Description of Firm StrongTower Wealth Management, PLC is a registered investment Advisor primarily based in Hot Springs, AR. We are organized as a limited liability company ("LLC") under the laws of the State of Arkansas. We have been providing investment advisory services through other companies since 2/10/1999. We are owned by Todd David Sadowski. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to StrongTower Wealth Management, PLC, and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Portfolio Management Services We offer discretionary portfolio management services through a wrap-fee program. A wrap-fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. For more information concerning the Wrap Fee Program, see Appendix 1 to this Brochure. When you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. The discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval before each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. StrongTower Wealth Management ("STWM") investment advice is tailored to meet our clients' needs and investment objectives. Many of the investment options we utilize include options for value-based screens. When limiting to only these investment options, it may result in higher expense ratios due to the limited selection. We draw from a common pool of investments for all clients, but the allocations may differ from one client to another. We provide several investment management styles for our clients as described below. Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based on an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single-subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter- term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, or provide online access to the plan, to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. STWM Mutual Funds/ ETF Portfolio Management The management of these portfolios follows a base of modern portfolio theory ("MPT"), tweaked for common sense adjustments as we are not MPT purists. We feel a blanket MPT approach can be too simplistic overall. Our portfolios are rebalanced periodically and can be weight adjusted by fund and asset category depending on the client’s unique desires. The funds that we use are monitored internally and we do an in-depth analysis of our holdings periodically. We attempt to seek funds that have quality money managers, reasonable fees, and a moral compass when choosing companies to invest in. We do not attempt to time the markets in these portfolios. Mutual funds are sold with different share classes. Share classes are described in the mutual fund's prospectus. Generally, mutual funds will only be purchased at

net asset value when that fund is available at net asset value to the client. In addition, the fund families that we use often have various share classes to choose from. STWM will conduct an assessment initially upon purchase to determine whether clients are purchasing the most beneficial mutual fund share class available. A semi-annual audit will be conducted to determine that lower-cost share classes have not been made available. Wrap Fee Program(s) We are a portfolio manager and sponsor of a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes administrative fees, management fees, and trading charges. When you participate in our wrap fee program, you will pay our firm a single fee, which includes our money management fees, certain transaction costs, and custodial and administrative costs. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. The wrap fee does not include some fees that are imposed by the Custodian which sometimes include but are not limited to account close-out fees, wire fees, early settlement fees, etc. 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 substantial periods, 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. At STWM we have chosen to only offer wrap fee accounts to clients to remove some conflicts of interest, provide an easier-to-understand platform to clients, and put everyone on an even playing field. Transactions for your account must be executed by Charles Schwab & Co. Inc., member FINRA/SIPC ("Schwab "), an unaffiliated SEC-registered broker-dealer and FINRA member. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies the brokerage commissions charged by other broker-dealers, and the advisory fees charged by investment Advisors. For more information concerning the Wrap Fee Program, see Appendix 1 to this Brochure. 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 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 arrangements create incentives for our Advisors to trade less frequently or select investments that reduce our costs, and in some cases increase expenses that are borne by the client. Additionally, Schwab generally does not charge commissions, or transaction fees for trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to Schwab. If you choose to enter a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. Types of Investments We primarily offer advice on Mutual Funds, Exchange-Traded Funds ("ETFs"), and Stocks. Refer to the Methods of Analysis, Investment Strategies, and Risk of Loss below for additional disclosures on this topic. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. In general, we manage wrap fee accounts on a discretionary basis. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. In the wrap fee program, we will provide you with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. You should also review Part 2A thoroughly to evaluate any differences between the services we offer as wrap versus non-wrap. Assets Under Management As of March 31, 2024, we provide continuous management services for $129,000,000 in client assets on a discretionary basis.