A. Monterey Private Wealth, Inc. (“MPW”) is a corporation formed under the laws of the State of California on June 4, 2001. MPW underwent a merger in 2011 whereby Willow Ridge Capital Advisers, Inc. and Petersen & Ramistella merged in to one advisory practice. MPW is principally owned by Gary E.D. Alt, Cristofer Cabanillas, and Steven C. Merrell. B. As discussed below, MPW offers to its clients (individuals, high net worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations, businesses, etc.) investment advisory services, financial planning and consulting services, and retirement plan consulting services. INVESTMENT ADVISORY SERVICES The client can engage MPW to provide discretionary and/or non-discretionary investment advisory services on a fee basis. MPW’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under MPW’s management. Before engaging MPW to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with MPW 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. MPW’s annual investment advisory fee shall include investment advisory services, and general financial advice. In the event that the client requires financial planning and/or consultation services (to be determined in the sole discretion of MPW), MPW may determine to charge for such additional services pursuant to a stand-alone Financial Planning Agreement (see below). MPW provides investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Then, MPW will allocate and/or recommend that the client allocate investment assets consistent with the designated investment objectives. MPW generally allocates or recommends that clients allocate investment assets among: exchange-listed securities, mutual fund shares, corporate debt, exchange traded funds (“ETFs”), structured notes and US government securities on a discretionary and/or non- discretionary basis in accordance with the client’s designated investment objective(s). Once allocated, MPW provides ongoing monitoring and review of account performance, asset allocation and client investment objectives. MPW believes that it is important for the client to address financial planning issues on an ongoing basis. MPW’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with MPW. It remains the client’s responsibility to promptly notify the MPW if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising MPW’s previous recommendations and/or services. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) MPW may also provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis as discussed at Item 5 below, the fee for which shall generally be based upon the individual providing the service and the scope of the services to be provided. Before engaging MPW to provide stand-alone planning or consulting services, clients are required to enter into a Financial Planning and Consulting Agreement with MPW 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 MPW commences services. If requested by the client, MPW may recommend the services of other professionals for implementation purposes. The client is 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 from MPW. Please Note: If the client engages any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged professional(s), and not MPW, shall be responsible for the quality and competency of the services provided. Please Also Note: It remains the client’s responsibility to promptly notify MPW if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising MPW’s previous recommendations and/or services. RETIREMENT PLAN SERVICES MPW provides retirement plan consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. If requested by the plan sponsor, MPW may also include discretionary trading models within the selection of investment alternatives of a retirement plan lineup. In addition, to the extent requested by the plan sponsor, MPW shall also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between MPW and the plan sponsor. MPW may also provide discretionary and/or non-discretionary investment management to pooled retirement plans, in accordance with the plan’s designated investment objectives. In such engagements, MPW will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Before engaging MPW to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with MPW 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. MISCELLANEOUS Client Obligations. In performing its services, MPW 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 MPW if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising MPW’s previous recommendations and/or services. Non-Discretionary Service Limitations. Clients that determine to engage MPW on a non- discretionary investment advisory basis must be willing to accept that MPW cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that MPW would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, MPW will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual Funds and Exchange Traded Funds : While MPW may recommend allocating investment assets to mutual funds and exchange traded funds (“ETFs”) that are not available directly to the public, MPW may also recommend that clients allocate investment assets to publicly-available mutual funds and ETFs that the client could obtain without engaging MPW as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds or ETFs without engaging MPW as an investment adviser, the client or prospective client would not receive the benefit of MPW’s initial and ongoing investment advisory services. In addition to MPW’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through registered investment advisers. MPW may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of MPW’s services to a client, restrictions regarding transferability and/or additional purchases of, or reallocation among DFA funds will apply. MPW’s Chief Compliance Officer, Steven Merrell, remains available to address any questions that a client or prospective client may have regarding the above. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, MPW generally recommends that Charles Schwab and Co., Inc. (“Schwab”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab may charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) may differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions (including ETFs), others do). Please Note: there can be no assurance that Schwab will not change its transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom MPW and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab). These fees/charges are in addition to MPW’s investment advisory fee at Item 5 below. MPW does not receive any portion of these fees/charges. Independent Managers. MPW may allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to- day responsibility for the active discretionary management of the allocated assets. MPW will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors MPW considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is set forth in a separate agreement between the client and Independent Manager(s) and is separate from, and in addition to, MPW’s advisory fee. Account Aggregation Platform(s). MPW may provide its clients with access to certain online account aggregation platform(s). The platform(s) allows a client to view their complete asset allocation, including those assets that MPW does not manage (the “Excluded Assets”). MPW does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, MPW 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 MPW, shall be exclusively responsible for such investment performance. The client may choose to engage MPW to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between MPW and the client. The platform(s) may 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 MPW. Finally, MPW 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 platform(s) without MPW’s assistance or oversight. Cash Positions. MPW treats cash as an asset class. As such, unless determined to the contrary by MPW, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating MPW’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), MPW 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, MPW’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, MPW shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless MPW 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 a MP 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 MP unmanaged accounts Cybersecurity Risk. The information technology systems and networks that MPW and its third-party service providers use to provide services to MPW’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in MPW’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and MPW 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 MPW has established its processes to reduce the risk of cybersecurity incidents. There is no guarantee that these efforts will always be successful, especially considering that MPW 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. Retirement Rollovers – No Obligation / 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 MPW recommends that a client roll over their retirement plan assets into an account to be managed by MPW, such a recommendation creates a conflict of interest if MPW will earn a new (or increase its current) advisory fee as a result of the rollover. If MPW 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), MPW 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 MPW, whether it is from an employer’s plan or an existing IRA. MPW’s Chief Compliance Officer, Steven Merrell, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Private/Alternative Investment Funds. MPW may provide investment advice regarding unaffiliated private investment funds. MPW, on a non-discretionary basis, may also recommend that certain qualified clients consider an investment in unaffiliated private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. MPW’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of MPW calculating its investment advisory fee. MPW’s fee shall be in addition to the fund’s fees. MPW’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, 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. The value(s) for all private investment funds owned by the client reflect either the initial purchase price and/or the most recent valuation provided by the fund sponsor. If the valuation reflects initial purchase price (and/or a value as of a previous date), please understand that the current value(s) (to the extent ascertainable) could be significantly more or less than original purchase price. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by MPW), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. . If implemented, MP shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Variable Annuity Sub-account Management. In the event that the client owns a variable annuity product, the client can engage MPW to provide investment management services relative to the investment subdivisions that comprise the variable annuity product. MPW’s investment selection shall be limited to those provided by the variable annuity sponsor. If so engaged, the MPW shall charge an ongoing advisory fee based upon the market value of the assets per its fee schedule at Item 5 below. Please Note: Neither MPW, nor any of its employees, offers to sell variable annuity products to its clients. Neither MPW, nor any of its employees, are registered as, or associated with, a broker-dealer or an insurance agency. In the event that the client owns a variable annuity product and/or seeks to purchase a variable annuity product, MPW shall refer the client to an unaffiliated broker- dealer/insurance agency to advise on same, and if agreed upon by the client, engage the unaffiliated broker-dealer/insurance agency to exchange a current, or purchase a new, variable annuity product. Neither MPW, nor any of its employees, shall receive any portion of the fees earned by the unaffiliated broker-dealer/insurance agency. MPW’s only compensation shall be limited to the management of the investment subdivisions that comprise the variable annuity product, should the client engage the MPW to do so. The client is under no obligation to engage MPW to provide such management services, nor is the client under any obligation to consider addressing variable annuity issues with the unaffiliated broker-dealer/insurance agency that may be recommended by the MPW.: Because MPW could earn an advisory fee on the variable annuity assets, a potential conflict of interest arises in the event that the MPW recommends that the client should address variable annuity issues with the unaffiliated broker-dealer/insurance agency. Please Further Note: Variable annuities are long-term investment products. Variable annuity product sponsors generally impose financial penalties for early withdrawals as set forth in the variable annuity documents. Thus, the client must consider such potential penalties prior to agreeing to exchange or purchase a variable annuity product. Fee Dispersion. MPW, in its discretion, may charge a lesser or higher investment advisory fee, charge a flat fee, waive appliable minimum asset or minimum fee levels, waive its fee entirely, or charge a fee on a different interval, based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin – -The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan –- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, MPW does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). MPW does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to MPW:
• by taking the loan rather than liquidating assets in the client’s account, MPW continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by MPW, MPW will receive an advisory fee on the invested amount; and,
• if MPW’s advisory fee is based upon the higher margined account value, MPW will earn a correspondingly higher advisory fee. This could provide MPW with a disincentive to encourage the client to discontinue the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Portfolio Activity. MPW has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, MPW 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, market conditions, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when MPW determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by MPW will be profitable or equal any specific performance level(s). Disclosure Statement. A copy of MPW’s written Brochure as set forth on Part 2A of Form ADV, along with MPW’s Relationship Summary (Form CRS), shall be provided to each client before, or contemporaneously with, the execution of the Investment Advisory Agreement. C. MPW shall provide investment advisory services specific to the needs of each client. Before providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, MPW shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on MPW’s services. D. MPW does not participate in a wrap fee program. E. As of March 21, 2024, MPW had $1,005,871,830 in assets under management, of which MPW managed $943,389,571 on a discretionary basis and $62,482,259 on a non- discretionary basis.