Kaye Capital Management (“KCM” “the Firm”) is a corporation formed on January 17, 2003, in the State of California. The Firm was approved for registration by the SEC in April 2000. KCM is principally owned by the Watten Family Trust and the Hilton Family Trust, for which Kenneth J. Watten and David W. Hilton serve as respective trustees. Mr. Watten and Mr. Hilton are also the Firm’s Principals. ADVISORY SERVICES INVESTMENT MANAGEMENT KCM offers asset management services to advisory Clients. KCM will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the Client elects to use KCM on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing KCM to determine the securities to be bought or sold and the amount of the securities to be bought or sold. KCM will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use KCM on a non-discretionary basis, KCM will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, KCM will obtain prior Client approval on each and every transaction before executing any transaction. KCM may also recommend that certain qualified Clients consider an investment in private funds/offerings. KCM’s role relative to the private investment funds can include, but not limited to, initial and ongoing due diligence, performance reporting, and investment monitoring services. KCM’s Clients are under no obligation to consider or make an investment in a private investment fund(s). Each prospective private fund investor will be required to complete a Subscription Agreement or similar application, pursuant to which the Client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Please see Item 8 for more information on the risks associated with this type of investment. Account Aggregation and Planning Platforms. KCM may provide its clients with access to one or more online account aggregation and financial planning platforms, including those hosted by MoneyGuidePro and Orion Planning (each a “Platform”). The Platforms allow a client to view their complete asset allocation, including those assets that KCM does not manage (the “Excluded Assets”). KCM does not provide investment management, monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, KCM’s service relative to the Excluded Assets is limited to reporting only. Therefore, KCM 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 KCM, shall be exclusively responsible for such investment performance. Without limiting the above, the Firm shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage KCM to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between KCM and the client. The Platforms also provide access to certain information and applications, including financial planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by KCM. KCM 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 KCM’s assistance or oversight. FINANCIAL PLANNING AND CONSULTING Services include an evaluation of a Client's current and future financial state using currently known variables to predict future cash flows, asset values, recommend purchase and sales, and withdrawal plans. KCM will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Topics for planning may include, but are not limited:
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution.
• Long-term investment plan: Build a customized asset allocation strategy based on specific investment objectives and a risk profile. This strategy sets guidelines for selecting, buying, and selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. If a conflict of interest exists between the interests of KCM and the interests of the Client, the Client is under no obligation to act upon KCM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through KCM. INSTITUTIONAL RETIREMENT PLAN SERVICES KCM offers services to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans (“Plan”). KCM may act as a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. KCM acts as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor KCM has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using KCM can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide investment advice to the Plan about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. The Plan Sponsor will make the final decision regarding the initial selection, retention, removal,

and addition of investment options. KCM acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Plan in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Plan shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (QDIA) for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c)(5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with the Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Plan understands KCM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, KCM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. KCM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. KCM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between KCM and the Plan. 3. KCM has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to KCM in the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. 3(38) Investment Manager. KCM acts as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. KCM would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5).
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. The Advisor’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not providing fiduciary advice as defined by ERISA to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. KCM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Plan Sponsor. 3. KCM has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. CLIENT-TAILORED SERVICES AND CLIENT-IMPOSED RESTRICTIONS The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions may, however, prohibit engagement with KCM. WRAP FEE PROGRAMS KCM does not participate in a Wrap Fee Program. AMOUNTS UNDER MANAGEMENT As of December 31, 2023, the Firm had total assets under management of $668,671,257. Of that, $643,216,449 were managed on a discretionary basis, and $25,454,808 were managed on a non- discretionary basis. In addition to Assets Under Management, the Firm also advised on Retirement Plan assets that totaled $332,909,550.