A. WESPAC Advisors, LLC, is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, WESPAC Advisors, LLC, is a wholly-owned indirect subsidiary of Focus LLC. Ferdi- nand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because A. WESPAC Advisors, LLC, is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of WESPAC Advisors, LLC. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which pro- vide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited part- nerships, private funds, or investment companies as disclosed on their respective Form ADVs.
B. We have two primary lines of business: providing investment advisory and fiduciary over- sight services to participant-directed retirement plans and providing investment management services to high-net-worth clients in separately managed accounts. Services may be custom- ized depending on the client’s needs.
We provide investment advisory services to the plan sponsors of participant-directed retirement plans to plan, develop, design, implement and administer an investment program based on the client’s goals and needs. This typically includes providing the client with an investment policy statement, analyzing, and recommending the mutual funds and asset allocation portfolios to be included on the plan investment menu, monitoring those selections on an ongoing basis, and providing investment advice to the plan participants through group meetings, individual meetings or phone consultation. The plan sponsor is sent a report each quarter and invest- ment data and financial tools are available to participants through our interactive participant website. We will also take on the role of ERISA 3(21) co-fiduciary or ERISA 3(38) designated fiduciary over the plan assets. We also provide

investment management services to individu- als, trustee-directed plans (typically defined benefit pension plans), trusts, and corporations. Certain legacy client assets are sub advised by WESPAC Advisors SoCal, LLC d/b/a Stonemark Wealth Management, an SEC-registered investment adviser that formerly was affiliated with us. After obtaining information regarding clients’ investment objectives, financial circumstances, and risk tolerance, we typically invest client assets in strategies managed in accordance with our investment models. Some of our clients’ assets are managed by a sub-adviser.
C. We determine appropriate investment strategies for clients after assessing the client’s in- vestment objectives and risk tolerance. Clients with similar risk and return objectives will have these allocations implemented uniformly through the use of investment models. Clients are permitted to impose reasonable restrictions on the management of their accounts.
D. WA does not take part in any wrap fee programs.
WESPAC Advisors, LLC Page 5 of 17 E. As of 12/31/2023, we managed $926,337,523 on a discretionary basis.
F. We are a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plan clients, including plan participants. We are also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, we are subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations im- posed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpret- ed as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess.