4A. Description of the Advisory Firm Watts Capital delivers three primary services to its Clients: 1. Financial Planning 2. Wealth Management 3. Proprietary Investment Strategies. Watts Capital’s team includes professionals with the Certified Financial PlannerTM (CFP®) designation, as well as a network of accountants, attorneys and other financial professionals, to deliver planning services focused on seven important areas of one’s financial life: 1. Financial Planning for Business Owners to help entrepreneurs build the value of their companies, create and protect their personal wealth, monetize the value of their company ownership, and transition to future business and personal activities. These planning services include the development and implementation of employee retirement plans. 2. Gen X/Gen Y Financial Planning to serve younger and mid-career individuals and families to establish sound financial foundations, with an emphasis on professionals in high growth industries and the professionals serving them. 3. Cash Flow Planning to assist individuals and organizations match the timing of their cash uses with their cash resources, and to advise on bridging cash flow gaps with cost-effective financing resources, as well as to deploy cash balances to attractive investment returns. 4. Income Tax Planning, in conjunction with our Client’s accountants and tax advisors, to achieve a family’s financial goals in a tax-effective manner, including identifying methods to avoid or defer taxes. 5. Trust & Estate Planning and Administration to help individuals and families achieve their legacy goals and to pass their assets in a tax effective way to their heirs. We collaborate with a client’s legal and tax advisors to establish effective estate plans. We manage the transfer of assets during estate administration. We also educate and advise heirs in the management of investments both prior and subsequent to inheritance.
4B. Types of Advisory Services Financial Planning Services 6. Retirement Planning to assist individuals and families at all life stages to achieve their lifetime financial goals. 7. Charitable Gift and Legacy Planning, in conjunction with Clients’ other advisors, to ensure that Clients achieve the intended impact of their financial gifts in the most tax-effective means, both during after their lives. With each Financial Planning Client, the firm follows a 4-step process. Step 1. Assess The Client’s Current Financial Situation We work closely with each Client to organize and understand their unique circumstances, including their current financial situation, their values and background as they relate to money, and their views on risk. Based on this initial assessment, Watts Capital prepares a summary of the Client’s current financial status. Step 2. Identify The Client’s Personal and Financial Goals Watts Capital partners with each Client to identify their important personal and financial goals. The Firm works with the Client to understand their long term lifestyle, family, business succession, retirement, legacy and charitable giving goals, while keeping in mind their spending needs and savings patterns. Step 3. Create The Client’s Financial Action Plan Watts Capital develops a specific Financial Action Plan to bridge the gap between the Client’s current financial situation, and their goals for where they want to be. This action plan centers around the Client’s savings and investment plans, but also addresses the entire range of financial issues of concern to the Client, including debt management, spending, sale of a business, tax planning, charitable giving, insurance and trust & estate planning. Step 4. Monitor and Re-Evaluate Frequently Watts Capital views the regular monitoring and re-evaluation of each Client’s financial progress as a key component of achieving their financial goals. The firm monitors and re- evaluates the Client’s financial situation on a regular basis. The firm updates the Client regularly on its investment views, the actions taken in the Client’s portfolio, and the Client’s investment performance. In parallel, the Firm stays in touch with each Client to track the developments of their financial life. Watts Capital’s Wealth Management Services represent the implementation of each Client’s Financial Action Plan, which is typically developed during the Financial Planning segment of Our services to Clients. Implementation steps include taking action in any or all of the eight areas of a Client’s Financial Action Plan: 1. Asset allocation and investment monitoring 2. Debt management 3. Spending analysis 4. Sale of a business or execution of a major financial transaction 5. Tax planning 6. Charitable giving 7. Risk management and insurance 8. Trust & estate planning. The Firm’s asset allocation and monitoring process addresses the allocation of investment funds across three broad investment strategies:
• Core Investment Strategies (“CIS”) based on factors shown by academic research to have higher return potential. These strategies generally incorporate allocations of stocks, bonds and cash, and other investment vehicles that incorporate stocks and bonds such as mutual funds and ETFs. These allocations reflect a Client’s individual investment objectives, time horizon, and tolerance for risk. CIS typically involves “tilt” towards growth companies with potential to expand sales and earnings rapidly, two of the factors related to higher potential returns.
• Tactical Investment Strategies (“TIS”) that focus on achieving superior investment returns for defined levels of risk. Watts Capital’s Tactical Investment Strategies involve periodic trading to take advantage of expected periods of increased market volatility. The Firm’s TIS may include strategies developed or managed by third-parties, as well as strategies proprietary to the Firm. Allocations to the Firm’s proprietary strategies are made only on a non- discretionary basis, that is, with each Client’s express approval. For most investors, they represent a limited portion of a Client’s overall portfolio. Wealth Management Services
• Alternative Investment Strategies (“AIS”) that incorporate real estate investments, as well as other non-traditional assets such as private equity, private credit, and hedge funds to deliver absolute or non-correlated returns. A number of the AIS investments are less liquid than those of CIS or TIS. Allocations to AIS with limited liquidity are made only on a non-discretionary basis, that is, with each Client’s express approval. For most investors, they represent a limited portion of a Client’s overall portfolio. The Firm offers two proprietary investment strategies

that it makes available both to wealth management clients and to clients of other financial advisors on a separately managed account (SMA) basis.
• Tactical Growth Strategy. The Watts Tactical Growth Strategy is based on quantitative models that rely primarily on trend and counter-trend technical data. These models generate Buy and Sell signals that are applied to index-tracking ETFs. The models are based on actual trading results, as well as extensive backtesting of factors that the Firm believes influence future investment returns.
• Disruptive Stock Strategy. The Watts Preston Disruptive Stock Strategy invests in stocks that have prospects to achieve exceptional growth through the disruption of traditional industries. The investment team conducts ongoing screening of industry and company fundamentals to identify companies with rapid revenue and earnings growth, favorable returns on equity, product innovation, and competitive industry positioning. The team then uses a technical overlay to determine when to enter, adjust, or exit positions. The Firm also provides fixed income management and other investment management strategies tailored to the individual needs of Clients. Clients can terminate our services without penalty within five business days from the executed date of the agreement for services, via written notice. Services may be cancelled at any time by either party for any reasons upon receipt of written notice from the other party. Upon such a request, a Client’s files will be reviewed and the Client will Proprietary Investment Strategies 4C. Termination of Services be responsible for all unpaid fees through the date of termination or a pro-rated refund of any fees paid in advance will be provided. Watts Capital provides investment advice on a wide range of investments, including the following:
• Publicly traded equity securities, particularly stocks.
• Publicly traded debt securities including securities issued by the U.S. Government, government agents, municipalities, and companies.
• Exchange Traded Funds (ETFs) and ETNs.
• Mutual funds.
• REITs, MLPs, BDCs and other pooled investment vehicles.
• Investment strategies offered through Separate Managed Accounts (SMAs).
• Public, non-traded securities.
• Private placements of securities.
• Real estate properties, equity, debt, limited partnerships and other pooled real estate investment vehicles.
• Private equity, private credit, hedge fund and other alternative investment vehicles.
• Digital assets, including cryptocurrency and investment managers of crypto assets. The Firm does not provide advice on investing in collectibles, TV and movie projects, or intellectual property investments. The Firm’s Core Investment Strategies focus on long-term asset allocations using publicly traded securities. The Core Investment Strategies incorporate re-balancing and tax-loss harvesting where appropriate. These strategies incorporate portfolio “tilt” towards factors shown to lead to higher long-term investment performance such as small-company factors and value-company factors. Watts Capital’s Proprietary Investment Strategies are based on quantitative investment models and structured investment processes with the aim of generating attractive returns for given levels of risk. These strategies incorporate an element of “risk on/risk off” market timing to reduce risk exposure during times of expected market volatility. Watts Capital’s Alternative Investment Strategies incorporate real estate investments, as well as other non-traditional assets such as private equity and hedge funds to deliver absolute returns or that are non-correlated to the public markets. Incorporation of these investments in Client portfolios is intended to reduce portfolio volatility and increase 4D. Types of Investments Advised On portfolio risk-adjusted return. The complex and often illiquid nature of these investments often limit their use to the portfolios of a limited number of investors. Watts Capital’s services are tailored to the individual needs of each Client, including their net worth, net investable assets, investment horizon, needs for liquidity, income tax position, and individual risk preferences. The Firm also takes into account Clients’ special situations like low basis stock, legacy holdings, concentrated holdings, tax treatment and other restrictions on employee stock options and restricted stock, inheritances, trust provisions, closely held businesses, and special tax situations. The Firm’s services also give the Client the ability to reflect preferences or impose restrictions on their holdings, including the incorporation of Environmental, Social and Governance (ESG) guidelines or investing with Social Impact objectives. Watts Capital works with each Client on a one-on-one basis through interviews and questionnaires to determine the Client’s investment objectives, risk tolerance, and suitability. Watts Capital has the following assets under management/advisory: Discretionary Amounts Non-discretionary Amounts Date Calculated $423,933,314 12/31/2024 This figure includes the assets of WealthEdge Investment Advisors, which are managed under a CIO Services agreement with Watts Capital. 4E. Advisory Services Tailored to Individual Client Needs 4F. Client Assets Under Management Watts Capital offers Financial Planning services for an annual Financial Planning Fee, which is billed quarterly in advance. The Financial Planning Fee is determined as a percentage of the Client’s net worth and the complexity of services to be provided. In special situations, the Firm may undertake a limited financial planning services for a fixed fee. While Financial Planning services are provided with the intention of the Client implementing plan recommendations through Watts Capital, Clients are not obligated to do so. If a Client elects to have an associated person of the Firm implement the advice provided as part of the Financial Planning services, implementation will be made consistent with the terms outlined in this brochure. When implementing Financial Planning services, the Client may incur fees and expenses in addition to the planning fees described above. For each Financial Planning assignment, Watts Capital takes step to define the relationship between the Firm and the Client. This includes defining the scope of services to be provided, how the Firm is compensated, and any sources of additional compensation. The Client and the Firm discuss each of their expectations regarding the roles they will have during the Financial Planning process. They also agree on how decisions will be made. The agreement discusses the duration of the relationship and any provision for assignment termination.