PWA is owned by Mr. Kirk Stovesand and PT&C Group, LLC. PWA acquired the advisory business of Walpole Financial Advisors, LLC (“Walpole”). Walpole was originally formed in 2001 and conducted business as a SEC-registered investment adviser until its acquisition by PWA in December 2023. As this is PWA initial application for registration, there are no assets under advisement. Investment Management Services: PWA manages investment portfolios for individuals, qualified retirement plans, trusts, charitable organizations, corporations and small businesses. PWA will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement (IPS). PWA uses investment and portfolio allocation software to evaluate alternative portfolio designs. PWA evaluates the client’s existing investments with respect to the client’s investment policy statement. PWA works with new clients to develop a plan to transition from the client’s existing portfolio to the portfolio recommended by PWA. PWA will then continuously monitor the client’s portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. PWA will typically create a portfolio of no-load mutual funds, and may use model portfolios if the models match the client’s investment policy. PWA will allocate the client’s assets among various investments taking into consideration the overall management style selected by the client. PWA primarily recommends portfolios consisting of passively managed asset class and index mutual funds. PWA primarily recommends mutual funds and exchange-traded funds (ETFs) that follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s IPS. PWA manages mutual fund and equity portfolios on a discretionary basis according to the IPS agreed to by the client. A client may impose any reasonable restrictions on PWA’s discretionary authority, including restrictions on the types of securities in which PWA may invest client’s assets and on specific securities, which the client may believe to be appropriate. PWA has retained Buckingham Strategic Partners (“BSP”) to act as a discretionary sub-advisor. BSP shall provide various model asset allocation portfolios (each a “Portfolio”, collectively “Portfolios”) for selection by PWA. Each Portfolio strives to achieve long-term risk and return objectives through diversification among multiple asset classes using investment options available to BSP, which may include, but are not limited to, mutual funds and/or ETFs from Dimensional Fund Advisors LP, Bridgeway Capital Management, Inc., AQR Capital Management, LLC, The Vanguard Group, Inc., Stoneridge Asset Management, LLC, or other providers selected by BSP. Each Portfolio is designed to meet a particular investment goal which PWA has determined is suitable based on the client's circumstances. Once the appropriate Portfolio(s) has been determined, the Portfolio will continuously be managed based on the portfolio’s goal and BSP will have the discretionary authority to manage the Portfolio(s), including periodically rebalancing. However, PWA, on behalf of its client, will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Should material life events occur, clients should immediately contact PWA to determine if changes to an account and the allocation of the assets held in the account are necessary. On an ongoing basis, PWA will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. PWA will periodically, and at least annually, review clients’ IPS, risk profile and discuss the re-balancing of each client's accounts to the extent appropriate. PWA will provide to BSP any updated client financial information or account restrictions necessary for BSP to provide sub-advisory services. In addition to managing the client’s investment portfolio, PWA may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning,

insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. PWA does not participate in or sponsor any wrap fee programs. Employee Benefit Retirement Plan Services: PWA also provides advisory services to participant-directed retirement plans through third-party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. PWA will analyze the plan's current investment platform. PWA will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. PWA will recommend changes in the plan's investment vehicles as may be appropriate from time to time. PWA generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, PWA also works in coordination and support with BSP. Retirement plan clients will engage both PWA and BSP. BSP will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. PWA will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: PWA also provides advice in the form of a Financial Plan. Clients purchasing this service will typically receive a written financial report, providing the client with a detailed financial report designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. PWA may illustrate the impact of various investments on a client’s current income tax and future tax liability.
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of investment alternatives and their effect on a client’s portfolio. PWA gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed and a written report is typically prepared. Should a client choose to implement the recommendations in the plan, PWA suggests the client work closely with his/her attorney, accountant or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion. Consulting Services: Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client's existing portfolio, or any other specific topic. PWA also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, PWA provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning and/or income tax planning advice. Additionally, PWA offers a cash management aggregator system named Flourish Cash. Flourish Cash is a service offered by an unaffiliated third-party, Flourish Financial LLC, a registered broker-dealer and FINRA member. A Flourish Cash account is a brokerage account whereby the cash balance is swept from the brokerage account to deposit accounts at one or more third-party banks that have agreed to accept deposits from customers of Flourish Financial LLC. Flourish Financial LLC is an indirect, wholly-owned subsidiary of Massachusetts Mutual Life Insurance Company. Please refer to the applicable disclosures provided separately by Flourish Financial upon account opening.