A. CWS Financial Advisors LLC CWS Financial Advisors LLC (“CWSFA”) and/or “the firm”) is a Michigan limited liability company. CWSFA filed for registration as an investment adviser in April 2018 and is owned by Joseph Splendorio, Lindsey Splendorio, and Cory Wietfeldt. B. Advisory Services Offered Investment and Wealth Management Services CWSFA manages client investment portfolios on a discretionary or non-discretionary basis. In addition, CWSFA provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary and/or non- discretionary management of investment portfolios. ▪ Discretionary Basis: The client authorizes CWSFA, without prior consultation, to buy, sell, and trade in stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), and other securities and/or contracts or options for the client’s account(s). ▪ Non-Discretionary Basis: CWSFA will make recommendations of investments for the account, but the client retains complete authority to accept or reject CWSFA’s recommendations. CWSFA will not determine which Investments will be held in the client’s account(s). Upon client’s request, CWSFA will assist with implementing investment decisions. Where appropriate, the firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage CWSFA to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, CWSFA directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. CWSFA’s asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. CWSFA will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances. Clients agree to permit CWSFA to consult with and obtain information from their attorney, accountant, and other advisors to the extent necessary to assist us in providing our services, although we have no responsibility to seek these advisors out. Clients acknowledge that CWSFA is not obligated to independently verify any client information. Clients have the right to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. CWSFA will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. CWSFA will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Use of Independent Managers With respect to any discretionary services or non-discretionary services a client engages us to provide, client authorizes CWSFA, without prior consultation, consent or approval to delegate the management of all or part of the assets to one or more independent investment managers, subadvisors or independent investment management programs. The independent managers may be hired under separate written agreements and may charge fees in addition to our management fee. In the event CWSFA has been engaged to provide discretionary services, the independent managers will have limited power-of-attorney and trading authority over those assets we direct to them for management and they will be authorized to buy, sell, and trade in accordance with the client’s investment objectives and to give instructions, related to their authority, to the broker-dealer and the custodian of client’s assets. CWSFA will supervise the independent managers.

CWSFA may terminate or change independent managers when, in our sole discretion, we believe such termination or change is in the client’s best interest. CWSFA will continue to monitor and review asset allocation, asset performance, and client’s investment objectives. Financial Planning and Consulting Services CWSFA offers clients a broad range of financial planning and consulting services, which include any or all of the following: ▪ Cash Flow Forecasting ▪ Retirement Planning ▪ Social Security Planning ▪ Tax Planning ▪ Education Planning ▪ Budgeting Support ▪ Estate Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, CWSFA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. CWSFA recommends certain clients engage the firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the firm to recommend that clients engage CWSFA or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by CWSFA under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising CWSFA’s recommendations and/or services. Retirement Plan Consulting Services Plan sponsors may engage CWSFA to serve as a non-discretionary investment adviser to the plan. Each engagement is individually negotiated and customized, and includes any or all of the following services: ▪ Participant Education: On an annual basis, we will provide to the plan participants investment education services that conform with the guidelines established in Department of Labor Interpretive Bulletin 96-1. These educational services will address general investment principles, plan information, and other such financial matters. ▪ Group Enrollment Assistance: We will attend group enrollment meetings as requested by the plan sponsor and provide informational services about the structure and administration of plan benefits. ▪ Service Provider Analysis: As requested by the plan sponsor, we will assist you in evaluating the plan’s current service providers, including their services, fees, and performance, and conduct due diligence on alternative providers. ▪ Plan Benchmarking: We will prepare comparative benchmarks for the plan, including relative measures for fees, performance, and plan design. We will prepare reports illustrating these comparisons, based upon information provided to us by you, the plan provider, and/or other independent third parties. ▪ Personalized Participant Service: As requested, we will arrange to meet individually with participants (in person or via conference call) for individualized education regarding plan information, general financial, investment and retirement information (conforming with the guidelines established in Department of Labor Interpretive Bulletin 96-1). These meetings will generally be limited to one occurrence per participant per year. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs CWSFA does not participate in wrap fee programs, where certain brokerage commissions and transaction costs are included in the asset-based fee charged to the client. E. Client Assets Under Management As of December 31, 2023, CWSFA had $1,050,001,614 in discretionary assets under management and $4,539,274 in non-discretionary assets under management. Item 5: Fees and Compensation