A. USA Financial Securities is an investment adviser registered with the United States Securities and Exchange Commission ("SEC"). Our firm is also registered as a broker-dealer. USA Financial Securities was founded in 1998 and is a wholly owned subsidiary of USA Financial Corporation. Michael Walters and Brent Enders own USA Financial. Detailed information regarding our owners, directors, and officers can be found by visiting: www.adviserinfo.sec.gov. Our firm utilizes investment adviser representatives. Our representatives frequently work with individuals who are either planning for retirement or are currently retired, however, neither our firm nor our representatives specialize in any specific area or type of investment advice. B. USA Financial Securities offers three categories of advisory services: financial planning, advisory account management, and representative guided investment strategies that offer limited distribution. Our representatives may charge a comprehensive financial planning fee and also receive an asset-based fee for any dollars managed on behalf of a client. In rare cases, upon firm approval, representatives may offer strategies for client investment. Financial planning is a comprehensive engagement process whereby the representative analyzes a client’s entire investment portfolio in conjunction with their objectives, risk tolerance, and other relevant factors to determine an investment plan. Advisory account management may be a part of the financial-planning process, but clients can also have an advisory account without engaging in the financial planning process and vice versa. Advisory accounts are managed either on a transaction-based pricing method or an asset-based pricing method. Both methods are discussed in greater detail, below. Financial Planning Services USA Financial Securities' investment adviser representatives provide financial planning services. As mentioned above, financial planners use a comprehensive planning method. They help clients set and achieve long-term financial goals through investments, tax planning, asset allocation reviews, risk management analyses, retirement planning, and estate planning. USA Financial Securities collects important financial information from each client, and uses that information, along with any additional information communicated to the representative, to develop a plan designed to meet each client’s unique goals and objectives. Each client is advised that it remains the client’s responsibility to promptly notify USA Financial Securities if there is ever a change in the client’s financial situation or investment objectives for the purpose of reviewing and possibly revising USA Financial Securities’ previous recommendations or services. Additionally, as part of offering a holistic approach to advising clients, representatives may recommend the services of other professionals for certain non-investment topics, such as attorneys or accountants. In these cases, the client is under no obligation to engage the services of any recommended professionals. The client retains all discretion over all such decisions and is free to accept or reject any recommendation. If a client has engaged with such a professional, and a dispute arises thereafter, the client agrees to seek recourse exclusively from and against the engaged professional. Financial planning fees may be charged in addition to commissions or asset under management fees. Clients are not obligated to follow USA Financial Securities' recommendations or to pursue the recommendations through USA Financial Securities. Clients have control over investment decisions - clients may place restrictions on investing in certain types of securities or engaging in various investment activities. It is important that clients communicate their investment goals and objectives, including any restrictions, to the investment adviser representative. An open and honest dialogue between each client and their financial professional will help facilitate a successful working relationship. Representatives may provide ongoing advice for accounts that, for various reasons, need to be maintained at an external and unaffiliated firm. In these cases, the client understands that representatives may be limited in the advice they are able to provide and are dependent upon information provided by the client. Investment options may be limited to the selections made available within the external and unaffiliated account. FS-IADB-11 Page 5 of 19 Rev. 04.15.24 Advisory Account Management USA Financial Securities and its investment adviser representatives can manage advisory accounts in two ways (essentially, the category of management is dictated by the way the fee is charged): transaction-based pricing or asset-based pricing. Clients pay a custodial and administrative fee ("C&A Fee") under both pricing structures. However, the C&A Fee is less on a transaction based pricing platform for the reasons described below. In addition to the C&A Fee, USA Financial Securities' advisers also charge a management fee. Under no circumstances will the management fee exceed 2.7%. USA Financial Securities receives a portion of the fees. Transaction-Based Pricing Structure (Non-Wrap) USA Financial Securities' transaction-based pricing platform provides clients with investment advisory execution, clearing, and custodial services, through our custodian, Pershing. As the name suggests, under the transaction-based pricing structure, you pay a lower C&A Fee because you pay for transactions individually as they occur in addition to the C&A Fee. If clients do not engage in frequent transactions,

then transaction-based pricing structure is generally more advantageous because the C&A Fee is less, and clients only pay for transactions when and if they occur. Asset-Based Pricing Structure (Wrap) USA Financial Securities operates asset-based pricing programs at Pershing, a wrap-fee program. A wrap-fee program bundles various services together and charges an all-inclusive fee, named a "wrap fee" because it wraps around all services rather than charging a separate fee for each service. Under an asset-based pricing structure, clients pay a higher C&A Fee because the transaction costs are included in the C&A Fee - the C&A Fee does not increase regardless of how many transactions each client makes. If clients engage in a high number of transactions in their account, the asset-based pricing structure is more ideal because they will generally pay less as transaction costs can add up over time. Because wrap-fee accounts are charged a monthly fee, these accounts are typically best suited for investors who anticipate engaging in moderate to high levels of investment activity within their account. Infrequent trading is not supported by the fee structure, and clients with very little trading activity or account management are better served in a traditional commission based brokerage account or the transaction-based pricing platform. For more information regarding our wrap-fee programs, please see our separate, wrap-fee brochure, Appendix 1 - Wrap Fee Brochure. Third Party Money Management Representatives may provide access to the services and investment advisory service from third party, unaffiliated investment advisory firms. Representatives serve as the portfolio manager on these accounts and make strategic decisions and recommendations as to the strategies that would most appropriately align with the client’s stated investment objectives. In these situations, the third party money manager shall have the day-to-day responsibility for the active discretionary management of the assets allocated to these strategies. USA Financial Securities’ representatives shall evaluate the appropriateness of a particular strategy based upon a number of factors including investment objectives, management style, performance, reputation, financial strength, pricing and research. In some scenarios, the third party money manager recommended by a representative permits investment in various strategies offered by independent and unaffiliated firms, and in some cases the third party offers a platform for individualized advice and recommendations from the representative. In these situations, clients should obtain the Form ADV Part 2A Brochure from the third party money management firm through which their assets will be invested. FS-IADB-11 Page 6 of 19 Rev. 04.15.24 Representative Guided Investment Strategies USA Financial Securities serves as a sub-adviser on the USA Financial Exchange platform (further discussed in Section 10: Other Industry Affiliations). USA Financial Securities affords the opportunity to investment adviser representatives to offer customized financial strategies to clients, referred to as “AIM” (Adviser as Investment Manager) Strategies. AIM Strategies allow representatives to offer unique investment options to clients that reflect the representative’s investment philosophy. These strategies are exclusively distributed through USA Financial Exchange, an affiliate of USA Financial Securities. Clients that choose to invest in an AIM Strategy will require an account with USA Financial Exchange, which in turn will benefit USA Financial Securities as an affiliate through common ownership. Clients are able to request reasonable restrictions on investing in certain types of securities. AIM Strategies have varying fee structures, determined by the representative. Recommendations from representatives to invest in these customized strategies present a conflict of interest, as the representative serves as both the representative making the recommendation to the AIM Strategy and the strategy manager as well. Meaning, the representative will receive compensation twice: once to give investment advice on the overall portfolio and again will receive the strategy fee paid by the AIM Strategy that was recommended. This dual fee structure may incentivize representatives to prioritize the promotion of their own strategies over other alternative options. C. USA Financial Securities provides investment advisory services that are specific to the needs of each client. Before making any investment recommendations, representatives will ascertain each client’s investment objectives. Thereafter, USA Financial Securities will allocate and/or recommend the client allocate investment assets consistent with the client’s investment objectives. The client may impose reasonable restrictions, in writing, on USA Financial Securities’ services. D. USA Financial Securities offers both wrap and non-wrap advisory account services to clients. Non-wrap services are assessed charges separately for each service, on an unbundled basis. These services include but are not limited to: trade costs, investment advisory fees, and custody fees. USA Financial Securities also offers wrap fee advisory accounts to clients. In a wrap fee account, the client will pay a single fee for the bundled services that would otherwise be assessed separately. In a wrap fee account, USA Financial Securities does receive a portion of the fee for compensation for its services. E. USA Financial Securities supports discretionary and non-discretionary accounts. As of December 31, 2023, our firm was managing approximately $268,691,644. Approximately $173,955,595 was managed on a discretionary basis. [Balance of page intentionally left blank.] FS-IADB-11 Page 7 of 19 Rev. 04.15.24