periodically execute or recommend execution of transactions for the account based upon those reviews or other triggering events. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Vahanian may agree to provide financial planning and consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand- alone separate fee basis. Before engaging Vahanian to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Vahanian setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client before Vahanian commences services. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Vahanian may provide financial planning and related consulting services addressing investment or non-investment related matters, such as estate planning, tax planning, insurance, etc. Vahanian does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Vahanian does not prepare estate planning documents or tax returns. Unless specifically agreed in writing, neither Vahanian nor its representatives are responsible to implement any financial plans or financial planning advice; provide ongoing financial planning services; or provide ongoing monitoring of financial plans or financial planning advice. Clients are solely responsible to revisit the financial plan or financial planning advice with Vahanian, if desired. Vahanian’s financial planning and consulting services are completed upon communicating its recommendations to the client, upon delivery of the applicable written plan, or upon termination of the applicable agreement. Upon client request, Vahanian may recommend the services of other professionals for certain implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including representatives of Vahanian in their separate individual capacities as registered representatives of Osaic Wealth, Inc., (formerly Royal Alliance Associates) (“Osaic”) an SEC registered and FINRA member broker-dealer (as described in Item 5.E.), and as licensed insurance agents (as described in Item 10.C.). The client is under no obligation to engage the services of any recommended professional who is responsible for the quality and competency of the services they provide. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Vahanian and its representatives. Conflict of Interest. The recommendation by Vahanian’s representative that a client purchase a securities or insurance commission product through Vahanian’s representative in their separate and individual capacity as a registered representative of Osaic and 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 may purchase securities and insurance products

recommended by Vahanian through other, non-affiliated broker-dealers and insurance agents. If the client engages any recommended professional, and a dispute then arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. ERISA / IRC Fiduciary Acknowledgment. When Vahanian provides investment advice to a client about the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Because the way Vahanian makes money creates some conflicts with client interests, Vahanian operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule’s provisions, Vahanian must: meet a professional standard of care when making investment recommendations (give prudent advice); never put its financial interests ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that Vahanian gives advice that is in the client’s best interest; charge no more than is reasonable for Vahanian’s services; and give the client basic information about conflicts of interest. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving an employer 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 Vahanian recommends that a client roll over their retirement plan assets into an account to be managed by Vahanian, such a recommendation creates a conflict of interest if Vahanian will earn a new (or increase its current) advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to an account managed by Vahanian. Asset Aggregation / Reporting Services. Vahanian may provide access to reporting services through one or more third-party aggregation / reporting platforms that can reflect all of the client’s investment assets, including those investment assets that the client has not engaged Vahanian to manage (the “Excluded Assets”). Vahanian’s service for the Excluded Assets is strictly limited to reporting, and specifically excludes investment management or implementation. Because Vahanian does not have trading authority for the Excluded Assets, the client (and/or a designated investment professional), and not Vahanian, will be exclusively responsible for directly implementing any recommendations for the Excluded Assets and the resulting performance or related activity (such as timing and trade errors) pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also provide access to financial planning information and applications, which should not be construed as services, advice, or recommendations provided by Vahanian. Accordingly, Vahanian will not agree to be responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the third party reporting platforms without Vahanian’s participation or oversight. Portfolio Trading Activity / Inactivity. As part of its investment advisory services, Vahanian will review client portfolios on an ongoing basis to determine if any trades are necessary based upon various factors, including but not limited to investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when Vahanian determines that upon review, trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5 during periods of portfolio trading inactivity. Client Obligations. When performing its services, Vahanian is not required to verify any information received from the client or from the client’s designated professionals and is expressly authorized to rely on that information. Clients are responsible to promptly notify Vahanian if there is ever any change in their financial situation or investment objectives for the purpose of reviewing or amending Vahanian’s services or previous recommendations. C. Vahanian provides investment advisory services tailored specifically to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Then, Vahanian allocates or recommend that the client allocate investment assets consistent with the designated investment objectives. The client may, at any time, impose reasonable restrictions, in writing, on Vahanian’s services. D. Vahanian does not participate in a wrap fee program. E. As of December 31, 2023, Vahanian had $176,994,232 in assets under management on a discretionary basis.