A. Description of the Advisory Firm Northwest Wealth Advisors, LLC, d/b/a West Invest (hereinafter “NWAL”) is a Limited Liability Company organized in the State of Washington. The firm was formed in July 2023, and the principal owners are LaVelle Blair West and LaMar A West. B. Types of Advisory Services Portfolio Management Services NWAL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. NWAL 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 • Risk tolerance • Regular portfolio monitoring NWAL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. NWAL will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. NWAL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of NWAL’s economic, investment or other financial interests. To meet its fiduciary obligations, NWAL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, NWAL’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 NWAL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments NWAL generally limits its investment advice to mutual funds, fixed income securities, real estate funds, equities and ETFs (including ETFs in the gold and precious metal sectors). NWAL may use other securities as well to help diversify a portfolio when applicable. 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client 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. Financial Planning Services NWAL will often provide a variety of financial planning and consulting services to clients. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, financial planning, estate planning, tax planning, cash flow planning / debt management, personal savings, education savings, insurance and risk management, and/or other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to, the client will usually include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the client start or revise their investment programs, commence or alter retirement savings, or establish education savings and/or charitable giving programs. For certain financial planning engagements, NWAL will provide a written summary of the client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, NWAL may not provide a written summary. Clients are under no obligation to act on our financial planning recommendations. NWAL may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, NWAL will always ensure those other advisers are properly licensed or registered as an investment adviser. NWAL then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of NWAL's client. NWAL may also allocate among one or more private equity funds or private equity fund advisers. NWAL will not review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Use of LPL Programs NWAL provides advisory services through certain programs sponsored

by LPL Financial LLC ("LPL"), a registered investment advisor and broker-dealer. NWAL has included a brief description of each LPL advisory program that it intends to use. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. NWAL expects to use the following LPL programs. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, the client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. NWAL will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. NWAL will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $1,000 is required for OMP, but systematic contributions are required for account sizes below $10,000. In certain instances, LPL may permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. NWAL will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. NWAL will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL's Research Department consistent with the client's stated investment objective. LPL's Research Department, a third-party portfolio strategist and/or NWAL, through its investment adviser representative, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account's allocation amongst portfolios. An account minimum of $25,000 is required for most strategies, and a minimum of $10,000 is required for select strategies. In certain instances, a lower minimum for a portfolio may be permitted. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although NWAL will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty- five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and Alliance Financial, LLC by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or Alliance Financial, LLC, do not enter into an advisory agreement with LPL, FutureAdvisor or Alliance Financial, LLC, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. In certain instances, a lower minimum for a portfolio may be permitted. C. Client Tailored Services and Client Imposed Restrictions NWAL 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 a plan that will be executed by NWAL on behalf of the client. NWAL may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. NWAL does not participate in wrap fee programs. E. Assets Under Management NWAL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 152,263,001 $0 December 2023