4.1. Formation and Ownership February 2008 NUA Advisors, LLC was formed as a New Jersey Limited Liability Company July 2008 Registered as an Investment Advisor with primary registration in State of Maine April 2009 Converted to Maine Limited Liability Company May 2013 Changed name to Innovative Advisory Group, LLC and continued to do business as NUA Advisors Converted to Massachusetts Limited Liability Company September 2013 Changed primary registration to Commonwealth of Massachusetts August 2014 Included the use of IAG Wealth Management for marketing. IAG Wealth Management is only a description of the services provided, and not the name or assumed name under which Innovative Advisory Group provides its services. IAG is an acronym for Innovative Advisory Group, and Wealth Management is a descriptive service definition. Used together as IAG Wealth Management is a service mark of Innovative Advisory Group, LLC. CRD #: 146618 SEC #: 801-122046 Innovative Advisory Group, LLC (IAG) is owned by two individuals equally through their appropriate intermediate holding companies as follows: Mr. Kirk Chisholm – Stirling Global Advisors, LLC Mr. Rajeev Kotyan – Blue Haven Group, Inc. Each of the individuals is a 100% owner of their respective holding company. It should be noted that ownership of IAG does not imply that the person or entity can provide investment advisory services. Only disclosed Management Persons and those listed as Investment Advisor Representatives in IAG’s Brochure Supplement is permitted to provide investment advisory services through or on behalf of IAG. 4.2. Management Person Mr. Kirk Chisholm and Mr. Rajeev Kotyan are Management Persons of IAG based on the appointment by Managers as passed by resolution of Operating Agreement of IAG. Management persons may also be IAG’s Investment Advisor Representatives only if they are appropriately licensed and registered in accordance with appropriate regulators. Currently these are the only management persons of IAG, and all of them are also Investment Advisor Representatives. Mr. Kirk Chisholm Born April 1975; BA in Economics; Trinity College, Hartford, CT. Independent Representative and Investment Adviser Representative with UBS (1999-2003), Smith Barney (2003-2005), Royal Alliance (2005-2008). Mr. Kirk Chisholm’s CRD # is 4004975 Mr. Rajeev Kotyan Born July 1970; Bachelor of Engineering (Computers & Finance) - India. Financial and Technology Risk Management for various firms 1991-2005 including Citigroup, Investors Bank and Trust and Dow Jones. Business Advisor and Planner, owner for Blue Haven Group, Inc. Mr. Rajeev Kotyan’s CRD # is 5479610 © 2011-2024 Innovative Advisory Group, LLC; All Rights Reserved Page 11 of 40 4.3. Services Offered Investment Advisory Services Innovative Advisory Group, LLC provides Investment Advisory Services with regard to, but not limited to mutual funds, stocks, bonds, private and public partnerships, annuities, real estate investment trusts and other investment products that may not be considered securities. IAG provides full-service investment management which will take into consideration the clients’ individual needs, objectives and risk tolerance. IAG as a full-service investment advisor will address such issues as financial goals, risk management, taxation, retirement goals, investments, education and estate planning, relative to the investment management. It also may provide more limited and isolated services based on the clients’ request and requirements. IAG offers its services to individuals, as well as corporate clients (including small businesses which may be sole proprietors and other unregistered businesses and partnerships). Either client or IAG may terminate this service agreement at any time with written notice to the other. Asset Management Accounts (AMA): IAG may act as the investment manager for a client's portfolio. IAG in its capacity as an investment advisor and IAG's Investment Advisor Representatives (IAR) will manage and direct specified assets of a client on a discretionary basis. Clients may request IAG and IAG IAR’s for asset management on a non-discretionary basis, and such may be permitted on a case-by-case basis and in discussion with the client. Clients will permit trading authority to IAG's representatives to purchase and sell in the account pursuant to investment objectives of the client, to liquidate previously purchased investments, and purchase and sell separate accounts within annuities. Other investments such as equities, fixed income, structured products, and other investment products may be purchased and sold at the client's requirements. In authorizing the use of an AMA, the IAR obtains the necessary financial data from the client, assists the client in determining suitability, investment requirements, education and/or restrictions and assists the client in setting appropriate investment objectives. The client receives a monthly or quarterly statement showing account activity as well as positions held in the account as directly provided by the custodian, in accordance with the custodian’s policy and procedure. IAG does not custody any assets. Additionally, the client receives confirmation of each transaction that occurs with the AMA directly from the custodian of the AMA and will be within their policy. The client may also receive reports describing performance, positions and activities directly from the custodian of the AMA. While IAG is not responsible for the policy and procedures of the AMA custodian, IAG will make efforts to make sure that the AMA custodian follows the mentioned requirements. Plan Participant Accounts (PPA): Clients may provide IAG and IAG’s IAR with authorization to manage assets held within an Employer Sponsored Plan (i.e. plan participant account). IAG shall provide Client with allocation services within the PPA, restricted to the options available within the PPA. Unless separate trading authorization is provided to IAG, Client will be responsible for the implementation and execution of allocation recommendations within the PPA. Client may permit trading authorization to IAG and IAR, if such is available by the Plan, upon which IAG and its IAR shall carry out trades within the PPA on behalf of the Client. Client should expect to receive detailed quarterly reports, statements and trade confirmations in accordance with the PPA policies and procedure. One-Participant Plan Accounts (OPA): These plans shall be treated as AMA, limited to Client and Client spouse as defined in the Internal Revenue Code for One-Participant Plans. © 2011-2024 Innovative Advisory Group, LLC; All Rights Reserved Page 12 of 40 As of December 31, 2023 (approx. and rounded to the nearest $100,000.00) Discretionary Assets Under Management $ 129,000,000.00 Non-discretionary Assets Under Management $ 00,000.00 Totals $ 129,000,000.00 Comprehensive Financial Planning Services IAG shall provide the client with comprehensive Financial Planning Services that will include a review of client's financial circumstances, financial goals and a written report of recommendations. This information normally would cover present and anticipated assets and liabilities, including insurance, savings, investments, and anticipated retirement or other employee benefits. The program developed for clients will usually include general recommendations for a course of activity or specific actions to be taken by Clients. For example, recommendations may be made that the Client obtains insurance or revise existing coverage, establish an individual retirement account, increase or decrease funds held in savings accounts or investment funds in securities. IAG may refer clients to a tax accountant or attorney for development of tax or estate plans, in coordination with the financial plan recommendations. IAG does not render legal, tax or accounting advice or prepare any legal documents for clients. Client's personal attorney shall be solely responsible for providing legal advice, legal opinions,

legal determinations and legal documents. Client's personal tax adviser or accountant shall be solely responsible for any tax or accounting services provided to client. IAG may also create a cash flow analysis or work with and advise clients as to the rearrangement of cash flow in order to achieve certain goals and objectives such as buying a house, education planning, retirement planning, etc.. Clients who receive Financial Planning Services may receive Investment Advisory Services from IAG. Thus, IAG may have a conflict of interest when providing Comprehensive Financial Planning Services because IAG may receive additional compensation if Client chooses to use Investment Advisory Services from IAG. Client is under no obligation to use IAG's Investment Advisory Services. Some of the planning services are: a. Credit Report Analysis: Review of the credit reports as made available by the client to IAG from the various credit bureaus to analyze how the various accounts and account types are affecting the positive or negative aspects of the client’s credit worthiness. b. Cash Flow Analysis: Review of the inflows and outflows of cash that a client has, based on the data provided by the client to IAG. The analysis provides the client an understanding of their potential for savings, spending and investment, and assists in the determination of financial projections. c. Income Tax Analysis: Review from an investment advisor perspective, including but not limited to investment tax gains or losses and retirement contribution impact. IAG does not render comprehensive tax advice, and shall with client approval, work with the clients’ tax accountant, as appropriate. d. Retirement Analysis: Projection to determine if client will have the resources to achieve their stated retirement goals, and/or to provide optional strategies to improve the probability of success. e. Estate Plan Analysis: Provide an investment advisor perspective, including but not limited to allocation of portfolio to beneficiaries and charities. IAG does not render legal advice, and shall with client approval, work with clients’ estate planning attorney, as appropriate. f. Insurance Analysis: Provide a review and analysis to include, but not limited to survivor needs, disability needs, and long-term care needs. IAG hereby discloses that IAG is not licensed to sell any insurance products, but the IAGs IAR’s may be licensed in certain states. © 2011-2024 Innovative Advisory Group, LLC; All Rights Reserved Page 13 of 40 g. Education Analysis: Project to determine if clients will have the resources to achieve their stated education financial goals, and/or provide optional strategies and choice to improve probability of success. h. Individual Investment Analysis (non-securities investments): Provide a review of the non- securities, based on the information that has been made available to the client, and/or from publicly available sources, or from third-party providers and aggregators. IAG does not provide legal or tax advice on the documents, and shall with client approval, work with the client attorney and accountant, as appropriate. i. Investment Portfolio Analysis: Provide a review of client investment portfolio, including but not limited to the status, and the projections based on market assumptions. This service is only available to client who do not use IAG’s Investment Advisory Services. Start: Disclosures Specific to State of California Residents In accordance with California Code of Regulations Title 10, Chapter 3, Subchapter 2, Article 10, Section 260.235.2, IAG hereby discloses: a) A conflict exists between the interests of IAG and the interests of the Client, and neither the Client nor IAG are under any obligation to align their interests, b) Client is under no obligation to act upon the financial plan recommendations provided by IAG, c) If the Client elects to act on any of the financial plan recommendations provided by IAG, the client is under no obligation to effect any transactions through the services provided by IAG. End: Disclosures Specific to State of California Residents Business Retirement Planning Services IAG provides Business Retirement Planning Services with regard to, but not limited to development and selection of Employee Retirement Plans. The services would include the following: A. Plan and Platform Identification Services: This shall include plan participant profiling of risk, retirement goals and objective, investment objective and estate planning objectives for the purposes of development and/or identification of appropriate plans and platforms which meet the requirements of the Client and plan participants. B. Plan and Platform Document and Operation Review: This shall include review and analysis of plan documents and platform operations, in accordance with the goals of the Client and the plan participants. C. Plan Administration Review: This shall include either, research and recommendation of Plan Administrator to satisfy the need of the Plan or review and analysis of the Plan Administrator in accordance with the Plan Document requirements. D. Investment Recommendation Services: This shall include either the recommendation of types investment, including but not limited to mutual funds, stocks, bonds, private and public partnerships, annuities, real estate investment trusts and other investment products that may not be considered securities, and/or the research and analysis of existing investments in the Plan, in accordance with the Plan Documents. Client may choose any/or all of the above services which shall determine the scope of the service provided. As part of the service, IAG may refer clients to a specific Plan sponsor, platform, broker(s), custodian(s) and administrator(s), accountants or attorneys for development, administration, auditing or legal advice. IAG does not render legal, tax, plan sponsorship, or administration of the Plan. Client's attorney shall be solely responsible for providing legal advice, legal opinions, legal determinations and legal documents associated with the Plan or contracts with the third-party provider, accountant or any other provider to the Plan. IAG shall provide review © 2011-2024 Innovative Advisory Group, LLC; All Rights Reserved Page 14 of 40 and analysis of the Plan on an annual basis, at the anniversary of the Plan, or anniversary of agreement. IAG does not provide any ongoing supervision or monitoring of the Plan. Either client or IAG may terminate this agreement at any time with written notice to the other. IAG does not provide investment advice or allocation services to the Plan participants, unless the individual plan participants have signed a separate Investment Advisory Services Agreement or Comprehensive Financial Planning Services Agreement with IAG or is a one-participant plan. Plan assets shall not be considered as Assets under Management, and the cumulative value of the Plan Assets may only be used for the purposes of charging fees. As of December 31, 2023 (approx. and rounded to the nearest $100,000.00) ERISA Discretionary Plan Assets $ 0.00 ERISA Non-discretionary Plan Assets $ 0.00 Totals $ 0.00 Other Special Services IAG may provide other services, such as identification of third-party money managers, business management consulting, family office, office management or similar services under any other name. Such services are discussed with the client, and terms and fees negotiated between the individual, family or business requesting such services with IAG. Other services may be provided to clients who do not use any of the aforementioned services provided by IAG and IAG IARs. With any of such services, neither IAG nor IAG IARs shall have any custody of any client accounts in accordance with Item 15: Custody. © 2011-2024 Innovative Advisory Group, LLC; All Rights Reserved Page 15 of 40