A. Opal Wealth Advisors, LLC (“OWA” or the “Firm”) is an LLC formed under the laws of Delaware on January 18, 2019 and is registered as an investment adviser with the U.S. Securities and Exchange Commission since November 2, 2018. OWA became the successor investment adviser to Blaise Advisors, LLC effective January 18, 2019. OWA is principally owned by Lee Korn, Joseph N. Filosa, and Jesse Giordano.
While this brochure generally describes the business of OWA, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on OWA’s behalf and is subject to the Firm’s supervision or control.
B. OWA offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to OWA rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with OWA setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
Financial Planning and Consulting Services OWA’s services are heavily rooted in financial planning. The Firm offers clients a broad range of financial planning and consulting services, which includes any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence These services are generally rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). For services outside of the scope of the Firm’s wealth management services (including business consulting), the Firm may provide financial planning and consulting services on a stand-alone basis.
In performing these services, OWA 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. OWA may recommend certain clients engage the Firm for additional related services by its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other affiliated professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage OWA 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 OWA under a financial planning or consulting engagement. If the client engages a recommended professional, and a dispute arises related to the engagement, the client should seek recourse exclusively from and against the engaged professional. The preceding sentence shall not limit or waive any applicable rights under federal or state law, including securities laws and fiduciary obligations that cannot be limited or waived. 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 OWA’s recommendations and/or services. OWA believes that it is important for the client to address financial planning issues with OWA on an ongoing basis. OWA’s fee, as set forth at Item 5 below, will remain the same whether or not the client determines to address planning issues with OWA.
Wealth Management Services OWA provides clients with wealth management services which includes a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios.
OWA primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage OWA 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, OWA 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.
OWA tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. OWA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify OWA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if OWA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. We do not limit the scope of our investment advisor services to proprietary products or a limited group or type of investment.
ERISA Plan and 401(k) Individual Engagements:
• Trustee Directed Plans. OWA may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, OWA will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). OWA will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm.
• Participant Directed Retirement Plans. OWA may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between OWA and the plan. For such engagements, OWA shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by OWA), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process.

• Client Retirement Plan Assets. If requested to do so, OWA shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, OWA shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. OWA’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. OWA will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify OWA of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by OWA to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of OWA calculating its advisory fee.
Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by OWA as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of OWA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement.
Use of Independent Managers OWA selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. The Firm will typically access the Independent Managers through a Unified Managed Account (“UMA”) platform. As described below, the fees charged by the Independent Managers and the UMA platform provider are separate and in addition to the Firm’s advisory fee in order to provide transparency and limit any conflicts of interest in choosing a specific Independent Manager and UMA platform.
OWA evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, OWA seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. OWA also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. OWA seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.
Miscellaneous Disclosures OWA Asset Allocation Strategies. The Firm maintains two types of asset allocation strategies:
• Executive Model-comprised of mutual funds ETFs, and SMAs available on the Adhesion platform (the client pays a platform fee to Adhesion, an advisory fee to the Firm, transaction and/or asset based fees to the custodian, internal mutual fund and ETF fees, and SMA fees); and,
• Premier Model-comprised of mutual funds and ETFs available on the custodial platforms. The client pays an advisory fee to the Firm, transaction and/or asset based fees to the custodian, and internal mutual fund and ETF fees).
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by the client, OWA will generally provide financial planning and related consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. OWA will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions do occur based upon assets under management, special projects, stand-alone planning engagements, etc., for which Firm may charge a separate or additional fee). OWA believes that it is important for the client to address financial planning issues on an ongoing basis. OWA’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with OWA. OWA does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as same. Accordingly, OWA does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for non- investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including representatives of OWA in their separate individual capacities as representatives of Purshe Kaplan Sterling Investments (“PKS”), an SEC registered and FINRA member broker-dealer, and as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from OWA and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged unaffiliated licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not OWA, shall be responsible for the quality and competency of the services provided. Retirement Rollovers-Potential for Conflict of Interest. 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). If OWA recommends that a client roll over their retirement plan assets into an account to be managed by OWA, such a recommendation creates a conflict of interest if OWA will earn new (or increase its current) compensation as a result of the rollover. If OWA provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), OWA is acting as 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. No client is under any obligation to roll over retirement plan assets to an account managed by OWA, whether it is from an employer’s plan or an existing IRA.
Use of Mutual and Exchange Traded Funds. OWA utilizes mutual funds and exchange traded funds for its client portfolios. In addition to OWA’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). In addition to OWA’s investment advisory fee and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Non-Discretionary Service Limitations. Clients that engage OWA to provide investment advisory services on a non- discretionary basis must be willing to accept that OWA cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. Thus, in the event that OWA would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, OWA will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent.
Portfolio Trading Activity. OWA has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, OWA will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when OWA determines that changes to a client’s portfolio are neither necessary nor prudent. OWA’s advisory fee remains payable during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by OWA will be profitable or equal any specific performance level(s). Clients will nonetheless incur the fees described in Item 5 during periods of portfolio trading inactivity.
Independent Managers. As indicated above, OWA may allocate a portion of the client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to- day responsibility for the active discretionary management of the allocated assets. OWA shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors that OWA shall consider in allocating to Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee

charged by the Independent Manager is separate from, and in addition to, OWA’s advisory fee as set forth in the fee schedule at Item 5 below.
Unaffiliated Private Investment Funds. OWA also provides investment advice regarding private investment funds. OWA, on a non-discretionary basis, may recommend that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the fund’s offering documents. OWA’s role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of OWA calculating its investment advisory fee. OWA’s fee shall be in addition to the fund’s fees. OWA’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s).

• Private Fund Risks. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment.
• Private Fund Valuation. In the event that OWA references private investment funds owned by the client on any supplemental account reports prepared by OWA, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, OWA shall calculate its fee based upon the latest value provided by the fund sponsor.
Reporting Services. OWA can also provide account reporting services, via Yodlee, Fidelity’s Wealthscape, DST and ByAllAccounts, which can incorporate client investment assets that are not part of the assets that OWA manages (the “Excluded Assets”). OWA does not have access to aggregated accounts held at Yodlee. Only the client holds the Yodlee account credentials. OWA has access to certain non-managed accounts held at our custodians Schwab and Pershing (“Accommodation Accounts”). While OWA can access Accommodation Accounts, OWA does not manage these accounts, and only has access to allow integration with other account reporting services. Accounts associated with a representative’s PKS affiliation are not managed by OWA but can be integrated from Fidelity’s Wealthscape or with DST. OWA also aggregates certain accounts through ByAllAccounts. These accounts are reporting only accounts and OWA does not provide investment advisory services for these accounts. Unless agreed to otherwise, in writing, the client and/or their other advisors that maintain trading authority, and not OWA, shall be exclusively responsible for the investment performance of the Excluded Assets held in the aforementioned accounts. Unless also agreed to otherwise, in writing, OWA does not provide investment management, monitoring or implementation services for the Excluded Assets or assets held in the aforementioned accounts. The client can engage OWA to provide investment management services for the Excluded Assets or other assets in outside accounts pursuant to the terms and conditions of the Investment Advisory Agreement between OWA and the client.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/ or investment strategies recommended and/or undertaken by OWA), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. OWA generally relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate.
Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, OWA, may advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, OWA will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. OWA does not recommend or advocate the purchase of, or investment in, cryptocurrencies. OWA considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal.
Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin—The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and,
• Pledged Assets Loan—In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral; These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, OWA does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). OWA does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to OWA:
• by taking the loan rather than liquidating assets in the client’s account, OWA continues to earn a fee on such Account assets; and,
• if the client invests any portion of the loan proceeds in an account to be managed by OWA, OWA will receive an advisory fee on the invested amount; and,
• if OWA’s advisory fee is based upon the higher margined account value (see margin disclosure at Item 5 below), OWA will earn a correspondingly higher advisory fee. This could provide OWA with a disincentive to encourage the client to discontinue the use of margin. The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loans. Asset-Based Pricing Arrangements and Limitations. Relative to Independent Manager engagements (see above), OWA often recommends that clients enter into an “Asset-Based” pricing agreement with the account broker-dealer/custodian. Under an asset-based pricing arrangement, the amount that a client will pay the custodian for account commission/ transaction fees is based upon a percentage (%) of the market value of certain assets (excluding cash, equities, ETFs and certain mutual funds) in the account, generally expressed in basis points and/or a percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or 0.01% (0.0001). This differs from transaction-based pricing, which assesses a separate commission/transaction fee against the account for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by you to the account custodian. Under either the asset-based or transaction-based pricing scenario, the fees charged by the respective broker-dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to OWA per Item 5 below. OWA does not receive any portion of the asset-based transaction fees payable by you to the account custodian. You are under no obligation to enter into an asset-based arrangement, and, if you do, you can request at any time to switch from asset-based pricing to transaction-based pricing, However, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Thus, given the variances in trading volume, any decision by the client to switch to transaction-based pricing could prove to be economically disadvantageous. Cash Positions. OWA continues to treat cash as an asset class. As such, unless determined to the contrary by OWA, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating OWA’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), OWA may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, OWA’s advisory fee could exceed the interest paid by the client’s money market fund.
Interval Funds/Risks and Limitations. Where appropriate, OWA may utilize interval funds (and other types of securities that could pose additional risks, including lack of liquidity and restrictions on withdrawals). An interval fund is a non- traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Therefore, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct OWA, in writing, not to purchase interval funds for the client’s account.
Cash Sweep Accounts. Certain Account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, To help mitigate the corresponding yield dispersion OWA shall generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless OWA reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a OWA actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any OWA unmanaged accounts.
Client Obligations. In performing our services, OWA shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify OWA if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that OWA and its third-party service providers use to provide services to OWA’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in OWA’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and OWA are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although OWA has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that OWA does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions.
Disclosure Statements. A copy of OWA’s written Privacy Notice and disclosure statements as set forth on Part 2A and 2B of Form ADV shall be provided to each client or prospective client before, or contemporaneously with, the execution of the applicable form of client agreement. OWA will provide a Form CRS (“Customer Relationship Summary) to a retail