A. Harbor Wealth Management, LLC Harbor Wealth Management, LLC (“HWM” and/or the “firm”), is a Wisconsin limited liability company principally owned by Eric Heus and Brent Polzin. HWM is an independent investment advisory and financial planning firm offering a variety of financial services. HWM has been providing investment advisory and financial planning services since August of 2010. B. Advisory Services Offered HWM is a fee-only investment management firm offering proprietary investment management and financial planning services to individuals and high-net-worth individuals, trusts, retirement plans, pension and profit sharing plans, corporations, partnerships, and other legal entities. Advisory services may include financial planning, investment strategy, portfolio management, selection of third-party money managers, tax preparation, and tax and estate planning. B.1. Discretionary Asset Management Services For its discretionary asset management services, HWM receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this Brochure. HWM’s discretionary asset management services are predicated on asset allocation models to create diversified portfolios consisting of individual securities, mutual funds, exchange-traded funds, and portfolios managed by separate account managers engaged by HWM on the client’s behalf. The asset allocation methodology employed by HWM relies on modern portfolio theory, which involves the application of certain mathematical principles to the historical risk, return, and correlation characteristics of asset classes to combine asset classes in such a way that maximizes return potential for a targeted level of risk. The resulting asset allocation chosen seeks a projected return potential consistent with the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. In preparing the asset allocation, HWM will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance. HWM’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances, and make appropriate asset allocation recommendations and implementation decisions. HWM may engage third-party service providers to assist with the tax and estate planning portion of the services provided to clients. In addition, HWM may utilize third-party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. HWM will monitor those portfolios and make additional recommendations from time to time to rebalance and/or reallocate each client's investments. HWM's investment advisory services to clients are based on asset allocation models that, as noted above, take into account a client's personal financial circumstances, investment objectives, and tolerance for risk (e.g., cash-flow, tax, and estate). HWM's engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to HWM in response to a questionnaire and/or in discussions with the client and reviewed in meetings with HWM. ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Identifying tax planning strategies and tax preparation. ▪ Implementing and/or recommending separate account managers, mutual funds, exchange-traded funds, and individual equity and fixed income securities, each matched to the asset categories in the client's targeted asset allocation for consideration by the client. ▪ Reporting to the client on a quarterly basis or at some other interval agreed to with the client, information on contributions and withdrawals in the client's investment portfolio. ▪ Proposing changes in the client's targeted asset allocation in consideration of changes in

the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments, and/or the performance of any fund or manager retained by the client. In addition to providing HWM with information regarding their personal financial circumstances, investment objectives, and tolerance for risk, clients are obligated to provide HWM with any reasonable investment restrictions that should be imposed on the management of their portfolio and to promptly notify HWM in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals, and tolerance for risk. On a quarterly basis, HWM's reports to clients will remind clients of their obligation to inform HWM of any such changes or any restrictions that should be imposed on the management of their accounts. HWM will also contact clients at least annually to determine whether there have been any changes in their personal financial circumstances, investment objectives, and tolerance for risk. B.2. Financial Planning Services HWM provides the following financial planning services to its clients. B.2.a. Investment Consulting HWM will assess the client’s financial risk preferences by determining the extent to which the client would choose to risk experiencing a less favorable outcome in pursuit of a more favorable outcome, and will make a recommendation of a target asset allocation based upon the client’s financial situation and risk tolerance. HWM will also perform an evaluation of the client’s current investment holdings and make recommendations, if appropriate, to bring the client’s current investments into alignment with his or her risk tolerance and agreed-upon target asset allocation. B.2.b. Goal-Based Planning HWM will provide planning and counseling for the client to help quantify and prioritize his or her financial goals by order of importance, and HWM will determine the likely degree of success the client has in meeting each defined financial goal based on the assumptions made. HWM will prepare “what if” alternatives, if appropriate, to help the client understand trade-offs of contemplated decisions. HWM will also use “Monte Carlo” simulations to illustrate to the client how small changes in various factors can impact his or her chances of meeting financial goals. B.2.c. Other Services HWM will provide additional financial planning services as mutually agreed upon with the client as further described below: ▪ Reviewing and prioritizing goals and objectives. ▪ Developing a summary of current financial situation, including a net worth statement, cash flow summary, and income tax analysis. ▪ Reviewing current investment portfolio and developing an asset management strategy. ▪ Assessing exposure to financial risk and developing a risk management plan (insurance). ▪ Completing a retirement planning assessment, including financial projections of assets required during retirement. ▪ Assessing estate net worth and liquidity and developing an estate plan to ensure legacy objectives are met. ▪ Integrating and prioritizing all strategies outlined above into a comprehensive financial plan. ▪ Presenting a written financial plan to be reviewed in detail with the client, containing recommendations designed to meet stated goals and objectives and supported by relevant financial summaries. ▪ Developing an action plan to implement the agreed-upon recommendations. ▪ Providing referrals to other professionals, as required, to assist with implementation of the action plan. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs HWM does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2022, HWM had $294,358,597 in discretionary assets under management and $0 in non-discretionary assets under management. Item 5: Fees and Compensation