GVCM is a corporation organized under Wisconsin state law. Dina Fliss founded the Waukesha County based investment adviser in 2011. The firm is a wholly- owned subsidiary of Global View Capital Partners, LTD. (“GVCP”), which is owned by Dina Fliss and Dean Fliss. GVCM is a SEC registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. As of December 31, 2022, GVCM had $591,171,599 of discretionary assets under management. GVCM does not perform accounting, legal, tax, mortgage or other financial services, nor does it have direct or indirect custody of client assets. Investment Advisory Representatives (“IAR”) of GVCM may have properly disclosed outside business activities where they act in the capacity of an accountant, attorney, insurance agent, registered representative or mortgage broker. This may present a conflict of interest. The investment advisory services of GVCM are described in detail below. Investment Advisory Services GVCM serves as an investment adviser to clients under individual investment management agreements. GVCM requires clients to complete a suitability questionnaire as part of its investment process. This questionnaire establishes the client’s relative risk profile (conservative, moderate, balanced, growth or aggressive) and investment time horizon which guides the selection of strategies for the client’s account. Additionally, clients may impose restrictions that may affect the ability of GVCM to manage the client’s assets. There are no differences between GVCM’s management of wrap-fee accounts and management of other accounts, other than the variety of the strategies available and the underlying product’s or platform’s fee structure. GVCM receives a portion of the wrap fee for its services. Sub-Advisor to Flexible Plan Investments, Ltd. We provide investment advisory services as a sub-advisor to Flexible Plan Investments, Ltd. (“FPI”). FPI is a federally-registered investment adviser which sponsors the Strategic Solutions Program (the “Program”). Model portfolios are designed to meet various investment objectives. These model portfolios are actively managed and are offered through the Program. GVCM manages models to specific objectives rather than to the individual needs of clients. The IARs that monitor the client accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Restrictions on investing may preclude an IAR from choosing our models for their clients’ portfolios. Sponsor of the Personalized Managed Account Program GVCM sponsors the Personalized Managed Account Program (the “Program”), which includes Separately Managed Accounts (SMAs), Exchange Traded Funds (ETFs), Mutual Funds and discretionary asset management advised by GVCM and a selection of unrelated third-party asset managers and sub-advisors. The program is comprised of two different pricing schedules: Asset Based and Transaction Based. It should be noted that differences exist in both the product solutions available and the fees and expenses charged to the client dependent on the pricing schedule and custodian selected by the IAR. Strategies in the Program are managed to specific objectives rather than to the individual needs of clients. The IARs that monitor the accounts and utilize our services and that of the unrelated third-party asset managers match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Client restrictions on investing may preclude an IAR from choosing any of the Program models for their clients’ portfolios. In the event that account values fall below the minimum account value needed to effectively execute trades in client accounts, the account may: 1) not trade until additional funds are added by the client; or 2) GVCM may choose to discontinue its advisory agreement with the client. IARs of GVCM who are also associates of Global View Capital Advisors LLC. (“GVCA”) may recommend the Program to suitable clients and act as the client’s Financial Advisor for the Program. GVCA is an affiliated company of GVCM. GVCA is a marketing company that provides distribution services designed by GVCM and other third party asset managers. More complete information about the Program may be found in the GVCM Personalized

Managed Account Program Brochure (“Program Brochure”) which is available upon request. Low Cost Program GVCM will offer a low cost program that will include commission free ETF’s and MF’s. No strategies will be available, and the client has the option to build your own option from screened ETF’s. There is no account maximum for this service. Nationwide Advisory Solutions Monument Advisor Variable Annuity The strategies on the Nationwide Advisory Solutions Monument Advisor Variable Annuity platform are managed to specific objectives rather than to the individual needs of clients. The IARs that monitor the client accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. Employer-Sponsored Retirement Plans Schwab Personal Choice Retirement Account A PCRA is a self-directed brokerage account that resides within an employer- sponsored retirement plan. In addition to the choices typically offered by retirement plans, PCRA allows the participant to invest in a much wider range of investments. The strategies offered as part of the Schwab PCRAs are managed to specific objectives rather than to the individual needs of participants. The IARs that monitor the participant accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. ETF’s and mutual funds are available and Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. American Trust/First Mercantile Trust GVCM is a sub-advisor to American Trust/First Mercantile Trust. The strategies offered in the American Trust/First Mercantile Trust employer- sponsored retirement plans are managed to specific objectives rather than to the individual needs of participants. Participants in the employer-sponsored retirement plan determine their risk tolerance and then may select and manage their own investments or rely upon the managed portfolio options available. Heartland Retirement Plan Services GVCM is a sub-advisor to Heartland Retirement Plan Services in employer- sponsored retirement plans administrated by Heartland Retirement Plan Services. The strategies offered in the Heartland Plan Services employer- sponsored retirement plans are managed to specific objectives rather than to the individual needs of participants. Participants in the employer-sponsored retirement plan determine their risk tolerance and then may select and manage their own investments or rely upon the managed portfolio options available. Sub-Advisor to Harness Investment Management GVCM is a sub-advisor to Harness Investment Management, a Canadian asset manager. GVCM manages available strategies to specific objectives rather than to the individual needs of clients. These strategies are available only in Canada. Solicitors to Unaffiliated Third-Party Investment Advisers GVCM and its IARs may act as a solicitor and refer clients to third-party investment advisers that offer asset management services to clients. Written Acknowledgement of Fiduciary Status 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 and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. 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 interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.