Broadway Wealth Solutions, Inc. is a registered investment advisor firm registered with the United States Securities and Exchange Commission. Broadway Wealth Solutions, Inc. is a wholly owned subsidiary of Broadway National Bank. Broadway Wealth Solutions lnc.'s ("BWSI" or "Advisor") principal service is providing fee- based investment advisory services on a discretionary basis and related financial planning services (which are included in the fee for investment advisory services). The Advisor manages custom investment portfolios, on a discretionary or non-discretionary basis, according to the Client's risk profile and investment objectives. Asset allocation models are customized asset models built and managed by BWSl's affiliated Partners, Broadway National Bank's Investment Management Group ("IMG"). Broadway Wealth Solutions Inc. offers services to both retirement and non-retirement investors. The general steps involved in the Financial Planning process are:
• Establishing and defining the Client-advisor relationship
• Gathering Client data, including goals
• Analyzing and evaluating the Clients' financial status
• Developing and presenting financial planning recommendations and alternatives
• Implementing the financial planning recommendations and
• Monitoring the financial planning recommendations The Advisor's primary approach is to use strategic asset allocation, make tactical adjustments when indicated, and pursue a reasonable potential return for the level of risk assumed. For example, the Advisor may use any of the following: exchange-listed securities, over-the-counter securities, corporate debt securities, CDs, life insurance, fixed annuities, municipal securities, mutual funds, and United States government securities to accomplish this objective. IMG assesses and selects mutual funds using various criteria, such as the fund's investment strategy, the fund manager's tenure, overall career performance, expense ratio, risk/return profile, and the selections fit for the intended purpose as a component of the overall portfolio. The Advisor may recommend, on occasion, changes in investment allocations to reduce risk or increase potential return or otherwise achieve more significant benefit for the Client. The Advisor or IMG may recommend specific stocks to adjust sector weightings, anticipated dividend yield, or other characteristics better aligned with Client's objectives. The Advisor may recommend employing cash positions as a hedge against a possible market movement that adversely affects the portfolio. The Advisor may recommend selling positions for reasons that include, but are not limited to, the pursuit of tax efficiency, a perceived change in risk due to mispricing, new information related to a specific issuer, sector, or asset class, identification of opportunities the Advisor believes to be relatively more attractive, change in risk tolerance of the Client, or to maintain a level of cash the Advisor deems appropriate. The Client, prior or concurrent to entering into an agreement for these services, will be provided with the Advisor's Brochure. Further, BWSI and its Client will agree in writing that the Client's account will be managed by BWSI on a discretionary basis. If Clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions with the Client to have a clear understanding of the Client's requirements. Retirement Specific Services BWSI may recommend that a retirement investor rollover or transfer some, or all their funds from a 401k plan, qualified retirement plan or IRA (directly or indirectly) from another firm to BWSI. Prior to recommending or executing this type of transaction and in addition to the financial planning process above, the Advisor will provide the following service:
• Meet directly with the Client to understand individual personal retirement goals and needs
• Coordinate the management of the IRA in the context of all the Client's assets and investments
• The Advisor will provide the same ongoing management of Client accounts as mentioned above, utilize the same methodologies for analysis, investment strategies and products used will be consistent as explained in section 8 below
• Although, BWSI does not maintain physical custody of retirement Client funds

or securities, except for the withdrawal of advisory fees directly from Client accounts, Pursuant to Rule 206(4)-2 of the Advisers Act, BWSI is deemed to have indirect custody, because the Firm is a wholly owned subsidiary of Broadway National bank (see section 15)
• Clients will receive statements no less than quarterly from the qualified custodian; discrepancies should be immediately brought to the firm's attention
• Maintain records for the individual retirement account according to Internal Revenue Service rules
•
•
•
•
•
• The rates are tiered based on the asset value, as shown in the table below. New Client fees will be prorated from the inception of the agreement to the end of the first quarter and Client's closing accounts will have fees prorated from the first day of the quarter to the date the client closing request is processed. Account Value Annual Fee: First $1 million 1.00% !Next $1 million 0.80% !Next $3 million 0.60% lover $5 million 0.50% Jover $5 million 0.50% Under certain circumstances, at the sole discretion of the Advisor, advisory fees may be negotiated. Asset management fees will be directly deducted from Client assets quarterly by the qualified custodian. The Client will give written authorization permitting the Advisor to be paid directly from their account held by the custodian, and the custodian will send a statement at least quarterly to the Client. Deduction of Account Fees- All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. In some instances, If no securities are available for liquidation, BWSI may send a billing invoice to the client requesting payment for services rendered. Selling securities to pay fees may incur transaction costs and could create tax consequences for you. You may contact us at 210- 283-6600. The Advisor's annual investment advisory fee for retirement investor Clients follows the same tiered fee schedule. For the Advisor's services described above, the Client may terminate these services within five business days of the effective date of an Agreement signed with the Advisor without any payment of the Advisor's fee. All fees paid to BWSI for investment advisory services are separate and distinct from the expenses charged by mutual funds to their shareholders and the product sponsor, mutual fund product's prospectus describes these fees and expenses. These fees will generally include a management fee and other fund expenses. At no time will BWSI accept or maintain physical custody of a Client's funds or securities (see section 15) except for authorized fee deduction . The Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The Advisor's fee is separate and distinct from the custodian and execution fees. Neither BWSI nor its supervised persons accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Where acting in the capacity of an insurance agent, Investment Advisor Representatives of BWSI may act as agent and effect insurance transactions for typical and customary compensation. However, Clients are not obligated to use investment advisory representatives of BWSI to execute such insurance transactions. This practice presents a conflict of interest by creating an incentive to recommend investment products based on the compensation received rather than on a Client's needs. For example, when recommending the sale of investment products for which BWSI receives compensation, BWSI will inform the Client of the conflict of interest. A Client may be able to invest in products recommended by the firm directly, without the services of Broadway. In that case, the Client would not receive the services provided by BWSI, which are designed, among other things, to assist the Client in determining which products or services are most appropriate to each Client's financial condition and objectives.