Caldwell Advisors, LLC (Hereafter, “CA”) was founded in 2007 and provides both discretionary and non- discretionary advisory services to individuals, institutions, corporations, pension and profit-sharing plans and trusts (“Clients”). CA is a Tennessee Limited Liability Corporation and its sole member, Billy Ray Caldwell, Jr., is the principal portfolio manager. CA provides continuous advice to its Clients concerning the assets under CA's supervision or management. The assets can be made up of the following types of investment products: fixed income securities, equities, non-traded securities, mutual funds, options, and annuities. Advice is given at such times as CA determines that investment or reinvestments of such assets is appropriate on the basis of the individual goals of each Client and CA's assessment of the investment opportunities that are available from time to time. Additional advice is provided at such times as any Client requests information concerning a specific investment situation or investment problem. CA also provides certain administrative services to Clients including: maintaining the books and records relating to Client investments; placing orders for the purchase and sale of securities; and providing directions to custodians as necessary for the consummation of portfolio transactions. We at CA hold ourselves to a fiduciary standard, which means our firm and its associates will act in the utmost good faith and perform in a manner believed to be in the best interest of our Clients. As fiduciaries, we are obligated to put you - our Client - first. Through our annual review process and year-round communication with our Clients, we strive to understand all aspects of our Clients’ financial and life situations to better assist in helping them pursue their long-term goals and objectives. Communication between clients and portfolio manager is always encouraged. Formal meetings can be arranged periodically or communication can be by mail or phone contact. An account can be opened by depositing either cash or negotiable securities into a brokerage account. A client agreement will be signed either providing authorization for CA to make all investment decisions on a discretionary basis or after consultation with the client, depending upon which agreement is signed. From time to time, with client consent,

CA may engage sub-advisors through the LPL custodial platform to manage portions of client assets in situations where CA believes that certain expertise is warranted in a specific area (e.g. complex fixed income or foreign portfolios). In such arrangements, the fees may be negotiable and CA will collect the total fee and remit a portion thereof to the sub-advisor. Interest earned and dividends received are credited to each account and reinvested. If the client desires, however, a regular payout can be sent. The client may add or withdraw cash or securities at any time; however, instructions for a withdrawal must come directly from a client. The advisory agreement can be terminated in writing by either party at any time. There is no penalty for terminating the account. Upon termination the client receives a refund for the portion of the prepaid management fee which is not earned. CA may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee Program” for purposes of the SEC is a program under which investment advisory and brokerage execution services are provided for a single “wrapped” fee that is not based on the transactions in a client account. CA provides discretionary and non-discretionary investment advisory services to some of its clients through a Wrap Fee Program. CA will assist clients in determining the suitability of the Wrap Fee Program for the client. Wrap Fee Program accounts recommended by CA are not managed differently from non-Wrap Fee Program accounts. Because brokerage execution costs are included in the client’s overall advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule stated in CA’s Wrap Fee Brochure. All clients with Wrap Fee Program accounts will be provided with CA’s Wrap Fee Brochure. This Brochure is focused on non-Wrap Fee Program accounts. CA offers a clearing platform to execute securities business for investment advisory services, including Wrap Fee Program services, through Schwab Advisor Services division of LPL Financial. (“LPL”). Please see Item 12 – Brokerage Practices for additional information. As of December 31, 2023, Caldwell Advisors had $315,986,237 under management on a discretionary basis and $6,752,980 on a non-discretionary basis.