A. Description of our Advisory Firm CL Wealth Management LLC ("CLW") is a New York-based investment adviser registered with the Securities and Exchange Commission (“SEC”). We opened for business as CBS Advisors, LLC in September 2005. In July 2013, we changed our name to CL Wealth Management LLC. CL Wealth Management is affiliated with Cabot Lodge Securities LLC (“CLS”) a New York based fully disclosed introducing broker/dealer. CL Wealth Management LLC and Cabot Lodge Securities LLC are wholly owned by PKS Holdings LLC, a Delaware corporation. Most CL Wealth Management Advisory Representatives (“IARs”) are also registered representatives of Cabot Lodge Securities LLC. Many of these same representatives are also licensed insurance agents and hold insurance appointments from one or more insurance companies. Some clients of CL Wealth Management LLC may also be clients of Cabot Lodge Securities LLC. The relationship between CL Wealth Management LLC and Cabot Lodge Securities LLC is fully disclosed to all advisory clients. Our advisory services and fees are described below. Please refer to the description of each investment advisory service for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to CL Wealth Management LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. You may also see the term “Associated Person” throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all registered individuals providing investment advice on behalf of our firm. B. Description of Advisory Services Offered CLW is an independent investment advisory firm offering portfolio advisory and financial planning services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. CLW recommends securities transactions to its clients that include securities and strategies as described in Item 8 of this Brochure. We offer a variety of both discretionary and non-discretionary portfolio advisory services whereby investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio advisory services, an Investment Adviser Representative (“IAR”) will meet with you (either in person or by telephone) to determine your investment objectives, risk tolerance, time horizon, goals, liquidity needs, investment experience and other relevant information (collectively, your “investment information”) at the beginning of our advisory relationship. CLW, through its IAR, will use the information to develop and recommend a strategy or program that is best suited, given all relevant factors you provide to us, to meet your needs and objectives. As part of our portfolio advisory services, an IAR of our firm may customize an investment portfolio for you according to your risk tolerance and investment objectives and/or may invest your assets according to one or more model portfolios developed by the IAR or by a third-party Manager. Once the IAR constructs an investment portfolio for you or selects a model portfolio, the IAR will monitor your portfolio's performance on an ongoing basis and may rebalance the portfolio as needed based on changes in market conditions and/or your financial circumstances. Management of Accounts In some instances, a CLW IAR will manage the client's account on a discretionary or non-discretionary basis. After consulting with their client, IARs may use a combination of fundamental and/or technical analysis, and various other sources to acquire information about various investment options that may be suitable for each client. Fundamental analysis of a business involves analyzing its financial statements and health, its management and competitive advantages, and its competitors. Technical analysis employs models and trading rules based on such things as price, volume of shares traded, moving averages, and identification of chart patterns. Non-Discretionary Portfolio Management Services/Referrals to Third Party Manager Programs When managing an account on a non-discretionary basis, the IAR will gather the client’s investment information, and recommend a portfolio. If the client elects to have the CLW IAR manage their portfolio directly, the IAR, with prior authorization from the client, will buy, sell or to trade in stocks, bonds, and any other securities for the account. If you enter into these non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. The CLW IAR will monitor the client’s portfolio on a regular basis and will make recommendations for changes as warranted by the overall performance of the investments in the client’s portfolio, the performance of the model portfolio, or changes in the client’s financial circumstances or objectives. CLW Discretionary Portfolio Management Services If you elect to use our discretionary portfolio advisory services, we require you to grant our firm limited discretionary authority to manage your account. This discretionary authorization will allow us to determine the specific securities and the amount of such securities to be purchased or sold for your account without your prior approval, and to direct the custodian to deduct our fees directly from your account. This discretionary authority is typically granted through the investment advisory agreement you sign with our firm and the completion of the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Selection of Other Advisers/Third-Party Managers As part of our investment advisory services, we may recommend that

you use the services of a Third- Party Money Manager ("MM") to manage all or a portion of your investment portfolio. A CLW IAR will consult with his/her clients to determine the client’s investment objectives, investment goals, time horizon, and risk tolerance, among other factors, in order to best determine which program or manager is best suited for the client. The type of investment restrictions a client may place on an account varies by program and manager, and some do not allow any restrictions. Part of the selection process is to select the program or manager that best reflects the wishes of the client. After gathering information about your financial situation and objectives, we may recommend that you engage a specific MM or investment program. Factors that we take into consideration when making our recommendation include, but are not limited to, the following: the MM's historical performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. IARs will periodically monitor the MM(s)' performance to ensure their management and investment style remains aligned with your investment goals and objectives. If the client elects to use the services of a Third-Party Manager, their account will generally be managed by that Manager on a discretionary basis. When a client grants discretion over an account to a Third-Party Manager, that manager will determine the type of securities and the amount of each security to be purchased or sold. The manager will also determine the custodial broker/dealer where the account will be held. The manager may choose one of the firms that act as custodial firms for CL Wealth Management or another custodial broker/dealer which the Manager uses. A condition of participation with certain Third-Party Managers may be agreeing to use the custodian selected by that Manager. The manager may also determine what commission rate is used for the account. If the account is held at one of the firms that act as custodians for CLW managed accounts, the commission rate will be no greater than the clearing cost to the CLW IAR. Please consult the relevant Third-Party Manager’s disclosure documents for further information on conditions for managing client accounts. Third-Party Asset Manager Options When a Third-Party Asset Manager manages assets for a client referred by CLW, that manager will manage the client’s assets according to its own client advisory agreement and policies and procedures. In some instances, certain of these managers may serve as a sub-adviser for CLW. In other cases, CLW has entered into an arrangement to refer clients to them for asset management services and received a referral or “solicitor” fee. CLW is a principal sponsor of, and provides its clients access to, Envestnet Asset Management Inc. (“Envestnet”), an advisory third-party private wealth management program and platform. With this preferred program and platform, CLW clients have access to additional asset allocation, research, and evaluation services. Envestnet offers multiple program management options within its platform, and with the various management options there are various fee schedules and account minimums. Financial Planning, Consulting Services and Workshops/Seminars CLW offers personal financial planning services that include, but are not limited to, advice on education funding, asset allocation, budgeting and cash flow analysis, retirement planning, estate planning, and insurance planning. CLW also offers consulting services that include, but are not limited to, advice on portfolio holdings, asset allocation, and evaluation of retirement planning, estate planning, and insurance planning. Services rendered on a consulting basis are usually not ongoing but limited to a specific issue or issues important to a client. Neither CLW nor any of its representatives gives legal or tax advice. A client may hire a representative of the firm to monitor and make recommendations on a particular portfolio(s). This monitoring would be on an ongoing basis. Licensed associated persons of CLW may offer workshops and or seminars dealing with various financial planning / securities topics. There may be a charge to attend one of these sessions. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. CLW recommends the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if CLW recommends its own services. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Programs and Fees CLW does not offer wrap programs at this time. E. Client Assets Under Management As of February 28, 2023, CLW has a total of $474,892,271.00 in assets under management. Approximately $243,640,162.00 in client assets is managed on a discretionary basis representing 1247 accounts, and approximately $231,252,109.00 in client assets is managed on a non-discretionary basis representing 752 accounts.