Atwater Wealth Management (“AWM,” “Atwater,” “the Firm,” “our,” or “we”) is an independent investment advisory firm. The firm’s founding member Caroline Gaffney started AWM in 2008 and organized the firm as a corporation in 2013. Atwater Wealth Management registered as an independent investment adviser at both the state and federal level since December 23, 2014. Currently, we are registered as an investment adviser with the SEC and have notice filed with the appropriate states in which notice filings are required. Atwater Wealth Management provides fee-only investment advisory services primarily to individual clients and high-net worth individuals. Investment strategies and recommendations are tailored to the individual needs of each client. Although Atwater Wealth Management generally exercises limited investment discretion for each account that it advises, the portfolio composition within the same investment objective may, at any given time, differ as to composition. As a result, the performance of an account within a particular investment objective may differ from other accounts within that same investment objective. Clients should not expect that the performance of their portfolios will be identical to that of another client. These differences in portfolio composition are attributable to a variety of factors, including, but not limited to, the type of account, clients’ restrictions and guidelines, sizes, and significant account activity (e.g., significant number of contributions and/or withdrawals). In addition to investment advisory services, we also provide targeted financial advisory services on an as-needed basis. The financial advisory services include, but are not limited to, cash flow planning, retirement needs analysis, tax-efficient distribution strategies, gift and estate planning, insurance planning, annuity reviews, and education planning. As of December 31, 2023, AWM has $192,656,737 under management. Of this amount $190,047,649 is managed on a discretionary basis, and $2,609,088 is managed on a non- discretionary basis. Asset Management We have an affirmative duty of care, loyalty, honesty, and good faith to act in the best interests of our clients. AWM must abide by honest and ethical business practices including, but not limited to:
• Not inducing trading in a client's account that is excessive in size or frequency in view of the financial resources and character of the account;
• Making recommendations with reasonable belief that they are appropriate based on the information furnished by the client;
• Placing discretionary orders only after obtaining client’s written trading authorization contained within the advisory agreement or via separate amendment;
• Not borrowing money or securities from, or lending money or securities to a client;
• Not placing an order for the purchase or sale of a security if the security is not registered, or the security or transaction is not exempt from registration in the specific state; We ensure that we will:
• Allocate securities in a manner that is fair and equitable to all clients.
• Not effect principal or agency-cross transactions for client accounts. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interest ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that our and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the client’s best interest. Wrap Fee Program Atwater Wealth Management offers a Wrap Fee Program sponsored by LPL Financial as a platform, whereby Atwater Wealth Management pays the transaction charges for all our clients who participate in AWM’s wrap fee program. Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage and custodial services. Atwater does not pass this charge through to the client, nor does Atwater increase its fee to compensate for these charges. Atwater Wealth Management absorbs the transaction charges as a business expense. More information about the Wrap Fee Program can be found in our Wrap Fee Brochure ADV Part 2A, Appendix 1. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by paying transaction costs separately. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies, the brokerage commissions charged other broker/dealers, and the advisory fees charged by investment advisers. We will review with clients any separate program fees that may be charged to clients. There is no difference in how wrap fee accounts are managed. All accounts are managed in the same manner, as disclosed in our Brochure ADV Part 2A and in our Wrap Fee Brochure ADV Part 2A, Appendix 1. Hourly Consulting Services Atwater Wealth Management may provide consulting services on an hourly or fixed fee basis. These services may include, as selected by the client in the consulting agreement, advice regarding tax planning, investment planning, retirement planning, estate planning, cash flow/budget planning, business planning, education planning, and personal financial planning. The services consider information collected from the client such as financial status, investment objectives and tax status, among other data. AWM may or may not deliver to the client a written analysis or report as part of the services. Consulting fees are tailored to the individual needs of the client based on the investment objective chosen by the client. The engagement terminates upon final consultation with and/or delivery of written analysis or report to the client. The specific manner in which fees are charged is established in a client’s written agreement with us.