RWM is a limited liability company formed under the laws of the State of Texas and is registered with Securities and Exchange Commission (“SEC”). The Firm’s owners are as follows: Chase M. Robertson, 10%; Sonia Joao, 10%; and Double C Family 80%. Portfolio Management Services RWM offers discretionary and non-discretionary portfolio management services. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. We may allocate to both Liquid Market Solutions (such as Stocks, Bonds or Funds) and Illiquid Market Solutions (such as Alternatives, Private Equity or Hedge Funds) in order to effectuate the portfolio design. Discretionary authorization will allow us to determine the specific securities, and the number of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. Third Party Investment Manager Services Howard Capital Management RWM provides third party investment management services through our relationship with Howard Capital Management (HCM). HCM is a registered investment adviser with the Securities and Exchange Commission (CRD# 118070). HCM practices active money management and does not favor buy and hold or asset allocation in managing portfolios. HCM uses strategies that “strive to protect capital in market downturns while seeking to outperform the major indices during market upswings. HCM uses a proprietary indicator to assist in determining when to buy and sell securities.” The indicator “HCM Buyline identifies the sign of a rising market and then identifies the particular security that HCM believes has the best return potential.”1 HCM Buyline is used in individually managed portfolios and in HCM managed mutual funds. Once the RWM Investment Adviser Representative (“IAR”) decides to utilize a HCM portfolio for their client, the portfolio construction begins. Through a profiling process the IAR will get to know the client by asking various suitability type questions. Once the profiling is complete policy guidelines for the portfolio will be determined and a strategy can be selected based on understanding the client’s investment objectives. After these steps have been taken recommendations are made. The first step in portfolio construction is setting investment objectives. As an example, if the client is a couple, the IAR might ask if they want the portfolio to grow or provide income at retirement or possibly combine the two objectives to meet their goal. The IAR will ask questions about their risk tolerance and how much risk they are willing to take to meet their investment objective. Time horizon during the profiling process is important to know so that the adviser knows when they will need to start taking income out of their portfolio to live on. The other consideration that needs to be factored in is how much experience has the client had with investing. Knowing the experience level, the client has with investing gives the IAR an understanding of how much education the client needs in understanding the investment process and inherent risks in investing. 5 The second step in portfolio construction is to have the IAR develop policy guidelines for the portfolio. A policy for the portfolio might include making socially responsible recommendations. The third step is the selection of a portfolio strategy and is usually a decision about the use of either active or passive or fundamental or technical analysis. As mentioned earlier, Fundamental analysis is an analysis of the particular characteristics of a company. Technical analysis is passive in that the IAR is usually looking at some way to replicate an existing index. Crystal Capital Partners, LLC RWM provides third party investment management services through with Crystal Capital Partners, LLC (“Crystal”). Through our relationship, we may provide our qualified clients with customized private equity and hedge fund portfolios. Crystal specializes in building customized portfolios that help complement the existing holdings of client investments. Crystal is a registered investment adviser with the Securities and Exchange Commission (CRD#146010). With Crystal’s services, we will have

access to top tier private equity and hedge fund managers, detailed analytics, reporting and comprehensive due diligence previously only available to the largest institutions. Most customized accounts will be invested with investment managers or investment funds through a series fund organized by Crystal. The investment managers and investment funds that we recommend will be selected from a list that has been developed by Crystal, based on its quantitative and qualitative research of the managers and funds. After a client approves the customized portfolio that we recommend, the client will invest in a series or portfolio of a fund that is managed by Crystal (“Crystal Fund”). The Crystal Fund is a private investment fund that has several segregated portfolios. Each portfolio is a separate pool of assets constituting a separate fund with its own investment objectives and policies. Wrap Fee Program A wrap fee program is a program where RWM “wraps” both the asset management fees for advisory services and the transaction fees for execution services into a single fee charged to the client. Under a wrap fee arrangement, a client’s costs are the same regardless of the number of transactions in an account. Pursuant to the Agreement signed by each client, the client will pay RWM a monthly Management/ Wrap Program Fee, payable in arrears, based on the accounts average daily balance, prorated based on the amount of the assets to be managed by the adviser as of the opening of business on the first business day of each month. In the event a client should withdraw from a strategy mid-month, the prorated advisory fee will be charged at that time. As you are participating in a wrap fee program, you will not be charged brokerage commissions; 6 however, please note that your brokerage account may be charged a service charge by the clearing firm, as well as potential account opening, closing, or similar servicing fees, in addition to your wrap fees. Certain IRA accounts may be charged custodial or other service fees as well. If your account is invested in mutual funds, the mutual fund company may assess administrative charges against your investment in that fund. These fees are not charged by RWM, but rather by the product sponsor, brokerage firm, or custodian firm. In the normal course of effecting transactions, prices for certain trades made on behalf of your account may include mark-ups, mark-downs and spread differentials. Client Assets Under Management Assets Under Management (as of December 31, 2022) Discretionary - $146,516,279,000 Non-discretionary - $165,541.,416,000 Total - $312,057,695,000 Fees All clients and prospective clients should read the Fee Schedule below and if you have any questions, please ask your IAR. Also, please ask your IAR if there are any additional fees that you should be aware of given your interest in a managed portfolio. If you are considering opening an account with one of RWM’s IARs, ask to see the Brochure for the account you are interested in to make sure you have the most current information. Portfolio Management Service Fees: RWM offers discretionary and non-discretionary portfolio management services. The account could be discretionary or non-discretionary depending on the preference of the client. The IAR’s account design will be based on the client’s investment objectives. The fee for the Separately Maintained Accounts depends on the asset size of the account: Assets Under Management Annual Fee $0-$2.0MM 2.0% $2,000,001 - $5,000,000 1.75% $5,000,001 - $25,000,000 1.50% $25,000,001 -$75,000,000 1.25% $75,000,001- $100,000,000 1.00% $100,000,001-$250,000,000 .90% $250,000,001-$450,000,000 .75% $450,000,001-and above Negotiable RWM IARs have experience and can provide advice on the following investments: Equities, Limited Partnerships and Master Limited Partnerships, Bonds, ETFs, REITs, Mutual Funds, Preferred Stocks, Closed-End Funds, Limited Partnerships, Fixed Income, Venture Capital, Alternative Investments. We do not have a limited product line. 7 Generally, this is the list of investments on which our IARs most often provide advice. However, if a client would like advice on any investments that might be appropriate our IARs would be glad to take the opportunity to review the client’s interest in a particular investment. 8