ICW Investment Advisors LLC is a limited liability company formed on March 21, 2005, in the state of Delaware. ICW became registered with the SEC as an investment adviser on June 23, 2005. ICW is based in Scottsdale, Arizona and its founder and principal owner is Vincent Rossi, CFP . ICW provides ongoing fiduciary financial planning and discretionary investment management services (see Item 16) tailored in separately managed accounts (“Professional Services” or “Services”) primarily to high-net worth individuals and their families. Since our inception, we have operated on an independent, fiduciary, fee-only basis. We have no other financial industry activities or affiliations and offer no proprietary products (see Item 10). Our Professional Services help individual investors develop and implement various plans for the management of their wealth. Our work may include, but not be limited to, educating, collaborating, designing, documenting and helping clients address and manage their financial planning, retirement income planning, investment management, risk management, tax planning, estate planning, trust administration and philanthropic needs. We help clients clarify their goals and objectives, investment time horizons, and risk tolerances and risk capacities. We consider each client’s desire for liquidity, rising income, inflation protection, capital growth, portfolio stability and tax control. We develop and review with each client a long-term rate of return the client may need from savings and investments to meet their targeted goals and objectives. We also review the attendant risks of loss and various probabilities of negative portfolio volatility the client will likely need to endure through the time range of their plans, because positive investment returns are unpredictable, unassured and materialize sporadically. After we help clients clarify their goals and objectives and review their assets, we design and implement disciplined financial planning and investment management strategies appropriate for each client’s goals and objectives and risk tolerance and risk capacity. We work with clients to tailor their plans and investments to meet their needs and manage client accounts using our discretion. We do not use model portfolios. We monitor their managed investments, track their progress toward their goals and objectives, and provide ongoing financial advice. We prepare written investment guidelines for investment of client assets in publicly-traded individual stocks and bonds, exchange-traded funds (“ETF”s) and mutual funds. We may also include additional types of publicly-traded securities, such as, but not limited to, exchange-traded real estate investment trusts (REITs) and exchange-traded master limited partnerships (“MLP”s). Clients may impose restrictions on the purchase or sale of certain securities and investments in their accounts, subject to our approval (see Items 8 and 16). ICW does not sponsor, nor participate in, any wrap-fee programs. As of February 29, 2024, ICW had approximately $297,600,000 of regulatory assets under management. All assets under management were managed on a discretionary basis. Retirement Plans Qualified Under ERISA ICW may be engaged to provide Professional Services to a qualified retirement plan (“Qualified Plan” or “Plan”) under the Economic Recovery and Income Security Act of 1974 (“ERISA”), whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. As an investment adviser registered pursuant to the Investment Advisers Act of 1940, we are not subject to any disqualification in Section 411 of ERISA. To the extent we perform fiduciary Services, we act as a fiduciary as defined in ERISA Section 3(21) and we act as an investment manager under ERISA Section 3(38) when we provide discretionary Services to a Qualified Plan. We Do Not Provide Legal, Accounting, Actuarial or Tax Advice and Do Not Sell Insurance Products Nothing in our work is appropriate as, nor intended as, a substitute for the necessary legal, accounting, insurance, actuarial or tax counsel or representation on such matters. ICW does not prepare legal documents, prepare tax returns, or sell insurance and annuity products. Clients should discuss any legal, accounting, insurance, actuarial or tax issues with their legal, accounting, insurance, actuarial and tax advisors.
® Limitations of Unaffiliated Planning and Non-Investment Management Services ICW does not have an affiliation with any other planning or non-investment management service providers – attorneys,

accountants, insurance agents, actuaries, etc. (“Unaffiliated Professionals”). To the extent requested by a client, we may recommend the services of Unaffiliated Professionals for non-investment implementation purposes. Clients are under no obligation to engage the services of any such recommended Unaffiliated Professionals. Clients retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from ICW and/or its representatives. ICW does not pay nor receive solicitation or referral fees to or from Unaffiliated Professionals (see Item 14). Please Note : If the client engages any recommended Unaffiliated Professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged Unaffiliated Professional. At all times, the engaged Unaffiliated Professional, and not ICW, shall be responsible for the quality and competency of the services provided. Retirement Rollovers Potential for Conflict of Interest A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) liquidate and cash out the account value (which could, depending upon the client’s age and financial circumstances, result in adverse tax consequences). If ICW recommends that a client roll over their retirement plan assets into an account to be managed by ICW, such a recommendation creates a conflict of interest if ICW will earn new (or increase its current) compensation as a result of the rollover. When acting in such capacity, ICW may serve as a fiduciary under ERISA, the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by ICW. Account Aggregation Service, Excluded Assets and Non-Discretionary Assets ICW utilizes third-party services to electronically gather and aggregate financial account data from thousands of financial institutions (“Account Aggregation Services”) for the benefit of clients and import directly into the various financial planning and investment management software utilized by ICW. In conjunction with the Account Aggregation Services provided by these third parties, ICW provides client reporting Services which may incorporate client investment assets that are not part of the assets managed by ICW (“Excluded Assets”). Unless otherwise specifically agreed to in writing, ICW’s Services relative to Excluded Assets are limited to reporting only. ICW shall not be responsible for the investment supervision, monitoring, management and performance of Excluded Assets (see Items 8,13, 15 and 16). The sole exceptions to the above shall be if ICW is specifically engaged by written agreement to view and make non-discretionary recommendations for the client’s ERISA and IRS Qualified or other retirement accounts (i.e., 401k, 403a, 403b, 457, etc.) maintained with a custodian directed by the client’s employer or variable annuities held with an insurance company. ICW does not maintain any trading authority for Excluded Assets. The client and/or the client’s other designated investment professional(s) shall maintain the trading authority for Excluded Assets. If ICW is asked to make a non-discretionary recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and ICW shall not be responsible for any implementation error (timing, trading, etc.) relative to Excluded Assets (see Item 16). Client Obligations In performing our Services, ICW shall rely on the information provided by the client and the client’s other Unaffiliated Professionals and financial service providers (“Service Providers”) and shall not be required to verify any information received from the client or any other third party, and is expressly authorized to rely thereon. Importantly, it remains each client’s responsibility to promptly notify ICW if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or Services. We also advise our clients that they are responsible for verifying the accuracy of their accounts and our fee calculations and deductions (see Items 5, 13 and 15).