A. The Company Capital Wealth Planning, LLC is a privately held Florida limited liability company that has been registered with the SEC since June 2009. Throughout this disclosure brochure, Capital Wealth Planning, LLC is referred to as “CWP.” The principal owners of CWP are Kevin G. Simpson and JoAnna Irons. B. Advisory Services CWP provides discretionary investment advisory services to both separately managed accounts and other registered investment managers (on a sub-advisory basis) under the following investment programs: Investment Management Services CWP provides investment advisory services, defined as giving continuous advice to clients or making investments for a client based on the individual needs of the client. Through discussions, during which a client’s goals and objectives are established, CWP and the client determine the client’s risk profile and investment guidelines. CWP will create a portfolio principally comprised of mutual funds, exchange traded funds (commonly known as “ETFs”), and/or debt and equity securities in accordance with the investment objectives of the client. Each portfolio will be designed with the goal of meeting each client's individual needs and risk tolerance. Investment advisory services will be provided on a discretionary basis, wherein the client gives CWP full authority to manage the client's assets in accordance with what CWP deems to be in the client's best interest. Clients will have the opportunity to place restrictions on the types of investments which will be made on the client's

behalf. Clients will retain individual ownership of all securities. C. Client Tailored Services and Client Imposed Restrictions In order to provide appropriate individualized services, CWP will work with the clients that have come directly and not through a WRAP program to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. At least annually, CWP will review with clients their financial circumstances, investment objectives, and risk profile. In order for CWP to provide effective advisory services, it is critical that clients provide accurate and complete information to CWP and inform CWP anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. D. Wrap Fee Programs CWP invests assets for clients on several Wrap Fee sponsors’ platforms but does not sponsor any wrap fee programs. All accounts, Wrap or Non-Wrap, regardless of the type of platform they are on, are managed in identical manners. CWP receives a portion of the wrap fee for management services. The fee amount varies depending on the platform. E. Assets Under Management As of December 31, 2022, the total amount of client assets managed by CWP is approximately $ 7,577,626,251, all of which are managed on a discretionary basis.