A. Firm Description HWM is an SEC registered investment adviser based in Phoenix, Arizona. It is organized as a limited liability company since May 2011 under the laws of the State of Arizona. HWM is owned by Michael Frost, Ralph Nelson, David Maxey, and Jared Williams. David Maxey is the Chief Compliance Officer (CCO). HWM is a member of a family of companies that are separately owned by a common group of individuals. Ownership percentages for each individual vary by entity. The other affiliated, legal entities include the following:
• Heritage Family Offices, LLP
• HFO Certified Public Accountants, LLP
• Heritage Insurance Advisors, LLC
• Frost and Associates, LLC
• HFO Law, LLP
• HFO Payroll, LLC
• HFO Management, Inc. B. Description of Advisory Services The advisory services offered by HWM and its investment advisor representatives (“advisors”) are as follows: Wealth Management Services HWM offers wealth management services, which involves HWM providing the client with continuous and ongoing supervision over their specified accounts. The client must appoint our firm as their investment adviser of record on the specified accounts (collectively, the “Account”). The Account is held by qualified custodian(s) under the client’s name. The qualified custodians maintain physical custody of all funds and securities of the Account, and the client retains all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The client’s account is managed by HWM based on their financial situation, investment objectives and risk tolerance. We actively monitor our clients’ accounts and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the account. Wealth Management Services include the following:
• Portfolio Management by HWM
• Portfolio Management by Sub-Advisors Portfolio Management by HWM A client’s investment account may be allocated partially or completely to any one or more of the following channels for portfolio management:
• ETF Model Portfolios for active discretionary management (“Models”)
• Alternative Investments ETF Models HWM will assess whether the model selection is suitable for the client. On an ongoing basis, the advisor will monitor the client’s allocation among the selected Models to ensure that rebalancing occurs and the Model is consistent with the client’s stated investment objectives. HWM will engage in discretionary trading for the assets allocated to the Models. Also, HWM will initiate the steps necessary, including the receipt of investment funds, to open the client’s Account and to execute any changes to the allocation based on the client’s financial circumstances. Alternative Investments HWM may recommend a portion of a client’s funds be allocated to non-publicly traded securities, such as Private Real Estate Investment Trusts (“REIT”) depending on the client’s risk tolerance, investible asset amounts, liquidity needs, time horizon, and investment sophistication. The advisor provides the due diligence in the selection, ongoing review, and account maintenance for these investments. No additional monthly advisory fee is charged by HWM for these positions. Both accredited and non- accredited clients may be permitted to invest in the Alternative Investments. Portfolio Management by Sub-Advisors HWM may provide recommendations to the client to utilize one or more specific Sub-Advisor to manage the account or a portion of the assets of the account. When a Sub-Advisor is selected, the Sub-Advisor will have discretionary authority on our client’s account to place trades and make changes to the account or the portion of the client’s account the Sub-Advisor is authorized to manage. HWM will conduct due diligence of any recommended Sub-Advisor and monitor the performance of Sub-Advisor with respect to the Sub-Advisor’s management of the designated assets of account relative to appropriate peers and/or benchmarks. HWM will be available to answer questions client may have regarding any portion of client’s account managed by a Sub-Advisor and will act as the communication conduit between client and the Sub- Advisor. The recommendation of Sub-Advisors, or other products and funds, will be done on a discretionary basis with the specific terms outlined in the client’s agreement with HWM. When a client authorizes HWM to have the ability to select Sub-Advisors or other products and funds on a discretionary basis, HWM will have the authority to select and terminate Sub- Advisors, products or funds without the client’s specific approval. A complete description of the Sub-Advisor’s services, practices and fees will be disclosed in the Sub- Advisor’s Form ADV Part 2A that will be provided to client. Financial Planning Services HWM offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We

provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios Review, Asset Allocation, and Real Estate Planning. When providing financial planning services, the role of the client’s investment adviser representative is to find ways to help our clients understand their overall financial situation and help them set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by the client and HWM. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. The client should be aware that there are important issues that may not be taken into consideration when the client’s investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by HWM do not include specific recommendations of individual securities. Our financial planning services do not involve implementing any transaction on the client’s behalf or the active and ongoing monitoring or management of their investments or accounts. The client has the sole responsibility for determining whether to implement our financial planning recommendations. To the extent that the client would like to implement any of our investment recommendations through HWM or retain HWM to actively monitor and manage their investments, they must execute a separate written agreement with HWM for our wealth management services. HWM offers ongoing financial planning services which will include HWM providing one annual written financial plan update (after delivery of an initial written financial plan by HWM) in addition to periodic financial plan reviews. Periodic financial plan reviews will occur at least semi-annually and upon Client request, and may address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios Review, Asset Allocation and Real Estate Planning. Results of the periodic financial plan review will be communicated to client via in person meeting, telephone consultation, or written report. Client recognizes that Advisor’s ongoing financial planning services are dependent upon Client timely providing Advisor with current information pertaining to Client’s financial situation, investment objectives and risk tolerance. Client will timely notify Advisor of any changes to Client’s financial situation or investment objectives. Upon beginning a periodic financial plan review, Advisor will contact Client to determine whether Client’s financial situation, investment objectives or risk tolerance have changed, or if Client has any specific areas of concern relating to Client’s financial plan. Client understands that ongoing financial planning services do not include wealth management services, implementation of Advisor’s recommendations, or any other similar services. For accounts not held by a custodian such as fixed annuities, 401ks, and other similar products, the advisor may recommend allocations and/or provide consolidated reporting. If subject to the Wealth Management Services engagement and fee, these outside accounts must be specified in the client’s agreement with HWM. C. Tailored Relationships At HWM, we offer the same suite of services to all our clients. The management services and recommendations offered by HWM are based on the individual needs of our clients and the suitability of products and services. Specific client financial plans and their implementation are dependent upon the information we gather from clients, which illustrate each client’s current situation (income, objectives, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. HWM uses a variety of tools, including a financial plan, to analyze documentation provided by the Client and to determine the strategy best suited for the Client. D. Wrap Fee Programs HWM does not participate in and is not a sponsor of wrap fee programs. Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions, and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all-inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. E. Assets Under Management When calculating regulatory assets under management, an investment adviser must include the value of any advisory account over which it exercises continuous and regular advisory or management services. As of December 31, 2022, the Firm managed $545,050,946 assets on a discretionary basis and $0 on a non-discretionary basis. -Continued Next Page-