BCS Wealth Management, LLC (“BCSWM”) was formed in May 1998. Originally, the partners of the accounting firm of Blackburn, Childers & Steagall, PLC decided to create a firm that could assist their clients with financial planning and investment management. This decision was based on years of clients requesting advice and guidance in this important area of their lives. To that end, the firm partnered with Mike Alread, CFP® to launch BCSWM. Nicholas Clay, Nathan Goodwin, Myra O’Dell, and SCB Partnership are Members of BCSWM. Please see Brochure Supplements for more information on these principal owners and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. As of December 31, 2023, BCSWM managed approximately $598,504,000 on a discretionary basis and $867,000 in non-discretionary assets. The total firm assets under management were approximately $599,371,000. Services Provided At the outset of each client relationship, BCSWM spends time with the client asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Clients may elect to retain BCSWM to prepare a financial plan as described below. This written report is presented to the client for consideration. In most cases, clients subsequently retain BCSWM to manage the investment portfolio on an ongoing basis. For those financial planning clients making this election, and for other clients who do not need financial planning but retain BCSWM for portfolio management services, based on all the information initially gathered, BCSWM generally develops with each client: • a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments BCSWM will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. Financial Planning One of the services offered by BCSWM is financial planning, described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning generally includes advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. Depending on a client’s particular situation, financial planning may include some or all of the following: • Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning;
• Assessing risk and reviewing basic health, life, and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have BCSWM implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by BCSWM under a financial planning engagement and/or to engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, BCSWM meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client or when determined to be necessary or advisable by BCSWM based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, BCSWM will manage the client’s investment portfolio on a discretionary or a non-discretionary basis. As a discretionary investment adviser, BCSWM will have the authority to supervise and direct the portfolio without prior consultation with the client. Under a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the account(s) under management. This can result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Family Office BCSWM also offers services as a part of our marketed Still Waters Family Office (see Item 10 – Other Financial Industry Activities and Affiliations). At the heart of family office services is investment management, but a fully holistic family office can provide and coordinate a number of other services that is typically needed and desired for high net worth and ultra-high net worth clients. These services include, but are not limited to, financial planning, philanthropy management, business strategy, estate and wealth transfer, family education, governance, and succession planning. Separately Managed Accounts (SMAs) BCSWM may utilize the services of a professional investment firm for clients. Independent professional managers can offer the flexibility to structure an investment portfolio to the varying needs and goals of the client. Partnering with an independent professional manager, for a certain investment style and discipline, can provide further diversification and added expertise. Typically, accredited clients who require more customization and/or more specific investments goals as part of their overall investment strategy may benefit from SMAs. The adviser will discuss this option if he/she feels it is in line with the client’s objectives. Held Away Accounts BCSWM uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is(are) connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance.

Client account(s) will be reviewed at least annually, and allocation changes will be made as deemed necessary. Investment Management Services – Schwab Institutional Intelligent Portfolios® BCSWM offers an automated investment program (the “Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds and mutual funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co.”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment adviser and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Program. The Platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that, if we use the online questionnaire, we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 – Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles Schwab Bank, SSB, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative services fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. BCSWM will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, BCSWM will be considered a fiduciary under ERISA. To the extent that the Plan Fiduciaries retain BCSWM to act as an investment manager within the meaning of ERISA § 3(38), BCSWM will provide discretionary investment management services to the Plan. To the extent that the Plan Fiduciaries retain BCSWM to act as an investment adviser within the meaning of ERISA § 3(21), BCSWM will provide non-discretionary investment monitoring services to the Plan. Fiduciary Consulting Services
• Non-discretionary Investment Monitoring Services When retained as an investment adviser within the meaning of ERISA § 3(21), BCSWM will assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and BCSWM will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. Fiduciary Management Services
• Discretionary Management Services When retained as an investment manager within the meaning of ERISA § 3(38), BCSWM provides continuous and ongoing supervision over the designated retirement plan assets. BCSWM will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, BCSWM will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services BCSWM will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. BCSWM will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants. Non-Fiduciary Services
• Participant Education BCSWM will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages BCSWM for such services. In certain circumstances, Plan Participants are responsible for implementing transactions in their own accounts.