Page 5 of 37 securities, and/or industry sectors. Once the client's portfolio has been established, we review the portfolio periodically and if necessary, rebalance the portfolio as deemed appropriate based on the client's individual needs. Client assets will be managed on an individual client basis. BNB Wealth Management, LLC's provides investment advice and sponsors its own wrap fee program and is compensated for providing advisory services for the management of client portfolios participating in the wrap fee program. Given the fact that BNB Wealth Management only offers a wrap program to its clients, it is not required to create and file a separate wrap fee program brochure. Financial Planning and Consulting Services BNB offers financial planning services to its clients. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. Financial planning services may be offered for a single, one-time plan, or clients may choose to engage BNB to perform ongoing monitoring of their financial plan, investments, financial situation and financial objectives on a year-round basis. We gather the required information through in-depth in-person or teleconference interviews. Information gathered includes but is not limited to, the client's current financial status, primary and secondary investment objectives, tolerance for risk, need for investment income, assets, current sources of income, current liabilities, their investment experience, time horizon, special needs, tax status and financial goals. We carefully review investment, bank, insurance and retirement statements supplied by the client, and utilize their current investments to create portfolio snapshot report that breaks down their current holdings asset allocation, historic investment performance and risk metrics, and holdings detail. We compare and contrast the investments that the clients currently own versus their stated investment objectives, tolerance for risk and need for investment income. Should the client choose to implement the recommendations contained in the plan, we may suggest the client work closely with attorneys, accountants, insurance agents, and other related professionals if and as required. Implementation of financial plan recommendations is entirely at the client's discretion. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• 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, estateplanning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing home selection and expense planning, Medicaid and elder law.
• DIVORCE: We assist the client during the divorce process in regards to the financial impact of spousal support, qualified domestic orders, the division of assets and budget evaluation post-divorce.
• TUITION PLANNING: We assist the clients in reviewing all of the savings plans available including 529 Plans, Uniform Gift to Minor Plans, Coverdell Education IRA savings plans Pension Consulting Services With respect to advisory services provided to the sponsor of a pension plan, BNB may provide some or all of the following services:
• Due diligence on existing, potential, and selected investment managers and/or service providers
• Retirement plan asset-class menu recommendations
• Investment policy statement review or its development and implementation
• Trustee education
• Plan design recommendations
• Plan mid-year and year-end reviews with trustee(s), as appropriate
• Investment monitoring reports
• Substitution recommendations
• Watch list recommendations
• Model portfolio generation for participants
• Participant educational workshops
• Site visits when/where needed, upon request Upon request, BNB can review an existing or prepare a new investment policy statement (IPS) or similar plan document. The purpose of the IPS is to assist investment committees or plan sponsors in effectively supervising, monitoring and evaluating the company's retirement plan. Topics may include:
• Investment committee's expectations, objectives and guidelines for the plan, as well as ensuring effective communications between the investment committee and all parties involved with investment management decisions;
• Establishing formal criteria for provider selection and evaluation; and,
• Complying with all ERISA, fiduciary, prudence and due diligence requirements applicable with laws, rules and regulations from various local, state or federal entities that may impact plan assets. Non-Investment Consulting/Implementation Services To the extent requested by the client, BNB Wealth Management may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, and general education for employer based retirement plans. Neither BNB Wealth Management, nor any of its representatives, serves as an attorney and no portion of BNB Wealth Management’s services should be construed as legal advice. To the extent requested by a client, BNB Wealth Management may provide the client with a list of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including certain of BNB Wealth Management’s investment advisor representatives in their separate registered/licensed/certified capacity as discussed below. 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 BNB Wealth Management.
• Cash Positions. BNB

Wealth Management maintains cash positions for a variety of reasons including but not necessarily limited to, operational maintenance of the account, periodic distributions from the account and for defensive purposes. Positioning cash as a defensive asset may be undertaken at any specific point in time, depending on perceived or anticipated market conditions/events (there being no guarantee that such market conditions/events will occur). All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating BNB Wealth Management’s advisory fee. Please Note: If the client engages any such professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify BNB Wealth Management if there are ever any changes in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services.
• Private Investment Funds. BNB Wealth Management does not currently invest in private investment funds in any of its investment portfolios although legacy positions may exist.
• Client Obligations. In performing its services, BNB Wealth Management relies on information received from the client or from the client’s other professionals, and has no obligation to independently verify any of that information. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify BNB Wealth Management if there is ever any change in his/her/its financial situation, investment objectives, tolerance for risk, time horizon or need for investment income for the purpose of reviewing/evaluating/revising BNB Wealth Management’s previous recommendations and/or services.
• Disclosure Statement. A copy of our written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of an Investment Advisory or Financial Planning Agreement.
• Fee Differentials. As indicated in Item 5 below, in certain circumstances, BNB Wealth Management, in its sole discretion, may charge a different fee to its clients based upon various objective and subjective factors, including, but not limited to: the amount and composition of the assets placed under BNB Wealth Management’s management, the complexity of the engagement, the potential for additional deposits, your relationship and history with BNB Wealth Management, and the level and scope of the overall investment advisory services to be rendered. As a result of these factors, the services to be provided by BNB Wealth Management to any particular client could be available from other advisors at lower fees. All clients and prospective clients should be guided accordingly. When providing asset management services, BNB Wealth Management typically constructs each client’s account holdings using primarily mutual funds to build diversified portfolios. We do not typically attempt to time the market but we may increase cash holdings modestly, as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, and legacy holdings, inheritances, closely held businesses, collectibles or special tax situations. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. BNB Wealth Management’s services are provided based on the individual needs of each client. This means, for example, that clients are given the ability to impose restrictions on the accounts we manage for them, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine their investment objectives and suitability information. However, we reserve the right to not enter into an investment advisor relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. LIMITATIONS: As the IARs of BNB Wealth Management, LLC are registered as representatives of a broker-dealer and/or as insurance agents/brokers of various insurance companies, recommendations made in financial plans are limited to only those products offered through these companies. 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. 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. Amounts Under Management BWML has the following assets under management: Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 195,000,000 $ 24,500,000 December 2023 In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each service’s fees and compensation arrangements. Asset Management Services BNB Wealth Management Program accounts are serviced by our introducing broker-dealer (CSM) and their Custodian (RJA) in each one's capacity as a registered broker-dealer regulated by FINRA (the Financial Industry Regulatory Authority) and a member of SIPC (the Securities Investor Protection Corporation). CSM is also an investment advisor registered with the SEC, but does not serve as an investment advisor for you through the BNB Wealth Management Program. Raymond James & Associates provides clearing, custody and other brokerage services for accounts established through the BNB Wealth Management Program. You are required to establish a brokerage account(s) through CSM. Separate accounts are maintained for you and you retain all rights of ownership of your accounts (e.g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). Under the BNB Wealth Management Program,