The Firm U.S. Capital Wealth Advisors, LLC (“U.S. Capital Wealth” “USCWA” or “the Firm”) is an investment advisor registered with the Securities & Exchange Commission (“SEC”). The main office of US Capital Wealth is located at 4444 Westheimer, Suite G500, Houston, Texas 77027. U.S. Capital Wealth initiated business operations in 2017 (formerly known as Legacy One Financial Advisors). U.S. Capital Wealth is currently directly owned by U.S. Capital RIA Investors, LLC, Legacy One Financial Holdings, LLC, and PLH Financial Holdings, LLC. However, on February 29, 2024, USCW Holdco, LLC agreed to purchase USCWA. As of the effective date, April 12, 2024, USCW Holdco, LLC will own USCWA. A second stage of the USCWA purchase will have USCW Holdco, LLC acquire the USCWA affiliates USCA Securities, LLC and USCA Insurance Agency, LLC. The second purchase is expected to be executed sometime in Q3 2024. Types of Advisory Services offered by U.S. Capital Wealth U.S. Capital Wealth offers a full suite of wealth management services to individuals, including high net-worth individuals, family offices, institutions, and businesses, which include discretionary and/or nondiscretionary account management as well as financial planning and general advisory or consulting services. Accounts receiving discretionary and non-discretionary account management services are generally held at one of the primary custodians recommended by the Firm, National Financial Services, LLC (“NFS”), which is a subsidiary of Fidelity Custody and Clearing Solutions (”FCCS”), or by Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”). In certain limited circumstances, U.S. Capital Wealth provides consulting services and advice on accounts or assets held away from its primary custodians, including hedge funds and other types of types of investments. Additionally, U.S. Capital Wealth sometimes recommends to clients that all or a portion of their portfolio be managed on a discretionary basis by one or more affiliated or unaffiliated money managers, sub-advisors, or investment platforms (collectively “External Managers”). Available Advisory Services Discretionary Investment Management by USCWA Client will be provided ongoing management of designated assets or accounts by a USCWA Financial Adviser or Advisory Team that is selected and designated by Client. The selected USCWA Financial Adviser or Advisory Team will be responsible for the investment and reinvestment of assets, building and maintaining investment portfolios, and executing investment strategies designed to meet Client’s investment objectives and risk tolerance. Clients selecting this option will appoint the selected USCWA Financial Adviser or Advisory Team as Client’s attorney-in-fact and grant them a limited power-of-attorney with discretionary trading authority over the designated assets or accounts to buy, sell, or otherwise effect investment transactions involving the assets or accounts. Each Financial Adviser has multiple tools to assist in constructing, trading, monitoring and rebalancing portfolios. Page 6 of 41 U.S. Capital Wealth Advisors, LLC Form ADV Part 2A Rev. March 28, 2024 Non-Discretionary Investment Management by USCWA Client will be provided ongoing non-discretionary management of designated assets or accounts by a USCWA Financial Adviser or Advisory Team who will recommend portfolio approaches including buys, sells and trades in a variety of instruments based on the client’s investment objectives and risk tolerance. Client can request additional services such as asset allocation, research, analysis and performance reporting. Upon client’s approval, USCWA will execute such trades in client’s account(s). Discretionary Investment Management by External Managers. USCWA will recommend one or more External Managers to conduct active discretionary management of client assets or accounts in accordance with client’s investment objectives and risk tolerance. External Managers will be granted a limited power-of-attorney and trading authority over those assets directed to them for management, and they will be authorized to, without client’s consent, buy, sell and trade in securities in the account. USCWA will render services to clients relative to the supervision of the External Managers and ongoing monitoring of account performance, asset allocation and investment objectives. When an External Manager is used, the client continues to have direct ownership of the securities in the portfolio. The client will receive an agreement and/or other disclosures describing the services to be provided by the External Manager. The fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by USCWA. In some cases, clients will be charged separately for the External Manager’s fee. In other cases, USCWA will share a portion of its fee with the External Managers. The manner of billing and the amount received by the External Manager will be disclosed to the client. External Managers used by USCWA include Envestnet Asset Management, Inc. (“Envestnet”). USCWA offers several of Envestnet’s Private Wealth Management Programs. This includes Envestnet’s Separately Managed Accounts (“SMA”). SMA offers clients discretionary asset management in separately managed accounts by one or more third-party portfolio managers available through Envestnet. USCWA also uses Piton Investment Management, LP (“Piton”) as an External Manager for some of its accounts. Piton is an SEC-registered investment advisor focusing on fixed income investment management services to institutions and individual investors. Certain managers of US Capital Wealth are also managers of Piton. See Item 10 Additional Information – Other Financial Industry Activities and Affiliations for more information regarding this relationship. USCWA also uses 55I, LLC (also known as 55ip) as an External Manager for some of its accounts. If 55I, LLC is used it acts as a sub-advisor to some or all assets held in the client accounts and affects transactions based on the model portfolios selected by the USCWA Advisor. The models available to the Financial Adviser were selected by USCWA. These models predominantly (sometimes exclusively) utilize BlackRock and iShares ETFs. 55I, LLC is paid a fee by BlackRock, which allows 55I to provide this service at no additional fee to USCWA or the client, subject to specific terms and conditions. Other External Managers are also used. See Item 10 Additional Page 7 of 41 U.S. Capital Wealth Advisors, LLC Form ADV Part 2A Rev. March 28, 2024 Information – Other Financial Industry Activities and Affiliations for more information regarding related conflicts. General Advisory Services In connection with non-discretionary accounts, which can be wholly independent of USCWA or maintained as USCWA accounts, USCWA will provide other types of advisory services to the client, which can include investment policy advice and assistance, developing asset allocation strategies, manager selection

and evaluation, or review of outside accounts to assist with adherence to investment policy guidelines and providing consolidated reporting. The types of service will be tailored to the needs of the clients based on investment objectives and risk tolerance. Services will be outlined in the agreement with the client. In certain limited circumstances, U.S. Capital Wealth provides advice on accounts held at custodians other than Schwab or NFS, in which the client directs brokerage services to a third- party. U.S. Capital Wealth’s approach to providing service to outside accounts is generally the same as for accounts maintained at its primary custodians. Services will be provided in accordance with the client’s stated investment objectives and risk tolerance. However, U.S. Capital Wealth will often not have access to the same account management tools that it has when services are provided through its primary custodians. Additionally, U.S. Capital Wealth Financial Advisers might not be able to directly effectuate investment decisions in accounts using other broker-dealers. Directions instead can be provided to the client or an agent for the client. Therefore, the handling of these accounts often differs with regard to the degree of comprehensiveness and directness of the services provided. USCWA also provides advice on investments in private placements or alternative investments, including hedge funds or limited partnerships, held away from the Firm’s primary custodians. Where appropriate, U.S. Capital Wealth Financial Advisers recommend such investments and provide monitoring services or assist with allocations within the investment. These investments can be managed or offered by affiliates of U.S. Capital Wealth. Conflicts of interest exist when a U.S. Capital Wealth Financial Adviser recommends an affiliated investment because the Financial Adviser and the affiliated entities benefit. More detail regarding such conflicts can be found in Section 10 - Other Financial Industry Activities and Affiliates. U.S. Capital Wealth provides advice related to variable life insurance and other insurance-related products, and assets held in employee sponsored retirement plans and qualified tuition plans (for example, 529 plans) that are maintained at the underwriting insurance company or the custodian designated by the product’s provider. For such assets, U.S. Capital Wealth will generally direct or recommend the allocation of client assets among the various investment options available within the product. Fee-Based Financial Planning Services Fee-based financial planning offers clients an opportunity to develop a customized financial plan designed to illustrate their overall current financial situation. It is primarily offered by U.S. Capital Wealth Financial Advisers who have earned and maintain the Certified Financial Planner (CFP®) certification. The goal of the financial planning process is to work with the client to develop a customized financial plan (“Plan”) that provides a comprehensive written report reflecting the Page 8 of 41 U.S. Capital Wealth Advisors, LLC Form ADV Part 2A Rev. March 28, 2024 client’s current financial situation and identifies future opportunities, projections or plans. In conjunction with the client’s stated goals, the planning process will often include some or all of the following: comprehensive balance sheet review; lifetime cash flow analysis; survivorship cash flow analysis; corporate executive benefits review; insurance planning; estate documents review; wealth transfer planning; review estate planning needs and goals; philanthropic planning; detailed “cash flow” projections of present financial condition; alternative “cash flow” projections of hypothetical impact of planning recommendations; investment and wealth transfer strategies; tax planning, including estimates of gross estate and income taxes; analysis of the impact of establishing proposed foundations or trusts; and forecasts of assets available to surviving heirs. However, U.S. Capital Wealth does not directly render tax or legal advice. Fee-based Financial Planning Services are generally provided for an annual fixed fee charged at the initiation of the financial planning relationship and annually thereafter if desired by the client. Clients can place restrictions on securities or types of securities to be considered in the financial plan, if applicable. A Financial Adviser will work with the client to ascertain the full scope of services and the approximate amount of time that the proposed engagement will take, which will allow for the calculation of the fixed fee contract amount. Financial Planning Services will often include quarterly meetings, though meetings are sometimes more or less frequent. There is no obligation for the continuation of financial planning services unless the client and Financial Adviser agree to extend the term of the services. Should the client want additional services, such as investment advisory services, traditional brokerage services, or lending or insurance services, they will be agreed to and additional fees will be charged separately. Customization of Advisory Services Each client’s needs are different. U.S Capital Wealth tailors its wealth management services to the needs of each client. In order to provide appropriately customized services, the client’s Financial Adviser will work with the client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile, and other information regarding financial and investment needs. For the Firm to provide effective advisory services, it is important that clients provide accurate and complete information to the Firm and update their information when there is any change in circumstances, objectives or risk tolerance. It is an objective of the Firm to meet with clients at least annually (either in person or remotely) to review their financial circumstances, investment objectives and risk profile, although in many cases U.S. Capital Wealth Financial Advisers have more frequent and regular client contact. Clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts provided U.S. Capital Wealth determines that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for U.S. Capital Wealth’s management efforts. However, it is often not possible to accommodate restrictions when utilizing ETFs, mutual funds or with respect to certain third-party products or services. The ability to add reasonable trading restrictions for External Managers will depend on what the specific External Manager allows. Page 9 of 41 U.S. Capital Wealth Advisors, LLC Form ADV Part 2A Rev. March 28, 2024 Breakdown of Assets of Under Management As of February 29, 2024, U.S. Capital Wealth Advisors had approximately $6,817,172,721 in assets under management. Of that amount, $4,915,722,542 was managed on a discretionary basis and $1,901,450,179 was managed on a non-discretionary basis.