Description of Services and Fees We are a registered investment adviser primarily based in Wilmington, Delaware. We are organized as a corporation under the laws of the State of Delaware. We have been providing investment advisory services since 1996. The G. David Biddle Family Trust is the principal owner of Biddle Capital Management, Inc.; and, David Biddle is the President and Chief Compliance Officer. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Financial Planning Services
• Investment Management Services
• Asset Allocation Services
• Pension Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words “we”, “our” and “us” refer to BCM Wealth Management Inc., BCM Wealth Management, or BCM Retirement Solutions – the marketing names for each division. BCM Wealth Management provides services to clients other than employer sponsored retirement plans and BCM Retirement Solutions provides services exclusively to employer sponsored retirement plans. The words “you,” “your” and “client” refer to you as either a client or prospective client of our firm. As used in this Brochure, our “Associated Persons” refers to our firm’s officers, employees, and all individuals providing investment advice on behalf of our firm. 1. Advisory Services (Other than for Employer Sponsored Retirement Plans) Financial Planning Services We provide financial planning advice. If you purchase this service, you will receive a written financial plan designed to assist you in the management of life goals focused on wealth accumulation and preservation. Our Financial Planning Services may address topics such as spending and lifestyle, assets and liabilities, asset allocation, life insurance, gifting, asset protection, estate counseling, financial planning including retirement planning and investment planning, tax planning, college planning, wealth transfer, risk management, and any other client specific issues. As part of these services, you will have access to our client web portal to view your account information. Additionally, we offer clients reporting services on accounts, which are not managed by our firm where we will report the performance of those accounts on the periodic reports that we provide to you. Financial Plans, analyses, or reports are based on your financial situation at the time the plan/report is presented and based on the financial information disclosed by you to our firm. You are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. We cannot offer any guarantees or promises that your financial goals and objectives will be met. As your financial situation, goals, objectives, or needs change, you must notify our firm promptly. We charge a fixed fee or hourly fee for Financial Planning Services, which is negotiable, depending on the complexity of your holdings, financial situation and objectives, and the nature and extent of planning and analysis required. Our fees are negotiable and generally range between $575 and $2,000 for fixed fee arrangements and $250 per hour for hourly fee arrangements. An estimate of the total cost will be determined at the start of the advisory relationship. If the client chooses to proceed 50% of the fee up to $1,000 is due upon signing the financial planning agreement. Future updates or reviews to plan(s) are charged at 50% of the initial fee. For reporting services on non-managed accounts, we charge a negotiable annual fee not to exceed $400. Investment Management Services We offer discretionary investment management services whereby our investment advice is tailored to meet your needs and investment objectives. If you retain our firm for investment management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the “suitability information”) at the beginning of our advisory relationship. Based on the suitability information received, we will provide you with an investment policy statement, which will typically address investment goals, objectives, restraints, initial asset allocations, and other client-specific information. Upon your approval of the investment policy statement, we will customize an investment portfolio for you, and/or depending on the account size and the number of accounts, we may also invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you or select a model portfolio, we will monitor your portfolio’s performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and your financial circumstances. Depending on the relationship, it may be your responsibility to implement any advice rendered by our firm on 401k or other qualified plan accounts or other non-discretionary or non-managed accounts. For example, if the plan sponsor or custodian will not provide us direct access to make fund selections for the account, or software is not available to facilitate investment adviser trading, you would be responsible for the trading of plan assets if you choose to implement our advice. If you participate in our discretionary investment management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. As part of our investment management services, we may use one or more sub-advisers to manage all or a portion of your account on a discretionary basis. The sub-adviser(s) may use one or more of their model portfolios to manage your account. We will regularly monitor the performance of your accounts managed by sub-adviser(s) and may hire and fire any sub-adviser without your prior approval. Our ability to hire and fire sub-advisers on your behalf is based on you granting our firm discretionary authority. Any fees charged by a sub-advisor(s) are separate and apart from and in addition to the fees charged by our firm. All advisory fees paid by the client to BCM and/or any selected sub-advisors will be directly reflected on the custodial account statements sent to you by the custodian. SEI Platform The SEI platform shall include services provided to our firm and our clients by SEI Investments Management Corporation (“SIMC”), an investment advisor registered with the U.S. Securities and Exchange Commission (“SEC”), SEI Private Trust Company (“SPTC”), a limited purpose federally registered savings association supervised by the Office of the Comptroller of the Currency (“OCC”), and SEI Global Services, Inc. (“SGS”). Sub-Advisory Agreement with SEI Investments Management Corporation We have a Sub-Advisor Agreement with SEI Investments Management Corporation (“SIMC”), an SEC-registered investment advisor affiliated with SEI Private Trust Company (“SPTC”), a limited purpose federally registered savings association supervised by the Office of the Comptroller of the Currency, and their affiliates (collectively “SEI”). This agreement allows us to allocate client assets for participation in SIMC’s Sub-Advised Program. We are responsible to determine whether participation in the program is appropriate for our clients. Under the program, SIMC provides discretionary investment management services to us and makes available investment strategy models of SIMC or investment managers appointed by SIMC. These models seek to achieve particular investment goals and are not tailored to individual clients. Rather, we may allocate client assets to one or more of SIMC’s models which match the client’s objectives. SIMC then invests the allocated funds in accordance with the selected models as updated from time to time by SIMC or investment managers appointed by SIMC. In most cases, SIMC will implement those models and execute transactions; in others, the investment manager will do so. SIMC charges us an investment management fee for participation in the program. We have instructed SPTC to operationally facilitate the deduction of the investment management fees directly from our clients’ accounts held at SPTC where our clients have granted such permission in accordance with our agreement with the client. Other transaction costs are also charged to the client, including without limitation execution charges imposed by unaffiliated brokers/dealers or exchanges, wire transfer fees, auction fees, and transfer taxes. Clients with assets allocated to the program are subject to certain risks, including the investment manager implementing its model for its other accounts before implementing it for our clients. In that case, securities may be traded by our clients at prices different than those obtained by the manager’s other clients. The risk of price deviations is greater for large orders and thinly traded securities. Additionally, the performance of our client’s investments in a model may deviate from the performance of other accounts in such models or those managed by SIMC or the investment manager. Fund And ETF Models-Based Program We may choose to invest our clients’ assets into model portfolios of mutual funds and exchange-traded funds (“ETFs”) created by SIMC. This includes the SEI Asset Allocation Models (“SEI Asset Allocation Models”) which consist of allocations to SEI Funds and SEI ETFs and the Independent Funds Models Program (“Independent Funds Models Program”) which consists of model portfolios of allocations to certain families of third-party mutual funds or ETFs. Under the SEI Asset Allocation Models and the Independent Funds Models Program, SIMC provides non- discretionary services to our firm through the publication of investment models consisting of allocations to these different funds (i.e., SEI Funds, SEI ETFs, third-party funds, or third-party ETFs) allocated to the models. Specifically, SIMC: (1) makes available the models, developed and periodically updated by SIMC designed to achieve the model’s stated investment objective or goal based upon SIMC’s capital market assumptions and any other criteria that SIMC, in its sole discretion, determines is relevant; and (2) periodically publishes for consideration by firm revisions to a model’s percentage asset allocations among the underlying SEI Funds, SEI ETFs, third-party funds, or third-party ETFs, or adds, removes, or otherwise changes the individual SEI Funds, SEI ETFs, third-party funds, or third-party ETFs underlying an existing model. SIMC and its affiliates earn fees from the SEI Funds and SEI ETFs, which costs are indirectly borne by clients invested in these models. As a result, SIMC does not charge our firm or our clients participating in the program a direct fee for the use of the SEI Asset Allocation Models, although SEI Private Trust Company (“SPTC”), the custodian to the client and an affiliate of SIMC, will charge a custodial platform fee on client assets invested in SEI ETF products. In the Independent Funds Model Program, SIMC and its affiliates (including SPTC) charge direct fees that will be assessed to clients. Accounts held at SEI Private Trust Company (“SPTC”) are billed quarterly in advance based on the market value of your account on the last day of the previous quarter. As specified in our advisory agreement with our client, our fees will be automatically debited from the client’s investment account. All fees paid to us for advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders, or those charged to clients by product sponsors or by qualified custodians and sub- advisors. Qualified custodians, such as SPTC, also charge our clients fees for their services. Fees charged by SPTC differ and their fees may be higher or lower than at other qualified custodians. Advice Regarding Held Away Assets We also offer advice regarding accounts that are not held in the custody of the qualified custodian(s) recommended by our firm. The service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in the custody of the plan custodian(s). We regularly review and monitor the accounts and provide asset allocation advice depending on the options available to you in the plan. In most cases, we do not have trading authorization, so you would be responsible for implementing our advice on a non-discretionary basis if you choose to do so. Where available, you may grant us discretionary authority to place trades on a discretionary basis. Fees for these services cannot be charged to the employer plan; therefore, you may elect a taxable account held by your account custodian from which the fees can be directly deducted. Investment Management Fees - Our fee for investment management services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Portfolio Size Annualized Fee*** $0 - $499,999 1.60% $500,000 - $999,999 1.25% $1,000,000 - $1,999,999 1.00% $2,000,000 - $4,999,999 0.75% Over $5,000,000 0.50% ***We charge a minimum quarterly fee of $1,500, subject to waiver, at our sole discretion. Clients will never be charged more than 3% of assets under management. For client accounts that are managed, and for unmanaged accounts on which BCM provides reports, an annual account fee of up to $68 per account will be deducted in quarterly installments from the account(s) held at the qualified custodian. Management fees are billed and payable quarterly in advance based on the market value of your account on the last day of the previous quarter. If the investment advisory agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable investment management fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We treat cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there is no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. We have a

fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). For Financial Planning and Investment Management Services, we will deduct our fees directly from an account that you designate through the qualified custodian holding your funds and securities. We will deduct our advisory fees only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your account held by the qualified custodian.
• We or the sub-advisor send you an invoice showing the amount of the fee, the value of the assets on which the fee is based, and the specific manner in which the fee was calculated.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts dispersed from your account, including the amount of the advisory fee paid directly to our firm, the amount of funds, and each security in the account at the end of the period, and all transactions in the account during the period. For held-away assets, the Client must designate a taxable account that we manage for the client at the qualified custodian(s) recommended by our firm from which to deduct the advisory fee as agreed upon in the client agreement. Termination of Services Financial planning services terminate upon delivery of the financial plan. Otherwise, the Client may terminate a financial planning agreement or investment management agreement within five days of the date of acceptance without penalty. After the five-day period, either party may terminate the financial planning or investment management agreement upon written notice to our firm. For either service, you will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, will we return a prorated refund of those fees based on the number of days in the quarter for which you are a client. We encourage you to carefully review the account statements you receive from the qualified custodian(s). If you have questions regarding your account or if you did not receive a statement from your custodian, please contact David Biddle, President, at (888) 369-2261 or dave@bcmwealth.com. 2. Employer Sponsored Retirement Plan Services Pension Consulting Services The firm provides pension consulting services to employer sponsored retirement plans, both ERISA and non- ERISA. Such services may include (1) Reviewing the Plan design and consultations with the plan sponsor/fiduciary; (2) Creating an investment policy statement for the Plan including investment selection criteria; (3) Periodic monitoring of the Plan’s menu of investments, and on at least an annual basis, making recommendations to the Client to add or remove the selection of investments on the Plan’s menu; (4) Asset Allocation services for retirement plan participants as described below; (5) Providing the Client with a report on the Plan’s investment performance; (6) Providing enrollment and educational meetings to Plan Participants; and (7) Assistance with ERISA plan compliance. Our pension consulting services are tailored to the individual needs of clients whereby services will be provided according to the constraints and requirements of each individual governing Plan document. Clients may impose restrictions to limit our recommendations for investing in particular securities. Services to plans may be modified by a notice process as outlined in the advisory agreement. Plan Level Fees Services, fees, and payment arrangements will be negotiated on a case-by-case basis depending on the plan’s needs, the scope of agreed upon services, and the plan administrator’s processes. All services, fees, and payment arrangements will be clearly stated in the pension consulting agreement signed by the Client and us. The compensation arrangement for these services will be a negotiable flat fee or it will be based on a percentage of the plan assets. Additionally, we may impose a minimum quarterly fee of up to $2500 subject to negotiation or waiver at our discretion. Minimum quarterly fees in excess of participant-paid fees will be billed directly to the plan sponsor. Retirement Plan Participant Level Fees – Asset Allocation Services To enable plan participants to benefit from the asset allocation expertise of BCM Retirement Solutions, plans may engage us for an asset allocation service. The asset allocation strategies offered under this service are examples of ways to allocate balances in the plan account among the investments offered (that is, the plan’s designated investment alternatives or “core” funds). The asset allocations are not investments themselves, but instead, they are a service to help participants decide how to invest based on risk tolerance. The portfolios resulting from these asset allocations are not managed on an ongoing basis (other than the rebalancing and possible replacement of designated investment alternatives). The strategies are meant to be asset allocation choices for participants to consider and make, depending on the participant’s preferences. They are not recommendations to buy, sell, or trade any security and it is your decision whether to use the service. If a participant should decide to use these asset allocation services, they should select a relative risk level (conservative, moderate, or growth) that fits the participant’s personal profile and personal circumstances. The plan's fiduciaries or persons selected by the plan fiduciaries (BCM as a 3(38) investment manager for example) may decide to adjust the percentages (or funds) in a strategy (for example, to improve anticipated performance or to reduce risk), or may decide to add new investment categories (and to use core funds for those categories). Participants may elect to allocate the Plan's designated investment alternatives in a conservative, moderate, or growth strategy. The allocations or investment alternatives within the selected strategy may be updated from time-to-time without notice. However, if there is a fund or default investment alternative change, each participant will be notified and given a reasonable opportunity to decide whether to continue to use the portfolio's asset allocation strategies. If, after receiving the notice, a participant does not affirmatively change their investment allocations, the participant will be deemed to have agreed to the changes. Retirement Plan Participant Asset Allocation Service Fees Plan sponsors who choose the allocation service will pay an additional fee of 0.25% annually ($2.50 for each $1,000 of account value annually) billed at one-quarter of the fee (0.0625%), quarterly. Asset Allocation fees are negotiable at the plan level only, not individually for each participant. The underlying fees for the core fund will be the same as if you selected them individually. Fees affect returns and should be part of your investment decision process. Fees are billed on a quarterly basis against the participant’s balance. Fees will be paid quarterly in advance based on the value of the participant’s assets on the last day of the previous quarter. The fee is prorated for any partial quarter. Project Based Fees In the management and operations of an employer sponsored retirement plan, it is often necessary to complete an analysis or project and additional fees will apply as listed below. Due to the specific circumstances of each plan and project, the fees may be adjusted and are negotiable.
• Request For Proposals – The greater of .10% of plan assets with a minimum fee of $1,500
• Benchmarking – From $300 to $5,500
• Plan or Vendor Implementation Fees range from $1,500 to $9,000 based on the individual plan circumstances A deposit of 50% for the project fee is due upon the beginning of the project and the balance is due upon delivery to the plan sponsor. For the co-ordination services of a plan conversion, a fee of $1200 to $5,000 may be charged which is subject to waver or reductions based on the complexity of the conversion. Any conversion fee will be disclosed in the advisory agreement and are negotiable. We also offer additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Our advisory fees for these customized services will be negotiated with the plan sponsor or named fiduciary on a case-by-case basis. Upon instruction from plan trustees, pension consulting fees may be directly deducted from the plan’s account through the qualified custodian holding the plan’s funds and securities. Clients also have the option of paying pension consulting fees directly to our firm. We will deduct our fees only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your account held by the qualified custodian.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts dispersed from your account including the amount of the advisory fee paid directly to our firm. We encourage plan trustees to review service provider payments made through a qualified custodian. If you find any inconsistent information between fees and our advisory agreement, please call our main office number located on the cover page of this brochure. The initial fee will be the amount, prorated for the number of days remaining in the initial fee period from the effective date of the pension consulting agreement, based upon the market value of the Plan assets on the first business day of the initial fee period and will be due on the first business day of the fee period. Thereafter, the fee will be based upon the market value of the Plan assets on the last business day of the previous fee period (without adjustment for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distributions of assets) and will be due the following business day. Either party may terminate the pension consulting agreement by providing 30 days prior written notice to the other. If this Agreement is terminated prior to the end of a fee period, the fee will be prorated for the number of days in the fee period prior to the effective date of termination and will be due to BCM or any unearned fees will be returned to the client. Our Fiduciary services to the accounts described above may be regulated under the Employee Retirement Income Securities Act (“ERISA”). Plan participants must make the ultimate decision as to what investment option to select for their individual accounts. The Plan Sponsor/fiduciary is free to seek independent advice about the appropriateness of any recommended services for the plan. Employee Retirement Readiness Services An employer may engage us to provide retirement readiness services to plan participants (employees). Where so engaged, we will gather relevant information regarding the employee’s resources to the extent it is made readily available to us, including, but not limited to, the employee’s retirement plan benefits, other fixed income resources, and any other assets that are designated for retirement savings. We will then develop an estimated target retirement income for the employee, which will serve as the basis for the retirement readiness analysis. We will also review the employee’s current retirement savings deposits made to retirement accounts and other employee accounts to the extent such information is made readily available. Then we will create a report, no more than annually, that analyzes the employee’s assets and retirement savings deposits compared to the employee’s projected income needs during retirement based upon the information gathered as described above. The report will highlight shortage gaps and recommend general options to help close any gap. The report will be based only upon the information which is made readily available to us as of the date such information is provided to us. If requested in writing by an employee, we will prepare an updated report based on the updated information provided by the employee to us. Additionally, we will produce the initial report at the initial meeting with the employee. A second meeting is permissible if the employee requires further explanation of the report or implementation options; however, each employee is limited to two meetings in connection with each report. A copy of the report developed for each employee at the employee meeting will be mailed electronically to the employee for retention by the employee for the development of a specific implementation plan. The employer pays a non-refundable annual service fee of $1,400, due immediately upon entering into the agreement for services and annually thereafter until termination of the agreement by either party. Participant fees range between 0.05% and 0.40%, negotiated with the employer and payable quarterly. The fee will be based on the market value of the assets as reported by the plan custodian or record-keeper. The employer may choose to have our fees deducted directly from the plan assets by the plan custodian in advance or arrears depending on the custodian’s and/or record-keeper’s policies. Alternatively, the employer may choose to be billed directly for the plan participant fees, in which case the fee would be payable within 30 calendar days of the billing invoice date. All such terms will be clearly set forth in the agreement signed between us and the employer. Termination of Services Either party may terminate the service agreement upon 30 days’ prior written notice to the other party. The terminating party shall also provide thirty (30) days prior written notice of such termination to employees. The initial fee will be the amount, prorated for the number of days remaining in the initial fee period from the effective date of the service agreement, based upon the market value of the plan assets on the first business day of the initial fee period. If the agreement is terminated prior to the end of a fee period, the fee will be prorated for the number of days in the fee period prior to the effective date of termination. Any prepaid, unearned fees would be promptly returned by us. Types of Investments We do not primarily recommend one type of security over another. We recommend various types of securities. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Assets Under Management As of December 31, 2023, we provided continuous management services for approximately $294,492,808 in client assets on a discretionary basis; and, we had no client assets under management on a non-discretionary basis.