A. Description of the Advisory Firm FOCUS Wealth Advisors, LLC (hereinafter “FWA”) is a Limited Liability Company organized in the State of Texas. The firm was formed in March 2011, and the principal owner is Mark Andrew Frugoni. B. Types of Advisory Services Portfolio Management Services FWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. FWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring FWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. FWA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. FWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of FWA’s economic, investment, or other financial interests. To meet its fiduciary obligations, FWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, FWA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is FWA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Wealth Planning Services Our Family Wealth & Legacy Planning Services exist to coordinate with individuals and families in an effort to design, formalize, create and implement custom wealth, investment and legacy plans to meet our client’s needs and goals. Wealth Planning encompasses aggregating all sources of wealth; formalizing goals and objective parameters; defining and documenting risk perceptions, tolerance and capacity; assessing in place risk management strategies; reviewing estate, legacy, gifting and philanthropic plans; and determining cash management needs for large liquidity events. Investment Planning addresses the feasibility of the financial plan by assessing stress- tested scenarios for achievability results and deploying a final and agreed-upon investment allocation strategy from which to monitor on-going performance and plan progress. Legacy Planning seeks to solidify the client legacy goals, uncovered in the financial

planning process, by formulating strategies for protecting and distributing family or philanthropic wealth transfer goals; all with an eye toward passing on assets to heirs or charitable organizations in the most efficient, tax-advantaged and probate-friendly manner - now or in the future. Plan Reviews consist of the coordination of periodic and ad-hoc assessments of the financial, investment and legacy plans. During this process all goal, objective and assumptions are reviewed, inputs updated and hypothetical scenarios analyzed and assessed for possible consideration and deployment on an as-needed basis. Pension Consulting Services FWA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting includes, but is not limited to, some or all of the following:
• identifying investment objectives and restrictions
• providing guidance on various asset classes and investment options
• monitoring investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators, and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments FWA does not limit its services to specific types of investments. Fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, and a minimal amount of mutual funds are typically used, while other securities are periodically used to help diversify a portfolio when applicable. C. Client-Tailored Services and Client-Imposed Restrictions FWA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client’s Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients are permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FWA from properly servicing the client account, or if the restrictions would require FWA to deviate from its standard suite of services, FWA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. FWA does not participate in wrap fee programs. E. Assets Under Management FWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $244,372,796 $3,380,453 December 31, 2023