Founded in 2007, Pacific Wealth Strategies Group, Inc. ("PWSG" or "the Firm") is an investment adviser registered with the United States Securities and Exchange Commission ("SEC") and is a corporation formed under the laws of the State of California. Erin J. Neil is PWSG's President and Chief Compliance Officer ("CCO"), and Jeffery D. Brookshire is the Firm's Vice President, Corporate Secretary, and Treasurer, and each own 50% of the PWSG corporate entity in addition to their roles as investment advisors and officers of PWSG. All investment adviser representatives ("IARs") of PWSG are independent contractors of PWSG. As independent contractors they offer advisory services to their own clients with whom they have an investment advisory agreement. Please see Item 5 - Fees and Compensation below for a detailed description of PWSG's fees for its investment advisory services. Description of Investment Advisory Services PWSG provides its clients with a broad range of investment advisory services including investment management; comprehensive estate and financial planning and consulting; and pension consulting services. PWSG's objective is to provide proactive wealth management strategies to the Firm's clients, with a focus on risk mitigation, tax efficiency, investment management and family legacy planning. Each client's situation is different, and therefore requires a customized planning process designed for each client's unique set of circumstances. PWSG's services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one on-one basis through interviews and questionnaires to determine the client's investment objectives and suitability information. Integral to this process are in-depth, face-to-face meetings and concise written analyses. This process allows us to gain an intimate knowledge of each client's current situation, future time horizon, thoughts about the markets, family dynamics and deploy the appropriate strategies to address these issues. Our protocol addresses the following: (1) Investment Management, (2) Cash Management, (3) Risk Mitigation, (4) Integration of Tax Efficient Strategies, (5) Retirement Planning, (6) Liabilities, (7) Stock Options/Restricted Stock, (8) Business Succession Planning, (9) Document Review, (10) Wealth Distribution Planning, and (11) Charitable Gifting Strategies. The following are brief descriptions of PWSG's investment advisory service: Investment Management Services - PWSG provides advisory services in the form of Investment Management Services, which are also commonly referred to as asset management services. Investment Management Services involve providing clients with continuous and on-going supervision over their accounts. This means that PWSG will continuously monitor a client's account, make trades in client accounts when necessary, and manage the account in accordance with the client's stated investment objectives, risk tolerance, investment time horizon, tax considerations and other reasonable guidelines and restrictions imposed by the client. The investment advice provided is variable depending upon the desires, investment objectives, and other preferences of the client and in accordance with a written investment management agreement entered into between PWSG and the client. When providing Investment Management Services, PWSG typically constructs each client's account holdings using equities, fixed income products, exchange traded funds ("ETFs"), open and closed-end mutual funds, and cash instruments to build diversified portfolios. PWSG will also recommend the use of foreign issues, warrants, corporate debt securities (other than commercial paper), commercial paper, municipal securities, United States government securities (i.e., treasuries, T- bills, etc.), and options contracts on securities. Furthermore, while PWSG does not sell hedge funds, other types of private (i.e., non-registered) securities, interests in partnerships investing in real estate, and/or oil and gas interests, depending on the sophistication and suitability for PWSG clients, PWSG can recommend and/or provide advice and information regarding such security types. The Firm will modify its investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for additional information on PWSG's investment strategies and Item 5 - Fees and Compensation for a detailed description of PWSG's fees for Investment Management Services. Financial Planning/Consulting Services - PWSG provides comprehensive Financial Planning/Consulting Services. Financial planning/consulting can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to help guide the client to understand their overall financial situation, financial objectives, and assist the client in defining personal financial goals to be pursued with regards to some or all of the following areas: (1) Retirement Planning, (2) Estate Planning, (3) Insurance Needs Analysis including, but not limited to: Life Insurance, Disability Insurance, and Long-Term Care, (4) Tax Efficiency/Planning, (5) Real Estate Analysis, (6) Children's Education Planning and Funding, (7) Portfolio Reviews and Analysis, (8) Business Consulting, and (9) Divorce/Legal Separation Issues. PWSG generally conducts an initial consultation during which pertinent information about the client's financial circumstances and objectives is collected. PWSG reviews and analyzes the information provided by the client and then creates a written financial plan containing recommendations, which are designed with the intention of achieving the clients' stated financial goals and objectives. Financial plans are based on the client's financial situation at the time the plan is presented and are based on financial information disclosed by the client to PWSG. Clients are advised that certain assumptions will be made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. PWSG cannot offer any guarantees or promises that the client's financial goals and objectives will be met. As t he client's financial situation, goals, objectives, or needs change, the client must notify PWSG promptly. Financial Planning/Consulting Services are provided on a non-discretionary basis. Non-discretionary means PWSG provides recommendations to the client and the client makes the ultimate decision of whether to implement the recommendation, including the purchase or sale of investments. Clients are free at all times to accept or reject any or all recommendations made by PWSG and further retain the authority and discretion on whether or not to implement the written plan. If the client decides to follow the written plan, the client has the option, but is under no obligation, to request that PWSG implement the recommendations outlined in the written plan. Those clients who wish to engage PWSG for implementation of the written plan will be required to enter into a separate written agreement with PWSG for its Investment Management Services. In accordance with the separate agreement, PWSG will be paid separate and additional fees based on client account assets that are managed by PWSG (see Investment Management Services below). When providing financial planning and consulting services, PWSG advisory representatives will recommend, dependent on a client's needs, certain investment and/or insurance products (e.g., mutual funds, 529 plans, and personal insurance). Because certain advisory

representatives of PWSG are insurance agents and generally receive compensation when a PWSG client purchases such personal insurance products, providing those recommendations create a conflict between the interest of the PWSG advisory representative and the interests of the client. As stated above, clients have full discretion to accept or reject PWSG's recommendations at any time and are not required to implement any such personal insurance recommendations through PWSG, its representatives, or insurance agency with which the representatives are affiliated. Please see Item 10 for further information on these conflicts, including how PWSG addresses such conflicts. Please see Item 5 - Fees and Compensation for a detailed description of PWSG's fees for Financial Planning/Consultation Services. Pension Consulting Services - PWSG offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting services can include, but are not limited to:
• identifying investment objectives and restrictions
• providing guidance on various asset classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as record-keepers, custodians, administrators, and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. These services provide pension-consulting services to employee benefit plans (e.g., pension plans, profit sharing plans) and their fiduciaries based upon an analysis of the needs of the plan and in accordance with a written pension consulting agreement entered into between the plan and PWSG. In general, these services will be provided on a non-discretionary basis, but in some cases can be on a discretionary basis depending on the needs of the client. During the initial client consultation, PWSG will provide general advice to employers and their key executives on developing and structuring compensation, retirement, and benefit plans. Additionally, PWSG will provide general one on one guidance to plan participants and provide group education. For services provided on a non-discretionary basis, PWSG will perform the analysis and discuss recommendations with each client. Clients are free at all times to accept or reject any recommendations made by PWSG and also retain the authority and discretion on whether or not to implement any of PWSG's recommendations. If the client decides to implement some or all of PWSG's recommendations, the client has the option, but is under no obligation, to request that PWSG implement such recommendations. Those clients who wish to engage PWSG for implementation of PWSG's recommendations will be required to enter into a separate written agreement with PWSG for its Investment Management Services. In accordance with the separate agreement, PWSG will be paid separate and additional fees based on the client's account assets that are managed by PWSG. For client accounts that are regulated under the Employee Retirement Income Securities Act ("ERISA"), PWSG will provide Pension Consulting Services to the plan fiduciaries as described above. Typically, as described above, the client must make the ultimate decision as to whether or not to implement PWSG's recommendations and is free to seek independent advice about the appropriateness of any recommended services for the plan. Please see Item 5 - Fees and Compensation for a detailed description of PWSG's fees for Financial Planning Services. Financial Institution Consulting Services - PWSG provides investment consulting services to certain broker-dealer customers (“Brokerage Customers”) of Mutual Securities, Inc. (“Mutual Securities”), a broker- dealer, member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Brokerage Customers provide written consent to receive the firm’s consulting services. Brokerage Customers enter into a written advisory agreement with PWSG. Information Relating to PWSG's Services Information Received by Clients - At the onset of the client relationship, PWSG gathers information on each client's investment objectives, risk tolerance, time horizons, tax status, liquidity requirements, and any other information deemed necessary to assist PWSG in providing its investment advisory services ("Investment Guidelines"). PWSG does not assume responsibility for the accuracy of the information provided by the client and is not obligated to verify any information received from the client or from any of the client's other professionals (e.g., attorney, accountant, etc.). The client is responsible for informing PWSG of any changes to his/her investment objectives, individual needs, and/or restrictions. Prior to entering into an investment management agreement with PWSG, a client should carefully consider:
• that volatility from investing in the stock market can occur; and
• that over time the client's assets will fluctuate and at any time can be worth more or less than the amount invested In the event that a client notifies us of changes, we will review such changes and implement any necessary revisions to the client's portfolio. Clients can impose reasonable guidelines and/or restrictions on investing their assets. For example, a client can specify that the investment in a particular stock (or derivative of such stock) is prohibited or that specific investments should not exceed a set percentage of the value of the portfolio. All such guidelines and restrictions must be communicated to PWSG in writing. There could be times, however, when certain restrictions are placed by a client, which prevents us from accepting or continuing to manage the account. PWSG reserves the right to not accept and/or terminate management of a client's account if it feels that the client-imposed restrictions would limit or prevent it from carrying out its investment strategies. Client Agreements and Disclosures - Each client is required to enter into a written agreement with a PWSG IAR setting forth the terms and conditions under which the firm shall render its services (the "Agreement"). In accordance with applicable laws and regulations, the PWSG IAR will provide a copy of the disclosure brochure (ADV Part 2A), brochure supplement (ADV Part 2B), Form CRS (ADV Part 3), and Privacy Policy to each client prior to or contemporaneously with the execution of the Agreement. The Agreement between the PWSG IAR and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. PWSG's annual fee shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the client, as appropriate, in a timely manner. Neither PWSG, the IAR, nor the client can assign the Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of PWSG shall not be considered an assignment. PWSG will provide investment advisory services but will not provide custodial or other administrative services. At no time will PWSG or the IAR accept or maintain custody of a client's funds or securities. The client is responsible for all custodial and securities execution fees charged by the custodian and executing broker- dealer, unless otherwise negotiated. Wrap Program PWSG does not sponsor or manage any wrap programs at this time. Assets Under Management ("AUM') As of December 31, 2022, PWSG managed $115,701,915.05 in discretionary assets and $15,557,192.02 in non-discretionary assets for a total of $131,259,107.07 in assets under management.