Northwest Capital Management, Inc. is an investment management firm. We are about fifteen people who research investment options, manage Client portfolios, advise, and consult to ERISA1 and non-ERISA retirement plans, undertake personal financial planning, and provide performance reporting—all part of an ongoing effort to help investors achieve their investment goals. Some of our Clients are individuals. Their investment goals can include financial security and a comfortable retirement. Clients who are retirement plan sponsors (and plan fiduciaries) generally want best-of-class investment options, effective participant education, assistance with regulatory compliance, and relief from fiduciary liability. Our Institutional Clients have important corporate and charitable objectives to develop, maintain, and finance. The firm was founded by Fred Payne. First working with investors in 1985, Fred increasingly saw the importance of a fee-based advisory business and offered such services exclusively starting in 1990. In April 1998, Fred incorporated his investment practice as Northwest Capital Management, Inc. Brent Petty joined Fred in 2005, assumed leadership of the firm’s retirement plan consulting business, and became NWCM’s president in 2010. A sale occurred effective February 29, 2020, in which Fred sold all his shares in NWCM to Brent, making Brent the controlling owner of NWCM and ensuring the long-term, fiduciary stewardship of NWCM. Fred has not retired and continues working with NWCM under a long-term employment contract. Much of his corporate duties have been eliminated, allowing him to focus most of his time on Client service. Fred remains a voting member of NWCM’s Investment Committee. Fred, like us all at NWCM, is enthusiastic to provide answers to, and solutions for, our clients’ most basic question: How do I invest my money to achieve my goals? Northwest Capital Management, Inc. (NWCM) has been acquired by Carson Group Holdings, LLC. Carson Group Holdings, LLC, through its subsidiaries, is a multi-custodian advisory firm with over $20 billion in advisory assets. The transaction closed on June 10, 2023. NWCM is an affiliated firm of Carson Group Holdings, LLC. Types of Advisory Services With no qualifying statements, Northwest Capital Management, Inc. always acts as a fiduciary in our dealings with Clients. ERISA is an acronym for the Employment Retirement Income Security Act of 1974, federal legislation that governs most employee benefit programs. We provide a wide range of services to three categories of investors: 1. Our Institutional Clients contract with us for such services as asset allocation studies, manager searches, investment management and performance reporting. 2. Retirement Plan Sponsors ask us to help them evaluate their existing service providers, or to undertake a search for new ones. They ask us to evaluate and monitor the Investment Alternatives offered to their plan participants. We make recommendations about the continued suitability of an Alternative or its replacement. Most often, Plan Sponsors ask us to serve in a legal capacity as an Investment Manager as defined by the Employee Retirement Income Security Act of 1974 (“ERISA”) whereby Retirement Plan Sponsors delegate to us the discretionary authority to identify, monitor and replace their plans’ Investment Alternatives. Through this delegation, Plan Sponsors achieve important statutory relief of personal liability. Sponsors can also have us manage Model Portfolios and provide investment education to participants. 3. Besides investment management, our Private Clients look to us for help with financial planning, a process in which we enumerate and quantify investment objectives. Typical financial objectives include saving adequately for retirement, funding children’s college education, and achieving financial independence. Given a combination of time, capital, risk tolerance and an expectation for return, we evaluate various scenarios. Clients then identify the scenario that is most acceptable and appropriate to their circumstances. Once achievable and realistic investment objectives are defined, we make specific recommendations for the investment of assets among cash, stocks and bonds and other financial instruments. Such recommendations might include the purchase, sale or holding of securities. We do advise Private Clients on the advisability of investing in “private investments” such as real estate, private equity, private debt, and limited partnerships. If in that instance we are to charge a fee for the advice, we will enter into a separate advisory agreement specific to the services we will provide and the amount of our compensation. Financial planning services are facilitated by our Big Picture Study® internet site. Financial planning services can include advice on tax management and estate planning. In-depth, detailed advice in these areas is normally offered with your attorney or accountant. (We can provide more comprehensive planning upon request.) We do not sell life insurance or annuities; however, we frequently recommend that Clients own a certain amount of life insurance, or that they consider benefits of investing within an annuity. We can if asked to recommend a firm from which Clients can purchase insurance or an annuity. We do not receive commissions or referral fees for this service. Investment Management Approach Northwest Capital Management, Inc. historically has managed “fund of fund” portfolios, investing in various mutual funds (ones we consider “best of class”) to obtain exposure to different asset classes and management styles. As an alternative to mutual funds, we purchase exchange-traded funds (“ETF”) or collective trusts. In the income-oriented accounts of Clients, we can buy coupon bonds or insured certificates of deposits, generally holding these investments until their maturity. Certain Clients come to us with ownership of stock positions—long-term holdings whose sale would cause significant tax consequences. Or these securities might have some sentimental value to them, e.g., stock in a company at which they spent their working career. When Clients do not wish us to sell a specific security, we can build a portfolio around it by minimizing security holdings in that stock’s industry sector or in its market capitalization. Clients can always impose restrictions on our investing in certain securities or types of securities. Increasingly, we are adding “Alternative Investments” to Client Portfolios. Alternative Investments—or Alts— are narrowly defined as any investment that does not fit into the conventual categories of cash, bonds, or stocks, for example, managed futures, commodities, and derivative contracts. Alts also include niche investment strategies such as multi-strategy, market neutral, credit long/short, event driven, and global macro. Alt investments typically have low correlation to either stocks or bonds and are used to increase diversification within your portfolio. References in this Brochure to stocks or bonds assume we can substitute a percentage of a stock and bond allocation with Alts whose risk and return characteristics are similar. We purchase alternative investments through mutual funds and ETFs to ensure daily liquidity. The mix of cash, bonds, and stocks primarily determines the risk and reward characteristics of an investment portfolio. Getting the correct mix of stocks versus bonds and cash is imperative. Within the mix of stocks and bonds, we see our job as investing in those securities which our research identifies as our “best ideas”, be they individual securities, indexed funds, actively-managed funds or Alts. We undertake research into the investment capabilities of a fund’s manager. We need a strong conviction that throughout a market cycle the security can add value to a diversified portfolio across asset classes, here in the U.S. and abroad. We want the portfolio to include stocks of different market capitalizations, investment strategies, geographic concentrations, credit quality and varying fixed income durations. We sometimes take an active approach to our fund allocations, over- or under-weighting different securities given our economic and market forecasts. When providing services to Retirement Plan Sponsors and Institutional Investors, we are generally guided by a Statement of Investment Policy (“SIP”)

which states, among other things, the risk parameters, investment objectives, and the minimum performance criteria and measurable benchmarks that each security must generally meet. We use these criteria and benchmarks (both quantitative and qualitative) to narrow the universe of potential portfolio investments. The SIP can also impose restrictions on our investing in certain securities or types of securities. Most Private Clients authorize us to act with discretion. When managing their portfolios, we base our trading decisions on the same disciplined security analysis we do with Retirement Plan Sponsors and Institutional Clients; however, we do not employ SIPs. In our investment and financial planning activities, we help Private Clients decide upon a Target Allocation of Equities versus Fixed Income securities that controls the composition of the portfolio—particularly as it impacts their cash flow needs for income. Given what are often “fluid” financial circumstances, this Target Allocation can change frequently. In our quarterly reporting to Private Clients, we confirm the Target Allocation that is the basis for the investment strategy we are implementing; and we compare the Portfolio’s actual allocation of Equity and Fixed Income securities to the Target Allocation. We can exercise discretion for the selection of specific securities to be owned within the Equity and Fixed Income allocations of Private Client portfolios only if the resulting portfolio represents prudent diversification given such factors as capitalization, industry group, geographic region, bond duration, credit quality and other generally accepted industry criteria. We do not engage in any principal or agency cross- transactions. Besides the larger portfolio accounts which we manage, some Clients might have smaller accounts we do not actively trade. For these accounts, we typically provide minimum reporting to track its value. Personalized Investment Services We offer an investment service we call Signature Portfolio Strategies, a comprehensive investment approach that has as its foundation our financial planning services. Using our Big Picture Study® online software, we analyze your circumstances and resources to determine achievable financial goals such as saving for the education of children, retirement income, tax reduction, financial independence, philanthropy, and wealth transfer. (The Big Picture Study® website is available for you to log into 24/7 and can be updated daily to reflect the values of, and transactions in, their various accounts regardless of custodian.) Given this analysis, we implement investment strategies which can give you confidence in their financial success. Your investments may be custodied among several brokerage accounts, such as trusts, IRAs, Roth IRAs, 401(k) plans, and taxable accounts. A Signature Portfolio can incorporate some or all accounts into one strategically coordinated investment portfolio. A Signature Portfolio can own indexed and actively- managed funds, exchange-traded funds, individual stocks and bonds, and alternatives. You might have investments within your company’s 401(k) plan where investment options are typically limited. Such securities are given investment weight within a Signature Portfolio as if they were one of our discretionary selections. For each Signature Portfolio, we produce a performance report that can consolidate investments from multiple Client accounts as if they were owned in one account with one investment objective. (You access our performance reports via the Internet unless special arrangements are made for mailing reports.) In 2017, we suspended an investment service called Portfolio Bright associated with Institutional Intelligent Portfolios™, an automated investment management solution facilitated by Schwab Wealth Investment Advisory Inc. and its affiliates. In its place, we offer a proprietary investment service called Core Portfolio Strategies. Using indexed funds and exchange-traded funds (ETFs) to keep expenses and trading costs low, Core Portfolios (as do Signature Portfolios) will own securities here in the U.S. and overseas, with different market capitalizations, some with a value or a growth bias, in developed and emerging markets, and bonds with differing maturities, credit quality and currency risks—all designed to achieve meaningful and prudent diversification. Core Portfolio accounts differ from Signature Portfolio accounts in that Core Portfolios: 1. Will not own individual stocks or bonds; and 2. Are limited to a single brokerage account. Our determination of a suitable investment strategy for a Portfolio Bright account was generally limited to the answers Clients would give to a questionnaire as part of the online enrollment process. For our Core Portfolio Strategies, we offer, in addition to some online tools, one-on-one discussions with you to help determine which of the many Core Portfolio strategies is most appropriate. Given the low fee structure of our Core Portfolio Strategies service, we must limit financial planning services we otherwise provide to Clients with a Signature Portfolio Strategy. We do not participate in “wrap fee programs.” In a wrap fee program, all administrative and management fees are paid with one fee. The fees for our management of your assets are not "all inclusive." Internal fees of the mutual funds in which we invest are variable. Sometimes transaction fees or custodial fees will apply. You will sign an investment advisory agreement with us before we affect any trades in your account. The agreement spells out your and our obligations in the relationship, our trading authority, and our fees. Each of us can terminate the agreement for any reason upon 30-days written notice. Our Advisory Agreement includes terms that will bind and will inure to the benefit of your heirs, executors, personal representatives, successors, and assigns. If you enter into our Agreement in your capacity as a trustee of a trust, you will agree that our advisory contract, including any discretionary trading authority you have granted to us, and including any instructions you have given us regarding the assets or trading in your account, will bind, and will inure to the benefit of, any successor trustee of the trust. We will continue to manage the assets in your account after you are no longer the trustee of the trust (whether from death, resignation or otherwise) until the successor trustee terminates the Agreement upon a 30-day written notice. Assets under Management As of December 31, 2023, we managed or advised $6,825,274,960 of assets for Clients. $1,442,743,365 in discretionary assets and $5,382,531,594 in non-discretionary assets. Most of the retirement plans we advise are participant-directed, meaning that the participants can exercise control over their accounts. (When participants fail to make investment choices, their accounts are invested within a “default” Investment Alternative such as a Model Portfolio.) The primary responsibility for identifying the Investment Alternatives from which participants construct their portfolios, or for constructing the Model Portfolios in which they can invest their account balances, is that of the plan’s fiduciaries, e.g., most frequently us, but at other times, the Plan’s Investment Committee. When plan fiduciaries engage us to participate in this decision-making, we become co-fiduciaries to the Plan, i.e., we are subject to the fiduciary responsibility standards of the Employee Retirement Income Security Act of 1973 (“ERISA”). We can be retained either as an ERISA §3(21) fiduciary or a §3(38) fiduciary. When the plan fiduciaries have delegated discretionary authority to us to determine both the list of Investment Alternatives and the investment allocations of Model Portfolios, we act in the capacity of a §3(38) fiduciary or “Investment Manager”. A §3(38) Investment Manager offers important statutory relief of fiduciary liability to the plan’s trustees and investment committee. Retirement Plan Sponsors cannot claim this statutory relief when engaging us as a §3(21) fiduciary. When calculating the market value of assets we manage with discretion, we make no distinction between assets managed with discretion for Private and Institutional Clients and those assets under our supervision as a §3(38) Investment Manager for retirement plans.