Firm Description Brass Tax Wealth Management, Inc. DBA Brass Tax Wealth Management (“BTWM”), Also doing business as Schulte Financial Group and Storen Financial Group was founded in 2014 and registered as an investment advisor in 2016. Nicholas N. Schulte is 50% owner and Leah Schulte is 50% owner. BTWM is a fee based financial planning and investment management firm. The firm’s president is also a licensed insurance agent who also sells traditional insurance products, such as long-term care, disability, and traditional life insurance for separate, yet typical commission. The firm’s president is also a registered representative of a broker dealer and sells securities products for a commission. BTWM does not act as a custodian of client assets. An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged directly by the client on an as-needed basis and may charge fees of their own. For example, tax preparation and to the extent your estate plan needs to be updated, the tax preparer and/or attorney will bill the client separately. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. Types of Advisory Services ASSET MANAGEMENT Supervised Assets BTWM offers discretionary and non-discretionary direct asset management services to advisory clients. BTWM will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Discretionary When the client provides BTWM discretionary authority the client will sign a limited trading authorization or equivalent. BTWM will have the authority to execute transactions in the account without seeking client approval on each transaction. Non-discretionary When the client elects to use BTWM on a non-discretionary basis, BTWM will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, BTWM will obtain prior client approval on each and every transaction before executing any transactions. When deemed appropriate for the client, BTWM offers discretionary management services through programs sponsored by SEI Investments Management Corp (SIMC). Under the MAS program, SIMC acts as a co-investment advisor to the Investor, along with BTWM, pursuant to a tri-party investment management agreement executed among SIMC, BTWM and each Investor investing assets into the Managed Account Solutions (the “Tri-party Agreement”). Under the Mutual Fund Models Program, SEI will make available its various Mutual Fund Models to BTWM who, in turn, may assist Clients in determining into which Mutual Fund Model to invest their assets. SOLICITOR ARRANGEMENTS BTWM solicits the services of third party money managers to manage client accounts. In such circumstances, BTWM receives solicitor fees from the third party money manager. BTWM acts as the liaison between the client and the third party money manager in return for an ongoing portion of the advisory fees charged by the third party money manager. BTWM helps the client complete the necessary paperwork of the third party money manager, provides ongoing services to the client, provides the third party money manager with any changes in client status as provided to BTWM by the client and review the quarterly statements provided by the third party money manager. BTWM will deliver the Form ADV Part 2, Privacy Notice and Solicitors Disclosure Statement of the third party money manager. Clients placed with third party money managers will be billed in accordance with the third party money manager’s fee schedule which will be disclosed in Item 5 of this brochure. ERISA PLAN SERVICES BTWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. BTWM may act as either a 3(21) or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. BTWM typically acts as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non- discretionary basis. As an investment advisor BTWM has a fiduciary duty to act in the best interest of the client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using BTWM can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: a. Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. BTWM acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). b. Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. c. Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. d. Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. e. Meet with Client on

a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are: a. Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands BTWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, BTWM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. BTWM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. b. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. BTWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between BTWM and Client. 3. BTWM has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to BTWM under this Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. 3(38) Investment Manager. BTWM can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. BTWM would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are: a. BTWM has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. b. Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. c. Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. d. Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are: a. Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands BTWM’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, BTWM is not providing fiduciary advice as defined by ERISA to the Plan participants. BTWM will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. b. Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. BTWM may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between BTWM and Client. 3. BTWM has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to BTWM under this Agreement. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, the client will compensate BTWM on an fixed fee basis described in detail under “Fees and Compensation” section of this brochure. Services include but are not limited to a thorough review of all applicable topics including Wills, Estate Plan/Trusts, Investments, Taxes, Qualified Plans and Insurance. If a conflict of interest exists between the interests of the investment advisor and the interests of the client, the client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through BTWM. Financial plans will be completed and delivered inside of six (6) months. SEMINARS AND WORKSHOPS BTWM holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. BTWM does not charge a fee for attendance to these seminars. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented in our client files. Investment strategies are created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written client consent. Wrap Fee Programs BTWM does not sponsor a wrap fee program. Client Assets under Management BTWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $674,300,000 $0 March, 2024