THE FIRM SB Advisory, LLC (the “Advisor” or the “Firm”) is an investment advisory firm registered with the Securities & Exchange Commission that commenced providing investment advisory services and investment advice in 2009. The Firm is principally owned by IFS Group. IFS Group is the parent company of all SB entities (San Blas Securities, SB Advisory). Alexys McKenzie is the Executive officer of IFS Group. As of March 31, 2024, the Firm manages assets totaling $285,851,527 of which $21,613,914 is managed on a discretionary basis and $264,237,613 is managed on a non-discretionary basis. The following paragraphs provide a description of the programs and services offered by SB Advisory, LLC. ADVISORY MANAGEMENT Alex McKenzie – President & CEO Alex McKenzie, Started in the financial services industry as a stock broker in 1994 advising business owners both domestically and abroad. Experience since then has been starting three Broker/Dealers and three RIAs. Previously he served as treasurer of the Atlanta Workforce Development Authority (AWDA) and a member of the Young Presidents’ Organization. McKenzie is knowledgeable in Retail Wealth Management/ Capital Markets. He holds the Series 7, 24, 63, 66, 79 and 99 licenses. Danny Padilla –CCO Prior to San Blas Securities, Padilla served as Managing Director and Head of Institutional Equity Trading for IFS Securities. He also has held a series of senior roles at WBENC/MWBE firm Divine Capital and Magna Securities. Padilla holds Series 7,24,55 and 62 licenses. RBC. Accounts managed at RBC may be invested in a wide range of securities including mutual funds, exchange traded funds, individual equities, fixed income securities, and many more. There is no minimum investment amount for these advisory accounts. Under this program, the Advisor will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. The information may be collected by the Advisor through investor profiles, account forms completed by the Client, and through communication with the Client. On the basis of this information, the Advisor will tailor the advisory services to the needs of the Client. The Advisorwill utilize various securities to implement the customized portfolio. Client reserves the right to impose restrictions or guidelines on the management of the Client's assets, including any limitations on the purchase or sale of securities or types of securities. The Advisor can manage the assets on a discretionary basis, thereby allowing the Advisor to determine what securities and investments are to be bought or sold, the amount of transactions, and the timing of transactions, or on a non-discretionary basis where the Advisor will provide recommendations to the Client and the Client has ultimate authority for the approval of such transactions. All accounts are required to be at RBC. Clients will receive account statements from RBC no less than quarterly concerning all transactions, balances and portfolio holdings within their account. Advisor Choice Program The Advisor Choice Program offers Clients the opportunity to utilize various money managers in managing all or a portion of their assets. The managers are selected by the Advisor, unless the Advisor and Client have mutually agreed otherwise. Client assets will be custodied at a firm of the money manager’ choosing, unless the Advisor has the authority to select such custodian. A minimum investment may be required by the money manager. Under this program, the Advisor will obtain pertinent information concerning the Client such as financial condition, investment objectives, tax status, and general risk characteristics. The information may be collected by the Advisor through investor profiles, account forms completed by the Client, and through communication with the Client. The Advisor will select money managers whose investment philosophy, style, and discipline are commiserate with information obtained from the Client to meet the needs of the Client. Individual portfolios are determined independent of the Client’s financial situation by the money manager. Should the Client desire to limit the level and ability to select money managers by Advisor, the mutual agreement of the Client and Advisor is required. Client reserves the right to impose restrictions or guidelines on the management of the Client's assets, including any limitations on the purchase or sale of securities or types of securities subject to the terms and conditions imposed by the money manager. For more information on the ability of a Client to impose restrictions, refer to the ADV Part 2A or other information provided by the money manager. Clients will receive account statements no less than quarterly from the money manager managing the Client’s assets. AssetMark Programs These programs offer clients access to AssetMark’s mutual fund and exchange-traded fund (“ETF”) programs as well as AssetMark’s privately managed accounts and unified managed accounts. In the mutual fund and ETF asset allocation programs, AssetMark offers client’s asset allocations composed by a group of independent investment strategists (“Portfolio Strategists”), with the different model allocations designed to satisfy a gradient of risk/return objectives. The Portfolio Strategists have no direct relationship with SB or the client, make no analysis of and do not consider the clients’ individual circumstances or objectives, and do not tailor the model asset allocation to any specific client’s needs, circumstances or objectives, but only to the stated risk/return objectives. The investment advisor representative assists the client in selecting the risk/return objective and Portfolio Strategist that best suit the client’s objectives. The client then specifically directs the account to be invested in accordance with the chosen asset allocation. When the client selects the asset allocation, the client further directs that the account be automatically adjusted to reflect any adjustment in the asset allocation by the selected Portfolio Strategist. This client authorization results in the purchase and sale of certain mutual funds or ETFs without further authorization by the client or any other party when the Portfolio Strategist changes the composition of the selected model asset allocation. SB Advisory and the investment advisor representative have no authority to cause any purchase or sale of securities in any client account or change the selected model asset allocation or to direct the account to be invested in any manner other than as previously authorized by the client. SB Advisory and the investment advisor representative do not take any discretionary authority over client accounts. Additionally, AssetMark may offer, through investment advisor representatives, Privately Managed Accounts and Unified Managed Accounts. Under these accounts, the investment advisor representative will introduce clients to, and advise on the selection of, independent investment managers who provide discretionary management of individual portfolios using a variety of different securities analysis methods, sources of information and investment strategies. Clients receive separate disclosure from such investment managers regarding any such investment manager’s advisory services. Brinker Capital Brinker furnishes or arranges for investment management and supervisory services to meet the individual needs of its clients. The client's investment objectives will be determined based on answers to an investment strategy questionnaire as discussed in more detail in Item 8 of this Brochure. These programs are more fully described in the

firm’s Disclosure Brochure Brinker offers a variety of services to its clients in order to meet those needs. These services include highly customized separate managed account manager-of- manager services. Brinker may also recommend privately placed or publicly traded pooled investment vehicles (such as hedge funds, mutual funds or exchange traded funds (“ETFs”), etc.) in lieu of allocating assets separately to an investment manager. Brinker may provide discretionary management, in which case Brinker can hire and fire investment managers and select investment vehicles, in its sole discretion. Brinker has been retained as a sub-adviser on various third-party platforms. For these programs, Brinker provides asset allocation and manager selection services, and in some cases, may provide other operational related services. Brinker also offers certain of its investment strategies and programs on platforms of unaffiliated managers or sponsors. Brinker’s services are generally provided to the client pursuant to an investment advisory agreement between Brinker and the client. However, Brinker may also enter into a tri-party investment advisory agreement with the client and another investment advisory firm that assumes fiduciary responsibility for recommending and/or selecting the investment strategy for the client, including, in the case of an account invested in the Core Asset Manager program, a suitable asset allocation and selection of investment managers and other investments. EQIS CAPTIAL MANAGEMENT, Inc. EQIS Capital Management, Inc is a SEC registered investment adviser that sponsors wrap fee programs. EQIS offers separately managed accounts. The account minimum to invest is $25,000. EQIS has various model portfolios in asset classes such as stocks, American Depository Receipts (ADR’s), ETFs, target term trusts, US Government bonds, money market funds and mutual funds. The portfolios are actively managed on a discretionary basis. FLEXIBLE PLAN INVESTMENTS, Ltd. -Referral Agreement Flexible Plan Investments is a federally registered independent investment adviser that manages individual investment accounts. As of 12.31.2017 Flexible Plan has $1.95 billion assets under management. SB Advisory has a Referral Agreement in place with Flexible Plan Investments. FINANCIAL PLANNING SB Advisory offers financial planning services to Clients seeking advice and direction on various aspects of financial planning. The level and extent of such financial planning services is dependent upon the level of services desired by the Client. Such advice may include, but is not limited to, analysis of financial plans, retirement planning, budget analysis, estate planning, college planning, and cash flow analysis. The extent and nature of the financial planning is tailored to the desires and needs sought by the Client. Services may include the development of a written plan, providing analysis or recommendations, or may only involve consultation(s). Three basic types of financial planning are offered to Clients to select are:
• Comprehensive Financial Planning
• Limited Financial Planning
• Hourly Financial Planning & Consultation Each of these types of financial planning is discussed below. In determining or selecting to receive financial planning services, the Client is under no obligation to act upon the Advisor’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through the Advisor. Comprehensive Financial Planning The Advisor will thoroughly review of all pertinent Client information, including financial condition, tax status, and cash flow concerns, discuss Client objectives and needs, assess risk tolerance, and mutually agree upon a set of assumptions. On the basis of this information, the Advisor will provide Client with a customized written report of all analyses and recommendations. The purpose of comprehensive financial planning is to conduct a holistic review of the Client’s financial situation, goals, and risks to provide advice and recommendations on aspects of the Client’s financial situation disclosed to the Advisor. Services will be rendered to the Client within six months of entering into an agreement. Limited Financial Planning The Advisor will thoroughly review of all pertinent Client information, including financial condition, tax status, and cash flow concerns, discuss Client objectives and needs, assess risk tolerance, and mutually agree upon a set of assumptions as it pertains to the area(s) of financial planning services desired by the Client. On the basis of this information, the Advisor will provide Client with a customized written report of all analyses and recommendations. Unlike Comprehensive Financial Planning, the purpose of such limited planning is to target area(s) of financial planning services for which the Client desires. The financial planning activities of the Advisor are not a holistic review of the Client’s financial situation, goals, and risk. It is the responsibility of the Client to indicate to the Advisor what areas of financial planning the Client seeks information and a written report. Among some of the areas the Client can choose among are:
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• College Funding Charitable Planning Retirement Planning Investment Planning and Analysis Estate Planning Business Planning Budget Analysis Insurance Planning Cash Flow Management Review of Prior Financial Plans Services will be rendered to the Client within six months of entering into an agreement. Hourly Financial Planning & Consultation The Advisor will review pertinent Client information provided to it by the Client, discuss Client objective and needs, and analyze and assess other factors necessary in providing information and recommendations concerning area(s) of financial planning for which the Client seeks advice. The Advisor is not responsible for providing a written report of analyses and recommendations. The purpose of hourly financial planning is to provide a way for Clients to openly discuss financial planning matters affecting them, their families, and/or their businesses. The Advisor reserves the right, based on information obtained during consultations or through submissions, to provide advice and recommendations at a time other than any consultations, as additional time may be necessary to provide quality advice and recommendations. It is the responsibility of the Client to indicate to the Advisor what areas of financial planning the Client seeks information and potential recommendations. Individuals Retirement and Retirement Plan Accounts: When SB Advisory provides 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 SB Advisory makes 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);
• Put your financial interests ahead of ours 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.