A. Dew Wealth Management (the “Registrant”) is a limited liability company formed on July 23, 1999 in the state of Arizona. The Registrant became registered as an Investment Adviser Firm in November 1999. The Registrant is wholly owned by Dew Holdings, Inc. B. As discussed below, the Registrant offers to its clients (individuals, high net worth individuals, pension and profit-sharing plans, and charitable organizations, etc.) varying levels of investment advisory services, in addition to financial planning and related consulting services. FAMILY OFFICE ASSESSMENT Registrant’s Family Office Assessment is a multi-step processes designed to perform a deep dive into a client’s current personal and/or professional wealth management situation, in an effort to identify gaps and potential points of weakness and, ultimately, develop recommendations for improvement. The Family Office Assessment may be performed as a precursor to one or more of Registrant’s other advisory programs (described further below) or may be purchased on a separate standalone basis. The Family Office Assessment is designed to give clients a broad based review of their current personal financial situation, in order to develop recommendations for closing the wealth management gap. For clients who are business owners, the services rendered under the Family Office Assessment may also be tailored to establish an approximate valuation for the client’s business, identify key revenue drivers, and develop recommendations for improving the value of the client’s business. Registrant will first work with the client to gather relevant information about the client’s wealth management situation from various sources, including the client, and the client’s other engaged professionals, such as: CPA/Bookkeeper, estate attorney, personal insurance agent, life/disability insurance agent, investment adviser, and/or banker. Once relevant data has been collected, Registrant will coordinate for a one-hour discovery phone call, to cover topics such as the client’s: values, goals, relationships, assets, advisors, and interests. When the discovery call is complete, Registrant will take the collected information and use it to review the client’s wealth management situation. Depending on the client’s circumstances, this review will generally take approximately four weeks to complete and can cover topics including: personal insurance, life insurance, disability insurance, estate documents, asset protection plan, investments, and personal tax returns. The Family Office Assessment process concludes with a one hour review call. In this call, the Registrant will provide an approximate current business valuation and will advise the client on potential recommendations intended to increase business revenues and, ultimately, increase the valuation. For clients who are business owners, Registrant will explain the identified gaps in the client’s wealth management situation and will advise the client on potential recommendations for closing such wealth management gaps. WEALTH BUILDER The Registrant’s Wealth Builder service is a two-year program in which the client will be expected to participate in a bi-monthly, learning management system-driven curriculum to take point in the build out of their own Virtual Family Office. Upon engagement for Wealth Builder services, clients will gain immediate access to the following resources:
• Bi-monthly one on one calls with Registrant
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Access to a Personalized Online Net Worth Dashboard In addition to the above, over the course of the two-year program, Wealth Builder clients will also receive, to the extent applicable:
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review WEALTH ACCELERATOR In Wealth Accelerator engagements, Registrant will generally work alongside the client’s other engaged professionals in an effort to coordinate all aspects of the client’s financial profile. Registrant may be asked to evaluate the client’s other engaged professionals and, if needed, find and recommend replacement professional service providers. Registrant, as needed, may also be asked to identify experts for consultation in the event the client’s current team of engaged professionals are unable to adequately address a client’s needs in various niche disciplines. In addition to the above, to the extent specifically requested by the client, the Wealth Accelerator program can also provide:
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
• Access to a Personalized Online Net Worth Dashboard
• Advanced Tax Planning and Projections
• Business Valuation and Enterprise Value Optimization
• Financial Statement Review and KPI Benchmarking
• Private Deal Reviews (2/quarter)
• Cash Flow Management
• Time/Energy Shield
• Advanced Entity Optimization and Corporate Governance
• Ad hoc meetings and consultations on an as-needed basis, with up to three days lead time VIRTUAL FAMILY OFFICE The Virtual Family Office is generally designed for clients who run successful businesses, generate a high level of cash flow, and have a need for advanced financial planning and coordination with outside professionals. In such engagements, Registrant will generally work alongside the client’s other engaged professionals in an effort to coordinate all aspects of the client’s financial profile. Registrant may be asked to evaluate the client’s other engaged professionals and, if needed, find and recommend replacement professional service providers. Registrant, as needed, may also be asked to identify experts for consultation in the event the client’s current team of engaged professionals are unable to adequately address a client’s needs in various niche disciplines. In addition to the above, to the extent specifically requested by the client, the Virtual Family Office program can also provide:
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• 3rd Party Investment Management Review and In House Management
• Entity and Corporate Governance Review
• Access to a Personalized Online Net Worth Dashboard
• Advanced Tax Planning and Projections
• Business Valuation and Enterprise Value Optimization
• Financial Statement Review and KPI Benchmarking
• Private Deal Reviews (2/quarter)
• Cash Flow Management
• Time/Energy Shield
• Advanced Entity Optimization and Corporate Governance
• Family Office Subject Matter Expert Support
• Advanced Life Insurance and Liquidity Planning
• Domestic and Foreign Asset Protection Trusts
• Irrevocable Family Dynasty Trust Planning
• Advanced Charitable Designs
• Second Generation Education
• Advanced M&A Planning and Teambuilding
• Post-Exit Estate, Cash Flow and Investment Allocation Planning
• Proactive Deal Flow
• Access to The Inner Circle
• Ad hoc meetings and consultations on an as-needed basis, with up to three days lead time MAINTENANCE MODE The Maintenance Mode service is designed primarily for clients who have established a functional Virtual Family Office setup and who need ongoing assistance in coordinating and administering their Virtual Family Office. Upon engagement for Maintenance Mode services, clients will gain immediate access to the following resources:
• Quarterly one on one calls with Registrant
• Access to The Entrepreneur’s Virtual Family Office ™ System
• Monthly Wealth Acceleration Group Calls
• The Entrepreneur’s Rolodex and Forum
• Access to a Personalized Online Net Worth Dashboard In addition to the above, to the extent specifically requested by the client, the Maintenance Mode program can also provide:
• Tax Planning Strategies and Projections
• Personal Liability and Income Insurance Review
• Business Liability and Income Insurance Review
• Estate Planning Review
• Billionaire Investment Allocation and Glidepath
• Third-Party Investment Management Review and In House Management
• Entity and Corporate Governance Review INVESTMENT MANAGEMENT Registrant’s various other service offerings may also be combined with Registrant’s discretionary or non-discretionary investment management services, for an additional asset-based fee. FINANCIAL PLANNING AND CONSULTING (STAND-ALONE) To the extent requested by a client, the Registrant may determine to provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) either inclusive of the client’s discretionary or non-discretionary investment management services or on a stand-alone separate fee basis. For standalone engagements, Registrant’s planning and consulting fees are negotiable, but generally range from $1,000 to $20,000 on a fixed fee basis, and from $300 to $750 on an hourly rate basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging the Registrant to provide standalone planning or consulting services, clients are generally required to enter into an agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for rendering additional services or implementing Registrant’s recommendations. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such decisions and is free to accept or reject any recommendation from the Registrant. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. RETIREMENT CONSULTING The Registrant also provides non-discretionary pension consulting services, pursuant to which it assists sponsors of self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from which plan participants shall choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, the Registrant shall also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between the Registrant and the plan sponsor. EDUCATIONAL WORKSHOPS AND SEMINARS Registrant offers two-day workshops in which attendees can learn about financial and investment concepts to help guide them in their financial journey. These workshops are not tailored to any attendee’s circumstances and are not intended to constitute individualized advice. Attendees who sign up for Registrant’s Wealth Builder service while attending a Registrant-sponsored workshop will be eligible to receive a one month

Wealth Builder fee waiver. Please see Item 5 below for additional information. Registrant may also participate in educational seminars/workshops sponsored by third- parties that focus on investment and non-investment matters. These seminars are limited in nature and are not intended to provide the participants with personalized investment advice. Registrant typically does not receive compensation in connection with its participation in such seminars/workshops and fees paid to attend these third-party seminars/workshops are generally retained by the program’s sponsor. Program attendees are often invited to engage the program sponsor and/or one or more workshop/seminar presenters for the provision of additional services. For example, attendees may be invited to purchase a bundle of additional services, a portion of which bundle includes services to be rendered by Registrant. Although Registrant’s services would be included in this bundle, Registrant would generally not receive any portion of the compensation paid to receive such bundled services. MISCELLANEOUS Limitations of Family Office Assessments, Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by the client, Registrant may provide Family Office Assessments, financial planning, and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Registrant does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Registrant does not prepare estate planning documents or tax returns. To the extent requested by a client, Registrant may recommend the services of other professionals for implementation purposes (e.g., attorneys, accountants, insurance agents, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Registrant and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Independent Managers. Registrant may allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will have day-to-day responsibility for the active discretionary management of the allocated assets. Registrant will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The factors Registrant considers in recommending Independent Manager(s) include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Registrant’s advisory fee as set forth in Item 5. Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a non-discretionary basis must be willing to accept that Registrant cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that Registrant would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, the Registrant will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Retirement Rollovers: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If the Registrant recommends that a client roll over their retirement plan assets into an account to be managed by the Registrant, such a recommendation creates a conflict of interest if the Registrant will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant. ERISA / IRC Fiduciary Acknowledgment. When Registrant provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way Registrant makes money creates some conflicts with client interests, so Registrant operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, Registrant must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put its financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Registrant gives advice that is in the client’s best interest;
• Charge no more than is reasonable for Registrant’s services; and
• Give the client basic information about conflicts of interest. Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Registrant independent of engaging Registrant as an investment adviser. However, if a prospective client determines to do so, he/she will not receive Registrant’s initial and ongoing investment advisory services. Registrant utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through certain approved registered investment advisers. Thus, if the client was to terminate Registrant’s services, and not transition to another adviser who is approved to trade in DFA funds, restrictions regarding additional purchases of, or reallocation among other, DFA funds will generally apply. Data Aggregation Platforms. Registrant may provide its clients with access to online data aggregation platform(s). The platform(s) allows a client to view their complete asset allocation, including those assets that Registrant does not manage (the “Excluded Assets”). Registrant does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Registrant shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Registrant, shall be exclusively responsible for such investment performance. The client may choose to engage Registrant to manage some or all of the Excluded Assets pursuant to the terms and conditions of a services agreement between Registrant and the client. The platform(s) also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Registrant. Finally, Registrant shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the platform(s) without Registrant’s assistance or oversight. Cash Positions. Registrant considers cash and cash equivalents to be a material component of a client’s asset allocation. Depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), the Registrant may maintain cash and cash equivalent positions (such as money market funds, etc.) for defensive, liquidity, or other purposes. Unless otherwise agreed in writing, all such cash positions are included as part of assets under management for purposes of calculating the Registrant’s advisory fee. Clients are advised that, at any given time, Registrant’s annual fee may exceed the yield earned on cash and cash equivalent positions. Periods of Portfolio Inactivity. Registrant has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment management services, Registrant will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in the client’s investment objective. Based upon these and other factors, there may be extended periods of time when Registrant determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Registrant will be profitable or equal any specific performance level(s). Investment management clients remain subject to Registrant’s asset-based fees during such periods of account inactivity. Legacy Engagements. Certain of Registrant’s clients remain engaged with Registrant for legacy services and/or fee arrangements, which services and/or fee arrangements are not described in this Brochure and are no longer offered to new clients. Such legacy clients are advised to consult their executed agreement(s) with Registrant for further details. Trade Error Policy. Registrant shall reimburse accounts for losses resulting from the Registrant’s trade errors, but shall not credit accounts for such errors resulting in market gains, unless it is the policy of the respective custodian/broker-dealer. Where permitted by the custodian/broker-dealer, the gains and losses are reconciled within the Registrant’s custodian firm account and Registrant retains the net gains and losses. Certain custodians/broker-dealers that the Registrant has relationship with may net trade gains with losses and donate any proceeds to charity. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other designated professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. Unaffiliated Wrap Programs. Registrant does not offer a wrap fee program for its investment management services. However, Registrant is a participating investment adviser in certain unaffiliated wrap and managed account fee programs, including wrap fee programs sponsored by AssetMark. With respect to the wrap-fee program in which Registrant is a participating investment adviser, clients pay a separate and additional wrap fee directly to the wrap fee program sponsor. Under a wrap program, the wrap program sponsor arranges for the investor participant to receive investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the participant more or less than purchasing such services separately. E. As of December 31, 2023, the Registrant had $184,371,301 in assets under management on a non-discretionary basis and $109,499,361 in assets under management on a discretionary basis.