Benjamin F. Edwards Wealth Management (“EWM”) is a registered investment adviser. EWM became registered as an investment adviser subject to the jurisdiction of the Securities and Exchange Commission in August of 2018. EWM’s principal owner is its holding company, Benjamin Edwards, Inc., which owns 100% of EWM. EWM partners with affiliated investment adviser representatives (“advisors”) who in turn, work with individual clients. Throughout this brochure, the term “advisor” or “affiliated advisor” will refer to the individuals serving as the client’s affiliated investment adviser representatives and “BFE” refers to Benjamin F. Edwards and Co., a dually registered broker-dealer/investment adviser, which is also 100% owned by the holding company, Benjamin Edwards, Inc. EWM offers the following advisory services:
• Discretionary Investment Management Services
• Financial Planning
• Consulting Services
• Plan Participant Advisory Services Discretionary Investment Management Services EWM offers Discretionary Investment Management Services through a wrap fee advisory account or a non-wrap fee (unbundled) advisory account. In a discretionary advisory relationship, EWM provides portfolio management services to the client on a discretionary basis. As a discretionary account, the advisor is not required to contact the client prior to each transaction. The advisor and client will work together to develop or select an investment strategy. The advisor will monitor the account to ensure it remains consistent with the investment strategy and that the strategy remains appropriate. In a discretionary EWM account, portfolio management will be handled in one of the following ways:
• The advisor will act as the portfolio manager of the account, making all the investment decisions and trading in the account
• The advisor will use an investment solution provided by BFE or a third-party money manager with EWM trading the account
• The advisor will use an investment solution run by a third‐party money manager, where the third-party money manager makes the investment decisions and trades the account Clients can access unaffiliated third‐party money managers who offer specialized asset management expertise or services that EWM uses to manage all or a portion of the client assets in appropriate cases. Such third‐party money manager’s expertise ranges from research and selection of investment options, to monitoring the assets and deciding when to buy or sell them. Once selected, a third-party money manager’s strategy will be implemented in one of two ways. Either the third‐party money manager will have discretion to implement the strategy directly in client’s account or the third-party money manager will provide its strategy to EWM for EWM to implement. When the third-party money manager Benjamin F Edwards | Form ADV Part 2A Firm Brochure Page | 6 implements the strategy directly, for any portion of assets placed with them, the manager will have discretion to choose and manage investments prudently for the client, including the development of an appropriate investment strategy, and buying and selling securities to meet those goals (subject to restrictions imposed by the client). Once a client decides to participate in a program in which the third- party money manager has discretion, EWM has no ability to affect the trading decisions of the third‐ party money managers and can only choose whether to engage or terminate the third‐party money manager. EWM retains the right to replace (i.e., "hire or fire") third‐party money managers on behalf of clients that have given discretionary authority to EWM. Discretionary authority allows EWM to choose, combine or change any third‐party money manager approved for a given platform, without additional approvals from the client. For example, EWM can, at its discretion, fire XYZ Large Cap Value manager and hire ABC Large Cap Value manager as its replacement. EWM and/or its delegates performs initial and ongoing due diligence of the individual third‐party money managers’ performance and management, reviews the client’s account for adherence to objectives outlined with the manager, and will reallocate assets among managers if necessary. EWM may choose to outsource the due diligence reviews of third-party money managers to external parties that specialize in such reviews. EWM may rely on these outside parties when making recommendations to clients to use, terminate or replace a money manager. In some instances, clients will have a contract directly with the third‐party money manager in addition to the investment advisory agreement with EWM. This is known as a dual contract arrangement because there is an agreement between the client and EWM as well as a contract between the client and the third‐party money manager. In cases, of a dual contract arrangement with the manager the services provided by EWM and the third‐party money manager will be outlined in each agreement, and EWM can make recommendations to replace a third‐party manager but does not have the discretion to do so. Each third‐party money manager maintains a separate disclosure document that they provide to clients, outlining their investment process. In addition, EWM and third parties administering wrap fee programs maintain additional disclosure documents that specifically pertain to the wrap fee programs that they administer. Clients should carefully review these disclosure documents for important and specific details including, among other things, fees, experience, investment objectives and risk guidelines, and disclosure of the third-party money manager's potential conflicts of interest. Restrictions Clients can place reasonable restrictions on the types of investments that will be made on their behalf (i.e., no defense stocks, no tobacco, etc.). EWM reserves the right to not accept, or to terminate an account, if EWM believes the restrictions imposed are not reasonable or prohibit effective management of the account. EWM is not obligated to implement other investment selections if it believes such investments are inconsistent with a client’s risk tolerance or EWM’s management style. Note about Fees (see Item 5 for more information) Fees for the above, Discretionary Investment Management Services may be either “bundled,” or “unbundled”. When unbundled, clients pay separately for the following:
• custodial and transaction fees,
• EWM’s advisory fee (the portion EWM retains for our services), and
• managed account platform fee, if applicable. Benjamin F Edwards | Form ADV Part 2A Firm Brochure Page | 7 When choosing a bundled fee, also known as a “wrap fee,” clients pay one fee that covers numerous associated account fees including: custodial fees, EWM advisory fee (the portion EWM retains for our services) and/or third-party manager fees. However, additional ancillary fees and charges will also apply as detailed in the EWM investment advisory agreement and the qualified custodian (“Custodian”) will deduct these fees from the client account as applicable. These additional fees and expenses include, but are not limited to, internal fees charged directly by a mutual fund, exchange traded fund, closed end fund or unit investment trust (all of which will be described in the products’ prospectus), mark ups and mark downs, wire transfer fees, physical delivery of account

documents, and more. In addition, to the extent a client uses the assets in an account for purposes such as an asset‐based loan or margin loan, separate charges will apply and will be disclosed in applicable loan documents. Whether a client chooses a wrap fee or an unbundled fee structure has no bearing on how the accounts are managed. The fee structure decision is made between the client and advisor and is based on factors such as a) the types of securities the client will be investing in and the fees associated with those investments, b) the volume of trading expected given the investment strategy selected and c) the client’s overall preference on how they would like their fee to be structured. Whether a bundled fee or a wrap fee arrangement ultimately costs more depends on the extent to which individual unbundled fees are actually incurred. For example, the amount of transaction costs will vary depending on the level of transaction activity in the account. In an unbundled account, there is a point at which the amount of transaction costs, together with all other unbundled costs that are incurred, will cause the overall fee paid by the client to be greater than a given wrap fee amount. Thus, up to that point, a client account with lower levels of transaction activity will pay more in relative terms in a wrap account than an unbundled account; however, beyond that point a client account with more transactions will pay more in the unbundled arrangement. Financial Planning EWM offers Financial Planning services on a comprehensive or a la carte (limited focus) basis. Financial planning services are individually customized for each client’s needs, and services to be provided are based on a negotiated scope of services for each client. This can be provided either on an ad‐hoc or ongoing basis. EWM will not actually manage client assets as part of Financial Planning Services. Financial plans will encompass all or some of the following areas:
• Cash management
• Estate Planning Goals
• Asset Allocation Review and Recommendations
• Investments
• Education Planning
• Insurance Planning/Risk Management
• Retirement Planning Consulting Services EWM offers consulting services to various types of clients including but not limited to:
• Individuals
• High Net Worth Individuals
• Charitable Organizations Benjamin F Edwards | Form ADV Part 2A Firm Brochure Page | 8
• Corporations
• State or Municipal Government Entities
• Pension and Profit-Sharing Plans
• Plan Participants Consulting services are individually customized for each client’s needs, and services to be provided are based on a negotiated scope of services for each client. Consulting services can be provided either on an ad‐hoc or ongoing basis. EWM will not actually manage client assets as part of Consulting Services. Types of services include but are not limited to:
• review and/or monitor an Investment Policy Statement
• search and evaluate investment alternatives
• perform ongoing monitoring and due diligence of investment managers
• perform ongoing performance monitoring
• review past performance of the client’s investments
• provide fee‐billing services
• provide performance monitoring reports
• participate in periodic meetings as needed EWM may also negotiate other services based on the needs of the client. Plan Participant Advisory Services EWM offers clients ongoing advisory services for plans held outside of EWM through the Plan Participant Advisory Services (“PPAS”) program. This means the plans are not custodied at EWM or EWM’s Custodian but are rather held on the platform chosen by the plan administrator or the client, sometimes referred to as “held away” accounts. For the purposes of this program, the term “Plan” could refer to a held away retirement plan, a held away 529 plan or a similar held away plan. The term “Plan Participant” refers to the clients invested in said plans. Clients who enroll in EWM’s PPAS program have the option of choosing discretionary investment management services or non-discretionary consulting services. The discretionary PPAS option is an advisory service whereby EWM will agree to provide Plan Participants with discretionary investment management services. Alternatively, the non-discretionary PPAS option is a consulting service in which EWM will agree to provide plan participants with non-discretionary investment advice. For each option, EWM’s investment advisors will review the investment options available to the Plan Participant within the Plan. Investment advisors will then work with clients to identify their needs, objectives and risk tolerance. From the information obtained, the investment advisor will proceed in one of the following ways, depending on which program option is selected:
• For clients who select discretionary investment management services, the investment advisor will develop an asset allocation and implement the necessary trades to align the account with the allocation. The investment advisor will meet with the client to discuss whether changes to the account allocation may be appropriate. The client will permission their EWM investment Benjamin F Edwards | Form ADV Part 2A Firm Brochure Page | 9 advisor to directly trade with full discretion in the Plan account through capabilities provided by a third-party order management platform.
• For clients who select non-discretionary consulting services, the investment advisor will provide a written security level asset allocation recommendation. The investment advisor will meet with the client to discuss whether changes to the initial recommendation may be appropriate. It is the sole responsibility of the client whether or not to implement the advice provided. When providing Consulting Services or Plan Participant Advisory Services to a plan participant in a qualified retirement plan, EWM will enter into an agreement with the retirement plan participants to provide investment advice for ERISA or other types of participant‐directed plans. Advisors will review the investment options available to the plan participant within the employer‐sponsored retirement plan. Advisors will then work with clients to identify their needs, objectives and risk tolerance. This service may be performed for a one‐time fee or on an ongoing basis. If an ongoing service is the option selected in the agreement, the advisor will have subsequent meetings (at least annually) with the client to discuss whether changes to the initial recommendation may be appropriate. It is the sole responsibility of the client whether or not to implement the advice provided. Restrictions Clients can place reasonable restrictions on the types of investments that will be made on their behalf (i.e., no defense stocks, no tobacco, etc.). EWM reserves the right to not accept, or to terminate an account, if EWM believes the restrictions imposed are not reasonable or prohibit effective management of the account. EWM is not obligated to implement other investment selections if it believes such investments are inconsistent with a client’s risk tolerance or EWM’s management style. As of December 31, 2023, EWM has $740,402,470 managed on a discretionary basis. EWM does not currently manage assets on a non‐discretionary basis.