The Company SWS Partners, LLC (“we,” “us” or “SWS”) is an Ohio limited liability company owned by Kessler Wealth Advisors LLC. Kessler Wealth Advisors LLC is owned by James F. Parker (50%) and Philip Kessler (50%). SWS has been providing investment advisory services since November 2015. Advisory Services SWS provides personalized, confidential financial planning, investment management and consulting services to individuals, multi-family home offices, pension and profit-sharing plans, trusts, estates, charitable organizations, and small businesses. We consult with you and provide advice with respect to one or more of the following:
• Determining your financial objectives
• Identifying financial challenges
• Budgeting, cash flow analysis and debt management
• Retirement needs analysis
• Qualified and non-qualified employee/executive benefit planning
• Financial coaching
• Charitable, college and estate planning
• Tax planning
• Insurance and long-term care planning
• Investment and real estate planning
• Business and succession planning Our services are for clients seeking a personalized approach to implementing an individually customized strategy designed to meet their investment goals and objectives through portfolio monitoring and quarterly reporting. We work with clients to understand their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, SWS assists its clients in developing an appropriate strategy for managing their assets and financial affairs. We manage client accounts primarily on a discretionary basis but can accommodate clients who prefer their assets be managed on a non-discretionary basis. Assets managed within our wrap program must be on a discretionary basis. This individualized approach allows us to work with you to achieve your investment goals. At the beginning of SWS’s relationship with you, we review your current investment portfolio, obtain information necessary to understand your current and expected financial situation, discuss with you your investment history, objectives, special interests, and risk tolerance, and make recommendations regarding your portfolio. Additionally, you can participate in regular planning meetings, telephone consultations and educational seminars. We offer the following advisory services to assist clients in achieving their unique goals and objectives. The different services offer clients a personalized approach to implementing an investment strategy through asset allocation, portfolio monitoring and consolidated reporting. SWS Automated SWS provides portfolio management services through an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. SWS Automated is offered exclusively as a wrap fee program; please see SWS Automated Wrap Fee Program Brochure for details. SWS Private Client SWS’s private client services are designed to meet the challenging and diverse needs of its high-net-worth clients. These services are available to those high-net-worth clients that have committed at least $2,000,000 to SWS for portfolio management and is offered exclusively as a wrap fee program; please see SWS Private Client Wrap Fee Program Brochure for details. SWS private clients receive the following:
• Individually managed tactical portfolios constructed from ETFs, private equities, and individual equities.
• Real-time investment report incorporating performance measurement of the investments in accordance with the client’s investment objectives through Addepar.
• Banking – Assistance in establishing banking relationships, lending and credit facilities, and related services to meet your investment and business needs.
• Alternative Investments – SWS will recommend alternative investment managers that meet the client’s needs, including direct partnerships and fund of funds. SWS will also provide ongoing review of the managers and recommendations of new managers.
• Portfolio reporting through Addepar. SWS Financial Planning SWS will provide advice on one or more of the following issues:
• Determining your financial objectives
• Identifying financial challenges
• Budgeting, cash flow analysis and debt management
• Retirement needs analysis
• Qualified and non-qualified employee/executive benefit planning
• Financial coaching
• Charitable, college and estate planning
• Tax planning
• Estate/Trust planning
• Insurance and long-term care planning
• Investment and real estate planning
• Business and succession planning
• A minimum of four meetings per year with financial planner
• Client can call planner on an unlimited basis Under this service, SWS’ recommendations (e.g., investments, estate planning, taxes, insurance, etc.) shall be discussed by SWS with the client and may be implemented, at the client’s sole discretion, with the corresponding professional adviser(s) (e.g., broker, accountant, attorney, etc.) of the client’s choosing, which may (but need not) be SWS. The client is free to obtain legal, accounting, and brokerage services from any professional source to implement SWS’ recommendations and the client will retain absolute discretion over all implementation decisions. Under this service, SWS’ services do not include investment supervisory or management services, nor the regular monitoring of the Client’s investment portfolio. To add these services, a separate investment advisory agreement must be entered into between SWS and the client. SWS Multi-Family Office SWS shall provide multi-family offices the following non-discretionary services:
• Single point of contact for all financial matters.
• Access to the full breadth and depth of the SWS team of specialists to include, where ap p r o p r i at e : 1) access to direct alternative assets such as real estate/private equity/ venture capital; 2) reviewing and providing due diligence on third party managers/investment products; 3) providing strategic advice when requested regarding alternative assets such as real estate, private equity, and venture capital; and providing advice and counsel

where necessary as it pertains to estate and succession planning.
• Comprehensive goals-based financial planning consisting of, where appropriate: 1) reviewing and prioritizing your goals and objectives of your current financial situation; 2) completing a succession planning assessment, including financial projections of assets required to maintain lifestyle while achieving additional life goals; 3) assessing exposure to financial risk and developing a risk management plan, where applicable; and 4) identifying tax planning strategies to optimize financial position, where applicable.
• Reviewing current investment portfolio and suggesting an asset allocation for those assets.
• Integrating and engaging with other professionals, as required, to assist with implementation of the action plan.
• Total portfolio administration and reporting through Addepar.
• Yearly retainer fee based on the terms of the engagement, charged quarterly. Under this service, SWS’ recommendations (e.g., investments, estate planning, taxes, insurance, etc.) shall be discussed by SWS with the client and may be implemented, at the client’s sole discretion, with the corresponding professional adviser(s) (e.g., broker, accountant, attorney, etc.) of the client’s choosing, which may (but need not) be SWS. The client is free to obtain legal, accounting, and brokerage services from any professional source to implement SWS’ recommendations and the client will retain absolute discretion over all implementation decisions. Under this service, SWS’ services do not include investment supervisory or management services, nor the regular monitoring of the Client’s investment portfolio. To add these services, a separate investment advisory agreement must be entered into between SWS and the client. SWS Institutional Asset Management Under its institutional arm SWS Institutional Asset Management, SWS offers a suite of institutional services to other investment advisers, large institutions, and multi-family offices. These services are designed for institutional clients with portfolio assets of at least $20,000,000 to assist in delivering portfolio management services that are consistent with the institution’s investment policy mandate. SWS offers the following services:
• Discretionary investment program designed for taxable and tax-exempt institutions on a separate account basis. SWS Managed Account Programs SWS participates in sub-advisory programs, sometimes referred to as SMA programs, where we furnish investment advice and recommendations by managing and executing separately managed accounts as the program’s investment manager. This service is offered via Charles Schwab’s Managed Account Marketplace ® platform. The firms that offer our SMA programs are solely responsible for determining the suitability of our program for their clients, and we manage and execute trades for these accounts. The firms are also responsible for providing all administrative and performance reporting services to their clients. On occasion, these SMA programs can hold slightly different funds than SWS’s direct advisory accounts due to position restrictions imposed by the client. SWS has the ability to obtain waivers in some cases and makes every effort to obtain access to restricted funds. Because of this fact. the performance between our standard direct models and our platform models can and will differ. SWS Outsourced Chief Investment Officer (“OCIO”) SWS provides OCIO services to other investment advisers, large institutions, corporations, and multi-family offices. SWS offers the following services as part of its OCIO program:
• Discretionary investment program designed for taxable and tax-exempt institutions on a separate account basis.
• Portfolio construction generally comprised of a diversified portfolio of index funds, mutual funds, separately managed accounts, exchange traded funds and/or commingled fund products. Includes all of the following:
• Investment Policy Statement: SWS will assist the client in drafting a policy or modifying a current policy that specifies the client’s goals and objectives, as well as the asset allocation targets and ranges, the performance and risk benchmarks, manager guidelines and restrictions, how the managers will be evaluated, and concludes with an acknowledgement section where all applicable constituents attest to these policies. SWS will assist the client in the ongoing review and implementation of the Investment Policy Statement on at least an annual basis and recommend updates as needed.
• Asset Allocation Study: Based on the client’s return objectives and risk tolerance, SWS will assist the client in developing the appropriate asset mix. SWS will review the asset allocation annually.
• Performance Reports: Clients receive real-time investment reports incorporating performance measurement of the investments in accordance with the client’s investment objectives through Addepar.
• Alternative Investments: SWS will recommend alternative investment managers that meet the client’s needs, including direct partnerships and fund of funds. SWS will also provide ongoing review of the managers and recommendations of new managers. SWS Consulting On a case-by-case basis, SWS will provide business consulting for institutional or individual investors of institutional size (e.g., family offices) who are interested in better understanding the impact of their current internal investment management operations and/or asset allocation. A fixed retainer will be based on the type of consulting needed, the size of the portfolio, complexity, and length of time of engagement. Client-Tailored Services and Client-Imposed Restrictions We will work with you to accommodate reasonable restrictions in any investment strategy. You must advise us of any such restrictions in writing, and you should be aware that imposing investment restrictions could adversely affect the performance of your account. Wrap Fee Programs SWS Private Client and SWS Automated are both offered exclusively as wrap fee programs, where the client receives investment management and portfolio transaction services for a single fee based on the amount of assets in the account. Please see the SWS Private Client Wrap Fee Program Brochure and the SWS Automated Wrap Fee Program Brochure for details. Assets Under Management As of December 31, 2023, SWS managed $353,460,038 in discretionary assets and $0 of non- discretionary assets.