Firm Description and Types of Advisory Services OFM Wealth (OFM or the Firm) provides financial planning and investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, insurance companies and corporations. Principal Owners OFM was founded in 1982 and is owned by Sam Ogrizovich. Financial Planning OFM offers the following financial planning services: risk tolerance and asset allocation design, income management, retirement feasibility studies, income tax planning, cash flow analysis, account (e.g., 401k, 529 plans, etc.) analysis and asset allocation, estate analysis and distribution planning, education funding, risk management (insurance) analysis, required minimum distribution planning, estate administration, and retirement plan consulting. OFM advisors initially meet with clients to discuss goals, objectives, risk tolerance, time horizons, income needs, tax situations, etc. A financial plan or report is presented to the client. At this meeting, the client is provided with recommendations that are consistent with the client’s stated goals and objectives. An implementation schedule is reviewed with the client to determine which steps will be pursued, and with whom the steps may be accomplished. The client is under no obligation to utilize additional services of OFM and its representatives and is under no obligation to implement the advice or plan. Clients may choose all or certain components of advice and recommendations and can implement the recommendations through the service providers of their choice. Discretionary Asset Management OFM provides continuous advice to clients regarding investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, OFM develops a client’s personal investment plan and creates and manages a portfolio based on that plan. Discretionary managed accounts are not custodied at OFM. Rather, assets are held at an outside custodian and managed to the client’s objectives. OFM will create a portfolio consisting of one or all of the following: individual equities, bonds, separately managed accounts, other investment products, no-load or load-waived mutual funds, ETFs, and no-load variable annuities. OFM will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. Mutual funds will be selected on the basis of any or all of the following criteria: the fund’s performance history; the industry sector in which the fund invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management style and philosophy; and the fund’s management fee structure. Portfolio weighting between funds and market sectors will be determined by each client’s individual needs and circumstances. Non-Discretionary Asset Management OFM provides advice for assets regardless of custodian, investment manager, or investment platform (i.e., 401k plans). As such, OFM’s recommendations are based on the client’s objectives and implemented by the client based on OFM’s directions and third-party authorizations. Independent Managers OFM may recommend that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment managers, based upon the stated investment objectives of the client. The terms, compensation and conditions under which the client engages the Independent Managers are set forth in either a separate written agreement between the client and the designated Independent Managers or in a separate fee disclosure addendum to the OFM Wealth Advisory Agreement. OFM renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers, OFM also monitors and reviews the account performance and the client’s investment objectives. When recommending or selecting an Independent Manager for a client, OFM

reviews information about the Independent Manager such as its disclosure statement and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that OFM considers in selecting or recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, reporting, pricing, and research. The investment management fees charged by the designated independent managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, OFM investment advisory fee. In addition to OFM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than OFM. In such instances, OFM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Tailored Relationships OFM tailors investment advisory services to the individual needs of the client. OFM clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to OFM. Clients will retain ownership of all securities. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money may create some conflicts with your interests. This potential conflict of interest is mitigated, however, based on the additional advice and services that we provide. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs OFM does not participate in a Wrap Fee Program. Client Assets As of December 31, 2023, OFM manages approximately $291,214,586 in assets under management; approximately $279,754,800 is managed on a discretionary basis; and approximately $11,459,786 million is managed on a non-discretionary basis.