We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed in the State of Minnesota in 1995. Our firm has been in business as an investment adviser since 2013 and is solely owned by Michael Rogers. Description of the Types of Advisory Services We Offer 360 Asset Management: We emphasize continuous and regular account supervision. As part of our 360 Asset Management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Generally, Financial Planning & Consulting services are included in our 360 Asset Management service for no additional fee for accounts with at least $500,000. Financial Planning & Consulting is also offered as a separate service, please see the succeeding section. We do not monitor your investments for the Financial Planning & Consulting service. Financial Planning & Consulting: We provide a variety of financial planning and consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months to twelve (12) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Financial Professional Estate Planning Assistance: We will work with Clients to gather information who either have an estate plan that no longer reflects their desires, or they have no estate plan at all and are electing to work with us for providing estate planning services. We will work with the Client to gather information and decisions in ENCORESTATE PLANS (“ENCORE”) software. ENCORE will then prepare the estate planning documents strictly using the date collected in the software. We are not licensed attorneys and will not be giving legal advice. The general nature of the matters for which Planner will be compensated pursuant to the Agreement

are the following: (1) General estate tax education and guidance; (2) General trust guidance –types and features; (3) General explanation of estate planning structures/documents; (4) General explanation of estate planning and gifting strategies; (5) General explanation of taxation issues of trusts and estates; (6) General explanation of types and treatment of trust income; (7) General guidance on sources of estate liquidity; (8) General guidance on ownership titles and titling of assets; (9) General guidance on the impact of account and trust beneficiary designations (10) Assistance with gathering information to transmit to EncorEstate Plans. Pension Consulting: We provide pension consulting services to employer plan sponsors on an ongoing basis. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services described in section 1 of the Pension Consulting Agreement). Educational Webinars: 360 Financial offers clients and prospective clients the opportunity to attend educational webinars hosted by Mr. Michael Rogers, with various guest speakers, including but not limited to the other advisors of 360 Financial. The webinars will cover a range of topics which will include but are not limited to the following:
• Market Overview – Presentation of data pertaining to stock market performance in the previous year, economic factors, and outlook for the coming year.
• Financial Management – Financial issues that are of critical importance to long-term financial security will be addressed, particularly as they pertain to retirement planning and making sound financial decisions to help protect clients’ families and their assets.
• Retirement – Topics include types and characteristics of various retirement vehicles, projecting income, expenses and needs, deciding when to retire, retirement lifestyle, budgeting, and money management during retirement.
• Investments – Discussion of various investment products to include but not limited to bonds, stocks, mutual funds, and commodities. Investment terminology, distinctions among various asset classes and bond classifications will also be reviewed.
• Well Being – Presentation of the “5 Elements of Well Being” and the “Family Index” as they integrate with financial security and living a life of purpose.
• Social Security – Discussion regarding social security benefits, timing of benefits and other factors (such as spousal benefits).
• Minnesota Residency – Discussion regarding some facets of Minnesota Residency guidelines. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our 360 Asset Management service. Additionally, we offer general investment advice to clients utilizing our Educational Webinars, Financial Planning & Consulting, Pension Consulting services. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our asset management services. We do not manage assets through our other services. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management 360 Financial has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $462,222,814 $40,346,839 April 8, 2024