Description of Firm Diastole Wealth Management, Inc. ("DWM") is a registered investment adviser based in Guilford, Connecticut. We are organized as a corporation under the laws of the State of Connecticut. We have been providing investment advisory services since May 2000. DWM is primarily owned by Elizabeth D. Eden, Elizabeth E. Cook, Ethan A. Eden, and Meredith P. Eden.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to DWM and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Investment Advisory Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. We consider financial planning and consulting an integral aspect of the portfolio management process designed to assist our clients in reaching their financial and retirement goals. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you according to your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
We also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Financial Planning and Consulting Services We offer financial planning and consulting services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning and consulting services, we will meet with you to gather information about your financial circumstances, investment goals, objectives, and risk tolerance. This service includes the generation of a comprehensive financial plan, consultations on wealth transfers, estate planning, retirement planning, education funding, and charitable gifting. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
12 Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Private Investment Funds DWM serves as the Adviser and Eden Investment Partners, LLC (an affiliate of DWM which is owned and controlled by Elizabeth Eden, Elizabeth Cook, and Ethan Eden) serves as the General Partner to Eden Partners Absolute Growth Fund, LP and Steamboat Fund, LP ("Funds"), each a private investment fund ("Fund"), and is responsible for the formulation and implementation of the Funds' investment strategies, evaluating and monitoring the Funds' investments

and making all investment decisions for the Funds. Specifically, DWM will manage the assets of the Fund on a discretionary basis in accordance with the overall investment objectives of the Funds. DWM bases its advice to each Fund on the investment objectives set forth in the applicable private placement memorandum, organizational documents, investment management agreement, and/or subscription agreements, as the case may be (each and collectively, the "Governing Documents"). The Funds are available for investment only by institutional investors and other sophisticated, high-net worth investors, who meet the eligibility requirements of the applicable Fund set forth in their Governing Documents.
Investments in the Funds are not registered under the Securities Act of 1933, as amended, and are only offered after delivery of a private placement memorandum and execution of the subscription agreement and other offering documents. Investors and prospective investors should refer to each Fund's offering documents for a complete description of the risks, investment objectives and strategies, fees, the minimum initial capital contribution or commitment required, and other relevant information pertaining to investments in the Fund(s).
Selection of Other Advisers We may recommend that you use the services of a third-party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
Types of Investments We primarily offer advice on exchange traded funds ("ETFs"), mutual funds, stocks, bonds, option contracts, certificates of deposit, US government securities, pooled investment vehicles, real estate limited partnerships, money market funds, real estate, and real estate investment trusts ("REITs"). Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
13 Wrap Fee Programs We do not participate in any wrap fee programs.
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 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $223,750,000 in client assets on a discretionary basis, and $162,450,000 in client assets on a non-discretionary basis.