A. Firm Description Moloney Securities Asset Management LLC, (“MSAM”) is a federally registered investment adviser with the Securities and Exchange Commission (“SEC”) pursuant to the Investment Advisers Act of 1940. MSAM was organized as a limited liability company in 2015, with its principal place of business located in Manchester, MO. MSAM is a successor investment adviser to its affiliate, Moloney Securities Co., Inc., (Moloney Securities). Prior to the effectiveness of MSAM's successor application, MSAM conducted its investment advisory activities as a d/b/a of Moloney Securities, which was dually registered as a broker- dealer and investment adviser from 1995 to the effective date of MSAM’s registration as a registered investment adviser. MSAM is owned 100% by Briar Green Holdings, Inc., a privately held company. MSAM, the registered investment adviser, has relationships with independent Investment Advisors. The firm's clients receive personalized investment advice from these Investment Advisors. These Investment Advisors may do business under their own corporate entity, such as: St. Croix Capital Management, Warren Financial Services, Arlington Financial Services, Heritage Investment Management, LLP, Advanced Financial Solutions, LLC, Artisan Asset Management, LLC, Asset Alliance Financial Wealth Management and Planning, Bridges Financial, Inc., Christianson Financial Advisors, LLC, Grand Glaize Wealth Management, Investment Center, Investment Center of Estes Park, Inc., JCL Capital Management, LLC, Kekeris Financial Group, Littlewood Financial Services, LLC, Minnesota Valley Investments, Royal Route Company, LLC, Salish Wealth Management, Sentinel Wealth Management, St. Louis Asset Management, Sugar Creek Advisory Group, Synergistic Financial Center, Team Duncan, Planned Investment Co., Inc., NMG Financial Services, Lilleberg Financial Group, CP Wealth, Russell Wealth Group, Netstreet, Nye Investment Planners, Inc., Westport Advisory Group and others, but all advisory services are offered through MSAM. Investment advisory services are provided to clients for a fee under an investment advisory agreement. MSAM does not act as a custodian of client assets other than those situations that are disclosed in MSAM’s Form ADV. When your Financial Advisor manages your investment, in most instances, RBC Correspondent Services or Charles Schwab & Co., Inc. will maintain custody of the investment assets in your investment advisory account. As of December 31, 2023, MSAM manages approximately $1,201,212,148 in assets under management of which $1,110,431,980 was in discretionary accounts and $90,780,168 was in non-discretionary accounts. The primary affiliation of MSAM, through a holding company is with Moloney Securities, a registered broker/dealer, member FINRA/SIPC, through various licenses and registrations. B. Types of Advisory Services MSAM provides custom investment planning, wealth management services and pension consulting for individuals, companies, retirement assets and investment adviser representatives. MSAM makes these programs available to clients directly and through third party investment adviser firms (Independent Investment Advisers). These Investment Advisors may do business under their own corporate entity, such as: St. Croix Capital Management, Warren Financial Services, Arlington Financial Services, Heritage Investment Management, LLP, Advanced Financial Solutions, LLC, Artisan Asset Management, LLC, Asset Alliance Financial Wealth Management and Planning, Bridges Financial, Inc., Christianson Financial Advisors, LLC, Grand Glaize Wealth Management, Investment Center, Investment Center of Estes Park, Inc., JCL Capital Management, LLC, Kekeris Financial Group, Littlewood Financial Services, LLC, Minnesota Valley Investments, Royal Route Company, LLC, Salish Wealth Management, Sentinel Wealth Management, St. Louis Asset Management, Sugar Creek Advisory Group, Synergistic Financial Center, Team Duncan, Planned Investment Co., Inc., NMG Financial Services, Lilleberg Financial Group, CP Wealth, Russell Wealth Group, Netstreet, Nye Investment Planners, Inc., Westport Advisory Group and others, but all advisory services are offered through MSAM. The following is a description of MSAM’s investment advisory services: MSAM investment philosophy focuses on utilizing experienced investment management talent to create custom portfolios. MSAM believes in a holistic wealth management approach that means connecting investment strategies to client’s desired life goals. MSAM or their partners incorporate a client’s unique risk tolerance, asset allocation and investment preferences along with life goals, values and ongoing adjustments. MSAM combines the internal expertise with external resources to build a set of investment solutions. MSAM manages client accounts on a discretionary or non-discretionary basis. MSAM

obtains all the necessary information about the client as to the client’s assets and liabilities, investment objectives, financial objectives and other pertinent information. In addition, MSAM offers the following strategies/composites: MSAM Growth The composite seeks long term growth of capital. The investment process is focused on identifying investment value through actively targeting factors such as: size, cash flow, payout to shareholders, return on invested capital and other company attributes where the expectation of increased value can be realized. Portfolio construction methods are used to manage risk and maintain a consistent ongoing portfolio profile. MSAM Opportunistic The Opportunistic Strategy seeks to purchase growth-oriented companies that may be underappreciated or undervalued across the entire investment spectrum. We use both quantitative and qualitative analysis to determine our "Central Value" of each company under consideration and seek to buy at or below this number. Our investable universe is focused on, but not limited to, companies with the following characteristics: Strong Balance Sheet, Recurring Revenue, High Barriers to Entry, Novel or Disruptive Products or Technologies and large R&D spending. MSAM Balanced/Conservative Growth The composite seeks long term growth, income, and capital conservation, in combination. It utilizes both active and passive investment vehicles to create a balanced portfolio profile. Equities, whether individual stocks or index ETF's, purchased primarily for growth, normally make up around 60% of the portfolio and securities purchased for income make up the remainder. Portfolio construction methods are used to manage risk and maintain a consistent ongoing portfolio profile. MSAM also has longstanding relationships with partners like RBC Correspondent Services, a division of RBC Capital Markets, LLC, member NYSE/FINRA/SIPC, to provide additional tools such as international tax planning, professional trust services and alternative investment management services. MSAM does not act as custodian to accounts. C. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in the client's investment advisory agreement and maintained in the firm's recordkeeping system. Any restrictions placed on the account by the client will necessarily be a part of the client's discretionary and non- discretionary investment advisory agreement.
D. Wrap Fee Program MSAM acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and other administrative fees. This brochure describes MSAM’s wrap fee advisory service which is referred to as -the MSAM Investment Management Program. Fees paid under this program will be given to MSAM as a management fee. Please also see Item 5 and Item 12 of this brochure. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no- transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the agreed-upon MSAM Investment Management Program Fee with the amounts that would be charged by other advisors, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the MSAM Investment Management Program. E. Pension Consulting Services MSAM offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants.
Pension consulting services may involve the direct investment management of one or more 401(k) participant accounts, provide the selection and monitoring process for the various mutual funds offered to plan participants, develop and maintain an Investment Policy Statement for the plan, and/or provide group and individual employee education on investment options, asset allocation, and retirement planning.
F. Amounts of Assets under Management As of December 31, 2023, MSAM manages approximately $1,201,212,148 in assets under management of which $1,110,431,980 was in discretionary accounts and $90,780,168 was in non-discretionary accounts.