Tanglewood Total Wealth Management, Inc. “Tanglewood” was originally founded in 1979 by John F. Merrill. John is currently the President and majority owner of the firm. In addition, Keith Fenstad and Brian Merrill each own 10%. John, Keith, and Brian collectively serve as the firm’s management team. Tanglewood offers its clients professional money management and access to a complete range of personal wealth planning services. Depending on the range of services desired by the client, Tanglewood offers two distinct advisory relationship types from which clients can choose: the “Wealth Management” relationship or the “Investment Management” relationship. With its Wealth Management relationships, Tanglewood offers to address a client’s total financial well- being. In addition to individually-tailored investment management services, personalized wealth planning is available at no additional charge. For Investment Management relationships, Tanglewood provides turnkey investment management. The Investment Management relationship is offered to those clients who do not wish to receive wealth planning services available through the Wealth Management relationship. In either of the above advisory relationships, Tanglewood has discretion over the purchase of liquid (tradable) investments including U.S. or foreign government bonds, mutual funds, Exchange Traded Funds (ETFs), annuities and cash or equivalents for each client’s account. An unrelated qualified custodian or broker/dealer maintains custody of all client assets under management. Tanglewood is named as investment advisor on these accounts. As of December 31, 2023, Tanglewood managed $1,305,375,189 of client assets on a discretionary basis. Wealth Management Relationship In addition to investment management, our primary wealth planning role is to serve as a knowledgeable and unbiased source of information and education. The depth and complexity of planning varies with each client. Wealth planning is a “value added” service offered to our Wealth Management clients. Tanglewood offers personalized wealth planning advice to those Wealth Management clients who seek our guidance in one or more of the following areas: - Estate Planning - Asset Protection - Retirement Planning - Employee Benefit Analysis - Insurance Analysis - Business Planning - College Funding - Charitable Planning All Wealth Management clients are encouraged to involve us in each aspect of their financial lives. As a value-added service for Wealth Management relationships, Tanglewood offers Family Financial Consulting (FCC) free of charge to the adult children of its Wealth Management clients. FCC includes access to tools and resources developed by Tanglewood to help with common financial planning areas of most interest to them. These individuals would not be clients of the firm unless they otherwise qualified and engaged Tanglewood for investment management services directly. Investment Management Relationship There are no ongoing financial planning services for Investment Management relationships. However, advice necessary to the professional management and servicing of the accounts is provided as needed. Miscellaneous Notes Regarding Tanglewood’s Advisory Business Financial Planning Limitations and Non-Investment Consulting/Implementation: To the extent requested by a Wealth Management client, Tanglewood shall generally provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Tanglewood will generally provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, extraordinary matters, special projects, stand-alone planning engagements, etc. for which Tanglewood may charge a separate or additional fee). Please Note: Tanglewood believes that it is important for the client to address financial planning issues on an ongoing basis. Tanglewood’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Tanglewood. Tanglewood does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, Tanglewood does not prepare estate planning documents or tax returns, not does it sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.). The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Tanglewood and/or its representatives. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Tanglewood and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Tanglewood recommends that a client roll over their retirement plan assets into an account to be managed by Tanglewood, such a recommendation creates a conflict of interest if Tanglewood will earn new (or increase its current) compensation as a result of the rollover. If Tanglewood provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Tanglewood is acting as a fiduciary 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. No client is under any obligation to rollover retirement plan assets to an account managed by Tanglewood. Tanglewood’s Chief Compliance Officer, Keith Fenstad, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Charles Schwab & Co., Inc.: As discussed below in Item 12, unless the client directs otherwise, Tanglewood shall generally recommend that Charles Schwab & Co., Inc. (“Schwab”) serve as the broker- dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge brokerage commissions and/or transaction fees for effecting securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on individual equity transactions, others do). In addition to Tanglewood’s investment management fee, brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Please Note: there can be no assurance that Schwab will not change their transaction fee pricing in the future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather than electronically. Use of Mutual Funds: Most mutual funds are available directly to the public. Thus, a prospective client can obtain many of the mutual funds that may be recommended and/or utilized by Tanglewood independent of engaging Tanglewood as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Tanglewood’s initial and ongoing investment advisory services. Separate Fees: All mutual funds (and exchange traded funds) impose fees at the fund level (e.g., management fees and other fund expenses). All mutual fund fees are separate from, and in addition to, Tanglewood’s Wealth Management fee as described at Item 5 below. Tanglewood’s Chief Compliance Officer, Keith Fenstad, remains available to address any questions that a client or prospective client may have regarding the above. Cash Positions: Tanglewood continues to treat cash as an asset class within its managed portfolio allocations Separate cash holdings identified as restricted by the client will not be included in advisory fee calculations. As such, unless determined to the contrary by Tanglewood, all managed cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Tanglewood’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Tanglewood may overweight cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields,

at any point in time, Tanglewood’s advisory fee could exceed the interest paid by the client’s cash holdings. Tanglewood’s Chief Compliance Officer, Keith Fenstad, CFP, remains available to address any questions that a client or prospective client may have regarding the above fee billing practice. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Tanglewood shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Tanglewood reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral or
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Tanglewood does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Tanglewood does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Tanglewood:
• by taking the loan rather than liquidating assets in the client’s account, Tanglewood continues to earn a fee on such Account assets and
• if the client invests any portion of the loan proceeds in an account to be managed by Tanglewood, Tanglewood will receive an advisory fee on the invested amount. Please Note: The client must accept the above risks and potential corresponding consequences associated with the use of margin or pledged asset loans. Other Assets: A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Tanglewood. Generally, with potential exceptions, Tanglewood does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by Tanglewood will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Tanglewood) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which Tanglewood does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which Tanglewood does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by Tanglewood, Tanglewood shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by the Registrant; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Tanglewood Dashboard: Tanglewood may provide Wealth Management relationships access to account aggregation services (provided by eMoney or Right Capital), which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets that we manage (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not us, shall be exclusively responsible for the investment performance of the Excluded Assets. Tanglewood does not provide investment management, monitoring or implementation services for the Excluded Assets. The client may engage Tanglewood to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Tanglewood and the client.
• eMoney and Right Capital. In the event that Tanglewood provides the client with access to an unaffiliated vendor’s website such as eMoney or Right Capital, and the site provides access to information and/or concepts, including financial planning, the client, should not, in any manner whatsoever, infer that such access is a substitute for services provided by Tanglewood. Rather, if the client utilizes any such content, the client does so separate and independent of Tanglewood. Client Obligations: In performing our services, Tanglewood shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her responsibility to promptly notify Tanglewood if there is ever any change in his/her financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. WE DON’T HAVE OR RECOMMEND an ESG strategy: Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable, or prove successful. Registrant does not maintain or advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Tanglewood, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Tanglewood will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: Tanglewood does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Tanglewood considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal.