General Information Cahaba Wealth Management, Inc. ("Cahaba") was formed in 2009, and offers a comprehensive package of wealth management services to its individual and corporate clients. These services include investment management and comprehensive financial planning.
Brian P. O'Neill, George H. Wideman, William D. Jackson, and Christopher D. Conkell are the principal owners of Cahaba. Please see Brochure Supplements, Exhibit A, for more information on these principal owners and other individuals who formulate investment advice and have direct contact with clients, or have discretionary authority over client accounts.
As of December 31, 2023, Cahaba managed $1,496,425,464 on a discretionary basis, and no assets on a non-discretionary basis.
SERVICES PROVIDED At the outset of each client relationship, Cahaba spends time with the client, asking questions, discussing the client's investment experience and financial circumstances, and broadly identifying major goals of the client.
Clients may elect to retain Cahaba to prepare a full financial plan as described below. This written report is presented to the client for consideration. In many cases, clients subsequently retain Cahaba to manage the investment portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need financial planning but retain Cahaba for portfolio management services, based on all the information initially gathered, Cahaba generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the client's risk tolerance level (the "Financial Profile" or "Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan" or "Plan"). The Financial Profile is a reflection of the client's current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments Cahaba will make on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client, but are not necessarily written documents.
With respect to any account for which Cahaba meets the definition of a fiduciary under Department of Labor rules, Cahaba acknowledges that both Cahaba and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between Cahaba and Client.
Financial Planning Services One of the services offered by Cahaba is financial planning. This service may be provided as a stand- alone service, or may be coupled with ongoing portfolio management.
4 The primary objective of the Financial Planning services is to provide the client with a balanced financial plan creating the necessary cash flow to meet the client's living standards and sound, suitable investments for future income. Financial planning generally includes advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design.
Depending on a client's particular situation, financial planning may include some or all of the following:
•Gathering factual information concerning the client's personal and financial situation;
•Assisting the client in establishing financial goals and objectives;
•Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
•Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
•Making recommendations to help achieve retirement plan goals and objectives;
•Designing an investment portfolio to help meet the goals and objectives of the client;
•Providing estate planning;
•Tax planning;
•Assessing risk and reviewing basic health and life insurance needs
•Reviewing goals and objectives and measuring progress toward these goals. As part of the financial planning process, Cahaba also provides business succession advice, determination of long term care or disability insurance needs and evaluation of employee benefits. Cahaba may also offer limited administrative services, which include cash flow management, document and record management, and coordination of external advisers. These services are offered in conjunction with financial planning services.
Once financial planning advice is given, the client may choose to have Cahaba implement the client's financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by Cahaba under a financial planning engagement and/or to engage the services of any recommended professional Clients may also engage Cahaba to provide ongoing monitoring and continuous advice relating to the financial plan.
Wealth Management Services Cahaba Wealth Management views investment management as part of the comprehensive financial plan. We use varying tools and experiences to guide us to recommending an appropriate asset allocation to help our clients achieve their goals. These include, but are not limited to: 1. Long-Term Cash Flow Projections – The basis of any investment recommendations come from a comprehensive review of our clients' cash flow, comfort with risk, and time horizon for needing from their assets. We use detailed cash flow projections, updated regularly, to determine to the best of our ability when assets might be needed, the tax consequences of withdrawing from specific accounts, and whether a recommended portfolio would have the ability to create returns necessary to achieve goals. 2. Risk Tolerance Questionnaire – We utilize risk tolerance questions to help create a "Risk Score" for each client for whom we actively manage assets. This serves as a second data point, in addition to the overall view of the financial plan and cash flow projections, to choose an appropriate risk model for the recommended portfolio. 3. Risk Discussions With Clients – In addition to the more technical data points mentioned above, 5 we rely heavily on the ongoing communications with have with our clients and our knowledge of their personal financial situation to give additional support for a recommended asset allocation. After taking all of the pertinent information into account, we will recommend a portfolio based on an agreed upon level of risk. Each adviser in the firm selects the appropriate securities to fill the asset allocation, based in part upon the client's specific tax & other financial planning considerations. We constantly monitor each client's portfolio, and will rebalance

based on deviations from the desired asset allocation. Overriding factors could be, but are not limited to, tax consequences and other client specific factors. Clients' aptitude and ability to take investment risk can change over time, so we will update the Risk Tolerance questionnaire, financial plan projections; and communicate with clients to determine if any changes to the agreed upon level of portfolio risk are necessary.
In circumstances where we do not provide a comprehensive financial plan, we substitute a more substantial Investment Policy Statement. The IPS outlines, amongst other things, the agreed upon parameters for that portfolio between the client and CWM. These parameters include time horizon, risk level, asset allocation, tax status, any prohibited asset classes and/or securities, any expected contributions/withdrawals to/from the portfolio, etc.
As described above, at the beginning of a client relationship, Cahaba meets with the client, gathers information, and performs research and analysis as necessary to develop the client's Investment Plan. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by Cahaba based on updates to the client's financial or other circumstances.
To implement the client's Investment Plan, Cahaba will manage the client's investment portfolio on a discretionary basis. As a discretionary investment adviser, Cahaba will have the authority to supervise and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on Cahaba in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of Cahaba.
Selection of Other Advisers When appropriate and in accordance with the Investment Plan for a client, Cahaba may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. Having access to various managers offers a wide variety of manager styles, and offers clients the opportunity to utilize more than one manager if necessary to meet the needs and investment objectives of the client. Cahaba will select or recommend the manager(s) it deems most appropriate for the client. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
6 Cahaba will rely on the custodian or investment platform that sponsors the TPMM for conducting due diligence.
The TPMM will generally be granted discretionary trading authority to provide investment supervisory services for the portfolio. Cahaba retains the authority to terminate the TPMM relationship or to add new Managers without specific client consent. Fees paid to such TPMM(s) are separate from and in addition to the fee assessed by Cahaba.
In any case, with respect to assets managed by a TPMM Manager, Cahaba's role will be to monitor the overall financial situation of theclient, to monitor the investment approach and performance of the TPMM Manager(s), and to assist the client in understanding the investments of the portfolio.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Types of Investments We primarily offer advice on ETFs, and Mutual Funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
7