SAM Advisors, LLC, doing business as Sierra Asset Management (SAM), is a SEC- registered investment adviser with its principal place of business located in Oakhurst, California. SAM began conducting business in 1999. The firm's sole LLC owner (member) is Donald Anthony DeBernardi Jr., President. SAM offers the following advisory services to our clients: INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides asset management of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on the client's particular circumstances are established, we develop the client's personal investment strategy. We create and manage a portfolio based on that strategy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. We may leverage an Order Management System through Pontera to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client in “held away” accounts. These are primarily 401(k) accounts, HSA’s, 403(b), 457 Plans, Profit Sharing Plans, and other assets we do not custody. Once the client's portfolio has been established, we review the portfolio on a continual basis and if necessary, rebalance the portfolio on at least an annual basis, based on the client's individual needs. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests
• Other Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. FINANCIAL PLANNING We provide general financial planning services. Financial planning is an evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive an oral briefing, and if purchased, a written report that provides the client with a financial plan designed to assist the client achieve his or her financial

goals and objectives. We will work with the client's tax preparation professionals, accountants, attorneys and/or insurance agents as appropriate. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax, spending, and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, and liability. We are not insurance agents, and we do not receive sales commissions, referral fees, or compensation of any kind for recommending any type of insurance.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. Our advice is of a general nature only. Clients should consult their own attorney regarding all legal advice. We do not provide legal advice of any kind. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, return objectives and attitudes towards risk. We carefully review documents supplied by the client, and provide an oral briefing for the client, and if purchased, a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial planning recommendations is entirely at the client's discretion. We also provide general non-securities advice on any financial planning topic, including but not limited to tax and budgetary planning, retirement planning, estate planning and business planning. PUBLICATION OF PERIODICALS SAM publishes a quarterly newsletter providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. No specific investment recommendations are provided in this newsletter and the information provided does not purport to meet the objectives or needs of any individual. This newsletter is distributed free of charge to our advisory clients. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on an isolated area(s) of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $328,700,386 of clients' assets on a discretionary basis plus $5,421,498 of clients' assets on a non-discretionary basis.