A. Description of Advisory Firm Physician Wealth Solutions Inc. (“PWS”) is a registered investment adviser with the U.S. Securities and Exchange Commission. PWS is a fee only investment advisory and financial planning firm. PWS can do business as Physician Wealth Solutions. PWS has been in business since September 2013. The principal owner of PWS is Setu Mazumdar, MD, CFP®, RICP®, AIF®. B. Types of Advisory Services General Description of Primary Advisory Services The following are brief descriptions of our advisory services. A detailed description of each service is provided in Item 5 – Fees and Compensation so that you can review the services and description of fees in a side-by-side manner. PWS provides three services: Investment management for individuals and families, financial planning for individuals and families, and qualified retirement plan consulting services for qualified retirement plans. Investment Management Investment management includes managing an investment portfolio across all accounts, including taxable, IRA, Roth IRA, SEP IRA, and other investment and retirement accounts mutually agreed upon by PWS and each client. For investment management PWS specializes in managing investments through diversified index and passively managed mutual funds and exchange traded funds. Index funds and passive mutual funds are mutual funds that do not attempt to “beat” the market or engage in market timing. Instead they provide broad diversification to each investment class in a low-cost way and attempt to match the returns of an investment class. Held-Away Asset Services In an effort to provide comprehensive wealth management, we offer advice, as requested by Clients, on held-away assets. This includes assets held outside PWS’ primary custodian, such as an employer-sponsored 401(k), 403(b) account, 529 account, separately managed accounts, as well as mutual funds or trusts. Under this service we will provide ongoing monitoring and guidance and integrate held- away assets into the client’s total portfolio. Held-away services include, but are not limited to, guiding a client on security transactions and helping rebalance held-away portfolios. The client is responsible for making the trades in held-away accounts. Financial Planning Financial planning services include reviewing personal and financial goals, reviewing insurance needs, doing cash flow analysis, retirement planning, reviewing estate plans, education planning, providing general financial advice on matters a client has questions about, and coordination with other consultants. Retirement Plan Services – Physician Wealth Solutions offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services Physician Wealth Solutions provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. Physician Wealth Solutions will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Investment Selection Services. Physician Wealth Solutions will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Monitoring. Physician Wealth Solutions will assist in monitoring investment options in the following ways: the custodian will prepare periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement, and Physician Wealth Solutions will make recommendations to maintain or remove and replace investment options.
• Non-Discretionary Investment Advice. Physician Wealth Solutions will provide you with general, non-discretionary investment advice regarding assets classes and investment options, consistent with the Plan’s investment policy statement.
• Default Investment Alternative Advice. Physician Wealth Solutions will provide non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). Physician Wealth Solutions acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Physician Wealth Solutions will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Physician Wealth Solutions to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Physician Wealth Solutions (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services Physician Wealth Solutions provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. Physician Wealth Solutions will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. PWS’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. Physician Wealth Solutions will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non-fiduciary should not be considered

fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. All recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investment recommendations of Physician Wealth Solutions and then physically make changes to the plan itself. In the event a client contracts with Physician Wealth Solutions for one-on-one consulting services with plan participants, such services are consultative in nature and do not involve Physician Wealth Solutions implementing recommendations in individual participant accounts. It will be the responsibility of each participant to implement changes in the participant’s individual accounts. PWS can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. Retirement plan consulting services are not management services, and Physician Wealth Solutions does not serve as administrator or trustee of the plan. Physician Wealth Solutions does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct PWS’s fees). In addition, PWS does not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by PWS is solely responsible for implementing all transactions. Physician Wealth Solutions will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that PWS is required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which PWS is informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond PWS’s control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), PWS will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond PWS’s control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If PWS makes an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), PWS will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which PWS learns of such error or omission. IRA Rollovers - When recommending that a client rollover his or her account from current retirement plan to an IRA, Physician Wealth Solutions and its investment adviser representatives have a conflict of interest. Physician Wealth Solutions and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, Physician Wealth Solutions and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan (unless a client retained Physician Wealth Solutions to provide advice about the client’s retirement plan account). Thus, Physician Wealth Solutions and its investment adviser representatives have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest. Physician Wealth Solutions has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA and has adopted an impartial conduct standard through its code of ethics whereby Physician Wealth Solutions and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Physician Wealth Solutions receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by Physician Wealth Solutions and its supervised persons and any material conflicts of interest related to Physician Wealth Solutions recommending the rollover of funds from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. To the extent Physician Wealth Solutions provides investment advice to a participant in a retirement plan under Employee Retirement Income Security Act of 1974 as amended ("ERISA") regarding whether to maintain investments and/or proceeds in an ERISA retirement plan, rollover such investment/proceeds from the ERISA retirement plan to an individual retirement account (“Rollover IRA account”) or make a distribution from the ERISA retirement plan, Physician Wealth Solutions hereby acknowledges its fiduciary obligations with regard to its investment advice about whether to maintain, rollover or distribute proceeds from those ERISA retirement plans, and as such a fiduciary with respect to its investment advice about whether to maintain, rollover or distribute proceeds from those ERISA retirement plans, Physician Wealth Solutions and its representatives shall act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Physician Wealth Solutions or its affiliates. C. Tailor Advisory Services to Individual Needs of Clients Our services are provided based on the individual needs of each client. This means, for example, that the client is given the ability to impose restrictions on their accounts, including restricting specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. D. Participation in Wrap Fee Programs PWS does not participate in wrap fee programs. E. Client Assets Managed by Physician Wealth Solutions, Inc. As of 12/31/22 PWS manages $201,158,690 in total assets. Of that total PWS manages $201,158,690 in discretionary assets and $0 in nondiscretionary assets.