Wela Strategies, Inc. (hereinafter referred to as “Wela”) was created in 2008. The principal owners of Wela are Michael Reiner & Associates, LP, Wesley Moss, Mitchell Reiner, and Matthew Reiner. Please see Brochure Supplement, Exhibit A, for more information on these principal owners and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. Wela provides asset management services based on model portfolios Wela has designed. As of December 31, 2022, Wela has $202,286,113 of discretionary assets under management and $876,630 of assets under advisement where Wela acts as a model provider to other Independent Advisors (overlay managers, other financial/investment advisers). Wela’s management services are designed to accommodate both smaller portfolios (generally those under $500,000) as well as larger portfolios. This allows us to serve you over time as your needs change. SERVICE OFFERED Model Management Wela’s model portfolios are not based on the individual needs of any client. We manage various model portfolios, which are then applied to each client’s portfolio of investment assets as appropriate for that client. Most of Wela’s managed model portfolios are based on a mix of growth assets and income producing assets. The majority of our models are referred to or described as “Own Your Age” (“OYA”) model portfolios. All these models are comprised primarily of exchange traded funds (ETFs). Advice will generally be limited to the holdings in Wela’s model portfolios. Wela also operates two non-OYA models:
• Wela All Growth – does not include allocation to income strategies.
• Wela Agg Yield – 100% income strategies and is more aggressive than a typical fixed income portfolio. Includes closed-end mutual funds in its allocation. These funds are not ETFs by the true definition but are close investment opportunities. Many of these closed-end mutual funds use leverage and therefore accentuate returns in both positive and negative market environments. Models are designed around owning your age in “income” investments. However, if you have a financial situation or risk tolerance that indicates an age-based allocation is not suitable, we will suggest another model portfolio more suitable to your needs. Wela has three models specifically designed for accounts with less than $25,000 in investable assets. The three models attempt to conduct fewer transactions and strive to reduce the costs for smaller investable dollar figures. The models mirror Wela’s model account allocations for accounts with more than $25,000 in investable assets for an 80/20, 50/50 and 20/80 mix of equity and fixed income. Accounts under $10,000 will be invested in fewer positions until the Account’s investable value 5 of 19 reaches at least $10,000, at which point we may be able to consider additional holdings. Each portfolio will generally maintain 3-7% cash as part of its asset allocation. Wela offers the following models for accounts with more than $25,000 in investable assets:
• OYA 20 = 80/20 equity to fixed income mix
• OYA 30 = 70/30 equity to fixed income mix
• OYA 40 = 60/40 equity to fixed income mix
• OYA 50 = 50/50 equity to fixed income mix
• OYA 60 = 40/60 equity to fixed income mix
• OYA 70 = 30/70 equity to fixed income mix
• Conservative Yield = 20/80 equity to fixed income mix
• All Growth Portfolio = 100% equity portfolio
• Agg Yield Portfolio = comprised of a combination of ETFs and closed-end funds. Additionally, within the model there is the ability to provide a more customized allocation by selecting alternative sleeves within a model, offering more or less diversification depending on the needs of the client and the focus of the portfolio. Once we have agreed upon one or more models to employ in your investment portfolio, we will manage your portfolio on a discretionary basis. This means that we will make changes to the holdings in the model(s) selected as deemed appropriate. We will determine the securities to be purchased and sold in your account and will alter the securities holdings from time to time, without prior consultation with you. If we believe your investment portfolio would benefit from having a different make-up of models over time, we will discuss that with you before implementing such a change. Please note that transactions in your account, such as account reallocations and rebalancing, may trigger a taxable event, with the exception of certain IRA accounts, 403(b) accounts and other qualified retirement accounts. Your account will also pay any applicable transaction fees assessed by the account’s custodian. These fees do not flow through to Wela. When considering mutual funds for inclusion in a model portfolio, we generally select the share class with the lowest expense ratio available (usually the Institutional share class). Purchases and sales of such share classes often means you will pay transaction fees. We will monitor the models and your account. If an asset allocation deviates by more than 20% in any direction (positively or negatively) we will reallocate the account back to the original allocation twice a year. Re-balancing and re-allocation will typically occur twice per year and typically will be around February 25 and August 25 of each year. Adjustments to the model accounts will be applied to client accounts without consideration to the taxable consequences to any client. If you establish your account within 25 days of February 25 or August 25, your account will generally not be allocated to a model portfolio until February 25 or August 25, whichever date first after the funding of the account. The purpose of waiting is to avoid additional transactions as a result of potential near-term adjustments to the allocation of the model. This lowers your overall cost and also minimizes the short-term gain impact that trading in a short period time could cause. 6 of 19 The investment recommendations and advice offered by Wela are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. Please inform us promptly with respect to any changes in your financial situation or investment goals and objectives. Failure to notify us of any such changes could result in investment recommendations not meeting your needs. A relationship with Wela is initiated in one of the following ways:  Direct Relationship. Wela will work with you to help define your investment goals and objective, tolerance for risk and other factors relevant to investment planning. The first meeting between you and your Wela Advisory Representative is introductory in nature and provides an opportunity to determine whether our services are suitable for you. We will ask you a series of fact- finding questions and complete data gathering information. We help identify your risk tolerance, return expectations, financial goals, investment objectives, risk profile, and investment time horizon. The discussion and information gathered will assist us in recommending one or more model portfolio options that appear suitable to your financial situation. You will be asked probing questions about your financial history, goals, objectives, and concerns, as well as details about you, your retirement goals, cash flow needs, standard of living, special needs such as education or elder care, etc.  Model Portfolio Provider to Other Investment Advisors Wela

also acts as a model provider to various investment management programs. We provide our model allocations to other Independent Advisors that have elected to utilize Wela’s model portfolios for their clients. Under such an arrangement, we do not directly engage in the transactions or execute any transactions in an individual client’s account. Instead, we only provide model portfolios to the Independent Advisor. We will not have a relationship with the client investing into a Wela model portfolio. However, a client may contact us with questions about the model portfolio. These relationships are typically offered through a distribution platform of some type. Currently, Wela’s models are offered through the Sawtooth Asset Management, Inc. platform.  401(k) Advisory and Retirement Plan Consulting Services We offer retirement consulting services to employee benefit plans and their fiduciaries. The services are designed to assist the plan sponsor (the “Company”) in meeting its management and fiduciary obligations to the plan under ERISA. As a 3(38) adviser, we offer the following services: i. Provide ongoing and continual discretionary investment management with respect to the included assets as defined above in accordance with the Plan’s investment policies and objectives. ii. Select a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. The Company retains the sole responsibility for all other compliance with ERISA section 404(c). iii. Develop and execute an Investment Policy Statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. 7 of 19 iv. Monitor investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformity to the guidelines set forth in the IPS and determine whether to maintain or remove and replace investment options. v. Meet with Company at least annually to discuss the reports and the investment decisions made by Wela to assist the Company with their monitoring role, and more frequently at the discretion and agreement of Wela and the Company. vi. Select a Qualified Default Investment Alternative (“QDIA”) for participants whom no investment selection has been made if Company determines the Plan should have a QDIA. Company will decide upon the type of investment that will serve as a QDIA (e.g., target date fund, balanced fund or managed account). Once Company has made that determination, we will select the investment to serve as the QDIA. The Company retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). vii. We will provide investment advice to participants. In addition to the fiduciary services provided above, Wela offers certain non-fiduciary services for employee benefit plans and their fiduciaries. In those instances, we offer the following services: i. Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Company understands that our assistance in participant investment education shall be consistent with and within the scope of (d) (i.e., the definition of investment education) of Department of Labor Interpretive Bulletin 96-1. ii. Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. iii. Offer services to plan participants regarding assets outside the plan. These services will be governed by agreements directly with the participant and considered outside the scope of this Agreement. It is understood and will be communicated to the participant that the Company does not specifically endorse these services. Costs of these services vary from those charged inside the Plan and will be based on the scope and complexity of each participant’s situation. We will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. We will also provide additional disclosures about our services and fees, where required by ERISA. We will not be required to verify the accuracy or consistency of any information received from the Company. Regardless of the type of relationship you have with Wela, you will have access to an Advisory Representative at any time and may request a meeting at any time to discuss your portfolio or changes to your financial situation. Because our services are built around managing model portfolios and then 8 of 19 applying those models to your portfolio of investment assets, if you have specific investment restrictions or limitations that do not fit into our model portfolios, our services are likely not suitable for you. However, the allocation to one or more Wela models may change over time as your financial circumstances change. Your Wela Advisory Representative is here to help you with those adjustments. IRA Rollover Considerations As part of our consulting and advisory services, we offer recommendations and advice concerning your employer retirement plan or other qualified retirement account. We may recommend that you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"), which we can then manage for you. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement investors. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between Wela and Client. General Information Wela will deliver required disclosures, client reports, newsletters, and other communications electronically and/or by email, unless the client opts out and requests, we deliver all communications, reports, and required disclosures in hard copy. Delivery will then be executed by the U.S. postal system. The Investment Advisory Agreement or other notification obtains the client’s authorization and agreement for electronic delivery. The client may revoke electronic delivery authorization at any time upon request.