CWA is a registered investment adviser based in Myrtle Beach, South Carolina. We are a limited liability company formed under the laws of the State of South Carolina. We have been providing investment advisory services since 2017. Our owners are RPWCM, Inc., M. Radcliff Lowery CPA LLC, and Sweet Bailey, LLC. Christopher St. John is the President and CEO of RPWCM, Inc., M. Radcliff Lowery is the sole member of M. Radcliff Lowery CPA LLC, and Christy Horlacher is the sole member of Sweet Bailey, LLC. Currently, we offer the following investment advisory services, personalized to each individual client:
• Financial Planning Services
• Portfolio Management Services
• Pension Consulting Services The following paragraphs describe our services and fees. Each investment advisory service is listed below with a description of how we tailor our advisory services to your individual needs. You may see the term “Associated Person” throughout this Brochure. As used in this Brochure, this term refers to anyone from CWA who is an officer, employee, or other person providing investment advice on behalf of CWA. All persons who provide investment advice are properly registered as investment adviser representatives in required jurisdictions. Financial Planning Services We offer various financial planning related services that assist our clients in the management of their financial resources. Financial planning services are based upon an analysis of your individual needs and begin with one or more information gathering consultations. Once we collect and analyze all documentation gathered during these consultations, we provide a written financial plan designed to achieve your financial goals and objectives. In this way, CWA assists you in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services may include any one or all of the following:
• Cash Flow Analysis – Assessment of your present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements etc. The firm advises on ways to reduce risk, coordinate, and organize records, and estate information.
• Retirement Analysis – Identification of your long-term financial and personal goals and objectives including advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management associated with advisory recommendations based on a combination of insurance types to meet your needs, e.g., life, health, disability, and long-term care insurance. This will necessitate an analysis of cash needs of family at death, income needs of surviving dependents, and disability income analysis.
• Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset allocation, and effect on your portfolio. We evaluate economic and tax characteristics of existing investments as well as their suitability for your objectives. We identify and evaluate tax consequences and their implications.
• Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education.
• Estate Analysis – We provide advice with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques. The recommendations and solutions we provide are designed to help you achieve your desired goals, subject to periodic evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are based on your financial situation based on the information provided to us. We should be notified promptly of any change to your financial situation, goals, objectives, or needs. You can also request financial planning services that cover a specific area, such as retirement or estate planning, asset allocation analysis, manager due diligence and 401(k) platform due diligence. We offer consultative services where we set an appointment to meet with you for financial planning advice for an hourly fee. You may choose to accept or reject our financial planning recommendations. If you decide to proceed with our recommendations with respect to portfolio management or other products and services we offer, you may do so either through us or through any other advisory, brokerage, or insurance provider of your choice. Portfolio Management Services Our firm offers continuous discretionary and, in limited cases, non-discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions are made based upon your stated investment objectives. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Non- discretionary portfolio management service means that we must obtain your approval prior to making any transactions in your account. Our investment advice is tailored to meet your needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. If you engage us for portfolio management services, we will monitor your portfolio’s performance on a regular basis, and will rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. Pension Consulting Services CWA provides pension consulting services on a stand-alone basis or in combination with other services. While the primary clients for these services will be pension, profit sharing, and 401(k) plans, CWA will also offer these services, where appropriate, to businesses, individuals, trusts, estates, and charitable organizations. Pension

consulting services are generally comprised of various services as agreed upon in the advisory agreement. Typically, clients may choose to use any or all of the services offered, such as: Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): CWA will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. CWA then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles CWA will review various investments, consisting of one or all of the following: individual equities, bonds, other investment products, and mutual funds (both index and managed) to determine which of these investments are appropriate to implement the client's Investment Policy Statement. The number of investments to be recommended will be determined by the client, based on the client’s Investment Policy Statement. Monitoring of Investment Performance Client investments will be monitored regularly based on the procedures and timing intervals outlined in the Investment Policy Statement. Although CWA may not be involved in any way in the purchase or sale of these investments, CWA will supervise the client's portfolio and will make recommendations to the client as market factors and the client's needs dictate. Employee Communications For pension, profit sharing, and 401(k) plans where the individual account participant exercises control over assets in his/her own account (hereinafter ''self-directed plans''), CWA also provides educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by CWA and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. Management Services Where contracted, CWA will provide discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. Other pension consulting and management services may be available on request. All of our pension consulting services, whether general or customized, will be described in a written agreement that shows the services that will be provided and the fees that will be charged for those services. Types of Investments We offer advice on various types of investments including any investments we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must request these restrictions to our firm in writing. We will accept any such request that we deem reasonable. Wrap Fee Programs We do not sponsor or manage any wrap fee programs. Assets Under Management (“AUM”) As of February 1, 2024, we manage $274,489,564 in discretionary assets and $3,722,184 in non-discretionary assets, for a total of $278,211,748 AUM. IRA Rollover Considerations When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's/former employer’s retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than based solely on your needs. We manage this conflict of interest by always acting in the client’s best interest and keeping documentation of our determination that the rollover recommendation is in the client’s best interest. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits. An employee will typically have four options: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer’s retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. We will speak with your CPA and/or attorney if you authorize us to do so in connection with any rollover recommendation we make. Similarly, we may rely on information you obtain from your CPA or tax attorney and communicate to us prior to making any such recommendation.