A. Description of Firm Corvus Wealth Advisors LLC (also referred to as “CWA”, “us”, “we” or the “Firm” throughout this document) is a California-based advisory firm. The Firm provides investment supervisory services on a discretionary and non-discretionary basis to certain clients described in Item 7 herein (“Clients”). The investment instruments CWA advises its clientele on include, but are not limited to, equity stocks, fixed income securities, bonds, exchange traded funds (“ETFs”), mutual funds, options, and cash equivalent instruments. Please refer to Item 8 for additional information relating to the investment strategies pursued by CWA and their associated risks. B. Principal Owners The Firm is a limited liability company organized in the State of California. The Firm’s primary owners are Garcia Wealth Management Group, Inc. (“GWM”) and Compass Financial Planning, LLC (“CFLP”) and minority owner JB’s Bread and Butter, LLC. Mr. Garcia is the sole owner of GWM. CFLP is a Limited Liability Company organized in the state of California. CFLP, and the principal owner is Carolyn Jane Herzog (“Ms. Herzog”). Both Mr. Garcia and Ms. Herzog serve as managers of CWA. Mr. Garcia also serves as the Firm’s Chief Compliance Officer (“CCO”). Giselle Crout is the principal owner of JB’s Bread and Butter, LLC and serves as the firm’s Chief Operating Officer. C. Types of Advisory Services Offered 1. Financial Guidance Services CWA’s financial planning services range from comprehensive financial planning to more focused consultations, depending on the needs of each Client. Typically, the Firm will provide a written financial plan that can include, but are not limited to, the following.
• Retirement Planning
• Education Planning
• Insurance Needs Analysis
• Cash-Flow Needs
• Debt Analysis
• Estate Planning Financial guidance can be described as helping individuals determine and set their long-term financial goals, through an analysis process which may include, but is not limited to, investment management, tax planning, retirement/cash flow modeling, transition planning, estate design, risk management and philanthropic planning. CWA’s role is to find ways to help the Client understand their overall financial situation and help the Client set financial objectives. To begin the process, we will meet with the Client to begin gathering information and documents needed to assess the Client’s current financial situation and planning considerations and to begin preparing the requested plan. We rely on the information provided by the Client. Therefore, it is very important that the information provided is complete and accurate. CWA is not responsible for verifying the information supplied by the Client. Our services do not include legal or tax advice. Clients are urged to work closely with their respective attorney, accountant or other professionals regarding their financial and personal situation. CWA generally presents a completed plan to the Client within 3 - 4 weeks of the required information being received. CWA will hold a meeting to present the drafted plan and discuss the items, including any change needed in scope or scenarios of the plan. Another meeting is held to go over the final plan. There may be additional meetings as recommended and agreed upon by the parties. Financial Guidance only is a one-time service and CWA does not provide ongoing monitoring and updates to our guidance. Financial planning recommendations are based on the Client’s financial situation at the time the recommendations are provided and are based on the information provided by the client. In addition, certain assumptions are made with respect to interest and inflation rates, use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance and CWA cannot offer any guarantees or promises that the Client’s financial goals and objectives will be met. Should the Client’s financial situation, goals, objectives, or needs change while the financial plan in being formulated, the Client is strongly urged to promptly notify CWA. For more information on the risks associated with investing, please refer to Item 8, below. Clients should understand that a conflict of interest exists because CWA has an incentive to recommend its own investment management services as CWA receives additional compensation for such services. Advice and recommendations will at times also be given on non-securities matters. Clients always have the right to accept or reject any or all recommendations made by CWA. Should Clients to decide to act on such recommendations, Clients always have the right to decide with whom they choose to do so. Please refer to Item 5 below for detailed information on fees and compensation for these services. 2. Investment Management Services Investment Management Services involves providing Clients with continuous and on-going supervision over Client accounts. This means CWA will continuously monitor a Client’s account and make trades in Client accounts when appropriate. In order to provide this service, we work with the Client to determine the Client’s goals, objectives, liquidity needs, time horizon and risk tolerance through personal discussions and data gathering tools. This information is used to develop a custom target asset allocation for each client. CWA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, CWA may also accept client accounts on a non-discretionary basis in its sole discretion. CWA’s investment approach strives to achieve each Client’s target asset allocation and provide attractive risk-adjusted, fee-adjusted returns over the long-term by investing the Client’s portfolio in a mix of securities, including stocks, bonds, mutual funds and/or ETF’s, and other securities as may be in the best interest of the Client. Further, while CWA will at times in its sole discretion accept management of other types of securities which were previously owned in Client accounts (including stocks and bonds), CWA will generally recommend a plan to reduce those positions over time based on each Client’s specific situation in order to obtain a more diversified portfolio consistent with CWA’s investment approach. a. Selection of Sub-Advisors For certain Client assets, CWA will outsource a portion of the investment management to United Capital Financial Advisors, (“United Capital”) an investment adviser not affiliated with CWA who serves as a sub‐advisor (“Sub‐ Advisor”) to the Client’s assets. United Capital is granted discretionary investment authority over assets that CWA assigns to United Capital . For the assets directed to Sub‐Advisor for services, its responsibility includes the authority to:
• exercise discretion to determine the types of securities bought and sold, along with the percentage allocation;
• apply its discretion as to when to buy and sell;
• apply its discretion as to the timing of transactions;
• select the broker/dealer for execution of securities transactions, if appropriate; and
• take other portfolio management actions CWA delegates or deems appropriate. Any authority of United Capital only applies to the specific assets, within the Client’s custodial account, for which United Capital has been appointed as the discretionary manager. United Capital shall not provide investment advice, or have any advisory responsibility to the Client, beyond the assets for which it is appointed as Sub‐Advisor. The terms of services provided by United Capital are directed in accordance with a separate written agreement entered into between CWA and United Capital. See also important disclosures under Item 5 below. b. Selection of Third-Party Investment Managers At times, CWA will also direct Clients to one or more third-party investment managers (“TPIMs”) to manage a portion of the Client’s assets if the Firm deems such actions to the best interest of the Client. Before selecting TPIMs for Clients, CWA will: (i) verify that

all recommended TPIMs are properly licensed, notice filed, or exempt in the states where CWA is recommending the adviser to Clients. (ii) gather such information as investment objectives, risk tolerance, investment guidelines, time horizons and other important and necessary information relating to the Client’s assets; (iii) based upon such information, determine appropriate allocations of Client’s assets; and (iv) recommend one or more TPIMs whose management style and strategies are consistent with Client’s objectives and financial profile. Depending upon the TPIM selected, Clients may be required to enter into a separate advisory agreement with the TPIM, which will be in addition to, and distinct from, the Client Agreement executed with the Firm. TPIMs will typically have discretionary authority over the assets allocated for management, and authorized to buy, sell, and trade in securities in accordance with the Client’s investment objectives and/or selected investment strategy. CWA shall typically provide information and/or documentation to the TPIM relative to the Client’s investment objective(s), initially when the account is opened, and anytime the Client informs the Firm of any change to their investment objectives. CWA’s fees do not include those fees associated with allocating Client assets to designated TPIMs. Please refer to Item 5 below for additional information regarding fees. c. 1031 Exchange Services CWA will assist potential investors in identifying properties, reviewing sponsor related due diligence material, and request/review independent third-party due diligence reports. Additionally, the Firm will facilitate the completion of required paperwork and transfer of funds from the qualified intermediary and the sponsor. Finally, CWA provides potential investors with disclosures of risks and fees, and other information to help evaluate an exchange offering before any investment is made. 3. Financial Life Management Services CWA’s Financial Life Management Services include both the Investment Management Services and Financial Guidance services as outlined above. As such, CWA will provide ongoing financial guidance to our clients as their life situations change and update their plans regularly, in addition to ongoing investment management of Client assets. 4. Retirement Plan Consulting Services CWA offers consulting services to organizations (“Plan Sponsor”) who sponsor a qualified (or nonqualified) Retirement Plan for the benefit of its employees. The Plan is a qualified or non- qualified employee benefit plan intended to comply with all applicable federal laws and regulations, including the Internal Revenue Code of 1986, as amended, and the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, if applicable. In addition, applicable Plans are intended to comply with ERISA Section 404(c). Retirement Plan Consulting Services typically includes, but is not limited to:
• Assisting with the development and updates of an Investment Policy Statement (“IPS”) for the plan;
• Providing recommendations on investment options for the plan to offer to participants;
• Monitoring performance of money managers and investment options and making recommendations for changes;
• Facilitating interactions with other retirement plan service providers, such as custodians, third party administrators and record keepers;
• Providing educational presentations to plan participants,
• Facilitation of plan conversions between investment and/or recordkeeping providers; and/or
• Supporting participants with enrollment into the plan, investment or allocation changes, facilitation of loans and/or distributions. These services are based on the objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. The terms and conditions of the engagement are generally set forth in the Retirement Plan Services Agreement between CWA and the Plan Sponsor. The plan fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan. For those services outlined above, CWA acknowledges that it is a fiduciary with respect to the Plan under Section 3(21)(A)(ii) of ERISA and, as such, is a co-fiduciary with the trustees(s) of the Client’s plan solely with respect to (a) the provision of investment education of the employer and/or plan participants (depending on the specific services provided); (b) the periodic reporting on, and analysis of, the investment options available under the Plan; and (c) the provision of advice to the trustee(s) regarding the elimination or addition of investment options available under the plan; provided, however, that the trustee(s) acknowledge and agree that the trustee(s) have the final and conclusive responsibility for the investment options selected to be available under the plan. At times, CWA may also act as an investment manager with respect to the Plan under Section 3(38) of the ERISA. In such role, CWA is a limited scope fiduciary with respect to the plan under Section 3(38) of ERISA for only those services under the Client Agreement for which CWA has received explicit authorization and discretion over plan assets. The fiduciary duties of CWA are limited to the creation of the IPS, and the selection, mapping, monitoring, and replacement of plan investment options for which CWA will have explicit authorized discretionary control. CWA is not responsible for any fiduciary duties or responsibilities imposed on the plan’s fiduciaries under ERISA not explicitly contemplated in the Client Agreement; and will not be responsible for investment decisions made by plan participants with respect to the investment of their accounts. D. Advisory Agreements 1. Information Received by Individual Clients At the onset of the Client relationship, CWA gathers information on each Client’s investment objectives, risk tolerance, time horizons and financial goals. CWA does not assume responsibility for the accuracy of the information provided by the Client and is not obligated to verify any information received from the Client or from any of the Client’s other professionals (e.g., attorney, accountant, etc.). Under all circumstances, Clients are responsible for promptly notifying CWA in writing of any material changes to the Client’s objectives, risk tolerance, time horizon, and financial goals. If a Client notifies CWA of any changes, CWA will review such changes and implement any necessary revisions to the Client’s portfolio. 2. Client Agreements and Disclosures Each Client is required to enter into one or more written agreements with CWA setting forth the terms and conditions under which the Firm shall render its services (the “Agreement”). In accordance with applicable laws and regulations, CWA will provide its disclosure brochure (ADV Part 2A), brochure supplement (ADV Part 2B), Form CRS and most recent Privacy Notice to each Client prior to or contemporaneously with the execution of the Agreement. The Agreement between CWA and the Client will continue in effect until terminated by either party pursuant to the terms of the Agreement. CWA’s fees (as discussed below) shall be prorated through the date of termination and any remaining balance shall be charged or refunded to the Client, as appropriate, in a timely manner. Neither CWA nor the Client may assign the Agreement without the prior consent of the other party. Transactions that do not result in a change of actual control or management of CWA shall not be considered an assignment. E. Participation in Wrap Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and other administrative fees. CWA does not participate in any wrap programs at this time. F. Amount of Client Assets Managed As of December 31, 2023, the following represents the amount of client assets under management by the Firm on a discretionary and non-discretionary basis: Type of Account Assets Under Management Discretionary $ 679,978,585 Non-Discretionary $ 40,939,265 Total: $ 720,917,850