A. Wright Associates operates an independent Registered Investment Adviser. That means we are a fee-only financial planning and investment advisory firm. We offer one service that we call Wealth Management. It is intended that all clients receive our complete service. We give continuous planning and investment advice to clients and make investments primarily through mutual funds, exchange traded funds, and individual stocks based on each client’s individual needs. The business was started in its present form in 2002. As of 1/1/2024, the principal and 80% owner of the firm is Adam K. Wright, CFA, CFP® and Kyle Beckhusen, CFP®, CLU® is 20% owner. B. Wright Associates offers holistic private wealth management and investment advisory services to high-net- worth individuals, corporations, ERISA plans and other institutional clients. We focus on clients that are at least age 50 with at least $1,000,000 of invested assets and ERISA plans with at least $5,000,000 of assets. Our private client focus is on retirement planning to help clients have a plan for their income, taxes, risks, and investments and align it with their goals. We take clients through our financial planning process each year. Clients that work with Wright Associates will be asked to sign a Wealth Management Agreement. Financial planning services generally revolve around helping clients save money, invest better, pay less in taxes, and protect what is important. For clients, a financial plan incorporates pertinent aspects of their personal financial situation such as defining goals and objectives, providing an analysis of current financial positioning, planning for retirement, asset planning, investment management, insurance planning, and general tax and estate planning. The plan helps clients stay on track to reach their goals. Investment management is designed to help clients interact with the capital markets. It primarily deals with portfolio construction, asset allocation, rebalancing, performance reporting and security selection. Wright Associates creates portfolios consisting primarily of mutual funds, exchange traded funds, and individual stocks. Under certain circumstances, Wright Associates may also include various other investments in client portfolios, including, but not limited to, any combination of the following: individual equities, corporate debt securities, ETFs, commercial paper, certificates of deposit, municipal securities, United States government securities, and other alternative investments. Wright Associates also offers an investment program through “Institutional Intelligent Portfolios” (“IIP”), software provided by Charles Schwab & Co. Clients are invested in a specific model portfolio consisting solely of exchange traded funds and a cash allocation. Portfolios are selected based on a risk-tolerance questionnaire as well as interactions and interviews with representatives of Wright Associates. The accounts are held in a brokerage account opened by the client at Charles Schwab & Co. We do not pay fees for use of the platform. We, and not Schwab, are the client’s investment adviser and primary point of contact with respect to the portfolio and the program. We have contracted with Charles Schwab & Co to provide us with the platform, which consists of technology and related trading and account management services for the platform. The platform enables us to automate certain parts of the investment management process. Wright Associates may use money market mutual funds to “sweep” unused cash balances until they can be appropriately invested. Clients maintain ownership of all securities purchased in their accounts. C. We tailor our advisory services to the unique needs of individual clients. Each client receives an Investment Policy Statement. An investment policy typically includes items such as client background, objectives, return requirements, risk tolerances, time horizons, liquidity needs, taxes and other unique circumstances, including a strategic asset allocation. Wright Associates manages advisory accounts on a discretionary basis; therefore, clients may only impose reasonable restrictions on investing activities. However, we will take certain strong opinions under consideration and may incorporate them in a client’s asset allocation. Wright Associates attempts, at a minimum, to meet with clients to discuss and review their investment goals once per year. For the IIP program, clients may instruct Wright Associates to exclude up to three Funds from their portfolio. D. Wright Associates does not participate in wrap fee programs. See Item 5 for details on our fees and compensation. E. As of December 31, 2023, Wright Associates managed client assets in the amount of $305,555,488.10 on a discretionary basis. We have 151 client relationships as of December 31, 2023. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent specifically requested and engaged to provide such services, Wright will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. Please Note: Wright does not serve as a law firm, CPA firm, or insurance agency, and no portion of our services should be construed as same. Accordingly, Wright does not prepare legal documents or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.), including Wright for tax preparation services-see below. The client is under no obligation to engage the services of any such recommended professional, including Wright for

tax preparation services. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Wright and/or its representatives. Please Also 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 licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not Wright, shall be responsible for the quality and competency of the services provided. Please Note: Retirement Rollovers-Potential for 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 Wright recommends that a client roll over their retirement plan assets into an account to be managed by Wright, such a recommendation creates a conflict of interest if Wright will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, Wright serves as a fiduciary under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by Wright. Wright’s Chief Compliance Officer, Adam K. Wright, 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. Custodian Charges-Additional Fees: As discussed below at Item 12 below, when requested to recommend a broker- dealer/custodian for client accounts, Wright generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge transaction fees for effecting securities transactions. In addition to Wright’s investment advisory fee referenced in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds exchange traded funds, individual equity and fixed income securities, etc.) ANY QUESTIONS: Wright’s Chief Compliance Officer, Adam K. Wright, remains available to address any questions that a client or prospective client may have regarding the above. Please Note-Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by Wright independent of engaging Wright as an investment adviser. However, if a prospective client determines to do so, he/she will not receive Wright’s initial and ongoing investment advisory services. Please Note-Use of DFA Mutual Funds: Wright utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate Wright’s services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Please Also Note: In addition to Wright’s investment advisory fee described below, and transaction and/or custodial fees discussed below, 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). ANY QUESTIONS: Wright’s Chief Compliance Officer, Adam K. Wright, remains available to address any questions that a client or prospective client may have regarding the above. Portfolio Activity. Wright has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Wright 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, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Wright 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 Wright will be profitable or equal any specific performance level(s). Client Obligations. In performing our services, Wright shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Wright if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Wright) will be profitable or equal any specific performance level(s).