(A) Firm Description CM Wealth Advisors LLC (“CMWA”) is a wealth management and investment advisory firm. It serves a limited number of high-net-worth individuals, families, and foundations. The firm’s members provide personal attention, objective counsel and custom solutions focused on growing and preserving real wealth. CMWA was founded by William J. O’Neill, Jr. in 1983 as a single-family office. The goals were to professionally manage the founding family’s financial affairs – including estate planning, tax preparation and philanthropy – while investing financial assets to achieve real growth over time. In 2000, the firm broadened its services to a multi-family office, leveraging the skills and capabilities honed over the first decade and a half, to new clients with similar needs. Originally called “Clanco” – for “family company” – the firm changed its name to CM Wealth Advisors Inc. in 2010. Effective January 1, 2019, CM Wealth Advisors Inc. is now CM Wealth Advisors LLC. Since 2003, CMWA has been a registered investment adviser under the Investment Advisers Act of 1940, as amended. The firm had assets under management of approximately $1.756 billion as of December 31, 2023. Of this total, approximately $1.615 billion are managed on a discretionary basis and $141 million are managed on a non-discretionary basis. CMWA is an Ohio limited liability company. The Manager of CMWA is R. Douglas McCreery. All of CMWA’s membership interests are owned by CMWA LLC, an Ohio limited liability company (the “Holding Company.”) The Holding Company is owned and managed by its members, all of which are employees and officers of CMWA (together, the “Members”). William J. O’Neill, Jr. continues to serve CMWA in his capacity as a member of the Holding Company’s Advisory Board. CMWA’s officers are as follows: R. Douglas McCreery Manager and Chief Executive Officer Douglas J. Smorag Chief Operating Officer and Secretary Paul A. Bodnar Chief Investment Officer Neal B. Colby Chief Financial Officer and Chief Compliance Officer Additional information about CMWA is available on the Internet at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for CMWA is 119467. CMWA’s website is CMWEALTHADVISORS.COM. (B) Types of Advisory Services CMWA offers its clients four basic types of advisory service programs: (1) a comprehensive Wealth Management Advisory Services program (the “WMAS Program”) that provides a wide range of financial, risk management and investment advisory services; (2) a comprehensive Wealth Management and Investment Advisory Services program (the “WMIAS Program”) that provides, on a non-discretionary, non-custodial basis, financial oversight, asset allocation strategies and investment advisory services; (3) an investment advisory program that provides only investment management and supervisory services; and (4) business consulting. These programs are described in detail below. Commented [JC3]: These figures will be updated once the Part 1A data is received. CMWA ADV Part 2 – March 18, 2024 Page 5 (1) Wealth Management Advisory Services Program CMWA’s Wealth Management Advisory Services program (the “WMAS Program”) is a comprehensive financial, risk management and investment advisory program that bundles together certain services as described below. As a participant in the WMAS Program, each WMAS client is entitled to utilize the full range of such services, as needed from time to time. The foundation of the WMAS Program is its broad-based, independent, and comprehensive approach to financial management. The following services are included in this Program: (a) Financial and Estate Planning and Consulting CMWA works with each WMAS client to develop a comprehensive financial/estate planning and investment program for the client and all “Covered Client Parties” based on the client’s individual financial needs, objectives, and circumstances.1 As part of the planning process, CMWA reviews background information and existing estate and investment documentation as needed to create the program. CMWA then coordinates and documents such relationships with third-party service providers (including investment managers, custodians, attorneys, and other professionals) as may be required to implement the program. On an ongoing basis throughout the term of the client’s WMAS agreement, CMWA consults with and makes recommendations to the client with respect to the program components, as well as with respect to the handling of such investment, tax, cash flow, risk management and estate planning matters and issues as may need to be addressed from time to time. The nature of CMWA’s role and comprehensive annual services in developing and implementing a financial/estate planning and investment program will vary from client to client. However, in all cases, the services will include a comprehensive annual review of the client’s financial, estate, tax, risk management and philanthropic affairs. Based on this annual review, CMWA will develop a checklist of action items to be accomplished to address any issues or desired changes in the client’s program. CMWA will meet with the client periodically throughout the term of the client’s WMAS agreement to provide updates on progress in making any required changes to the client’s program. As part of CMWA’s estate planning review and consultation services, CMWA coordinates and oversees the services of the client’s legal and accounting professionals. CMWA meets with such professionals as needed to ensure that the client’s financial/estate planning and investment program is properly implemented and documented. (b) Investment Advisory and Portfolio Management Services CMWA provides each WMAS client with investment advisory, management, and reporting services. Client accounts are managed on either a discretionary or non-discretionary basis, principally using a team of third-party investment managers and funds. CMWA’s main role is to act as a “manager of managers” for these accounts. 1 For each client entering into a WMAS Advisory agreement with CMWA, “Covered Client Parties” means all of the following: (a) the spouse and minor children of the client (provided that the client’s spouse authorizes CMWA in writing to act for him/her); (b) any trust, partnership, corporation or other entity controlled by or benefiting the client or his/her spouse or minor children, provided it was formed for a purpose related to their estate, financial, investment or family planning (e.g., not a for-profit operating business); (c) any child of the client or the client’s spouse who is between 18 and 25 years old and is a full-time student (provided that such child authorizes CMWA in writing to act for him/her); and (d) other related persons and entities as CMWA agrees in writing to cover. CMWA ADV Part 2 – March 18, 2024 Page 6 Portfolio allocations are guided by the objectives of the client as stated with their “Investment Objective” statement (i.e., aggressive growth, growth, moderate growth, conservative, principal stability), considering the client’s tolerance for risk and volatility. Recommendations for each client are incorporated into a written “Investment Objective” for the client. CMWA then assists the client in creating the portfolio, monitors the investments and periodically reports to the client on its performance. The client’s Investment Objective is reviewed periodically and updated as needed to reflect any changes in the client’s financial needs, objectives, and circumstances. Any client can restrict the types of investments that are included in such clients’ portfolios. Clients retain individual ownership of all securities and non-securities, which are custodied with independent third-party custodians. As part of its services, CMWA assists each of its clients in the establishment and monitoring of these separate custody accounts. CMWA does not receive any portion of the fees charged by any custodian for its

services. Because CMWA’s role generally is to act as a “manager of managers,” the firm does not regularly recommend or direct the purchase or sale of specific securities for client accounts. From time to time, if requested by a client or as necessary to implement a client's investment strategy, CMWA may direct that specific securities be purchased or sold in a client's account. In such cases, CMWA will utilize independent broker-dealers or agents selected solely based on obtaining the best execution of the transaction. (See “BROKERAGE PRACTICES” below). CMWA does not receive any payments, products, research or other “soft dollar” consideration from any broker-dealer or agent selected to execute client transactions. (c) Tax Planning and Compliance CMWA provides each WMAS client with comprehensive tax planning, reporting and compliance services. Utilizing in-house or third-party accounting professionals, CMWA prepares and/or reviews all tax returns for the client and generally makes payments from the client’s accounts to cover all estimated and final tax liabilities. (d) Insurance and Risk Management CMWA consults with each WMAS client with respect to and provides the client with assistance in obtaining and monitoring insurance appropriate for the client’s lifestyle, including life, health, and casualty insurance. CMWA also advises clients about loans, mortgages, and other financing arrangements. As part of this service, CMWA works directly with lenders to negotiate terms and document the client’s loans. (e) Trustee Services If the use of a third-party trustee (whether an institutional trustee or an individual trustee) is needed for a WMAS client, CMWA will assist the client in establishing criteria and selecting such a trustee. Under certain circumstances, a Member may agree to act as an individual trustee for client accounts. If an institutional trustee is desired, CMWA will perform searches for various institutional trustees and will recommend which institutional trustees may be appropriate to meet the client’s needs. Factors considered in making such recommendations include account size, risk tolerance, the client’s opinion, and the investment philosophy of the institutional trustee. CMWA does not receive any referral compensation from any selected institutional trustee. If CMWA determines that a trustee is performing inadequately, then CMWA will recommend that the client change trustees and will assist the client in selecting a new replacement trustee. CMWA ADV Part 2 – March 18, 2024 Page 7 (f) Lifestyle Management If desired by a WMAS client, CMWA may provide the client with various additional services generally categorized as “Lifestyle Management” services, including bill paying and individualized cash flow management services. Certain of these services may require additional fees or costs, which will be agreed upon in writing by the client and CMWA. (g) Family Philanthropy CMWA has a long history of supporting our WMAS clients’ philanthropic programs. Among the services available are investment management services for private charitable foundations, assistance in planning and structuring private charitable gifting programs (such as structured gifts, grantor retained annuity trusts and charitable lead annuity trusts), and administrative, regulatory and tax management services. Certain of these services may require additional fees or costs, which will be agreed upon in writing by the client and CMWA. (2) Wealth Management and Investment Advisory Services Program CMWA’s Wealth Management and Investment Advisory Services Program (the “WMIAS Program”) is a comprehensive financial and investment advisory program, similar to the WMAS Program, except CMWA, on a non-discretionary, non-custodial basis, will monitor and report on client accounts, not manage. With that distinction in mind, the above-mentioned WMAS Program services (see Item 4(B)(1)(a)-(g) above) are also offered to clients in the WMIAS Program. (3) Investment Advisory Services Program When the client prefers, CMWA can provide stand-alone investment advisory services. CMWA’s investment advisory program generally includes all the investment-related services CMWA provides to its WMAS clients.2 In certain cases, particularly when working with foundation clients, CMWA may agree to serve as the “Chief Investment Officer” (“CIO”) for the client. In such cases, CMWA will structure, implement, and oversee the client’s entire investment program, reporting to the client, family, board, or investment committee on a periodic basis. CMWA’s investment advisory clients generally are afforded full access to all third-party managers utilized by CMWA, as well as to the private equity and pooled investment vehicles offered by CMWA. (4) Business Consulting CMWA also provides business advisory consulting services. CMWA Members and employees have the skills, experience, and knowledge of different aspects of business, legal, and market forces. After listening to our client’s concerns, we identify, analyze, and solve business issues by planning and executing business strategies consistent with a client’s overall financial needs, obligations, and circumstances. (C) Pooled Investment Vehicles CMWA uses an array of limited liability companies (“CMWA Pooled Investment Vehicles”) to facilitate investment by its advisory clients in various types of programs, including publicly traded securities, 2 These are described in the preceding section, Item 4(B)(1)(b), captioned “Investment Advisory and Portfolio Management Services.” CMWA ADV Part 2 – March 18, 2024 Page 8 private equity, venture capital and alternative investment programs. CMWA, CMWA Pooled Investment Vehicles and/or the Members may also be limited partners, general partners, members, or managers of such CMWA Pooled Investment Vehicles. (Please refer to the disclosure in Item 11 of this Brochure for information on CMWA's policies and procedures for instances where either CMWA and/or any Members may have a personal interest in client transactions.) In many cases these CMWA Pooled Investment Vehicles provide access to investment funds and managers that otherwise would not be open to individuals because of high investment account minimums, high fees, fund closure to new investors, or other reasons. Each CMWA Pooled Investment Vehicle pays the fees and expenses associated with such Vehicle's investments and business activities, including legal, accounting, custody, and third-party investment management fees. CMWA does not receive any investment management or advisory fees from any CMWA Pooled Investment Vehicle. CMWA is, however, entitled to be reimbursed for expenses incurred for any accounting and tax services provided to, as well as some manager diligence costs, for such Vehicles. (D) Retirement Plans and Individual Retirement Accounts When CMWA provides investment advice to clients regarding their retirement plan account or individual retirement account, CMWA is 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. The way CMWA makes money creates some conflicts with clients’ interests, so CMWA operates under a special rule that requires CMWA to act in the client’s best interest and not put CMWA’s interest ahead of the client’s. Under this special rule’s provisions, CMWA must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put CMWA’s financial interests ahead of the client’s when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that CMWA gives advice that is in the best interest of the client;  Charge no more than is reasonable for services provided by CMWA; and  Give the client basic information about conflicts of interest.