CORPORATE HISTORY Calamos Wealth Management LLC (“CWM”) is an investment adviser registered with the U.S. Securities and Exchange Commission (the “SEC”) and a wholly owned subsidiary of Calamos Investments LLC (“CILLC”). Calamos Asset Management, Inc. (“CAM”) is the sole manager of CILLC, which owns and manages our operating companies. Unless the context otherwise requires, references to “we,” “us,” “our,” “the firm,” “our company” and “Calamos” refer to Calamos Wealth Management LLC. As it relates to this brochure, our affiliate, Calamos Advisors LLC (“CAL”), is an investment adviser that provides investment advisory services to investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”), Undertakings for Collective Investment in Transferable Securities (“UCITS”), institutional and managed accounts and also serves as sub-investment adviser to several registered investment companies. References to the “Calamos Family of Funds” or the “Calamos Funds” refers to those investment companies registered under the 1940 Act managed by CAL. Our founder, John P. Calamos, Sr., began investing for his clients in the difficult markets of the 1970s. John developed pioneering strategies that sought to maximize the potential of convertible securities. Convertibles were little known at the time, but John recognized the potential of these securities to enhance returns and manage risk. Because Mr. Calamos recognized that successful wealth management is about more than asset management, our firm was founded in 2007 to offer clients a suite of wealth planning services, including, to the extent requested, financial planning and related consulting services. Our firm is headquartered in Naperville, Illinois, and has offices based in New York, San Francisco, Los Angeles*, Portland, Fort Worth*, Milwaukee, Chicago and Coral Gables. *These locations are private residences that are not held out to the general public as branch office locations. CWM advisors do not meet with clients in such locations. As of December 31, 2023, approximately 22% of the outstanding interests of CILLC was owned by CAM and the remaining 78% of CILLC was owned by Calamos Partners LLC (“CPL”) and John P. Calamos, Sr. CAM was owned by John P. Calamos, Sr. and John S. Koudounis, and CPL was owned by John S. Koudounis and Calamos Family Partners, Inc. (“CFP”). CFP was beneficially owned by members of the Calamos family, including John P. Calamos, Sr. SERVICES PROVIDED We provide discretionary wealth management services, which include asset allocation planning, proprietary investment offerings, external manager selection, and general wealth consulting, to high-net- worth individuals and organizations. We offer customized asset allocation advice and individualized services such as the following:  Asset allocation services that take into account investment objectives, risk tolerance, and investment time horizon; Form ADV Part 2A – Disclosure Brochure PAGE 5 March 22, 2024  Oversight of Separately Managed Account (“SMAs”) portfolios managed by sub-advisers or us that are allocated to mutual funds. We also recommend or use a combination of sub- advisers and mutual funds in both taxable and tax-deferred accounts;  Development and execution of multi-generational investment policies, asset management, and income distribution plans; and  Management of retirement and deferred compensation plans. PRIVATE WEALTH ADVISORY SERVICES As part of its services, CWM manages client investment assets in either of its two investment programs, which are described in greater detail below. While CWM and its employees, including relationship team members, may recommend one program to a client over another program, clients are responsible for reviewing this brochure and determining which program is appropriate for them initially and on an ongoing basis. WEALTH ADVISORY PROGRAM CWM will manage a portfolio typically consisting of one or more of the following types of securities: individual equity and fixed-income securities, Calamos Funds and non-Calamos Funds, exchange traded funds (“ETFs”), and limited partnerships. CWM will also recommend or select sub-advisers to manage a portfolio of individual equity and fixed-income securities. CWM generally recommends CAL to serve as a sub-adviser for a portfolio, subject to the client’s consent in their investment advisory agreement or the investment policy statement. All securities used will be evaluated based on the desired impact in a portfolio, which includes performance, overall volatility, downside risk, yield, as well as other general strategy level factors, such as manager tenure, active or passive approach, etc. Any use of Calamos Funds will be subject to the same process as non-Calamos Funds. Clients and prospective Wealth Advisory Program clients should consider the following:  CWM’s advisory fee is higher in the Wealth Advisory Program than in the Calamos Managed Mutual Fund Program, and our affiliate receives management fees from the Calamos Funds in both programs. More information about the fees and expenses of each program is described in Item 5 below. Clients and prospective clients should also review Item 4 under the heading “Calamos Funds and The Use of Affiliated Sub-Adviser”, and Item 8 under the heading “Investment Strategies” to more fully understand the total cost of each program.  CWM generally charges its advisory fee on all assets purchased in the Wealth Advisory Program, except that CWM provides a waiver on its advisory fee with respect to investments in the Calamos Funds. CALAMOS MANAGED MUTUAL FUND PROGRAM CWM will manage a mutual fund portfolio comprised of Calamos Funds that are open-end mutual funds. CWM will only use non-Calamos Funds when and if, in CWM’s sole discretion, the desired asset class or Form ADV Part 2A – Disclosure Brochure PAGE 6 March 22, 2024 strategy is not available in an existing Calamos Fund. At most times, CWM expects that portfolios in the Calamos Managed Mutual Fund Program will be invested entirely in Calamos Funds. Given the structure of this program, a current or prospective Calamos Managed Mutual Fund Program client should review the disclosure below under the heading “Calamos Funds and The Use of Affiliated Sub-Adviser”. Clients and prospective clients should consider the following:  The advisory fee charged by CWM for the Calamos Managed Mutual Fund Program is lower than that charged for the Wealth Advisory Program, but our affiliate receives fees from the Calamos Funds in both programs. More information about the fees and expenses of each program is described in Item 5 below. Clients and prospective clients should also review Item 4 under the heading “Calamos Funds and The Use of Affiliated Sub-Adviser”, and Item 8 under the heading “Investment Strategies” to understand the total cost of each program more fully.  In the Calamos Managed Mutual Fund Program, CWM provides a waiver of its advisory fee on any investment in the Calamos Funds held in an individual retirement account (“IRA”) or a portfolio that is subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Certain clients who, as of August 4, 2015, were receiving services from a sub-adviser, including CAL, will continue to receive those services under the Calamos Managed Mutual Fund Program. CALAMOS FUNDS AND THE USE OF AFFILIATED SUB‐ADVISER As described above, both the Wealth Advisory Program and the Calamos Managed Mutual Fund Program invest in Calamos Funds. In addition, in the Wealth Advisory Program, we will recommend the use of CAL as a sub-adviser, subject to the client’s consent in their investment advisory agreement or the investment policy statement. In the Wealth Advisory Program, the selection of securities and sub-advisers, including the Calamos Funds and CAL, is subject to the selection process described in Item 8 below. The amount of Calamos Funds included in a portfolio in the Wealth Advisory Program is determined by CWM in accordance with its security selection process described in Item 8 below. Both the allocation and the specific investments used for the Wealth Advisory Program are subject to change. Your account statements will reflect the current composition of your account, including any Calamos Funds. We have a conflict of interest in selecting Calamos Funds for portfolios in both the Wealth Advisory Program and the Calamos Managed Mutual Fund Program, because our affiliates earn compensation for managing and operating the Calamos Funds, which are described in greater detail in each fund prospectus. In the Calamos Managed Mutual Fund Program, the fees payable to CAL as investment adviser to the Calamos Funds are in addition to the fee that you pay to CWM for participation in this program and results in CWM and its affiliates receiving “two levels of fees”. In the Wealth Advisory Program, you will also be responsible for the fees payable to CAL as investment adviser to the Calamos Funds, but as described below, we provide a waiver of our advisory fee for all investments in the Calamos Funds. We also have a conflict of interest in recommending the use or continued use of CAL as a sub-adviser in Form ADV Part 2A – Disclosure Brochure PAGE 7 March 22, 2024 the Wealth Advisory Program and the continued use of CAL in the Calamos Managed Mutual Fund Program, because we avoid paying other unaffiliated sub-advisers. We seek to mitigate these conflicts of interest in the Wealth Advisory Program in several ways, including disclosing the conflicts of interest in this brochure, by subjecting the Calamos Funds and the initial recommendation of CAL as sub-adviser to the investment selection process described in Item 8 below, and by providing a waiver of our advisory fee for all investments in the Calamos Funds. Even though we provide a waiver, the compensation that CAL receives from the Calamos Funds may be greater (or less) than your advisory fee that we waive. Clients may also direct us not to recommend or use the Calamos Funds, may direct us at any time to discontinue use of CAL as a sub-adviser, or may withhold their consent to using CAL in the first instance. For the Calamos Managed Mutual Fund Program, we seek to mitigate these conflicts of interest in several ways, including disclosing the conflicts of interest in this brochure, and by providing a waiver of our advisory fee on any Calamos Funds held in an IRA or a portfolio that is subject to ERISA. Clients may also direct us at any time to discontinue the use of CAL as a sub-adviser. Clients and prospective clients should consider these conflicts of interest and our additional sources of compensation when evaluating the amount and appropriateness of the fees we earn in connection with their selection of either program. TRUST SERVICES CWM recommends the services of several trust companies, chartered nationally and in different states, that can assist clients with their unique planning trust service needs. These trust companies and their services are made available under the name Calamos Trust Services. The client is under no obligation to engage the services of any recommended trust company. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from CWM and its representatives. CWM does not receive any compensation (direct or indirect) from any trust company for these referrals. The terms and conditions of a client’s engagement with the trust company, including the fee payable by the client, are outlined in a separate agreement between the client and the trust company. Additionally, CWM can provide trust services to its clients through an affiliation with National Advisors Trust Company, FSB (“NATC”). NATC is a federally chartered trust company regulated by the Office of the Comptroller of the Currency (“OCC”) and is a member of the Federal Deposit Insurance Corporation (“FDIC”). In connection with NATC and as an accommodation to addressing the needs of certain clients, CWM offers trust services through a private label trade name, Calamos Private Trust (“CPT”), a Trust Representative Office of NATC. By law, CWM’s client assets are segregated from the capital assets of NATC and are not subject to potential NATC creditor claims. CWM and NATC are not related entities. The terms and conditions of a client’s engagement of NATC, including the fee payable by the client to NATC, are outlined in a separate agreement between the client and NATC. We have a conflict of interest in recommending NATC as a trust company, because we are shareholders of National Advisors Holding, Inc. (NAH), the parent company of NATC. No client is under any obligation to use NATC’s trust services. CWM, as a matter of policy, regardless of the type of client engagement or service, does not provide tax, Form ADV Part 2A – Disclosure Brochure PAGE 8 March 22, 2024 accounting, regulatory or legal advice. Rules in the areas of law, tax, and accounting are subject to change and open to varying interpretations. Before implementation, clients should consult with professionals on the tax, accounting and legal implications of any recommended trust strategy based on their circumstances. INSTITUTIONAL ADVISORY SERVICES We provide discretionary institutional advisory services, which include proprietary investment offerings, external manager selection, and general investment consulting to corporations, charitable organizations, family offices, endowments, and private foundations. We also offer customized asset allocation advice services such as the following:  Management of SMA portfolios comprised of individual securities, other sub-advised accounts, mutual funds, or a combination of these;  Individualized reporting; and  Team-based servicing, led by a relationship manager and institutional portfolio specialists. Our firm’s minimum relationship size is $1,000,000. Individual SMAs are accounts managed to meet each client’s unique needs, with a minimum investment amount of $100,000 and vary based on strategy. Institutional SMAs are accounts managed to meet an institutional client’s needs, with a minimum investment of $5,000,000. These minimums are reduced or waived in certain circumstances. These portfolios include but are not limited to common and preferred stock, convertible stocks and bonds, options, warrants, rights, corporate, municipal, government agency, and government bonds, notes, and bills, open-end, closed-end or exchange-traded funds. As a component of our SMA practice, we also have complete discretionary authority to delegate investment responsibilities to one or more persons or companies (each a “sub-adviser”) pursuant to an agreement between the firm and each sub-adviser (“Sub-Advisory Agreement”). Each Sub-Advisory Agreement provides that the sub-adviser, subject to our control and supervision, will have full investment discretion for the account assets assigned to the sub-adviser and will make all determinations with respect to account assets assigned to them and the purchase and sale of portfolio securities with those assets, and any steps necessary to implement its decision. We will monitor and evaluate the investment performance of each sub-adviser; determine the portion of your assets to be managed by each sub-adviser; make changes or additions of sub-advisers when deemed appropriate; and coordinate the investment activities of sub-advisers. We shall be solely responsible for paying the fees of each Sub- Adviser unless otherwise agreed to by a client. In our institutional advisory services offering, we invest in Calamos Funds and recommend the use of CAL as a sub-adviser, subject to the client’s consent in their investment advisory agreement or the investment policy statement. Clients and prospective clients should review the disclosures above under the heading “Calamos Funds and The Use of Affiliated Sub-Adviser” for additional information about the conflicts of interest these practices present, and how we seek to mitigate them. Form ADV Part 2A – Disclosure Brochure PAGE 9 March 22, 2024 PREMIER PROGRAM We also perform non-discretionary investment consulting services relative to those specific investment assets and/or accounts specified in a Premier Program Agreement. We shall, when requested by you, review the assets described in such an agreement and provide advice consistent with your designated investment objectives. All such advice shall be based exclusively upon the information we receive from you. You will maintain absolute discretion to accept or reject any of our investment recommendations and you will be responsible for implementing any such recommendations. TAILORED SERVICES APPLICABLE TO ALL PROGRAMS During our initial consultations, the Client Relationship Management Team (the “Team”) will ask a series of questions about your priorities and concerns. Based upon these consultations, we will then work to create an investment policy statement to serve as a primary point of reference to ensure that your objectives are clearly defined. We remain available to review the policy statement with you on an ongoing basis, modifying it as necessary to accommodate changes to your long-term goals and objectives. Your portfolio can be customized to suit your investment needs and goals. You have the option of imposing reasonable investment restrictions on certain securities, industries, sectors, or asset classes by providing us with written instructions when you open your advisory account, or at any time thereafter. MISCELLANEOUS Private Investment Fund Recommendations and Advice CWM also provides investment advice regarding unaffiliated

private investment funds. CWM, on a non- discretionary basis, recommends that certain qualified clients consider an investment in unaffiliated private investment funds. CWM’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of CWM calculating its investment advisory fee. CWM’s clients are under absolutely no obligation to consider, or make, an investment in a private investment fund. Private investment funds involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a subscription agreement, where the client will establish that they are qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with their investment. NO client is under any obligation to invest in any private investment fund. In valuing the assets of any private investment fund for purposes of calculating its advisory fee, CWM relies on the most recent valuations provided by the fund’s sponsor. When a fund sponsor has not provided any updated valuations, CWM will use the most recent valuation obtained from the sponsor of Form ADV Part 2A – Disclosure Brochure PAGE 10 March 22, 2024 the investment. In the event a private fund sponsor is unable to provide a current fund valuation, the firm, shall reflect the most recent valuation provided by the fund sponsor. If no subsequent valuation post purchase is provided by the Fund sponsor, then the valuation shall reflect initial purchase price (and/or a value as of a previous date), the current value(s) (either the initial purchase price and/or the most recent valuation provided by the fund sponsor). If the valuation reflects initial purchase price (and/or a value as of a previous date), the current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. To the extent private fund proxies are sent to CWM, our affiliated sub adviser, CAL will vote for these proxies. Interval Funds Interval Funds/Risks and Limitations: Where appropriate, Calamos Wealth Management LLC (“CWM”) utilizes interval funds, including Calamos Funds. Clients and prospective clients should also review Item 4 under the heading “Calamos Funds and The Use of Affiliated Sub-Adviser”, and Item 8 under the heading “Investment Strategies” to understand the costs and conflicts that exist in recommending our own funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund.. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares and the fund will not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors will sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct CWM, in writing, not to purchase interval funds for the client’s account. Limitation of Financial Planning and Non‐Investment Consulting To the extent specifically requested, CWM will provide financial planning and consulting services regarding non-investment related matters, such as tax, estate, wealth structuring, and risk management planning. CWM does not generally charge clients receiving any Private Wealth Advisory Services beyond its advisory fee described in Item 5 below when its employees have the specialized knowledge and skill to render these services. However, in its sole discretion, CWM reserves the right to notify the client that Form ADV Part 2A – Disclosure Brochure PAGE 11 March 22, 2024 its requested services fall outside the scope of its initial engagement and may negotiate with the client the scope of any additional services. CWM is not a law firm, tax or accounting firm, and no portion of our services should be construed as legal or accounting advice. To the extent requested by a client, we recommend the services of other professionals for non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, investment bankers, and appraisers). The client is under no obligation to engage the services of any recommended professional. The client retains discretion over all implementation decisions and is free to accept or reject any recommendation from CWM and its representatives. If the client engages any professional (i.e., attorneys, accountants, insurance agents, investment bankers, and appraisers), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorneys, accountants, insurance agents, investment bankers, and appraisers), and not CWM, shall be responsible for the quality and competency of the services provided. CWM believes that it is important for the client to address financial planning issues with CWM on an ongoing basis. CWM’s fee, as set forth in the client’s agreement, will remain the same regardless of whether or not the client determines to address planning issues with CWM. CWM is not responsible for implementing, monitoring, or updating the client’s financial plan without the client’s request. CWM remains available to address planning issues with the client, including updating the client’s financial plan, upon the client’s request. Variable Annuities Neither CWM, nor any of its representatives, sells variable annuity products, or is compensated for any incidental guidance concerning a variable annuity provided as part of our overall portfolio review and construction. However, when requested to do so by the client, CWM will provide general guidance to the client with respect to how their variable annuity fits within the client’s overall investments. Retirement Rollovers 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 the assets to an IRA; or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If CWM recommends that a client roll over their retirement plan assets into an account to be managed by CWM, such a recommendation creates a conflict of interest, if CWM will earn new (or increase its current) compensation because of the rollover. If CWM provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), CWM is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by CWM, whether it is from an employer’s plan or an existing IRA. CWM’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by a rollover Form ADV Part 2A – Disclosure Brochure PAGE 12 March 22, 2024 recommendation. Cash Positions. CWM continues to treat cash as an asset class. As such, unless determined to the contrary by CWM, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating CWM’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), CWM may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, CWM’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, CWM shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund available on the custodian’s platform, unless CWM reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. Please Note: The above does not apply to the cash component maintained within a CWM actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), assets allocated to an unaffiliated investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any CWM unmanaged accounts. ANY QUESTIONS: CWM’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above. Custodian Charges‐Additional Fees. When requested to recommend a broker-dealer/custodian for client accounts, CWM generally recommends that Fidelity and/or Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity and Schwab charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Fidelity and Schwab, do not currently charge fees on most individual equity transactions, others do. Please Note: there can be no assurance that Fidelity and/or Schwab will not Form ADV Part 2A – Disclosure Brochure PAGE 13 March 22, 2024 change their transaction fee pricing in the future). When beneficial to the client, individual fixed-income and/or equity transactions are effected through broker-dealers with whom CWM, its affiliates, and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker-dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker-dealer and a “trade- away” fee charged by Fidelity or Schwab ). See Item 12 below. The above fees/charges are in addition to CWM’s investment advisory fee in Item 5 below. CWM does not receive any portion of these fees/charges. Portfolio Activity. CWM has a fiduciary duty to provide services consistent with the client’s best interest. CWM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon a range of factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when CWM determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Introductions to Other Professionals In the event that a client advises CWM that it requires the services of an unaffiliated professional (i.e., attorneys, accountants, insurance agents, investment bankers, and appraisers), and the client requests an introduction from CWM, CWM will make an introduction to a professional who is also a CWM client. Unless otherwise indicated, in writing, neither CWM, nor any CWM employee, will receive any compensation from the professional for the introduction. If CWM introduces a client to an unaffiliated professional who it knows to be a CWM client, CWM will disclose the conflict, in writing, to the client. No client is under any obligation to utilize the services of any such recommended professional. Client Obligations In performing its services, CWM is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on the information the client or its other professionals provides. Moreover, each client is advised that it remains their responsibility to promptly notify CWM if there is ever any change in their financial situation or investment objectives so that CWM can review, and if necessary, revise its prior advice. Borrowing Against Assets A client who has a need to borrow money could determine to do so by using:
• Margin-The account custodian or broker-dealer lends money to the client. The custodian charges the client interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral; and
• Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the client pledges its investment assets held at the account custodian as collateral. Form ADV Part 2A – Disclosure Brochure PAGE 14 March 22, 2024 These above-described collateralized loans are generally utilized because they provide competitive interest rates. These types of loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains. However, such loans are not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, CWM does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). CWM does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the client were to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to CWM:
• by taking the loan rather than liquidating assets in the client’s account, CWM continues to earn a fee on such Account assets;
• if the client invests any portion of the loan proceeds in an account to be managed by us, CWM will receive an advisory fee on the invested amount; and
• CWM’s advisory fee is based upon the higher margined account value, therefore CWM will earn a correspondingly higher advisory fee. This will incentivize CWM to encourage the use of margin. Please Note: The Client must accept the above risks and potential corresponding consequences associated with the use of margin or pledged assets loans. ASSETS UNDER MANAGEMENT As of December 31, 2023 CWM had approximately $3.1 billion in discretionary assets under management and $216 million in non-discretionary assets under management.