Description of Advisory Firm Kingswood Wealth Advisors, LLC is a limited liability company formed in the State of Nevada on November 1, 2016 and is registered to conduct business as an SEC Registered Investment Adviser. KWA is headquartered in California and its affiliated investment advisor representatives (“Financial Advisors”) maintain independent offices throughout the U.S. Ownership KWA is wholly owned directly by Kingswood US, LLC (“KI”). KI is comprised of a family of affiliated financial service companies collectively registered, where required, to conduct securities and investment advisory activities. Specifically, KI is comprised of KWA and Kingswood Capital Partners, LLC (“KCP”), which is a FINRA registered broker-dealer and member of SIPC. KWA and KCP are collectively referred to in this document as KI. Advisory Services Offered KWA offers a variety of advisory services to retail and institutional investors through corporate and independent financial practices located throughout the U.S. KWA permits Financial Advisors to utilize alternative or “doing business as” (“d/b/a”) names for their advisory activities. As such, certain of KWA’s advisory services may be provided under alternative names, which are listed in Section 1.B of Schedule D of KWA’s Form ADV Part 1. Accounts managed through the Wrap Program are done so in substantially the same manner as those that are managed under a non-wrap arrangement. While this brochure generally describes the business of KWA, certain sections also discuss the activities of its Access Persons, herein mentioned as such, which refer to the Adviser’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on KWA’s behalf and is subject to the Adviser’s supervision or control. Description of the Program KWA sponsors/offers a Wrap Fee program which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Kingswood Capital Partners, LLC (“KCP”) or another broker-dealer that KWA approves under the Program (collectively “Financial Institutions”). At the onset of the Program, clients provide information describing 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, KWA assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary or non-discretionary basis by either KWA or a Third-Party Managers, as recommended or selected by the Adviser. KWA and/or the Third-Party Managers generally allocate clients’ assets among the various investment products available under the Program. KWA’s primary custodian is Raymond James Financial Services, Inc. (RJFS), which is used for custody of customer assets and execution of customer transactions. Raymond James & Associates, Inc. (RJA), an affiliate of RJFS and a member of the New York Stock Exchange (NYSE) and the Securities Investor Protection Corporation (SIPC), acts as the clearing agent in the execution of securities transactions placed through RJFS. RJFS’ involvement with KWA’s clients are exclusively that of a clearing and custodial firm/relationship. All investment decisions, due diligence, portfolio management, etc., are performed by KWA and are the sole responsibility of KWA. Accordingly, transactions through RJFS may result in higher commissions, greater spreads, or less favorable net prices than might be the case if KWA freely negotiated commission rates or spreads, or selected other broker-dealers or custodians on a competitive basis. RJFS charges commissions or markups/mark-downs on transactions. The foregoing notwithstanding, Adviser will monitor the execution capabilities and transaction costs of all broker-dealers it uses on an ongoing basis and may direct client securities transactions to other broker-dealers as appropriate. In addition to KWA, the Adviser also manages from time-to-time certain customer assets and accounts that may be held outside of RJFS (i.e. other custodians). Third Party Managers Based upon the objectives of the client, the Financial Advisor may recommend to certain clients that they authorize the active discretionary management of all or a portion of their assets by certain third-party managers that are not affiliated with KWA. Prior to selecting a third-party manager for a client, KWA conducts due diligence concerning the manager through assessing overall credentials, performance, as well as engaging the assistance of independent third-party institutions where deemed applicable. KWA shall continue to render services to the client and, in addition, monitor and review the performance of the third-party manager and the performance of the client’s accounts that are being managed accordingly. From time-to-time, Financial Advisor may also recommend affiliated investment managers to certain clients based on their investment objectives, guidelines, and risk profiles. KWA will monitor the performance of the selected managers. If KWA determines that a particular selected manager is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's goals and objectives, the Financial Advisor may suggest that the client contract with a different manager. In that case, the Financial Advisor will assist the client in selecting a manager. In order to assist clients with identifying and selecting an appropriate third-party money manager, KWA will typically gather information about each client’s financial situation, investment objectives, as well as any limits or restrictions considered for the management of account. KWA may provide advisory services for accounts managed by third party managers, but does not offer any advice or recommendations with respect to the selection of securities nor is it responsible for implementing any investment strategy or placing orders once determined by the client and selected third party money manager. Clients should refer to the selected manager's Firm Brochure or other disclosure document for a full description of the services offered. The client's Financial Advisor is available to meet with clients on a regular basis, or as determined by the client, to review the account. Advisory Fees and Compensation Advisory Fee Schedule The specific manner in which fees are charged by KWA is established in each client’s written IMA with KWA. Generally, and pursuant to such agreement, fees for the management of accounts are typically based upon a percentage of the total assets in the account (including margined assets). KWA typically receives an annual management fee that ranges up to 2.25% of the net asset value of the accounts subject to the IMA. All fees are negotiable and each Financial Advisor utilizes a different fee schedule; thus, fees differ per client. KWA also enters into flat fee arrangements from time-to-time, typically for administrative services provided to clients or client Accounts. Advisory Fee Billing Advisory fees are assessed and/or charged quarterly, based on prior quarter-end value. Fees are charged in advance unless agreed to in writing. For the initial period of engagement, the fee is calculated on a pro rata basis. Inflows and outflows of cash and securities are considered as well on a prorated basis when calculating fees. In the event the IMA is terminated, the fee for the final

billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Fees can be structured in one of the following ways: 1. Blended Management Fee: Total fee is calculated based upon sum of asset value times fee percentage in all asset ranges; 2. Breakpoint Management Fee: Total fee is calculated based upon total asset value times fee percentage of highest total asset value range; or 3. Flat Management Fee: Total fee is calculated based upon sum of asset value times fee percentage in all asset ranges. Fees are debited from clients’ custodial accounts. Custodians provide their clients with brokerage statements no less than frequently than quarterly. Such statement will reflect deduction of the advisory fee. Fees are collected by KWA from the amount of any contribution or transfer, from available cash in the client's account, from margin or by liquidating the client's assets held in the client's account in an amount equal to the fees that are due. Fee for Participation in the WRAP Program KWA’s Wrap Program is managed on either a discretionary or non-discretionary basis based on the terms outlined in the Investment Management Agreement, which include a minimum quarterly fee. As part of this agreement, the clients pay one fee (bundled fee) to KWA to cover Adviser’s advisory fees as well as commissions on transactions and custodian fees. The fee is bundled with KWA’s or the third-party money manager’s costs for executing transactions in client’s account(s), together your “wrap-fee”. This fee may also include other services, such as financial planning services. Wrapping these services together may result in a higher fee to the client than client would otherwise incur by paying for these services separately. The annual fee is not adjusted/reduced based on trading volume in account, so there is a chance that client would pay more by bundling the trading costs with the annual advisory fee based on the amount of trading being done in client’s account. The fees for the management of Accounts will be based upon a percentage of the total assets in the account (including margined assets). Adviser typically receives an annual management fee that ranges up to 2.25% of the net asset value of the Account. All fees are negotiable; thus, fees differ per client. Adviser also enters into flat rate arrangements from time-to-time, typically for administrative services provided to client or client Accounts. The wrap fee does not include annual account fees or other administrative fees, such as wire fees, charged by Third Party Manager or brokerage firm; certain odd-lot differentials, transfer taxes, postage and handling fees, and charges imposed by law with regard to transactions in the Client’s account; and advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds), closed- end investment companies or other managed investments, if any, held in Client’s account. The wrap fee also does not cover certain costs associated with securities transactions in the over-the-counter market, such as fixed income securities where Manager must approach a dealer or market maker to purchase or sell a security. Such costs include the dealer’s mark-up, mark-down or spread and odd-lot differentials or transfer taxes imposed by law. Platform Fees KWA assesses a “Platform Fee” to advisory accounts up to .25% (25 basis points), which is used to cover the cost of maintaining its platform and to offset certain administrative costs and services including, but are not limited to: arranging for custodial services to be provided by various custodians pursuant to a separate agreement between client and custodian; coordinating with custodians regarding delivery of comprehensive account services; preparation of quarterly performance reports (to complement account statements provided by custodians); and maintenance and access to an electronic or web-based inquiry system that provides detailed information on each client. The Platform fee is based on the market value of total assets in the accounts subject to an IMA. For accounts below KWA’s minimum account level of $100,000, such accounts will be assessed a $20.00 quarterly fee during the duration of time such account remains below the minimum account level. The Platform Fee constitutes an additional form of compensation for KWA and its investment adviser representatives and is a different a separate fee from advisory fee assessed by KWA for rendering advisory services. Termination Fees Upon 30-days written notice to KWA, the client has the right to terminate his or her advisory agreement with KWA without penalty or payment of additional fees. In the event the Client has pre-paid for any service, the Advisor will refund any pro-rata amount due to client, after deducting the $50 termination fee per account as disclosed in the IMA. The termination will not affect any liabilities or obligations from transactions initiated in clients’ accounts prior to the written notice. Fee Comparison As referenced above, a portion of the fees paid to KWA are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Services provided through the Program cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Therefore, the Adviser has an incentive to place less trades for clients in the Program since the Adviser incurs transaction expenses. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Fee Discretion KWA may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. Commissions and Sales Charges for Recommendations of Securities Clients can engage certain persons associated with KCP to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with KCP. Under this arrangement, the Adviser’s Access Persons, in their individual capacities as registered representatives of CPP provide securities brokerage services and implement securities transactions under a separate commission-based arrangement. Access Persons are entitled to a portion of the brokerage commissions paid to KCP, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. KCP may also recommend no-load or load-waived funds, where no sales charges are assessed. Prior to effecting any transactions, clients are required to enter into a separate account agreement with CPP. A conflict of interest exists to the extent that KCP recommends the purchase or sale of securities where its Access Persons receive commissions or other additional compensation as a result of the Adviser’s recommendation. The Adviser has procedures in place to ensure that any recommendations made by such Access Persons are in the best interest of clients. Compensation for the Sale of Securities Some Financial Advisors of KWA are also dual registered with KCP as registered representatives and receive compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, in their individual capacities as registered representatives of KWA’s affiliated broker- dealers, KCP. Financial Advisors who are solely registered with KWA do not receive such compensation with respect to accounts managed or advised by KWA.