Our Firm is an investment adviser that primarily provides individuals, high net worth individuals and other types of clients with discretionary investment advisory services. We are registered with the Securities and Exchange Commission. Our Firm is a Limited Liability Company formed under the laws of the State of Maryland. We have been operating in the financial services industry since 2011 and became registered as an investment adviser in 2018. Our Firm is wholly owned by Lance Scott, who also serves as President and Chief Compliance Officer. In each section below, you will find more information about the specific services We offer. Types of Advisory Services Offered The following are descriptions of the primary advisory services of BHWM. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and the Firm before We can provide you the services described below. A more detailed explanation of Our services is as follows: 1. Financial Planning & Consulting Services Our Firm may provide stand-alone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass investment planning, retirement planning, estate planning, charitable planning, education planning, corporate and personal tax planning, corporate structure, mortgage/debt analysis, insurance analysis, or business and personal financial planning. Written financial plans or financial consultations rendered to clients may include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Clients are free to implement recommendations through another financial advisor or firm and are under no obligation to implement the recommendations through Us. Our Firm will provide such clients with a summary of their financial situation, and observations for financial planning engagements. 2. Asset Management Services We primarily provide direct asset management services to Our clients. As part of Our asset management service, We create a portfolio tailored to the specific needs of the client, potentially including individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Our Firm may utilize the services of various third-party investment advisory firms, platform providers, third-party managers, portfolio specialists, or sub-advisers (collectively, “sub- advisers”) for the management of client accounts. Before selecting a firm or individual, Our Firm will ensure that the chosen party is properly licensed or registered as required. We use sub- advisers to aid in the implementation of an investment portfolio, allocating client assets among such managers as appropriate. In such cases, the sub-advisers will be responsible for continuously monitoring client accounts and making trades in client accounts when necessary. While the chosen sub-advisers will provide advice on specific securities and/or other investments in connection with this service, Our Firm has discretionary authority to hire and fire such sub- advisers and reallocate assets among them as deemed appropriate. We will assist clients with identifying their risk tolerance and investment objectives, and, in turn, We may retain sub- advisers in relation to their stated investment objectives and risk tolerance. Some sub-advisers are made available through an investment platform offered by AssetMark, LLC (“AssetMark”). Typically, when we recommend AssetMark to Our clients, each client then executes, at Our request, a separate client services agreement with AssetMark that authorizes participation on the platform. BHWM assists the client in selecting the risk/return objective and sub-advisers that best suit the client’s objectives. Although We have the authority to direct investments without further specific authorizations by clients, in practice We often request that the client specifically directs the account to be invested in accordance with the chosen investment solution. When the client selects the investment solutions, the client further directs that the account be automatically adjusted to reflect any adjustment in the asset allocation by the selected sub-adviser. This client authorization results in the purchase and sale of securities without further authorization by the client or any other party at such time as the sub-adviser changes the composition of the selected model asset allocation. Within the AssetMark platform BHWM may, without any further input from or permission of the client, move client assets from one sub-adviser to another, terminate the services of a sub- adviser with respect to a client, or reallocate client assets between sub-advisers. Information regarding AssetMark and its platform can be found in the AssetMark Platform Disclosure Brochure. In that Brochure, clients can read about, among other things, the account minimums applicable to sub-advisers or other investment programs available on the platform. BHWM may have the ability to negotiate lower account minimums. Prior to selecting sub-advisers, Our Firm will conduct due diligence on these managers as well as ongoing reviews of their management of client accounts. In order to assist in the selection of a sub-adviser, Our Firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our Firm will review sub-adviser reports provided to the client at least annually. Our Firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to sub-advisers as warranted; and, assist the client in understanding and evaluating the services provided by the sub-advisers. Clients will be expected to notify Our Firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. We also offer asset management services for fee-based fixed annuity insurance products. We will directly manage these annuity insurance products by reallocating buckets or sub-accounts within the annuities in accordance with the client’s suitability profile. Clients who have elected to use this service must also enter into a separate agreement with the product sponsor designating Our Firm to manage the accounts. Insurance products may be available through other channels and as a client you are not obligated to purchase products recommended by Us. As part of its asset management services, BHWM provides its clients with access to a client portal maintained with Black Diamond, a third-party portfolio management and reporting software. The cost for the Black Diamond client portal is paid by BHWM, and clients are not charged for this service. In addition to the client portal there is also an add-on feature, ByAllAccounts (“BAA”), which enables clients to link their outside accounts to the platform so they can see and track everything in one place. BHWM will incur an additional cost for any clients who elect to use the BAA feature. BAA is offered to clients at BHWM’s sole discretion. This presents a conflict of interest, in that BHWM is incentivized to not recommend the use of BAA in order to avoid the additional cost. We address this conflict of interest by disclosing it here and ensuring BAA is offered to any clients for which We determine it is in their best interest. 3. Retirement Plan Consulting Services We offer non-discretionary retirement plan consulting services to employer-sponsored retirement plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Our retirement plan consulting services include, but are not limited to, the following

services: Fiduciary Consulting Services
• Investment Policy Statement Preparation. The Firm assists clients in the development or review of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the plan. Clients have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. The Firm provides clients with general, non- discretionary investment advice regarding asset classes and investment alternatives available for the plan that are consistent with the plan’s IPS. The Firm assists clients with the selection of a broad range of investment options consistent with the investment option selection provisions of ERISA Section 404(c) and the regulations thereunder. Clients have the final decision-making authority regarding the selection, retention, removal and addition of any investment options.
• Investment Monitoring and Reports. The Firm assists clients in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. The Firm will meet with clients on a periodic basis to discuss the reports and the investment recommendations.
• Qualified Default Investment Alternative Advice. The Firm provides clients with non- discretionary investment advice to assist in developing qualified default investment alternative(s) (“QDIA”), consistent with ERISA Section 404(c) and the regulations thereunder, for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. Clients retain the ultimate responsibility to comply with the requirements of Section 404(c), to monitor Section 404(c) compliance, and to follow the terms of the plan document. The specific services to be provided will be listed in Our agreement with each retirement plan. The Firm acknowledges that in performing the retirement plan consulting services listed above it is acting as a “fiduciary” as such term is defined under ERISA Section 3(21)(A)(ii) for purposes of providing non-discretionary investment advice only. The Firm acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause the Firm to be a fiduciary as a matter of law. All recommendations are submitted to the client for ultimate approval or rejection. The retirement plan which elects to implement any recommendations made by Us is solely responsible for implementing all transactions. Non-Fiduciary Services
• Education Services to Plan Committee. The Firm assists in the education of the participants in the plan about general investment principles and the investment alternatives available under the plan. Such education services may include preparation of education materials and/or conducting investment education seminars and meetings for participants. Education services do not take into account the individual circumstances of each participant and do not refer to the appropriateness of any specific investment alternatives or options for the participants.
• Participant Enrollment. The Firm assists clients with group enrollment meetings designed to increase plan participation among employees and investment and financial understanding by the employees. These meetings do not include recommendations with respect to any specific investment alternatives or options available to participants.
• Service Provider/Vendor Services. The Firm assists clients by arranging for the plan’s other third-party service providers to offer these services, as agreed upon between Firm and client. In such cases, the Firm acts only in accordance with instructions from the client and shall not exercise any independent judgment or discretion. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 (the “Advisers Act”) and is required to meet the fiduciary duties required of an investment adviser, the services listed above as “Non-Fiduciary” are not considered fiduciary services for the purposes of ERISA since Our Firm is not acting as a fiduciary to the plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to clients are listed and detailed in the Retirement Plan Consulting Agreement. Tailoring of Advisory Services Our Firm offers individualized investment advice to Our asset management clients. General investment advice will be offered to Our financial planning & consulting clients. Each Asset Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Wrap Fee Programs We provide discretionary investment advisory services on a non-wrap fee basis. This means that if the client engages Us, the client will select individual services on an unbundled basis, paying for each service separately (i.e. investment advisory, trade execution, custody). Conflicts of Interest Please note that some of the Firm’s investment adviser representatives (“IARs”) are licensed to sell insurance and related products with Bay Harbor Insurance, LLC, a licensed insurance company. In such cases, the Firm’s IARs will earn typical and customary commission for the sale of insurance products purchased for a client’s account. This represents a conflict of interest in that Our representatives have an incentive to recommend purchasing insurance products based on compensation received rather than on the needs of the client. These products may be available through other channels and as a client you are not obligated to purchase products recommended by Our representatives. Please see Item 5 - Fees and Compensation and Item 10 - Financial Industry Affiliations for more information. When We provide investment advice to clients regarding their 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 our client’s interests, so We operate under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our clients. We may recommend that a client roll over their retirement assets into an account to be managed by Us. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). A client or prospective client with an IRA also has several options, including (i) leaving the money in the current IRA, (ii) rolling over the assets to another IRA, (iii) rolling over the assets to an employer plan, if one is available and rollovers are permitted, and (iv) cashing out the account value (subject to possible tax consequences). If We are asked by a client or potential client to make a recommendation from among these choices, We have a conflict of interest in that We have an incentive to recommend that a client roll over their retirement assets into an account to be managed by the Firm. Such a recommendation creates a conflict of interest as We will earn a new (or increase Our current) Advisory Fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement assets to an account managed by Us. Regulatory Assets Under Management Our Firm managed $291,564,962 in client assets on a discretionary basis as of December 31, 2023.