Fortitude Advisory Group L.L.C. (“Fortitude” or the “Firm”) is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”). Its principal place of business is in Gig Harbor, Washington. Fortitude began conducting business in November of 2001 under the name Argentus Advisors, LLC, as a wholly owned subsidiary of SAS Capital Partners, LLC. In September 2016, Sound Wealth Partners (“SWP”) became the sole owner of Fortitude. SWP is effectively 50% owned by each of Craig Johnsen and Ryan Finnigan. Fortitude’s advisory services are normally tailored to the individual needs of its clients (where relevant, e.g., advisory services provided to retirement plans may not be individually tailored to plan participants) and are based on the clients’ goals, investment objectives, time horizons and risk tolerances. In this capacity, Fortitude acts as a fiduciary to its clients. Fortitude generally provides investment advisory services through its investment adviser representatives (“Financial Advisors”). Financial Advisors may recommend the purchase or sale of securities or they may recommend the use of one or more third-party money managers. Fortitude, through its Financial Advisors, provides continuous investment advice to its clients (ex- retirement plans) based on the individual needs of each client. The Financial Advisor will discuss a client’s financial situation and will help the client establish financial goals, investment objective, time horizon and a risk tolerance. The Financial Advisor also reviews and discusses with clients the clients’ prior investment experiences, all in an effort to ensure that the advisory services provided are appropriate. Clients may elect to impose reasonable restrictions on investing in certain securities, types of securities, companies and/or industry sectors. However, Fortitude may refuse to continue offering advisory services if it determines that such restrictions cannot be accommodated. When advisory services are discontinued, client account(s) will be subject to the terms and conditions of the agreement between the client and the custodian and all advisory services and fees will no longer apply. Fortitude offers the following investment advisory services: Financial Advisor Directed Accounts A Financial Advisor directed account is one in which the account and the selected portfolio is managed by the Financial Advisor, either on a discretionary or non-discretionary basis. The Financial Advisor will recommend various investments, e.g., stocks, bonds, mutual funds, ETFs, alternative investments or other appropriate investments to help a client develop a portfolio designed to meet his or her financial goals and objectives. Because each type of investment involves varying degrees of risk, the Financial Advisor will only make recommendations that are consistent with a client’s stated goals, investment objectives, risk tolerance, time horizon and liquidity needs. The Financial Advisor will periodically discuss the portfolio’s investments with the client and recommend any changes to the portfolio if necessary to remain consistent with such client’s financial goals and investment objectives. Third-Party Money Manager Accounts In lieu of recommending individual investments under a Financial Advisor directed account, the Financial Advisor may assist a client in selecting one or more other advisers, which are referred to herein as “Third- Party Money Manager(s).” The Financial Advisor may utilize a number of factors in determining a prudent Third-Party Money Manager or Managers including performance, investment objectives, fees, and comparing those factors to the client’s stated goals and objectives (determining risk tolerance and investment styles). Third Party Money Managers may either be Portfolio Strategists or Portfolio Managers. Portfolio Strategists provide recommended asset allocation strategies that Fortitude will generally follow in investing a client’s portfolio, unless circumstances dictate that it should be modified or supplemented. Portfolio Strategists do not have discretion to trade a client’s account and do not provide discretionary asset management services; rather, direct management of the client’s assets is performed by the Fortitude Financial Advisor. A client may elect to employ a Portfolio Strategist for all or a portion of his or her account. Portfolio Managers also provide recommended strategies; however, they are generally provided with discretionary authority to effect transactions. Clients provide Portfolio Managers with discretionary authority through their advisory agreements with Fortitude. As with Portfolio Strategists, a client may employ one or more Portfolio Managers. Some Portfolio Managers may also provide “Overlay Services” for all or a portion of a client’s account if such services are selected. Overlay Services include, but are not limited to, services such as: harmonizing multiple account management services for the overall account, seeking trading and tax efficiencies or employing hedging or leveraging strategies to all or a portion of an account. The Financial Advisor will assist you in understanding and evaluating the services provided by any Third Party Money Managers selected. If the Financial Advisor determines that a selected Third-Party Money Manager is not managing your portfolio in a manner consistent with your stated investment objectives or your financial situation changes such that the Third-Party Money Manager’s services are no longer appropriate, the Financial Advisor may recommend a more appropriate Third-Party Money Manager for your account. Utilizing Third Party Money Managers A Third-Party Money Manager may recommend investing client assets in, or invest client assets in, one or more of its affiliated mutual funds, i.e., a mutual fund for which it or an affiliate serves as investment adviser (an “Advised Mutual Fund”). When an Advised Mutual Fund is utilized in a client’s portfolio, the Third-Party Money Manager receive fees directly from the client’s account, as well as advisory fees as adviser to the Advised Mutual Fund. Third Party Money Managers, in certain instances, may be compensated for the distribution or sales of these investment vehicles, which creates a conflict of interest with clients. Combined Financial Advisor Directed and Third-Party Money Manager Services You may elect to take advantage of Financial Advisor directed account services, as well as employ the services of one or more Third-Party Money Managers for your account(s). Such arrangements are accommodated and offered by Fortitude and its Financial Advisors. Company Sponsored Retirement Plan Advisory Services Certain of Fortitude’s Financial Advisors provide the following services to Employee Retirement Income Security Act of 1974 (“ERISA”) clients:  Education and enrollment assistance.  Draft, review and refinement of the Investment Policy Statement (IPS) to ensure the client’s (i.e., the plan sponsor’s and/or trustees’) objectives and risk tolerances have been met.  Working with the trustees of the plan to determine the appropriate mutual funds and/or securities for plan participant investments to meet the criteria outlined by the plan.  Meeting with the trustees of the plan to review the performance of the mutual funds and other securities selected by the trustees. Recommendations will be made to the trustees, who then have the sole authority to determine the course of action to take on behalf of the plan.  Periodic reporting as agreed upon. Fortitude does not act as plan sponsor or administrator of a plan. Fortitude’s role is as an adviser or consultant to the plan trustees or plan sponsor. The consulting services provided are limited to those assets specifically identified in the agreement with the client. Fortitude acknowledges its status as a “fiduciary” within the meaning of ERISA section 3(21). In most cases, Fortitude is an ERISA 3(21) fiduciary tasked with "recommending," "assisting," "helping," or "advising"

the sponsor as the sponsor goes about making selection/monitoring/replacement decisions. Other Advisory Services To the extent requested by a client, Fortitude may also provide advice or recommendations with respect to alternative investments, including private REITs, private funds and other private offerings. Financial Planning Certain Financial Advisors also provide financial planning services. Fees may be charged as a flat dollar amount, an amount based on a percentage of the assets under “advisement” or an hourly fee. A financial planning engagement may be effectuated by signing a separate “financial planning” agreement or the financial planning agreement may be incorporated into your client management agreement as one document. Financial planning is a comprehensive evaluation, assumption and analysis of a client’s current and future financial situation and needs using variable data such as current and future income, expenses, investment growth and performance, cash flows, asset values and withdrawal plans. Through the financial planning process, questions, information and analysis are considered as to how they may impact the current and future financial situation of the client. To prepare a financial plan, the Financial Advisor gathers information from the client though personal interviews. Information may include the client’s current financial status, tax status, current assets and liabilities, expenses, investment portfolio, future goals, investment return expectations and attitudes towards risk. The financial plan is designed to help the client create a plan and stay on track in attempting to achieve their financial goals and objectives. In general, a financial plan may address any or all of the following areas collectively or separately: asset allocation, education planning, estate planning, financial, insurance needs, retirement planning, and business retirement planning. The financial plan may contain specific recommendations from the Financial Advisor to purchase or sell specific securities. It is entirely up to each client whether or not to implement any recommendations made. If the client chooses to implement the recommendations made within the financial plan, the Financial Advisor may then recommend specific investments. To the extent that specific investment recommendations are made, the Financial Advisor may recommend securities or insurance transactions, in which case he or she would be acting as an insurance agent. This may create a potential conflict of interest as the Financial Advisor may be compensated for the purchase of insurance products in addition to the financial planning fee already received. Solicitation Arrangements Fortitude may, from time to time, utilize solicitors to introduce potential clients to its services. Solicitors are typically registered as investment adviser representatives with a state authority and may provide some level of advice such as suitability and/or risk tolerance assessment. A solicitor is not involved in the actual management of a client’s account. Solicitors share in the advisory fees paid by the client; however, the client will not pay any more for advisory services than he or she would if there were no solicitor involved. Solicitors are required to provide clients with a solicitor disclosure statement, which elaborates on the solicitor’s role and the relationship between the solicitor and Fortitude. Doing Business as Names Fortitude offers services through its Financial Advisors. Financial Advisors are investment adviser representatives within the meaning of the Advisers Act and may be referred to herein from time to time as “IARs.” One or more Financial Advisors may have a separate business name that is used for marketing purposes and may appear on marketing materials or client statements. The client should understand that businesses names belong to the Financial Advisor and not Fortitude. The Financial Advisors are under the supervision of Fortitude, and the advisory services or solicitor services of the Financial Advisor are provided through Fortitude. Fortitude has the arrangement described above with the following Financial Advisors:  Sound Wealth Partners  Wealth Innovations  AFM Investments  Proactive Planning Partners  Farr Financial  Valda Partners  Weitz Financial Group  Christopher V. Kimball Financial Services Sound Wealth Partners Sound Wealth Partners (“SWP”) provides investment advice primarily to individuals and their retirement trusts (i.e., IRAs) and also provides advice to corporate retirement plans. Its principal office is in Gig Harbor, Washington. SWP primarily provides Financial Adviser directed accounts as described previously. However, SWP Financial Advisors do from time to time recommend the use of Third-Party Money Managers. SWP does not provide financial planning services for a fee. Wealth Innovations Wealth Innovations acts as a solicitor for AssetMark. As such, it has no advisory clients. All customers that elect to use its services will become advisory clients of AssetMark and one or more of AssetMark’s subadvisers. Wealth Innovations provides financial planning services for a fee to its customers. AFM Investments AFM Investments primarily provides investment advice to individuals and their retirement trusts. In substantially all cases, AFM Investments uses a Portfolio Strategist in providing its services, typically, Donaghue Forlines LLC (“DF”). DF generally recommends that persons using its portfolio strategist service invest a portion of assets in DF affiliated mutual funds; although other mutual funds are also commonly used. Further, AFM investments normally initially charges a new client a financial planning fee based on the amount of assets over which it has discretionary authority. The Financial Advisors at AFM are registered representatives of Leigh Baldwin & Co., but they do not engage in brokerage transactions with respect to any assets they have under management. Proactive Planning Partners Proactive Planning Partners provides advice to individuals and their retirement trusts, and also provides advice to corporate retirement plans. When providing advice to individuals and their retirement trusts, Proactive Planning Partners may recommend that a client’s assets be managed by a Portfolio Manager. Proactive Planning Partners and its affiliates provide benefit advice to business enterprises that does not constitute investment advisory services. Certain of Proactive Planning Partners Financial Advisors are registered representatives of a broker dealer. Farr Financial Farr Financial primarily provides investment advice to individuals and their retirement trusts. FF primarily provides Financial Adviser directed accounts as described previously. However, FF does from time to time recommend the use of Third Party Money Managers. FF may provide financial planning services for a fee. Valda Partners Valda Partners (“Valda”) provides investment advice primarily to individuals and their retirement trusts. Valda primarily provides Financial Adviser directed accounts as described previously. However, Valda may from time to time recommend the use of Third Party Money Managers. Valda may provide financial planning services for a fee. Weitz Financial Group Weitz Financial Group (“WFG”) provides investment advice primarily to individuals and their retirement trusts and also provides nondiscretionary advice to 401k sponsors. WFG primarily provides Financial Adviser directed accounts as described previously. Christopher V. Kimball Financial Services Christopher V. Kimball Financial Services (“CKFS”) primarily provides investment advice to individuals and their retirement trusts. CKFS primarily provides Financial Adviser directed accounts as described previously. However, CKFS does from time to time recommend the use of Third-Party Money Managers. FF may provide financial planning services for a fee. Amount of Assets Under Management Fortitude has approximately $430 million of regulatory assets under management.