A. Description of the Advisory Firm Babb Wealth Advisors LLC (hereinafter “BWA”) is a Limited Liability Company organized in the State of Arizona. The firm was formed in July 2018, and the principal owner is Travis Christopher Babb. Kathleen Schroeder is the chief compliance officer. B. Types of Advisory Services Portfolio Management Services BWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Assessment of risk tolerance • Regular portfolio monitoring BWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. BWA will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. BWA will also accept non-discretionary account. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. BWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of BWA’s economic, investment or other financial interests. To meet its fiduciary obligations, BWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, BWA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is BWA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Other Advisers BWA may direct clients to third-party investment advisers. Before selecting other advisers for clients, BWA will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where BWA is recommending the adviser to clients. Written Acknowledgement of Fiduciary Status 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. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments BWA generally limits its investment advice to mutual funds, fixed income securities, real estate funds(including REITS), treasuries, insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, and non-U.S. securities although BWA primarily recommends diversified investment based investing strategies. BWA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions BWA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as an investment plan that will be signed and executed by BWA on behalf of the client. BWA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent BWA from properly servicing the client account, or if the restrictions would require BWA to deviate from its standard suite of services, BWA reserves the right to end the relationship. D. Wrap Fee Programs BWA acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes BWA’s non-wrap fee advisory services; clients utilizing BWA’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure. BWA manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. BWA receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management BWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 116,511,177.00 $0.00 December 2023 Assets Under Advisement: Date Calculated: $329,602.00 December 2023