BEWS was founded in 2014 and is owned by Brown, Edwards & Company, L.L.P. As of May 31, 2023, BEWS had $$232,085,420in assets under management on a discretionary basis and $26,110 on a nondiscretionary basis. We also have $16,779,231 of assets under advisement for participant-directed retirement plans. Investment Management Services BEWS manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations, corporations and small businesses. BEWS will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. BEWS uses investment and portfolio allocation software to evaluate alternative portfolio designs. BEWS evaluates the client's existing investments with respect to the client's investment policy statement. BEWS works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by BEWS. BEWS will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. BEWS will typically create a portfolio of no-load mutual funds, exchange traded funds (ETFs) and individual securities and may use model portfolios if the models match the client's investment policy. BEWS will allocate the client's assets among various investments, taking into consideration the overall management style selected by the client. BEWS primarily recommends portfolios consisting of passively managed asset class and index mutual funds. BEWS recommends mutual funds and/ETFs offered by Vanguard, Dimensional Fund Advisors (DFA) and other fund families. Mutual funds and ETFs that follow a passive investment philosophy generally have low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). BEWS manages mutual fund and equity portfolios on a discretionary or nondiscretionary basis. Clients may impose reasonable restrictions on BEWS’s discretionary authority, including restrictions on the types of securities in which BEWS may invest client’s assets and on specific securities, which the client may believe to be appropriate. BEWS has retained Buckingham Strategic Partners, LLC (“BSP)” to act as a sub-advisor for certain client accounts. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by BEWS. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but not limited to, mutual funds and/or exchange traded funds from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC or other providers selected by BSP. Each Portfolio is designed to meet a particular investment goal which BEWS has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, Adviser, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact BEWS to determine if changes to an account and the allocation of the assets held in the account are necessary. Selection of other Advisors: Fixed Income Subadvisor: BEWS may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. BEWS will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third party fixed income manager.

BEWS will prepare a Fixed Income Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, BEWS will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent with the client’s Fixed Income Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain BEWS’s consent prior to the sale of any client securities. BEWS will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. On an ongoing basis, BEWS will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. BEWS will at least annually review client’s investment policy and risk profile and will re- balance clients’ accounts as necessary. In addition to managing the client’s investment portfolio, BEWS may provide financial planning services to clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. BEWS will not charge a separate fee for this service. In performing its services, BEWS shall not be required to verify any financial information received from the client or from the client’s other professionals, and is expressly authorized to rely on the information provided. Moreover, clients are advised that it remains their responsibility to promptly notify BEWS if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revision their previous recommendations and/or services. Employee Benefit Plan Services BEWS also provides advisory services to participant-directed retirement plans through third party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. BEWS will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. BEWS will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. BEWS will recommend changes in the plan's investment vehicles as may be appropriate from time to time. BEWS generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, BEWS also works in coordination and support with other independent 3(38) service providers (‘401(k) Providers’). Retirement plan clients will engage both BEWS and the 401(k) Provider. BSP will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. BEWS will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Trustee Accounts For a limited number of client accounts, the Firm is deemed to have custody due to an adviser being a named co-trustee on a client account. When these situations arise, they are evaluated on a case by case basis, with the facts and circumstances documented and submitted to the COO for review. If approved by the COO, the accounts are listed on our custody report and included in our annual surprise examination. Please see Item 15 for further information.