Ownership Duncan Williams Asset Management, LLC (“DWAM” or “Advisor” or “we”) became an investment advisor registered with the SEC in February 2015. We are a Delaware Limited Liability Company headquartered in Memphis, Tennessee. Duncan F. Williams owns a controlling membership interest in DWAM. General Description of Primary Advisory Services We offer personalized investment advisory services including financial planning, retirement plan services, institutional client consulting, asset management services, including institutional cash management, referrals to third party money managers, and real estate coaching. The following are brief descriptions of our primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients and prospective clients (“clients” or “you”) can review the services and description of fees more thoroughly. Financial Planning Services (Plans and Consultations) Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. The role of a financial planner is to find ways to help clients understand their overall financial situation and help them set financial objectives. We offer advisory services in the form of financial plans and consultations. These services do not involve actively managing your accounts. Instead, comprehensive planning services focus on your overall financial situation. Modular planning services and consultations focus on specific areas of concern to you. Retirement Plan Services Duncan Williams Asset Management offers retirement plan services to retirement plan sponsors. These services can include, but are not limited to:  Retirement plan evaluation/search;  Development /review of investment policy statement;  Investment due diligence including review and analysis of choices offered by custodian;  Performance measurement and reporting;  Fiduciary services;  Consult on a one-on-one basis with Plan Participants;  Employee education; and  Fee analysis We offer Non-Discretionary Investment Advisory Services, Discretionary Investment Management Services, and Administrative Services (each a form of “Retirement Plan Services”) that are designed to assist plan sponsors of employee benefit plans (“Sponsor(s)”). When providing any Non-Discretionary Investment Advisory Service, we will solely be making investment recommendations to the Sponsor and the Sponsor retains full discretionary authority or control over assets of the Plan. We agree to perform any Non- Discretionary Investment Advisory Service to the Plan, as a fiduciary, as defined in ERISA Section 3(21)(A)(ii)k, and will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. When providing any Discretionary Investment Management Service, we will be exercising discretionary authority or control over assets of the Plan. We will have full power and authority to select, monitor, remove and replace the investment options offered under the Plan. We agree to perform Discretionary Investment Management Services to the Plan as a fiduciary under ERISA Section 3(38) and will act with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Under this arrangement, this discretionary authority is specifically granted to us by the Plan Sponsor, as specified in the Retirement Agreement. When providing any Administrative Service, we may support the Sponsor with Plan Governance and Committee Education, Vendor Management and Service Provider Selection and Review, Investment Education or provide Plan Participant Non-Fiduciary Education Services. We agree to perform any Administrative Service solely in a capacity that would not be considered a fiduciary under ERISA or any other applicable law. In the event a client contracts with DWAM for one-on-one consulting services with plan participants, such services do not involve the Firm implementing recommendations in individual participant accounts. It will be the responsibility of each participant to implement changes in their individual accounts. Conflicts of Interest Notice Regarding IRA Rollovers from a Qualified Employer Sponsored Retirement Plan A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If DWAM recommends that a client roll over their retirement plan assets into an account to be managed by DWAM, such a recommendation creates a conflict of interest if DWAM will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by DWAM. Asset Management Services We offer both discretionary and non-discretionary asset management services providing you with continuous and ongoing supervision over your accounts. As part of our Asset Management Service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds, options, mutual funds, brokered cd’s, alternative investment funds, and fee-based annuities, where appropriate. Depending on the engagement, these services can also include real estate coaching. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored and if necessary, rebalanced based on the client’s individual needs, stated goals or objectives. Institutional cash management may also be offered as part of our asset management services. This strategy utilizes brokered CD ladders with staggered maturity ranges that may offer more liquidity with competitive rates. These services are provided through Schwab’s fixed income trading desk. Investment Consulting Services Duncan Williams Asset Management also provides investment consulting services on accounts that may or may not be managed or maintained by our firm. If we do not have trading authorization or direct access to the accounts under this service, all trade implementation will be the responsibility of the client. Referrals to Third Party Money Managers We offer advisory services by referring clients to outside, or unaffiliated, money managers that are registered or exempt from registration as investment advisers. Third-party money managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Prior to referring clients, our firm will provide initial due diligence on third party money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of a third-party money manager, our firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will communicate information to third party money managers as warranted, and assist the client in understanding and evaluating the services provided by the third party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment

objectives, or account restrictions that could affect their financial standing. Institutional Intelligent Portfolios™/IMAGINE We offer an automated investment program (the “Program”), branded as IMAGINE, through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. Schwab is not responsible to the client for the Program, any portfolio, wash sales or other tax consequences of tax-loss harvesting, or DWAM’s suspension or resumption of trading in the client’s account. SPT’s role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. We have contracted with SPT to provide us with the platform, which consists of technology and related trading and account management services for the Program. The platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We do not receive a portion of a wrap fee for our services to clients through the Program. Clients do not pay fees to SPT in connection with the Program, but we charge clients a fee for our services as described below under Item 5 Fees and Compensation Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Program. Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. We do not pay SPT fees for its services in the Program so long as we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. Limits Advice on Certain Types of Investments We offer investment advice to clients on the following types of investments:  Exchange-listed securities  Securities traded over-the-counter  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Variable life insurance  Variable annuities  Mutual fund shares  Exchange Traded Funds  Unit Investment Trusts  United States government securities  Option contracts on securities  Interests in partnerships investing in real estate and real estate holdings  Interests in hedge funds  Fixed Indexed Annuities However, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. Please also see Item 5, Fees and Compensation, for additional information about portfolio holdings in managed accounts. Please refer to Item 8 , Methods of Analysis, Investment Strategies and Risk of Loss for more information. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on your specific needs. You have the ability to impose restrictions on your accounts, including specific investment selections and sectors. However, we will not enter into an investment advisory relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. You have sole discretion about whether or not to contract for our services. In addition, you have sole discretion about whether or not to implement any recommendations made by our representatives. If you do decide to implement recommendations, you are responsible for taking any actions or implementing any transactions required. You are free to select any broker/dealer and/or insurance agent to implement our recommendations. Portfolio Management Program versus Wrap-Fee Program We offer services through both traditional portfolio management and wrap-fee management programs. In a traditional portfolio management program, advisory services are provided for a fee but transaction services (fees associated with the purchase and sale of securities for your account) are billed separately on a per-transaction basis. Under our wrap-fee management programs, our advisory services (including portfolio management or advice regarding selecting other advisors) and transaction services are provided for one fee. For suitability purposes, each investment in each account is reviewed according to investment objectives, risk tolerance and overall net worth. Investments are recommended as part of a holistic wealth management approach to asset allocation for accounts within a wrap-fee program. The essential difference between transactional accounts and those under management in a wrap-fee program is the way in which transaction services are paid. Client Assets Managed by Advisor The amount of clients’ assets managed by Advisor totaled $1,022,050,200 as of December 31, 2023, with $797,136,102 managed on a discretionary basis, and $224,914,098 managed on a non-discretionary basis. Form ADV’s instructions on calculating assets under management in Part I of the Form ADV only permits assets managed on a non-discretionary basis to be included if we are responsible for executing the purchase and sale of the securities we recommend. We are engaged by sponsors of 401(k) accounts to regularly provide management advice on a non-discretionary basis, and if our recommendations are selected, we are responsible for modifying the menu of available investment options for the plan participants. However, we do not execute individual securities transactions on behalf of 401(k) participants. We consider these 401(k) Plan client assets in calculating our total assets under advisement since we regularly provide investment advice on a non-discretionary basis with respect to these assets.