A. The Advocates is a financial planning and investment management firm. The Advocates was formed in January 2006. The Firm provides comprehensive financial planning to individuals primarily for whom it also delivers investment management services. The Advocates will provide financial planning only services apart from investment management services but only on a case-by-case basis; we are very selective in this area. For most individual clients, The Advocates provides investment management services in addition to financial planning services. In these cases, we examine the individual financial planning needs of the client prior to making investment recommendations. The Advocates also manages investment advisory portfolios for those clients who decline full scale financial planning services. However, this is rare, and we prefer to provide planning work in addition to investment management because we believe this gives us a better understanding of the client’s overall financial picture, their personal goals, risks they may encounter, the risk they need to take (or not take) in their portfolio, etc. Principal Owners are Paul E. Palmer, Jr., Kurt L. Box and Coleman E. Campbell. B. The Advocates provides advice in two main areas: financial planning and discretionary investment management. 1. The financial planning services The Advocates provides can be quite broad in scope. The actual services that each individual client receives, however, are contingent upon their particular circumstances and needs. Specifically, the full list of financial planning services we provide includes:
• Cash Flow and Net Worth Statement
• Goal Setting
• Portfolio Analysis
• Retirement Analysis
• Retirement Plan Analysis
• Risk Management Analysis
• Employee Benefits Review & Enrollment
• Deferred Compensation Analysis
• Income Tax Analysis and Planning (Excludes Preparation)
• Charitable Planning
• Estate Planning (Excludes Document Preparation)
• Education Funding Analysis
• Social Security Claiming Analysis
• Business Continuity Planning 2. With respect to our investment advisory services, The Advocates is a diversified, global portfolio manager. We practice integrated asset allocation and believe that asset allocation – the way a client’s portfolio holdings are divided among stocks, bonds, cash equivalents and other non-correlated asset classes – is a vital determinant of the investment results over both long and short time periods. We do not purchase individual stocks and bonds for our clients but instead use mutual funds and Exchange Traded Funds (ETFs). C. The Advocates tailors both our financial planning and investment advisory services to the needs of individual clients. A multitude of personal circumstances are considered, and a multitude of documents are needed to prepare this plan. On the investment advisory side, while we do follow a set of 5 “Model Portfolios” for firm scalability purposes, clients’ portfolios are customized as follows:
• Beginning Investment Categories: For tax purposes (personal, taxable/tax-deferred/tax free), limited investment options (i.e., variable annuities, 401ks)
• Asset class percentage and dollar targets
• Pie charts detailing current versus proposed allocations by asset class
• Keep/Sell recommendations of existing holdings
• Tax consequences of implementation of suggested portfolio
• Which asset classes to hold in taxable versus tax deferred or tax-free accounts
• Specific investments to buy:  According to asset class  Identify investment custodian (Schwab Institutional, TD Ameritrade Institutional, other (i.e., no-load variable annuity contract, TIAA CREF, 401k, etc.)  Total dollar amounts As each client approaches us with different circumstances, those circumstances must be considered when putting together an optimal portfolio. For example, if a new client has a large gain in a variable annuity, rather than liquidate the annuity we will likely perform a 1035 exchange to a low-cost annuity. Even though the new annuity may have a large number of available investments, they will not be unlimited. Therefore, we must build the rest of the portfolio under this constraint. After the portfolio is fully invested, The Advocates monitors the portfolio and periodically re-balances the portfolio back in line with the original targets. Typically, rebalancing targets are set at + or – 20% of the clients recommended allocation. For example, if the recommended allocation was 20% for a particular asset class, the asset class would be rebalanced back to 20% once it reaches 16% or 24%. Other rebalancing opportunities occur as clients add to or withdraw from accounts. Clients may impose restrictions on investing in certain securities or types of securities, but the client must inform us in writing before The Advocates will place trades. D. We do not participate in any “wrap fee” programs. E. As of 12/31/2022 The Advocates managed $333,581,393 on a discretionary basis and $0 on a non- discretionary basis for 176 clients. MISCELLANEOUS
• Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested, The Advocates will generally provide planning and consulting services regarding non-investment related matters, such as tax and estate planning, insurance, etc. These services shall generally be inclusive of The Advocates’ advisory fee at Item 5 below. However, there can be exceptions, such that The Advocates will charge separately for such services per the terms and conditions of a separate Financial Planning and Consulting Agreement. The Advocates does not serve as a law firm or a CPA firm, and no portion of our services should be construed as same. Accordingly, The Advocates does not prepare legal documents or tax returns. To the extent requested by a client, we may recommend the services of other professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance, etc.), including The Advocates for insurance products-see disclosure at Item 10 below. The client is under no obligation to engage the services of any such recommended professional, including The Advocates for insurance services. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from The Advocates and/or its representatives. If the client engages any unaffiliated professional (i.e., attorney, accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not The Advocates, shall be responsible for the quality and competency of the services provided.
• Householding Policy: Clients that engage The Advocates via an Investment Advisory Agreement, jointly with another individual (a spouse, partner, sibling, etc.), will have their separate accounts that are owned individually (IRAs, I401ks, etc.) managed as part of a group or household that includes jointly and individually owned account(s) by the other party. The model allocation will be applied to the overall group, meaning a single account’s holdings may not reflect the entirety of the client’s specified model allocation. This may mean that a single account holds more conservative or aggressive positions as part of its aggregation toward the overall group allocation. In other words, your model allocation applies to your group, not your individual account unless specifically directed under written agreement.
• Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by The Advocates independent of engaging The Advocates as an investment advisor. However, if a prospective client determines to do so, he/she will not receive The Advocates’ initial and ongoing investment advisory services. Use of DFA Mutual Funds: The Advocates utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate The Advocates’ services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. In addition to The Advocates’ investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses).
• Cash Positions. The Advocates continues to treat cash as an asset class. As such, unless determined to the contrary

by The Advocates, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating The Advocates’ advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), The Advocates may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, The Advocates’ advisory fee could exceed the interest paid by the client’s money market fund.
• Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. To help mitigate this issue, The Advocates generally purchases a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless The Advocates reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account.
• 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) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If The Advocates recommends that a client roll over their retirement plan assets into an account to be managed by The Advocates, such a recommendation creates a conflict of interest if The Advocates will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by The Advocates.
• Private Investment Funds. If requested by a client, The Advocates will generally provide investment advice regarding private investment funds. The Advocates, on a non- discretionary basis, previously recommended that certain qualified clients consider an investment in private investment funds, including an affiliated private investment fund, SoTex Housing, LP, which is has been closed to new investor for several years, and is in the process of winding down its operations. The Advocates no longer recommend private funds (affiliated or unaffiliated to its clients), although some clients continue to retain a small position in private investment funds. Those assets are considered “assets under management” for purposes of The Advocates calculating its investment advisory fee.  Risks Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment.  Valuation. In the event that The Advocates references private investment funds owned by the client on any supplemental account reports prepared by The Advocates, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement will reflect that updated value. The updated value will continue to be reflected on the report until the fund provides a further updated value. As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than the value reflected on the report. Unless otherwise indicated, the client’s advisory fee shall be based upon the value reflected on the report.
• Client Retirement Plan Assets. If requested to do so, The Advocates shall provide investment advisory services relative to the client’s 401(k) plan assets. In such event, The Advocates shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. The Advocates’ ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. The Advocates will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify The Advocates of any changes in investment alternatives, restrictions, etc., pertaining to the retirement account.
• Portfolio Activity. The Advocates has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, The Advocates will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when The Advocates determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by The Advocates will be profitable or equal any specific performance level(s).
• Cybersecurity Risk. The information technology systems and networks that The Advocates and its third-party service providers use to provide services to The Advocates’ clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in The Advocates’ operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and The Advocates are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although The Advocates has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that The Advocates does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker- dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions.
• Client Obligations. In performing our services, The Advocates shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify us if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous recommendations and/or services. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by The Advocates) will be profitable or equal any specific performance level(s).