Description of Advisory Firm Argos Wealth Advisors is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of the State of Delaware. We are headquartered in Park City, Utah.
• The Firm’s Chief Executive Officer is Michael Russo. Mr. Russo is the only member with 25% or more control in the Firm and therefore he is considered our Firm’s controlling owner.
• Argos Wealth Advisors has been registered as an investment adviser since July 12, 2007. Client Advisory Board In order to actively solicit the advice of our clients regarding developing an efficient advisory consulting firm, we have developed a Client Advisory Board. The Client Advisory Board was formed to engage the talents of our clients and optimize the breadth of ideas the Firm can gain from our clients. It was formed from a diverse selection of clients and the members are rotated periodically in order not to over burden any one client and to keep the enthusiasm and the inflow of fresh ideas high. A five member board with terms of one to three years, at the advisory board member's discretion, is used to provide an appropriate balance of ideas and focus. Since different board members might select different terms, new members rotate in periodically changing the group dynamic. The goal is to keep fresh client perspective. Advisory board member service would be in the form of two annual think-tank sessions with some discussion specific follow up. It should be noted that advisory board members are not licensed as investment adviser representatives of Argos Wealth Advisors as they do not provide individualized investment advice to other clients. Description of Advisory Services Asset Allocation, Portfolio Construction and Monitoring Services This is our primary advisory service we provide to all of our clients. Please review this section very carefully and also be sure to read Item 5 – Fees and Compensation to learn about our fee arrangements. We have developed this program as a service designed to diversify your assets among one or more unaffiliated, third-party money managers that will be registered or properly exempt from registration as investment advisers. We construct money manager portfolios and select appropriate money managers for you based upon your individual needs. The selected money managers will then manage your assets by providing ongoing discretionary investment management services. Discretionary authority allows the money managers to determine the securities to be purchased and sold in your accounts managed by the money manager. We will not have any trading authority with respect to your accounts managed by a money manager. Prior to recommending and selecting a money manager for a client, we may discuss the money manager with you. However, our program permits us to hire and fire money managers on your behalf without directly consulting with you. Please refer to Item 16 – Investment Discretion for more information. Depending on your individual needs and if we believe appropriate money managers are not available, we can develop a portfolio of mutual funds and/or exchange-traded funds selected and managed by our investment team. We may also recommend the direct investment in pooled investment vehicles (contingent upon the client’s financial circumstances and eligibility participate in such investments). We will need to obtain certain information from you to determine your financial situation and investment objectives. It is important that all information you provide be accurate, complete and up-to-date. However, we cannot assume responsibility for the accuracy of information furnished by you or any third-party on your behalf. At least quarterly, you are reminded to notify us whether your financial situation or investment objectives have changed, or if you want to impose and/or modify any reasonable restrictions on the management of your accounts. At least annually, we contact individual clients to determine whether their financial situation or investment objectives have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts managed. We are always reasonably available to consult with individual clients relative to the status of their accounts and to facilitate communication with selected money managers. You have the ability to impose reasonable restrictions on the management of you accounts, including the ability to restrict certain securities. Your beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the account. A separate account is always maintained for each client with the custodian and clients retain right of ownership of the account (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important that you understand we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts managed by us or by third-party money managers. Steps are always taken to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our Firm and outside money managers among such accounts equitably and consistent with the best interests of all accounts. However, there can be no assurance that a particular investment opportunity that comes to our attention or the attention of a money manager will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. The services described in this section are provided through the Schwab Institutional Division of Charles Schwab & Company, Inc. ("Charles Schwab"). Charles Schwab & Company, Inc., Millennium Trust Company, and Pacific Premier Trust serve as broker/dealers and qualified custodians for client funds and assets. Please refer to Item 12 – Brokerage Practices and Item 15 – Custody for more information. In connection with our portfolio construction services, all clients receive financial planning analysis and services. Financial planning services may be provided in the form of consultations and written financial plans. Financial planning services are intended to focus on a client’s overall financial situation, not just the specific accounts under our management. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. Financial planning services are usually prepared for each client before investments are transferred or changes are initiated to portfolios that have been transferred to Argos Wealth Advisors, but may continue through your relationship with our firm. Financial planning services may be specific or modular in their

preparation (unique to each client in their depth of preparation). Specific issues covered in a financial plan are contingent upon each client’s unique needs and circumstances, but the following are basic areas our plans may focus on.
• Organization and assessment
• Retirement planning
• Education planning
• Debt management
• Investments
• Tax planning
• Life events Financial planning services may take into consideration factors such as your financial/investment objectives, risks you are willing to undertake, investment knowledge, net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions, social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for retirement. Based on the previous data and information compilation, suitable investments are selected for your portfolio. For most clients, we do not charge extra or ancillary fees for our financial planning services because they are part of our standard Asset Allocation, Portfolio Construction and Monitoring services. However, for situations that are more complicated requiring additional time and resources, we may charge a fixed or hourly fee in addition to our standard management fees. Please refer to Item 5 for details. AWA Small Cap Access Fund Management Services We provide investment supervisory services on a discretionary basis to the AWA Small Cap Access Fund, L.P. (referred to as the "Fund"), a limited partnership formed under Delaware law. The Fund is a private pooled investment vehicle and is not registered with the SEC as an investment company. The Fund has been established exclusively for our Firm’s clients. Argos Wealth Advisors serves as the general partner of the Fund, and therefore, we are not independent of the Fund. Investments in the Fund do not involve a public offering that is registered with the applicable securities regulators. As general partner and investment adviser to the Fund, we have sole and complete authority to manage the Fund's activities and are responsible for managing the Fund's investment portfolio pursuant to the investment objective and investment policies of the Fund. Argos Wealth Advisors is responsible for all major decisions of the Fund, including, without limitation, amending or changing the Fund's investment objective, investment strategy and investment policies or limitations. Similar to our individual client services, we select sub-managers to manage a portion of the assets contained in the Fund. Sub-managers are selected based on their anticipated ability to develop investment strategies that comply with the Fund's objectives. The selected sub-managers will be responsible for managing a portion or a majority of the Fund's assets on a discretionary basis. The sub- managers must be registered as an investment adviser or exempt from registration. Limited partners (i.e. investors) of the Fund receive specific information about the sub-manager, its investment style, and compensation arrangements, prior to or at the time of obtaining an interest in investments managed by a sub-manager. We also individually manage a portion of the Fund's assets by investing directly in various securities, including derivative instruments such as swaps, options, and securitizations, which in turn may include one or more tailored investment contracts or basket option structures. In addition to managing the Fund’s operations and assets, we are responsible for soliciting investors to the Fund. We only recommend the Fund to our individual clients. The objective for soliciting our individual clients to the Fund is to provide access to investment types that would otherwise have minimum account sizes out of the reach of most of our clients. Investors in the Fund must be "accredited investors" as defined under the Securities Act of 1933. Investors must also be "qualified purchasers" as defined under the Investment Company Act of 1940. Investors must provide all necessary information documenting to Argos Wealth Advisors confirming they qualify to participate in the Fund. Specialization. Argos Wealth Advisors specializes in investment management consulting serving clients with portfolios ranging from $1 million to $500 million. It seeks to improve client after-tax, and risk adjusted portfolio performance by addressing the three major deficiencies in portfolio management – conflicts of interest, infidelity to portfolio theory, and insensitivity to tax consequences. Argos then guides the client in the implementation and ongoing monitoring of their established portfolio goals. Limits Advice to Certain Types of Investments. As described above, Argos Wealth Advisors assists clients in selecting discretionary money managers to manage client assets, mutual funds, and/or exchange-traded funds. We will also manage a portion of a client’s assets by directly determining the securities held in accounts. We are generally available to discuss a client’s entire portfolio holdings including the following types of investments*. Ø No-Load (i.e., no trading fee) and Load-Waived (i.e., trading fee waived) Mutual Fund Shares Ø Exchange-listed securities (i.e. stocks) Ø Securities traded over the counter (i.e. stocks) Ø Fixed income securities (i.e. bonds) Ø Derivative instruments such as swaps, options, and securitizations Ø Closed-End Funds and Exchange Traded Funds (ETFs) Ø Investment contracts and basket option structures Ø Foreign Issues Ø Warrants Ø Corporate debt securities and Commercial paper Ø Certificates of deposit Ø Municipal securities and United States government securities Ø Real estate and limited partnerships (including the AWA Small Cap Access Fund, L.P.), and other entities that invest private equity, venture capital, publicly trades securities, futures, options, real estate loans, foreign investments, hedge funds, and various debt offerings. Such investments are often illiquid, which means that the investments can be difficult to trade and consequently limits a client's ability to dispose of such investments in a timely manner and at an advantageous price. Additionally, such investments may not have registered pursuant to the Securities Act of 1933, and therefore, the client will need to complete a subscription agreement showing the client is an "accredited" investor (as defined by applicable law and rules and regulations) and acknowledge that he or she has read and understands the private placement memorandum and is aware of the various risk factors associated with such an investment. *Please note we do not generally provide advice on variable life insurance, variable annuities, options contracts on securities or commodities, or futures contracts on tangibles or intangibles.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one-on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by Argos Wealth Advisors The amount of clients assets managed by Argos Wealth Advisors totaled $782309186 as of December 31, 2022. All assets under management are managed on a discretionary basis.