A. Describe Your Advisory Firm AWM is an SEC registered investment adviser which is owned by Erik Averill, Brandon Averill, Robert McConchie, Justin Dyer, and various minority members. Brandon Averill is the Managing Member. Erik Averill, Robert McConchie, and Justin Dyer are Members of AWM. We provide fee-based investment and financial planning advice focused on the best outcomes for clients. We are held to a fiduciary standard and must always act in the best interest of our clients. Our investment platform is open architecture, meaning we are not influenced or incentivized to push proprietary products. We instead focus on providing the best solution for each client. B. Describe the Types of Advisory Services Offered 1. Financial Planning Our financial planning services involve defining priorities and implementing portfolio recommendations. Non-investment-related services provided by AWM may include: Financial Structure Management
• Identify the client’s priorities and anticipated requirements to fund those priorities.
• Provide the necessary daily operating funds by facilitating the movement of money between operating and investment accounts per a client’s identified priorities. Tax Planning
• Proactively implement sophisticated tax-minimization strategies.
• Conduct comprehensive reviews of prior year returns. Estate Planning Services
• Present and implement wealth preservation and distribution strategies.
• Integrate estate planning strategies with income tax and investment strategies.
• Coordinate estate plan documentation with a qualified attorney. Insurance Analysis and Risk Management
• Coordinate a review of all current insurance policies and recommend cost savings or additional coverage if necessary.
• Implement insurance recommendations with best practices for securing competitive rates. We rely on the information the client or the client’s other professional advisors provide to us and thus will not verify this information when doing our analysis. We may recommend the services of other professionals, such as attorneys, insurance brokers, real estate agents, and mortgage brokers, to implement our recommendations. The client is not obligated to use either our in-house services or the referrals we suggest. The client retains discretion over all such implementation decisions. 2. Asset Management AWM’s asset management services are implemented on a discretionary and non-discretionary basis. Our investment recommendations typically include the use of registered mutual funds and exchange-traded funds (“ETFs”) and can also have separate investments in equities, bonds, and cash equivalents. Additionally, we will include private placements and third-party separate account managers (“SAMs”) for some clients if their situation fits such a strategy. For clients where we have discretionary authority, clients authorize us, without prior consultation, consent, or approval, to delegate the management of all or part of the client’s account to one or more third party separate account managers in our sole discretion. For clients where we do not have discretionary authority, we may from time to time recommend one or more SAMs for the client’s approval. In either case, whether we delegate to or suggest a SAM will be at our sole discretion. We provide investment consulting services that include the allocation of assets among different asset classes, portfolio diversification, managing portfolio risk, and other general economic and financial topics. Clients must provide AWM with financial information that helps AWM determine the client’s stated income, priorities, and desired outcomes from which their investment objectives are determined. Based on the client’s unique priorities, we develop a custom portfolio using a liability matching framework known as liability-driven investing (“LDI”). Clients must notify us if their goals and priorities change in a material fashion. We consult with clients periodically regarding their information and, if appropriate, will update their portfolio to reflect any changes in their goals and priorities. Under certain circumstances, AWM will recommend SAMs to clients for specific and specialized asset classes. Under such a scenario, the client will enter into separate agreements with AWM and the SAM. The client typically grants the SAM complete investment discretion and trading authority with sole responsibility

for implementing the client’s investment program while we monitor the SAM’s performance. SAMs may deduct their management fees from the client account at the custodian where the account is held. We will not place transaction orders in the client’s SAM account or otherwise exercise trading authority over the account. In addition, the agreement sometimes authorizes AWM to terminate the SAM. SAMs are subjected to a due diligence process conducted by AWM. Factors AWM considers when evaluating SAMs include the independence and reputation of the SAM, the SAM’s reputation and history, performance record, philosophy and continuity of management, client services, level of diversification, commitment to an investment mandate, awareness of after-tax performance objectives, minimum investment requirement, fees and the SAM’s administration, recordkeeping, and reporting services. We obtain SAM information from tracking organizations, business publications, investment managers, personal interviews, and other sources which we believe are reliable. Additionally, under certain circumstances, AWM will recommend private placements, including but not limited to private equity, venture capital, and private real estate, to clients for specific and specialized asset classes. Under such a scenario, the client will enter into separate agreements with a private fund (for more information, see Item 4. B. 3. below), directly with the private placement manager or the entity. In the case of the private fund, the client grants AWM complete investment discretion and trading authority, with sole responsibility for implementing the stated objectives of the private fund. Any private placement is subjected to a due diligence process conducted by AWM. Factors AWM considers when evaluating a private placement include: the independence and reputation of the source of the opportunity, the reputation and history of the key individuals involved in the opportunity, performance track record, philosophy and continuity of management, client services, level of diversification, commitment to an investment mandate, awareness of after-tax performance objectives, minimum investment requirement, fees and administration, recordkeeping and reporting services. We obtain information from tracking organizations, business publications, investment managers, personal interviews, and other sources which we believe are dependable. 3. Private Fund Management AWM is the advisor to private funds that invest in alternative assets for specific eligible clients. The funds seek long-term investments in private equity funds, venture capital funds, private companies and real estate as described in each fund’s subscription packets and other fund documents. These funds are closed-ended without redemption rights, and structured as limited liability companies or limited partnerships in which investors are non-voting members or limited partners and an AWM affiliate serves as the managing member or general partner. Due to the nature of private equity and venture capital investments, there is an inherent risk. When considering these types of investments, investors should have a high level of sophistication and net worth. Please refer to the funds’ subscription packets and other fund documents for private fund detail. 4. Retirement Account Advice When we recommend investing in one of our proprietary or related private funds or provide investment advice to a client regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Receiving our advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC in a client’s interests, so we operate under a special rule that requires us to act in the best interest of the client. 5. Other Services We provide business consulting to select small and medium-sized businesses for compensation. This consulting involves an analysis of cash flow, tax planning, and overall business strategy. We provide these services on an hourly or fixed-fee basis. 6. Wrap Fee Programs AWM does not participate in or sponsor a wrap-fee program. 7. Assets Under Management As of December 31, 2023, we managed $860,648,664 of client assets on a discretionary basis and $0 on a non-discretionary basis.