Sunlight Peaks Financial Partners (“Sunlight Peaks” or the “firm”) has been in business since 2021. Heritage Management Group, LLC, maintains 100% ownership of Sunlight Peaks; Ryan Parson is the sole owner of Heritage Capital USA, Inc., which owns and operates Heritage Management Group, LLC. Sam Beritela is the Chief Compliance Officer. Investment Management We provide investment consulting, investment sourcing, and investment research. We discuss each client’s financial situation, objectives and needs, and tailor our services to the individual situation and needs of the client. When providing investment management services and advice on portfolio design we identify suitable investments for the client’s portfolio and make recommendations. We assist with the completion of purchases of private investments, ongoing investment monitoring, management and administration, and advice relating to redemptions/liquidation of private investments. Private investments include alternative investments, such as pooled, privately-placed securities such as a private equity fund, a private debt fund, a private real estate fund, or a fund-of-funds managed by a private investment manager or other private placement including equity, credit, or real estate investments. Private investments are generally sourced from various platforms, including but not limited to CAIS, Verivest, and OpenAlt. These services are typically offered only to accredited and/or qualified investors. We also recommend the investment and reinvestment of the traditional investments. Traditional investments include stocks, bonds, commodities, mutual funds, and exchange-traded funds (“ETFs”). Our services are offered on a non-discretionary basis. We do not enter transaction orders on behalf of clients. As such, we do not monitor any investment restriction you may have concerning certain securities or types of securities. Upon your verbal or written authorization, we will communicate with issuers and/or sponsors of the private investment on your behalf. Financial Planning Services We may provide financial planning to clients. Financial planning services are offered on a comprehensive or on à la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client:
• Estate Planning
• Retirement Planning
• Education Planning
• Insurance

Planning/Risk Management
• Investments
• Charitable Giving
• Asset Allocation Review and Recommendations We obtain appropriate information from the client through personal interviews (including a discussion of current financial status, future goals and attitude towards risk) and reviews the documents and data supplied by the client. A written financial plan will be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. In performing these services, we are not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and are expressly authorized to rely on such information. It is the client’s responsibility to promptly notify us of any change in the client’s financial situation or investment objectives in order for the firm to adjust their services accordingly. Clients retain absolute discretion over all decisions regarding implementing any or all parts of the financial plan. Clients are under no obligation to act upon any of the recommendations made by firm under any non-discretionary engagement, financial planning or consulting engagement. Investment Advice to Qualified Plans We provide non-discretionary investment advisory services to qualified plans, including 401(k) Plans, in accordance with the Plan’s investment policies and objectives. After review of the Plan’s Investment Policy Statement, we assist the plan sponsor with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. In addition, we can monitor the funds selected and recommend replacements as appropriate, review and provide recommendations relating to the reasonableness of the fees paid to other providers. The client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). Sunlight Peaks does not provide investment advice to Plan participants unless they separately engage and become clients of the firm. We do not execute transactions at the participant level. Assets Under Management As of March 31, 2023, Sunlight Peaks had Regulatory Assets Under Management of $43,380,932, all of which was managed on a non-discretionary basis.