Overview of Woloshin Investment Management (WIM) WIM is a Limited Liability Company organized under the laws of New Jersey. Michael Woloshin founded the Medford, NJ-based investment advisory firm in 2004. Michael Woloshin is the principal owner. WIM is an investment advisory firm registered with the Securities and Exchange Commission. WIM provides discretionary and, at its sole discretion, non-discretionary investment management services to individuals, trusts, estates, foundations, retirement plans and corporations. Assets under the direct management of WIM are held at independent custodians including custodian Charles Schwab & Co., Inc. (Schwab). WIM does not serve as a custodian of client assets. As of December 31, 2023, WIM managed approximately $ 130,023,294 all on a discretionary basis and no assets on a non-discretionary basis. Services Provided Asset Management Services for Private Clients of WIM (WIM Managed Accounts) WIM provides advice as to the allocation of client portfolios and the investment of client assets. Investment advice is tailored to the individual needs of each client. WIM evaluates the client’s personal and financial circumstances at the onset of the relationship, and periodically thereafter. Each client is advised that it remains his responsibility to promptly notify WIM when there is any change in his/her financial situation and/or financial objectives for the purpose of reviewing, evaluating or revising previous recommendations or services. Managed Accounts will typically be invested in one of the four strategies described in Item 6 of this Brochure. WIM will manage the client’s investment portfolio on a discretionary or a non-discretionary basis. As a discretionary investment advisor, WIM will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Clients may impose restrictions on investing in certain securities or types of securities. This must be executed in writing and signed by the client, WIM and any third-party manager if applicable. The advisory engagement requires execution of a written contract and includes implementation of recommendations accepted by the client, unlimited telephone support, meetings as required, on-going communication and provision of periodic performance and portfolio reports. 5 | P a g e Management of Wrap Accounts WIM Managed Accounts for clients are offered on a wrap fee basis. The fee you pay in this program covers our advisory fee and all brokerage commissions and other trading costs of transactions placed through the custodian. We receive a portion of the wrap fee for our services.
• The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account.
• For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees.
• In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker- dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee.
• For example, our wrap fee arrangement creates incentives for our firm to trade less frequently or select investments that that reduce our costs, and in some cases increase expenses that are borne by the client. We are available to discuss the custodian’s execution related pricing with you so that you can compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total

cost to invest could exceed the cost of paying for brokerage and advisory services separately. Fees and Compensation We offer our services on a fee-only basis. Our fee is calculated based upon the market value of the assets in your account on the last day of the previous quarter. There is a minimum quarterly fee of $25 per account. Broker-dealers and other financial institutions that hold client accounts are referred to as custodians (“custodian/broker-dealer”). Your custodian/broker-dealer determines the values of the assets in your portfolio. Fees for the initial quarter are based on the value of your cash and securities on the date the custodian/broker-dealer receives them and are prorated based upon the number of calendar days in the calendar quarter that our agreement is initiated. 6 | P a g e Asset Management WIM Clients participating in WIM Managed Accounts are only available with a wrapped pricing option. Our wrap fee covers our advisory services, the brokerage and execution services provided by the custodian and administrative services. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from our custodian at another broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our Wrap fee schedule is described below: Assets Under Management Total Annual Advisory Fee* Up to $500,000 1.97% Next $500,000 1.87% $1,000,001 to $2,000,000 1.77% $2,000,001 to $3,000,000 1.67% $3,000,001 to$4,000,000 1.57% $4,000,001 to$5,000,000 1.47% Over $5,000,000 1.37% * WIM Managed Assets Program execution, custodial, and clearing fee is included in Total Annual Advisory Fee. A portion of this fee will be retained by WIM.All fees are negotiable at our sole discretion. There is a minimum quarterly fee of $25 per account. You must authorize us to have the custodian/broker-dealer pay us directly by charging your account. This authorization must be provided in writing. Fees are deducted quarterly in advance. The custodian/broker-dealer provides you with statements that show the amount paid directly to us. You should review and verify the calculation of our fees. The custodian/broker-dealer does not verify the accuracy of fee calculations. WIM may agree to direct billing of fees in certain circumstances. Both the client and WIM must agree to this arrangement in writing. The client agreement will generally serve as the memorializing document but WIM in its sole discretion may agree to such an arrangement in other written formats. 7 | P a g e Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by us. Complete details of these internal fees and expenses are explained in the prospectuses for each investment. You are strongly encouraged to read these explanations before investing any money. You may ask us any questions you have about fees and expenses. Please be sure to read the section in the Disclosure Brochure - Item 12 entitled “Brokerage Practices.” Advisory fees are charged in advance on a quarterly basis. Should you terminate the advisory agreement we have entered into within five (5) business days from the date the agreement is executed, you will receive a full refund of any fees paid. Should either one of us terminate the advisory agreement we have entered into before the end of a billing period, any unearned fees that were deducted from your account will be returned to you by us. The amount refunded to you is calculated by dividing the most recent advisory fee you paid by the total number of days in the quarter. This daily fee is then multiplied by the number of calendar days in the quarter that our agreement was in effect. This amount, which equals the amount we earned for the partial quarter, is subtracted from the total fee you paid in advance to determine your refund. We do not charge performance-based fees on any of our client accounts. Performance-based fees are designed to give a portion of the returns of an investment to the investment advisor as a reward for positive performance. The fee is generally a percentage of the profits made on the investments.