A. The Firm and Principal Owners Blacktower Financial Management (US) LLC provides financial planning and money management services primarily to individuals and high net worth individuals. Our history in the financial services arena dates back to 1986 - when the founding Company Blacktower Financial Management Ltd was established. Following this, our international footprint commenced in 2003 when Blacktower Financial Management (International) Limited was formed to provide services to expatriates throughout the EU. Blacktower Financial Management (US) LLC is owned by BFM Administrative Services LTD., which is wholly owned by John Westwood and Lyndsay Westwood. Blacktower Financial Management (US) LLC is an investment adviser that consists of many independent contractors who have affiliated with us as Advisory Representatives to offer the advisory services and programs described within this brochure. Advisory Representatives have a direct interest in the fee charged to you since we will pay a portion of the advisory fee charged to you to your Advisory Representative. It is important to refer to Item 5 – Fees and Compensation below. Our Advisory Representatives cannot exceed the fee disclosed under Item 5 below. However, the negotiability and the fee that you will pay for advisory services is determined between you and your Advisory Representative. Therefore, another Advisory Representative will charge more or less for the same services. B. Types of Services Offered We primarily offer investment advisory services to UK expatriates with residency in the United States of America. We also work with US citizens seeking financial planning and investment advisory services as well as US expatriates who have US retirement accounts and provide asset management services. In addition, and, to the extent specifically requested by the client, Blacktower also provides financial planning and consulting services. We offer the following investment programs to clients. Please see Item 8 below for additional information on the investment programs and material risks. i. Pension Plan Investment Services We work with UK expatriates to transfer their existing pension scheme(s) from former employers into a self-directed retirement plan in a tax compliant structure. Currently, the structure most commonly used is a Self-Invested Personal Pension ("SIPP"), which is a regulated pension product in the United Kingdom. The assets of the structure are then invested through an investment platform (the "Investment Platform Provider"). All funds are custodied with the pension provider or the investment platform and not with Blacktower Financial Management (US) LLC. Form ADV Part 2A 7 | P a g e The process of transferring a UK defined benefit or contribution plan is a complex and lengthy process with many layers of fees as further described below in Item 5. Defined benefit transfers will require you to engage a UK advisor to review your situation and you will be required to engage in an educational session to help you understand your options and determine if a transfer is right for you. The assets are then managed by the appointed financial advisor on a non- discretionary basis. In addition, the Firm also provides portfolio management services to individuals who have legacy Qualified Retirement Overseas Pensions ("QROPs"). Pension assets are held by a regulated pension trustee (authorized by the relevant financial services regulator where the pension plan is held) and subject to the terms and conditions of a separate agreement between the client and the pension trustee. Assets managed within a life bond platform such as: Quilter or RL360 or on an investment platform such as: Novia, Arden or MorningStar. Clients are encouraged to review the agreement between the client and the pension trustee and other disclosure materials (such as Key Features documents) provided by the pension trustee and the investment manager for a full understanding of the services provided and any associated costs therein. Refer to Item 5 below for an overview of the costs. We provide ongoing management of your pension assets in the QROPs or SIPP. Our advisors will create an investment allocation, which can include the use of a discretionary fund manager to manage some or all of the assets, and present the recommendation to you for approval. Use of a discretionary fund manager will add additional costs which are outlined below in item 5. One of the discretionary fund managers available is Nexus Portfolio Management Limited (NPML). One of our indirect owners of Blacktower Financial Management US (John Westwood) is a director and has a minority ownership in NPML. This is a conflict of interest since there is a benefit to the aforementioned indirect owner to utilize the portfolios of NPML. Clients are under no obligation to authorize or approve the use of NPML and are informed there are additional fees for using NPML or any discretionary fund manager or model management strategy. Clients will receive a written assessment or a reason why letter or report outlining why a pension transfer should or should not be considered. It is important clients considering transferring their UK pension review consumer information provided at https://www.fca.org.uk/consumers. There are advantages and disadvantages to transferring a UK pension as well as costs. A pension transfer is not appropriate for all individuals. When making a transfer, you will be giving up certain guarantees offered by the pension. Form ADV Part 2A 8 | P a g e Valuation statements are generally made available to clients on an annual basis (unless requested more frequently) by the selected platform or bond provider. Valuation statements can also be seen online as made available by the platform, as a feature of most of the custodians ’platforms. Online access will vary by provider. We do not provide tax advice including, without limitation, in relation to any US tax reporting requirements and/or other tax implications arising in relation to clients' pension transfers. We recommend you seek your own tax advice, including in relation to procedures under tax treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on their UK/EU pension arrangements. Further, holding US funds or other securities in your UK pension will likely result in a 30% tax withholding that you may not be able to recoup. Please speak to a tax advisor for guidance related to tax matters. ii. Asset Management Services We provide asset management services to US residents and US connected persons US based assets on a continuous and ongoing basis. Your advisor will gather information about you and create a portfolio allocation and make transactions as deemed appropriate for the client based on investment objectives and the client’s risk profile. We provide continuous and ongoing management services. From time to time, we will actively trade securities and hold such holdings for periods of 30 days or less or maintain positions for longer- or shorter-term periods at the discretion of your Advisory Representative and as determined in your best interest. The level of management authority (discretionary or nondiscretionary) is provided in the advisory agreement you execute between you and us. For additional information about discretionary authorization, please refer to Item 16 – Investment Discretion below. We primarily use exchange traded funds, open-ended mutual funds (no-load and load waived mutual funds), and individual equities and fixed income securities. Load waived mutual funds will include institutional shares or mutual funds purchased at net asset value (NAV). Mutual funds purchased at NAV will have higher internal expenses and will cost the client more. It is important to note the account custodians do not provide us with accessibility to the lowest cost share class in all situations. Therefore, the mutual fund share classes of some funds are more expensive than another share class. Managed accounts are not exclusively limited to the aforementioned types of securities and include other securities such as alternative investments, options, and other securities deemed suitable for your portfolio by the Advisory Representative. Third Party Managers We utilize the professional management services of third-party managers, discretionary fund managers, and model managed portfolios. Nexus Portfolio Management Limited (NPML): We have a relationship with Nexus Portfolio Management Limited (NPML) to assist us with designing model portfolios for managing our clients’ US based portfolios. One of our indirect Form ADV Part 2A 9 | P a g e owners of Blacktower Financial Management US (John Westwood) is a director and has a minority ownership in NPML. This is a conflict of interest since there is a benefit to the aforementioned indirect owners to engage the services NPML to create model portfolios since NPML will receive compensation based on the assets placed in the model portfolios. Clients are under no obligation to authorize or approve of the use of model portfolios and are informed there are additional fees for using one of our model portfolios. Advisors Capital Management (ACM): We have entered into an agreement with ACM to utilize their model portfolios and engage them to provide management services. ACM provides management services to accounts maintained at Charles Schwab and Fidelity on US based assets. Transactions in the account, account reallocations and rebalancing often trigger a taxable event, with the exception of IRA accounts, 403(b) accounts and other qualified retirement accounts. IRA Rollover Considerations When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act

in your best interest and not put our interest ahead of yours. As part of our consulting and advisory services, we offer you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations can include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand that many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. You will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. Form ADV Part 2A 10 | P a g e 2. Move the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Before making a change, we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans often have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy can have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could delay your required minimum distribution beyond age 73 (as of January 1, 2023). (You must take your first required minimum distribution for the year in which you turn age 73 as of any date after December 31, 2022, or if you turn 72 before January 1, 2023; or if you reach 70 ½ before January 1, 2020). 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. Form ADV Part 2A 11 | P a g e a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. iii. Other Solutions Blacktower Financial Management (US) LLC can also provide advice and support on a number of 'holistic' financial planning needs. These can include, but are not limited to, life and critical illness cover, health insurance and regular savings plans. iv. Financial Planning and Consulting Services We offer financial planning and/ or consulting services (including investment and non-investment related matters, estate planning, tax planning, insurance planning, and assistance regarding major financial decisions, development of cash flow forecasts, etc.) on a stand-alone separate fee basis. Our planning and consulting fees are negotiable depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Implementation of the recommendations is at the client's discretion and is the client's responsibility. Depending on the service, your advisory representative uses financial planning software to assist with determining your current financial position and define and quantify long term goals and objectives. The financial planning software will run hypothetical scenarios based on variables to assist you to determine a course of action. In no way can any program or software predict future results. It is a tool to enable analysis based on historical information to review possibilities that could occur if historical events repeat. Plans are based on your financial situation at the time and are based on financial information disclosed by you. You are advised certain assumptions are made with respect to interest and inflation rates and use of past trends and performance of the market and economy. However, past performance is in no way an indication Form ADV Part 2A 12 | P a g e of future performance. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Further, it is important you continue to review the plan and update the plan based upon changes in your financial situation, goals, or objectives or changes in the economy. Should your financial situation or investment goals or objectives change, you must notify us promptly of the changes. You are advised the advice offered by us is limited and is not meant to be comprehensive. Therefore, you should consider seeking the services of other professionals such as an insurance adviser, attorney and/or accountant. You are not obligated to implement advice through us. Should you implement the plan, other compensation will be received in addition to the advisory fee paid to us if the products are purchased through the Advisory Representative acting in the capacity as an insurance agent. The receipt of commissions is a conflict of interest. v. Retirement Plan Consulting We provide retirement plan consulting services to plan sponsors but do not participate in the final decisions regarding the investments of the plan. We do not accept discretionary authority or responsibility of selecting the investments offered in the plan. We provide the following services to plan sponsors:
• Assist in drafting the plan’s investment policy statement (IPS) as well as review and provide recommendations for revisions. Monitoring and recommending investments and revisions to the investment line-up offered by the plan.
• Participate in periodic review meetings with the plan sponsor’s investment committee.
• Participate in participant enrollment meetings. C. Level of Services Provided to Clients We tailor our advisory services to the individual needs of our clients. Our advisory representatives discuss and advise clients on the types of investments and investment strategies based upon their financial situation, risk profile and financial goals. This process requires our advisory representatives to collect information about clients through personal interviews and completion of client profile forms. We then place most clients in an appropriate established portfolio strategy. However, we may customize the strategies based upon the particular circumstances of the client. Clients are permitted to impose reasonable investment restrictions on investing in certain securities or types of securities. Investment recommendations and advice are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform us promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify us of any such changes could result in investment recommendations not meeting your needs. D. Portfolio Management Services to Wrap Fee Programs Form ADV Part 2A 13 | P a g e We do not provide portfolio management services for wrap fee programs. E. Assets Under Management BFM US LLC manages clients’ assets on a non-discretionary basis. As of December 31, 2023, our non-discretionary regulatory assets under management are $183,238,000.