We are dedicated to providing individuals and other types of clients with various investment advisory services. Juncture is a limited liability company formed in the State of Delaware. We have been in business as an investment adviser since 2010 and are owned indirectly by the following individuals: Barry S. Rhonemus Jack A. Barker Bradley J. Haines Investment Advisory Services Our Investment Advisory services are designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one (but sometimes more than one) meeting in person, if possible, (otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We will work with the client to develop written Investment Objectives based on short and long- term financial goals, asset amount and makeup, risk tolerance, and other preferences. Each portfolio is designed to meet a particular investment goal which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been constructed, we review the portfolio with the client at least annually given the complexity and frequency of change of a given client’s circumstances. Investment strategies are then adjusted according to those changed circumstances. Portfolios are rebalanced in response to market conditions in an effort to maintain the appropriate risk level for a given client, as well as to benefit from changes in relative price movements of different investments. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. We prefer that clients do not impose restrictions on investing in certain securities or types of securities, but we will consider and strive to accommodate reasonable requests which we feel we can do in an effective manner. Portfolio Management and Implementation We may propose an investment portfolio consisting of exchange traded funds, mutual funds, individual stocks, bonds, or other securities. The client’s individual investment strategy is tailored to their specific needs and may include some or all of these mentioned securities/investment solutions. Juncture’s investment recommendations are not limited by any specific product or service offered by a broker-dealer or custodian and are based on each client’s specific needs and objectives. The client will enter into a written agreement with Juncture to define the appropriate method of investment management: 1. Investment Advisor Representative (“IAR”) as Portfolio Manager – Juncture’s IAR may provide portfolio management services for a client’s account held at one or more custodians chosen by the client. The IAR is directly responsible for the trading of the account while the custodian provides safekeeping of the assets as well as other services and support. 2. Directly Held Accounts – Clients may have an account held directly at a product sponsor such as a mutual fund and/or annuity company. In this capacity, the IAR may provide investment services that oversee the management of these products. 3. Third Party

Money Manager (“TPMM”) – Clients may authorize Juncture to direct their accounts held at a custodian to be serviced by an affiliated or unaffiliated TPMM. TPMMs may provide investment management services and programs via the following methods:
• Sub-advisory agreement between JWS and the TPMM
• Separately Managed Accounts (TPMM creates a single account to manage for a client)
• Unified Managed Accounts (multiple managers for a client account)
• Model allocation programs TPMMs are either registered investment advisers or exempt from registration as investment advisers. Juncture’s advisors may recommend TPMM investment services to clients based on a client’s financial needs and agreed-upon investment strategy. The TPMM may or may not have a separate service contract directly with the client. The TPMM may also be delegated investment management powers (including discretionary trading authority) over the client’s account through the contract between JWS and the client. Further, the TPMM may also provide administrative services which include the calculating and processing for payment of advisory fees on behalf of Juncture. Juncture has entered into an agreement with an affiliated TPMM, Juncture Asset Management (“JAM”), to serve as a TPMM only if it is suitable for the client based on the investment objectives. Services provided by JAM include portfolio management using proprietary strategies, the management to model portfolios, and trading/implementation services for a Juncture IAR’s investment models. JAM currently files with the SEC as a ‘related adviser’ to JWS and performs JWS’s portfolio management functions. The Juncture IAR does not receive compensation incentives for using JAM’s services. Participation in Wrap Fee Programs - We do not offer wrap fee programs. Standalone Financial Planning/Consulting After we have conducted our inquiry into the client’s financial background, goals, and risk tolerances, we may provide further financial planning services, subject to an agreement, for a fee, apart from any investment advisory service being provided to a client. Clients are not required to engage in financial planning services offered by JWS. When providing these services, JWS will obtain additional financial information and documents from clients to determine the appropriate advice to be provided. The financial planning process includes, but is not limited to, the following:
• Data gathering and establishing objectives
• Analyzing the client’s current situation
• Designing a plan to meet the client’s objectives that may include: o Retirement Planning o Business succession o Insurance analysis o Employee benefit analysis o Tax planning o Estate planning document review o Asset protection planning o Entity structure
• Presenting the plan and making any needed changes
• Recommendations and action steps
• Reviewing/Monitoring the plan when applicable Clients are not required to implement the IAR’s recommendations related to a JWS financial plan. Additionally, the client may elect to implement recommendations using a Broker-Dealer, Investment Adviser or insurance agent of the client’s choice. Regulatory Assets under Management We manage $324,164,654 on a discretionary basis and $8,667,960 on a non-discretionary basis as of December 31, 2023.