Capstone Wealth Management Corp. (“CWM”, “us”, “we”, “our”) is a corporation organized under the laws of the State of Florida on August 8, 2012 and owned by Allen R. Montgomery. We have been registered as an investment adviser since 2012. Currently, we are applying for registration with the U.S. Securities and Exchange Commission (“SEC”) and notice file with the appropriate state regulatory authorities. As of March 4, 2024, the firm had $88,394,939 in assets under management which were managed on a discretionary basis and $2,361,514 were managed on a non- discretionary basis. This Disclosure Brochure provides you with information regarding our qualifications, business practices, and the nature of advisory services that should be considered before becoming our advisory client. Please contact Allen R. Montgomery, CCO, if you have any questions about this Brochure. Individuals associated with us who are qualified will provide investment advisory services on our behalf. Such individuals are known as Investment Advisor Representatives (“IARs”). We require IARs engaged in determining or offering investment advice to clients to have at a minimum three years investment securities business experience, or a college degree related to investment management. These IARs must also be properly licensed and registered in the states, unless exempted, in which they provide investment advisory services. We offer investment advisory services to individuals, including high net worth individuals, pension and profit-sharing plans, charitable organizations, and corporations. Below is a description of the investment advisory services we offer. For more detail on any product or service please reference your advisory agreement or contact your CWM Investment Advisory Representative (“IAR”). DESCRIPTION OF SERVICES PROVIDED We provide continuous personal consultation and interaction when providing discretionary or non-discretionary investment advisory services. We will work with you to identify your investment goals, objectives, and risk tolerance in order to create a portfolio allocation designed to reach those goals and objectives and to ensure that the goals and objectives selected by the client are suitable, given the established client guidelines and information. We typically create a portfolio consisting of individual stocks or bonds, mutual funds, and variable annuity and life products including ETFs, municipal and government securities, real estate, and oil and gas. It is our policy not to recommend investments in limited partnerships, but we may recommend investments in master limited partnerships. Investment strategies vary based on your investment objectives and risk tolerance and may include long-term buy and hold or short-term trading or margin transactions. Short- term trading and margin transactions generally hold a greater risk and clients should be aware that the risk of loss may be greater in using any of these strategies. The use of margin transactions could create a conflict of interest where we may have an incentive to use margin to create a higher market value and therefore receive a higher fee. The use of margin will result in interest charges and heightened risk in addition to all other fees and expenses associated with the security involved. Nevertheless, each portfolio will be designed to meet your particular investment goals, objectives, circumstances, and risk tolerance. You will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Portfolio Management Services Our IARs provide continuous and regular investment advisory services on a discretionary or non-discretionary basis to you in connection with establishing and monitoring your investment objectives, risk tolerance, asset allocation goals and time horizon. In addition, our IARs may provide information and research about investment products and strategies, and review portfolio performance reports. You can place reasonable restrictions or constraints on the way your account is managed; however, such restrictions may affect the composition and performance of your portfolio. For these reasons, the performance of the portfolio may not be identical with our average client or other client portfolios. If we manage your account on a discretionary basis, such discretion must be granted in writing. CWM manages your account and makes investment decisions without consultation with you that would involve determinations regarding which securities are bought and sold, the total amount of securities to be bought or sold, the price per share, and the commission rates at which securities transactions are effected. Our discretionary authority in making these determinations will be limited by the conditions imposed by you in your investment guidelines, objective, or instructions otherwise provided to us. If we manage your account on a non-discretionary basis, we customarily make periodic investment recommendations to you involving which securities are to be bought or sold and the total amount of such purchases or sales. You have the option to accept or reject our recommendations. If you accept the recommendation, you also have the option to implement the transactions with a broker-dealer of your choosing or to have CWM effect the transactions. Unless otherwise determined by the client, all accounts will be held at TD Ameritrade and Axos Clearing LLC (“Axos”). Sub-Adviser Management Services CWM also offers, on a discretionary basis, sub-adviser management services to clients of other registered investment advisers. From time-to-time, CWM may enter into a sub- advisory agreement with registered investment advisers to provide investment management services to the clients it accepts from those firms. Through this arrangement, CWM will assist and advise the client in establishing investment objectives and develop an investment strategy to meet those objectives by appropriately identifying investments and monitoring such investments. In return for its sub-advisory services, CWM is paid an annual asset-based fee by the registered investment advisers it has entered into an investment advisory agreement with. Clients may obtain a copy of the agreement between CWM and their registered investment advisers by contacting their IAR. Clients receiving CWM's services have regular contact with their IAR who assist in periodically reviewing and evaluating the progress being made by CWM. Financial Planning Services In addition, to the Portfolio Management Services, and for a separate fee, CWM makes available a variety of financial planning services. The scope

of the services and the fees for these services is pursuant to a written financial planning agreement that is distinct from the Portfolio Management Agreement. Generally, such financial planning services will involve preparing a written financial plan or rendering a financial consultation for clients based on their current situation, financial goals, and objectives. This planning or consulting may encompass one or more of the following areas: 1. Accumulation - an analysis based on the estimated rate of return on investments and the estimated long-term inflation rate of the lump-sum and/or periodic dollar commitment necessary to meet stated financial goals. 2. Financial Independence (Retirement) - an analysis of the lump-sum and/or periodic dollar commitment necessary to meet stated financial goals during retirement taking into consideration the client’s assets and liabilities, projected social security, pension or other retirement benefits and desired level of income at retirement. 3. Investments - an analysis of appropriate investments, and appropriate adjustments to existing investments, based upon the client’s description of his/her primary investment concerns, needs, goals and objectives. This analysis does not include ongoing management or monitoring of investments or portfolios. 4. Risk Management - an analysis of the client’s insurance needs and coverages, taking into account the client’s accumulation goals, assets and liabilities, sources of income, and income needs for the client’s beneficiary upon death or disability. 5. Estate Planning - an analysis of estate settlement costs, which include taxation and administrative costs and an evaluation of estate reduction and tax payment techniques. It involves discussion of gifts, trusts, and estate planning documents. Analyses are subject to verification by the client’s own estate planning expert. 6. Income Taxes - an analysis of the client’s tax situation that is based on a general understanding of current tax laws. Analyses are subject to verification by the client’s own tax expert. 7. Miscellaneous Advisory Services - hourly fees may be charged for an annual review of a financial plan or for specific advice regarding implementation of the planning topic(s) selected above, investment techniques and investments in specific securities, insurance products, and other investment vehicles or specific advice. The plan or separate financial consultation will usually include general recommendations for a course of activity or specific actions to be taken by the client. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. CWM’s financial planning services involve an assessment of the client’s financial situation, including an analysis of financial planning needs and current investment portfolio(s). The information provided by the client is examined in relation to long and short-term investment objectives, specific client needs as perceived by CWM, market conditions and general economic conditions. The advice includes specific recommendations regarding long- and short-term financial planning and recommendations regarding the retention or disposition of the client's securities and other investments. This service also includes at least one written report and one or more meetings to discuss the status of your financial situation and CWM’s specific recommendations. Prior to engaging CWM to provide financial planning or consulting services, clients will be required to enter into a Financial Planning Agreement that sets forth the terms and conditions of the engagement, describing the scope of the services to be provided and the fees due to CWM upon completion of the services. If requested, CWM may recommend the services of other professionals for implementation purposes. Clients will provide these professionals with the necessary information to perform the required services. We will not be compensated for referring clients to these professionals. Clients are under no obligation to engage the services of any such recommended professional. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendations. Advisory recommendations are based on your financial situation at the time the services are provided and are based on financial information disclosed by you. You are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. You are advised that you have the responsibility to promptly notify CWM if there are ever any changes in your financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. IRA Rollover Recommendations For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the clients’ best interest. Wrap Fee Programs CWM does not participate in wrap fee programs.