We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of Texas. Our firm has been in business as an investment adviser since 2015 and is solely owned by Russell Gebhard. Description of the Types of Advisory Services We Offer Wrap Comprehensive and Comprehensive Portfolio Management: Our Wrap Comprehensive and Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we collaborate with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Our portfolio management accounts consist of Comprehensive (you pay for ticket and other charges for trades executed in your account) and Wrap Comprehensive (you will not incur transaction costs for trades executed in your account) accounts. As a result of your advisor executing transactions with no cost to you, wrap comprehensive fees are typically higher than comprehensive advisory fees. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, with an independent custodian, and not with us. SWA recommends that our clients use LPL Financial LLC, Charles Schwab & Co., Inc., all are FINRA-registered broker-dealers, member SIPC, as qualified custodians. You will enter into a separate custodial agreement with the custodian which authorizes the custodian to take instructions from [us/you] regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. Financial Planning & Consulting: We provide a variety of financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Educational Seminars: We offer clients the opportunity to attend educational seminars hosted by advisors from our firm. The seminars will cover a range of topics which will include but are not limited to the following:
• General: We will discuss how individuals may live within their means, save more, and spend less. This discussion will also touch on budgeting, creating an emergency fund, and basic financial planning.
• Market Overview: Presentation of data pertaining to stock market performance in the previous year, economic factors, and outlook for the coming year.
• Estate Planning: We will explore various estate-planning issues such as wills, the need for a durable power of attorney for health care, using a financial power of attorney, and when a trust makes sense. Additionally, we will discuss using life insurance, the potential impact of estate taxes, business succession, and funeral expense planning.
• Retirement: Topics include types and characteristics of various retirement vehicles, projecting income, expenses and needs, deciding when to retire, retirement lifestyle, budgeting, and money management during retirement.
• Investments: An emphasis will be placed on familiarizing attendees with investment terminology and types of investment products to include but not limited to bonds, stocks, mutual funds, and commodities. In addition to, the distinctions among various asset classes such as value and growth; large, medium, and small cap; and municipal, corporate and other types of bond classification. Retirement Plan Consulting: We provide retirement plan consulting services to employer plan sponsors on a one-time or ongoing basis. Generally, such retirement plan consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. All retirement plan consulting services shall be in compliance with the applicable state law(s) regulating retirement plan consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) or Section 3(38) of ERISA (but only with respect to the provision of services described in section 1 of the Retirement Plan Consulting Agreement). Sponsored Advisory Programs: Our firm may provide advisory services through certain programs sponsored by LPL Financial (“LPL”) or Charles Schwab. Below is a brief description of each advisory program available to our firm. For more information regarding the advisory programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the respective custodians Form ADV Part 2 or the applicable program’s Appendix 1 (wrap fee program brochure) and the applicable client agreement. Optimum Market Portfolios Program (OMP) - LPL OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisors will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. Personal Wealth Portfolios Program (PWP) - LPL PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisors will also have discretion for selecting third party money managers (PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL will function as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds and equity and fixed income securities. Model Wealth Portfolios Program (MWP) - LPL MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department is responsible for selecting the mutual funds within a model portfolio and for making changes to the mutual funds selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds (including in certain circumstances exchange traded funds) and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. The MWP program makes available model portfolios designed by strategists other than LPL’s Research Department. The Advisor will have discretion to choose among the available models designed by LPL and outside strategists. Manager Access Select Program - LPL Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial

and ongoing assistance regarding the Portfolio Manager selection process. Guided Wealth Portfolios (GWP) - LPL GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although SWA will be available to discuss investment strategies, objectives, or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and SWA by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or SWA, do not enter into an advisory agreement with LPL, FutureAdvisor or SWA, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. 55IP – Charles Schwab 55IP provides sub-advised ETF and Mutual Fund actively managed model portfolios through JPMorgan and Blackrock. The advisor helps the client pick from many portfolio choices based on several risk/return profiles and 3 main Model Types: Strategic, Tactical and Multi-Asset Income. Exceptional care is taken for using tax-aware strategies to lower clients’ turnover and taxable gains. The tax-aware strategies used are transition, loss harvesting and withdrawal. 55IP is accessed through custodian Charles Schwab Third Party Asset Managers: We may determine that opening an account with a professional third-party asset manager is in your best interest. We utilize the services of LPL Financial LLC (“LPL”), SEI Investments, City National Rochdale, Lockwood and Assetmark as third-party asset managers. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The asset managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent asset managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may:
• Assist in the identification of investment objectives.
• Recommend specific investment style and asset allocation strategies.
• Assist in the selection of appropriate money managers and review performance and progress.
• Recommend reallocation among managers or styles within the program.
• Recommend the hiring and firing of money managers utilized by you. You will receive a separate Form ADV Part 2 from the third-party asset manager that discusses how its fees and expenses are paid and your relationship with them. The third-party asset manager fees may be separate from our fees and vary based on the total client assets we have invested. These fees are separately charged to advisory clients. All fees are disclosed in the Client Agreement and displayed on quarterly statements. You should read the ADV Part 2 disclosure document of the asset manager you select for complete details on the charges and fees you will incur and ask us any questions you may have. Please refer to the ADV Part 2 for LPL, SEI Investments, City National Rochdale, Lockwood and Assetmark for a complete description of the services offered through these third-party asset managers. SEI Investments SWA participates in the Separately Managed Accounts Program sponsored by SEI Investments Management Corporation. To participate in the Program, SWA, SEI and each client execute a three-party agreement (hereinafter, a Managed Account Agreement) providing for the management of certain investor assets in accordance with the terms thereof. By means of the Managed Account Agreement, the client appoints SWA as its investment advisor to assist the client in selecting an asset diversification strategy, which includes allocating a percentage of client assets to designated portfolios of separate securities and which may include a percentage of assets allocated to a portfolio of mutual funds sponsored by SEI or an affiliate of SEI. The client appoints SEI to manage the assets in each Separately Managed Account Portfolio in accordance with a strategy selected by the client together with SWA. SEI may delegate its responsibility for selecting securities to one or more portfolio managers. Please refer to SEI’s ADV Part 2 disclosure brochure for a full description of fees. City National Rochdale The Wrap Program offered directly through City National Rochdale by SWA offers continuous management of client accounts on a fully discretionary basis making all security purchase and sale decisions. Securities transactions are executed through Advisor’s brokerage affiliate, RIM Securities LLC, a member of FINRA. Clients participating in the City National Rochdale Wrap Program are required to direct the use of RIM as their broker/dealer. RIM clears all its transactions on a fully disclosed basis through Pershing LLC, but separate commissions are not charged for securities transactions under the City National Rochdale Wrap Fee Program. Pershing also serves as the custodian for all client Accounts that participate in the City National Rochdale Wrap Fee Program. In addition to actively managing client accounts, the City National Rochdale Wrap Program aid clients in setting investment objectives, as well as determining appropriate asset allocations. A variety of investment styles may be employed, with client consultation, with a view to establishing the investment style most appropriate for the client’s investment objectives. Lockwood Investment Advisors Lockwood provides access to individual portfolio managers (“Portfolio Managers”) and investment advisory and discretionary services to financial planners, certified public accountants, broker- dealers, registered investment advisers, and other financial advisors (“Firms” or “Firm” in the singular) which, in turn, provide investment advice and consulting services to their clients. An affiliate of Lockwood, Pershing LLC (“Pershing”) is a SEC registered broker-dealer that is a member of the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”) and the New York Stock Exchange (“NYSE”) and provides clearing and custody services for the Lockwood program described in this Brochure. Another affiliate of Lockwood, Pershing Advisor Solutions LLC (“Pershing Advisor Solutions”), is a SEC registered broker-dealer that is a member of FINRA and SIPC and provides retail brokerage services for certain Clients in the Managed360 Program. Lockwood, Pershing and Pershing Advisor Solutions are affiliated companies, each of which is indirectly owned by BNY Mellon. Lockwood’s range of investment offerings includes the following:
• Separately Managed Accounts (“SMA”) – Researched SMA managers and open architecture SMA managers.
• Lockwood AdvisorFlex Portfolios – A flexible mutual fund and exchange traded fund (“ETF”) wrap product.
• Lockwood Investment Strategies – A fixed unified managed account (“UMA”) wrap product.
• Lockwood WealthStart Portfolios – A fixed mutual fund and ETF wrap product.
• Lockwood Asset Allocation Portfolios – A fixed mutual fund and ETF wrap product.
• Lockwood/American Funds Core Portfolios – A fixed mutual fund and ETF wrap product constructed using American Funds mutual funds.
• Lockwood Flexible Unified Managed Account – A flexible UMA wrap product.
• Third Party Strategists – Open architecture mutual fund and ETF models. AssetMark AssetMark, Inc. (“AssetMark”) is the sponsor of the AssetMark Platform (“Platform”) through which it offers its advisory and Platform services to Clients (the “Client”). Representatives of third-party investment adviser firms (these firms are referred to in this brochure as “Financial Advisory Firms” and their representatives are referred to as the “Financial Advisors”), consult with Clients to assess their financial situation and identify their investment objectives in order to implement investment solutions designed to meet the Client’s financial needs. If the Client and the Financial Advisor choose a Solution Type (or “Solutions,” described below) managed by ISG or Savos, AssetMark is responsible for the management of that Solution Type for the Client’s Account (described below). AssetMark also serves as the investment adviser for the following registered investment companies (“Proprietary Funds”) available in certain Solution Types under the Platform: 1) GPS I, a series of sub-advised no-load mutual funds that include the GuideMark® Funds; 2) GPS II, a series of no-load mutual funds that include GuideMark Funds as well as GuidePath Fund of Funds; and 3) the Savos Investments Trust Dynamic Hedging Fund (“Savos DHF”), a registered investment company used by Savos to provide risk mitigation in some Solution Types. AssetMark is responsible for the management of each of these registered investment companies. However, the Client and the Financial Advisor, and not AssetMark, are responsible for selecting the Solution Type that uses these investment companies. Current approved custodian of AssetMark assets is Pershing LLC and AssetMark Trust Company. Please refer to the ADV Part 2 for LPL, SEI Investments, City National Rochdale, Lockwood Investment Advisors and Assetmark for a complete description of the fees charged by these third-party asset managers. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our Comprehensive Portfolio Management service. Additionally, we offer general investment advice to clients utilizing our Financial Planning & Consulting, Educational Seminars, and Retirement Plan Consulting services. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Comprehensive Portfolio Management service. We do not manage assets through our other services. Participation in Wrap Fee Programs We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap comprehensive fee accounts in a different fashion than comprehensive fee accounts. As further described in our Wrap Comprehensive Program Brochure, we receive a portion of the wrap fee for our services. Regulatory Assets Under Management As of March 30th, 2024, our Registered Investment Advisor manages $509,346,87 on a discretionary basis and $38,057,332 on a non-discretionary basis.