Firm Description: Founded in 1987, Wescott Financial Advisory Group is an SEC registered, fee only investment ‐‐ advisory and wealth management firm with its principal places of business located in Pennsylvania and Florida. The Firm's clients are high net worth individuals, families, trusts, foundations, pension plans, ‐‐ pooled investment vehicles, corporations and other businesses and institutions. The Firm's investment philosophy is a uniquely disciplined, tax sensitive,‐ opportunistic "open architecture, multi manager ‐ (passive and active management)" approach that has been maintained for over 30 years.
Listed below are the Firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).

•Grant Rawdin;
•Wescott Holding Company LLC. Wescott Holding Company LLC is the company through ‐ which Duane Morris LLP, a law firm, owns its interest in Wescott Financial Advisory Group. Advisory Services: Wealth Management Program The Firm offers ongoing financial planning and investment advice to our clients based upon the individual needs of the client. Through discussion with our clients, we come to understand our client's objectives, goals and individual circumstances. We then develop a client's personal Investment Policy, basing our recommendations and portfolio management upon that policy. During our data gathering process, we determine the client's individual objectives, time horizons, ‐ risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, professional experience and occupation, as well as family situation and background.
Different types of investments involve a variety of risks. We strive to explain the nature of the risks that a client will have in their portfolio. These risks may be in the stock or bond portfolio and may involve the volatility of the portfolio, risk to principal, illiquidity, lack of marketability (the ability to sell an asset at a particular time at a "fair" price) and a host of other risks that every investor faces, but about which an investor should be aware. Our recommendations, then, are based upon our client discussions and analyses. These recommendations are described in the Investment Policy Statement, which is provided to our clients for their approval before we invest their portfolio. In their Investment Policy Statement, we describe many of the risks and provide a range of losses that a client may experience with the investment objective recommended and that is approved by the client. These loss possibilities are meant to illustrate the volatility of the stock and bond markets.
It is very important that we are aware of changes to a client's situation that might impact our current and future recommendations. There are many actions we take to gather information from clients about these changes. Some of these actions follow: 1. Provide detailed quarterly written reports to each client providing updated specific portfolio performance and asset allocation information, with recommendations for changes, including our Investment Commentary and Outlook; 2. At least annually, contact each client to determine whether there have been any material 5 changes in the client's financial, or personal, situation or investment objectives, and whether the portfolio and investment strategy require adjustments to meet with client wishes and needs; 3. Be reasonably available to consult with the client; and 4. Maintain up to date client Investment Policy Statements and amendments in each ‐ ‐ client's file. Our investment recommendations are not limited to any specific product or service offered by a broker dealer, or insurance company, and will generally include advice regarding the advisability of owning any of the following securities:  Exchange listed securities‐  Securities traded over the counter‐‐  Foreign issuers  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Mutual fund shares  Private fund securities  United States governmental securities  Interests in partnerships investing in real estate  Interests in partnerships investing in oil and gas interests  Interests in partnerships investing in other businesses Wescott allows clients to place reasonable restrictions on investments in certain securities or types of securities.
Additionally, some clients may be a participant in various employer benefits and benefit plans, such as 401(k), stock options or defined benefit plans that Wescott will value, monitor and include as part of Wescott's comprehensive portfolio management structure. Wescott does not "select" these, and Wescott's monitoring and portfolio management of these assets may be limited to tracking them until certain employer limitations or timeframes are met.
Use of Independent Managers The Firm selects, or recommends, certain third party independent managers ("Independent Managers") to actively manage a portion of its clients' assets. When selecting or recommending certain Independent Managers, the Firm delegates its authority to the Independent Manager and no separate client agreement is necessary. The firm may provide the client with the Independent Manager's disclosure brochure. Certain Independent Managers will set forth the specific terms and conditions under which a client engages an Independent Manager in a separate written agreement with the designated Independent Manager. In those cases, clients will also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. The Firm evaluates a variety of information about Independent Managers, which may include the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third party analyses it believes are reputable.‐ To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance and risk results in relation to its clients' individual portfolio allocations and risk 6 exposure. The Firm may also take into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. The Firm continues to provide services relative to the discretionary or non discretionary selection, ‐ or recommendation, of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers, and seeks to ensure their strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Entrada® Management Program The Firm developed the Entrada® Management Program to provide investment management services for those clients with investable assets below $2 million. The Entrada® portfolio retains Wescott Financial Advisory Group's hallmark of a strategic, disciplined and diversified portfolio, blending the advantages of passive investing with active management. Entrada® combines Wescott Financial Advisory Group's investment management service with a coordinated and efficient process of needs assessment, account suitability, account administration, portfolio rebalancing, portfolio reporting and tax optimization.
Financial Planning Financial planning is included as part of our Wealth Management Program and Entrada® Management Program. Financial planning is a comprehensive evaluation of a client's current and future financial state. For this comprehensive evaluation, we use currently known information and, what we believe to be, reasonable variables to predict future cash flows, asset values and withdrawal plans.
Through the financial planning process, questions, information and analysis are considered as they impact and are impacted by the entirety of a client's financial and personal situation. Clients for whom these services are provided receive a written report that provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives.
In general, the financial plan may address any or all of the following areas:  Personal: We review family records, budgeting, personal liability, estate information and financial goals.  Cash Flow & Tax Planning: We analyze a client's projected cash flows that considers income from earned income, pensions, retirement plan distributions, and other income from investment portfolios or through other sources. We subtract a client's projected expenses, including projected income taxes, from the income sources to illustrate whether a client is spending more or less than their income. We then project the trend of this annual cash flow pattern to illustrate whether this pattern of spending, in relation to income, may be sustainable for the client's lifetime.  Investments: We analyze investment alternatives and their effect on the client's portfolio.
 Insurance: We review existing policies to ensure proper coverage for life, health, disability, long term care, liability, home and automobile.‐  Retirement: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.  Death & Disability: We review the client's cash needs at death, income needs of surviving dependents, estate planning and disability income. 7  Estate: We assist our clients in assessing and developing long term estate planning ‐ strategies, be they for planning in reducing estate taxes, or to ensure that a client leaves assets in a manner that assures they will be available for heirs in a protected and organized way. Such analysis and recommendations may include: the examination, analysis and recommendation of and for living, irrevocable and testamentary trusts, wills and codicils, durable powers of attorney, asset protection plans, long term care facility ‐ planning and elder law. Through in

depth personal interviews, we gather required information. The information gathered in‐ these interviews includes, the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report of our financial plan recommendations.
Should the client choose to implement the recommendations contained in the financial plan, we suggest the client work closely with his/her attorney, accountant, insurance agent and other advisors as appropriate. Implementation of financial plan recommendations is entirely at the client's discretion. We are available to our clients to assist them in the implementation of these recommendations.
If a financial plan is contracted for such analysis separately from the plan included in the Wealth Management Program, then the financial plan is generally presented to the client within six months of the contract date.
General Business Planning: We provide business planning advice to individual and corporate clients and will represent clients in financial negotiations, including business acquisitions, sales and mergers. Such consulting services are generally provided at an agreed upon fee that is in addition to our Wealth Management Program fee.
Wealth Management Services: MRK Powered by Wescott ("MRK PBW") Initial Wealth Management Plan (MRK PBW) The Initial Wealth Management Plan includes financial, tax, estate and investment planning for Merck® executives. It is a multi-disciplinary process that brings together our experienced team of financial, tax, estate, investment and risk management professionals to provide broad based and integrated recommendations. Through discussion with our clients, we come to understand their objectives, goals, time horizons, family situation, risk tolerance, liquidity needs and unique circumstances. The breadth and depth of this understanding forms the basis for the development of a client's personal wealth management plan.
Creation of the initial wealth management plan requires a significant investment of time by the Firm and the client duri.ng a multi-week process that includes preparation and presentation of a customized wealth management plan and investment strategy recommendations to help you achieve your goals.
After presentation of the plan, for a client who elects to engage the Firm for ongoing advisory services under either the Wealth Management or Entrada Programs described below, the Firm creates an Investment Policy Statement (IPS) for approval by the client before we invest their 8 portfolio. The IPS is a foundational and strategic document which specifies the guidelines which the Firm will follow to manage a client's investment program with regard to the other integrated aspects of their wealth management program. Wealth Management Program (MRK Powered by Wescott) (For Legacy APS clients, known as the PARTNERS Program) The Firm developed the MRK Powered by Wescott Wealth Management Program to provide wealth management services for Merck® executives with investable assets above $2 million. This minimum account size may be negotiable under certain circumstances, but may still be subject to a $25,000 minimum fee. On a triennial basis, clients in this program are offered a plan update to assess progress since their initial or previously updated Wealth Management Plan. The update will incorporate new or adjusted objectives, market performance data, revised inflation assumptions, and any new tax laws. The update includes a comprehensive and integrated review of a client's financial, tax, estate and risk management plans. There is no additional fee for this triennial service. For this level of integrated planning to work effectively, all assets must be tracked by Wescott.
SUNSET and PIMA Programs These programs are no longer offered to clients. We do however, continue to support existing clients that are still in these programs. Clients should refer to their contracts for specific fee information.
Financial Consulting Services We offer financial consulting services that primarily involve advising clients on specific financial- related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation.
Pension Consulting Services Wescott also provides advisory services to pension, profit sharing and 401(k) plans. Pension Consulting Services are comprised of three distinct services. Clients may choose to use any, or all, of these services: Selection of Investment Vehicles and Asset Allocation Models: Wescott assists plan sponsors in constructing appropriate asset allocation models and recommends specific investment vehicles.
Monitoring of Investment Performance: Wescott continuously monitors the performance of recommended investment managers and recommends changes to plan sponsors, as appropriate.
Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self directed plans''), ‐ Wescott provides an annual report covering mutual fund manager performance and annual educational support designed for plan participants. The nature of the topics covered are determined in consultation with plan sponsors under the guidelines established in ERISA Section 404(c). The educational support and investment workshops do not provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations.
9 Asset Allocation Services We offer asset allocation services that are tailored to meet our clients' needs and investment objectives. Once you have retained our firm for asset allocation services, we will gather information about your financial situation and objectives, and assist you in determining your investment goals, objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with recommendations as to how to allocate your investments among categories of assets. We will then review your account on a periodic basis. Where appropriate, we may provide you with recommendations to change your asset allocation in an effort to remain consistent with your stated financial objectives. You are free at all times to accept or reject any of our investment recommendations. You are solely responsible for implementing our recommendations. Unless you separately retain our services, we will not execute any transactions or changes in asset allocation on your behalf.
Family Office Solution Services We offer Family Office Solution Services designed to help our clients organize their financial situation and plan for the successful transfer of wealth to the next generation in the most tax- advantaged manner. Such services generally include financial planning in the following areas:
•Family Continuity;
•Estate Planning and Trustee Oversight;
•Integrated Tax and Financial Planning;
•Lifestyle Management;
•Family Philanthropy; and
•Risk Management Trustee Services Wescott Trust Services provides trust solutions for clients whose financial, family, or business needs require the services of a professional fiduciary. Wescott Trust Services is a trust representative of National Advisors Trust Company, a federally charted trust company regulated by the Office of the Comptroller of the Currency (OCC), a bureau of the U.S. Treasury Department, and is authorized to do business in all 50 states. Wescott Financial Advisory Group is a shareholder in National Advisors Trust Company (Wescott Financial Advisory Group owns less than .25% of NATC). A conflict of interest exists as a result of this ownership interest.
Tax Return Preparation Services (MRK PBW) This service is no longer offered to new clients. We do however continue to provide this service for legacy tax return preparation clients. This is an elective service for which clients must opt-in annually to receive services. Additionally, the firm has strategic alliances with several CPA firms, with whom clients can have federal and state income tax preparation completed by professionals familiar with our clientele. Wescott does not receive any compensation from these alliances. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your 10 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. Assets Under Management As of April 3, 2024, the Firm managed $3,477,406,798 in assets, of which $2,634,384,321 was managed on a discretionary basis and $843,022,477 was managed on a non discretionary basis.‐