ASW is a registered investment adviser with its principal place of business located in Texas. ASW, formerly known as Pauley Financial Services, Inc. began conducting business in 2000. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of the company):
• Kimberly Victoria
• Brian A. Cox Brian Cox is also the Chief Compliance Officer. ASW offers the following services: 1. FINANCIAL PLANNING AND INVESTMENT MANAGEMENT SERVICES (SILVER, GOLD, AND PLATINUM)
• ASW offers financial planning and investment management services designed to meet the specific needs of clients. Clients may select the level of service they need from the services offered below.
• Investment management services are provided on a discretionary and non-discretionary basis. Discretion is agreed upon at inception of the client relationship. For non-discretionary accounts, no transactions will be made without the client’s prior approval.
• While the advisor can recommend various insurance products to the client, the advisor does not engage in the sale of insurance products nor does the advisor receive commissions from the sale of insurance products. Silver: This service includes (all or part of this list depending on client needs and complexity):
• Core services. All clients receive the following core services:
• Information Gathering and Assimilation: Advisor and client to exchange information regarding client goals, resources, liabilities, accounts, and risk tolerance. Advisor will assimilate data into a cohesive system for running projections, provide assistance opening, consolidating, or transferring accounts, and provide single sign-on access to a client portal for client ongoing access.
• Baseline Financial Goal Plan and Investment Plan Design: Advisor and client will work together to create an initial baseline financial goal plan, supplemented with an investment plan which includes an investment model and Investment Policy Statement (IPS). The baseline financial goal plan is a summary of resources and financial goals with a projection of the intersection of the two. The IPS will govern the trading and management of managed accounts. The baseline financial goal plan and the investment plan create the foundation for monitoring, measuring and adjusting client’s progress toward goals.
• Ongoing Services: With a baseline financial goal plan and investment plan in place, advisor will transition to recurring services that will provide support to client in the following areas:
• An Annual Plan Update to update, review, adjust and monitor client’s progress toward achieving the goals stated in the baseline financial goal plan and investment plan. Annually, the baseline financial goal plan, and if applicable, the investment plan, will be updated and then considered to be the current baseline financial goal plan and investment plan.
• Ongoing, Discretionary Investment Management for managed account(s) in accordance with IPS
• Managed Account(s) Titling and Beneficiary Designation review
• Review of ERISA Accounts. Upon request or at the annual plan update, advisor may review ERISA account investment selections, beneficiary designations, contribution amounts and type (pre-tax or Roth). Advisor does not manage these accounts and therefore these accounts are not considered “Managed Accounts”. Advisor will not obtain or maintain login access for any client ERISA accounts – review of these accounts will be accomplished via client screen share. Gold:
• In addition to the advisor’s core Silver services, the Gold service level includes (all or part of this list depending on client needs and complexity):
• In coordination with client’s tax professional(s), the incorporation of tax-efficient strategies (if applicable) such as asset location, rebalancing, tax-deferred and tax-free savings opportunities, tax-loss harvesting, Roth conversions, required minimum distribution(s), donor-advised funds and gifting of appreciated securities, and education planning (529 plans)
• An Estate Plan Review, or recommendation to update or create a set of estate documents by an estate attorney.
• Client Insurance Coverage Needs (risk mitigation) may be reviewed as applicable to include life, disability, and umbrella.
• Non-Standard Investment Asset Review: o Optionally, upon request only, and charged separately, a non-standard Investment Asset may be reviewed. While not exhaustive or inclusive of each item below, the consultation regarding non-standard investment assets may include such things as a review of marketing materials (or “pitch book”), limited due diligence of principals, review of investment vehicle structure or document(s), terms, liquidity, auditor(s), other relevant third-parties, risks, and position size considerations. Note: each analysis may incorporate significantly different considerations. non-standard Investment Assets may bear significantly higher and/or different risks than the assets managed by Advisor in Managed Accounts. Advisor will not track, monitor, price, value, trade or include non-standard Investment Assets in Managed Accounts. Non-Standard investment assets will not be included in the calculation of the Investment Management Fee. o A non-standard investment asset review charge of $1,000 will be due upon delivery of each review.
• Additional Services Available: o Advisor has set the annual financial planning fee based upon the estimated client needs with respect to the topics and activities described above. However, we understand that circumstances change, and unexpected needs arise. We describe these as special situations, and we offer special situation support. Based upon the level of special situation support required, the annual financial planning fee will be evaluated and adjusted, if necessary, in accordance with the provisions in the Financial Planning and Investment Management Services Agreement. o Examples of special situation support are:  In conjunction with client’s other advisors (attorneys, consultants, insurance providers, tax professionals, lending professionals), review, resource coordination and/or analysis for topics such as:  Coordinated semi-annual tax planning meetings as requested  Cash-flow  Financing  Employee equity strategies  Employee contract review and benefit analysis  Business owner equity strategies to include exit strategies planning  Estate plan creation or revision with consideration to tax optimization, wealth transfer, intergenerational planning, risk mitigation  Specific decision analysis (buy or lease? second homes, paying off mortgages etc.)  Philanthropic endeavors  Divorce support by way of assistance with Qualified Domestic Relation Order(s) Platinum
• In addition to advisor’s core Silver services and those services provided at the Gold level, the Platinum service level includes (all or part of this list depending on client needs and complexity):
• Non-Standard Investment Asset Review: o Annually, a limit of two (2) non-standard investment asset(s) may be reviewed upon written request. While not exhaustive or inclusive of each item below, the consultation regarding non-standard investment assets may include such things as a review of marketing materials (or “pitch book”), limited due diligence of principals, review of investment vehicle structure or document(s), terms, liquidity,

auditor(s), other relevant third-parties, risks, and position size considerations. Note: each analysis may incorporate significantly different considerations. Non-standard investment assets may bear significantly higher and/or different risks than the assets managed by advisor in managed accounts. Advisor will not track, monitor, price, value, trade or include non-standard Investment assets in managed accounts. Non-standard investment assets will not be included in the calculation of the investment management fee. o Additional reviews of non-standard investment assets may be requested (to include a re- review, or review of a new non-standard investment asset). A non-standard investment asset review charge of $1,000 will be due upon delivery of each review beyond the two that are included with this service agreement.
• Additional Services Available: o Advisor has set the annual financial planning fee based upon the estimated client needs with respect to the topics and activities described above. However, we understand that circumstances change, and unexpected needs arise. Based upon the level of special situation support required, the annual financial planning fee will be evaluated and adjusted, if necessary, in accordance with the provisions in the Financial Planning and Investment Management Services Agreement. o Special Situation Support (as applicable): In conjunction with client’s other advisors (Attorneys, Consultants, Insurance Providers, Tax Professionals, Lending Professionals), review, resource coordination and/or analysis for topics such as:  Coordinated semi-annual tax planning meetings as requested  Cash-flow  Financing  Employee equity strategies  Employee contract review and benefit analysis  Business owner equity strategies to include exit strategies planning  Estate plan creation or revision with consideration to tax optimization, wealth transfer, intergenerational planning, risk mitigation  Specific decision analysis (buy or lease? second homes, paying off mortgages etc.)  Philanthropic endeavors  Divorce support by way of assistance with Qualified Domestic Relation Order(s) 2. NON-STANDARD FINANCIAL PLANNING SERVICES: (18-25 UNDER PARENTS, PRO BONO, HOURLY) 18-25 Under Parents and Pro Bono:
• These service levels include the following services (all or part of this list depending on client needs and complexity):
• Ongoing, Discretionary Investment Management for Managed Account(s) in accordance with IPS.
• Managed Account(s) Titling and Beneficiary Designation review.
• Review of ERISA Accounts. Upon request, advisor may review ERISA account investment selections, beneficiary designations, contribution amounts and type (pre-tax or Roth). Advisor does not manage these accounts and therefore these accounts are not considered “Managed Accounts”. Advisor will not obtain or maintain login access for any client ERISA accounts – review of these accounts will be accomplished via client screen share. Hourly Financial Planning Service (Hourly Service):
• This is an hourly consultation service billed at $300/hour on a quarterly basis in arrears. 3. RETIREMENT PLAN CONSULTING SERVICES: For clients who are seeking a retirement plan solution, we offer the following range of services: Limited Scope ERISA 3(21) Fiduciary:
• ASW may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions. As an investment advisor ASW has a fiduciary duty to act in the best interest of the client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using ASW can help the plan sponsor delegate liability by following a diligent process.
• Fiduciary Services are:
• Provide investment advice to the client about asset classes and investment options available for the plan in accordance with the plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. ASW acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the plan Sponsor with respect to the selection of a qualified default investment option for participants who are automatically enrolled in the plan or who have otherwise failed to make investment elections. The client retains the sole responsibility to provide all notices to the plan participants required under ERISA Section 404(c) (5) and 404(a)- 5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with client on a periodic basis to discuss the reports and the investment recommendations.
• Non-fiduciary Services are:
• Assist in the education of plan participants about general investment information and the investment options available to them under the plan. Client understands ASW’s assistance in education of the plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, ASW is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the plan participants. ASW will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees.
• ASW may provide these services or, alternatively, may arrange for the plan’s other providers to offer these services, as agreed upon between ASW and client.
• ASW has no responsibility to provide services related to the following types of assets (“Excluded Assets”): o Employer securities; o Real estate (except for real estate funds or publicly traded REITs); o Stock brokerage accounts or mutual fund windows; o Participant loans; o Non-publicly traded partnership interests; o Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or o Other hard-to-value or illiquid securities or property.
• Excluded Assets will not be included in calculation of Fees paid to ASW on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
• Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent.
• Wrap Fee Programs ASW does not sponsor any wrap fee programs. ASSETS UNDER MANAGEMENT ASW has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $334,634,854 $39,589,409 April 30, 2024