Asia Pacific Financial Management Group, Inc. provides personalized investment advice, investment management, and retirement & financial planning to individuals, qualified retirement plans, trusts, estates, charitable organizations, and business entities. Advice is provided through consultation with the client. It may include determining financial objectives, cash flow management, time horizon, risk tolerance, investment management, education funding, retirement planning, and insurance review. Advice is provided through consultation with the client. It typically includes the determination of financial objectives, cash flow management, time horizon, risk tolerance, investment management, education funding, retirement planning, and insurance review. Asia Pacific was founded in 1993 and is currently operated by principals and owners Sandra McKeever, Melinda Sulit, Jonathan Ulloa, and Sophia Brindejoic-Choi. In March of 2023, Asia Pacific ceased its brokerage operations, and since then, it has exclusively operated as an investment advisor. As of December 31, 2023, Asia Pacific managed approximately $248,444,711 in client assets on a discretionary basis. Before engaging Asia Pacific to provide any of the investment advisory services, the client must enter into one or more written agreements setting forth the terms and conditions under which Asia Pacific renders its services (collectively the "Agreement"). Agreements may be assigned without the client's consent. At the start of each client relationship, their current financial situation is evaluated. Periodic reviews are also communicated to remind of the specific courses of action that must be taken. The initial meeting is considered an exploratory interview to determine the extent to which Asia Pacific's financial planning and investment management may benefit the client. This disclosure brochure describes the Asia Pacific business. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Asia Pacific's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or any other person who provides investment advice on Asia Pacific's behalf and is subject to Asia Pacific's supervision or control. Investment Management Services Clients can engage Asia Pacific to manage all or a portion of their assets on a discretionary basis. In select and limited cases, Asia Pacific may also manage assets on a non- discretionary basis. Investment management clients may also receive retirement planning and financial planning services in conjunction with portfolio management. Asia Pacific primarily allocates clients' investment management assets among exchange- traded funds ("ETFs"), mutual funds, and, to a lesser extent, individual debt and equity securities in accordance with the investment objectives of the client. Asia Pacific, as requested, provides advice about any legacy positions or investments in clients' portfolios. Additionally, Asia Pacific provides investment management services to clients relative to variable life/annuity products they may own, their employer-sponsored retirement plans, and/or 529 plans or other products that the client's primary custodian may not hold. Asia Pacific tailors its advisory services to the individual needs of clients. Asia Pacific consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon, and other factors that may impact the clients' investment needs. Asia Pacific strives to ensure that clients' investments are suitable for their investment needs, goals, objectives, and risk tolerance. Often, clients choose to have Asia Pacific provide ongoing investment advice and life planning. Important aspects of the client's financial affairs are reviewed. Realistic and measurable goals are discussed, and objectives to reach those goals are defined. Clients are advised to promptly notify Asia Pacific if there are changes in their financial situation or investment objectives or if they wish to impose reasonable restrictions upon Asia Pacific's management services. Clients may impose reasonable restrictions or mandates on the management of their account if, in Asia Pacific's sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Additions and Withdrawals to Accounts Clients may make additions to and withdrawals from their account at any time, subject to Asia Pacific's right to terminate an account. Clients may withdraw account assets on notice to Asia Pacific, subject to the usual and customary securities settlement procedures. However, Asia Pacific designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a client's investment objectives. Miscellaneous When performing the services

described above, we are neither your attorneys nor your accountants, and you should interpret no portion of any services rendered by us as legal or accounting advice. We recommend that you seek the advice of a qualified attorney and accountant. Asia Pacific may recommend the services of its Supervised Persons in their individual capacities as licensed insurance agents to implement its recommendations. Clients are advised that a conflict of interest exists if Asia Pacific recommends the services of itself or its Supervised Persons for purchasing an insurance product, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions received rather than on a particular client's need. Clients retain absolute discretion over any Asia Pacific recommendations to purchase insurance products and are free to accept or reject the recommendation. The client is not obligated to act upon any of the recommendations made by Asia Pacific. Asia Pacific may recommend the services of other professionals to implement its recommendations. The client is under no obligation to act upon any of the recommendations made by Asia Pacific to engage the services of any such recommended professional. Clients retain absolute discretion over all such decisions and are free to accept or reject any of Asia Pacific's recommendations. Please note that if the client engages any unaffiliated recommended professional, and a dispute arises after that relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Client Obligations In performing its services, Asia Pacific shall not be required to verify any information received from the client or the client's other professionals, and it is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Asia Pacific if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Asia Pacific's previous recommendations and/or services. Retirement Rollovers 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. How 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. A client leaving an employer typically has four options (and may engage in a combination of these options): i) leave the money in his former employer's plan, if permitted, ii) roll over the assets to their new employer's plan, if one is available and rollovers are permitted, iii) rollover to an IRA, or iv) cash out the account value (which could, depending upon the client's age, result in adverse tax consequences). Asia Pacific may recommend that investors roll over plan assets to an individual retirement account (IRA) managed by Asia Pacific. As a result, Asia Pacific and its representatives may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their old employer or roll the assets to a plan sponsored by a new employer will generally result in no compensation to Asia Pacific (unless you engage Asia Pacific to monitor and/or manage the account while maintained at your employer). Asia Pacific has an economic incentive to encourage an investor to roll plan assets into an IRA that Asia Pacific will manage or to engage Asia Pacific to monitor and/or manage the account while maintained at your employer. There are various factors that Asia Pacific may consider before recommending a rollover, including but not limited to i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan's investment professionals versus Asia Pacific, iv) protection of assets from creditors and legal judgments, v) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to rollover plan assets to an IRA managed by Asia Pacific or to engage Asia Pacific to monitor and/or manage the account while maintained at your employer. Please Note: If Asia Pacific's engagement will include the management of the client's retirement account per the same fee schedule outlined in Item 5 below, regardless of the custodian or the client's decision to process a rollover, the above economic incentive to recommend a rollover is moot.