Ownership/History Harlow Wealth Management, Inc., formerly known as “NW Tax & Wealth Advisory Group, Inc.” is an investment adviser registered with the Securities and Exchange Commission. Registration as an investment adviser does not imply a certain level of skill or training. Danny J. Harlow founded NW Tax & Wealth Advisory Group, Inc. in 2005. In July 2017, the firm’s name was changed to Harlow Wealth Management, Inc. (“Harlow" or the “Firm”). Together, Danny, Esther, and Christopher Harlow own 100% of the Firm. Harlow offers investment advisory and financial planning services, as well as the sale of insurance to its clients. Advisory Services
• Investment Management: Harlow offers ongoing investment management based on a client’s individual needs and circumstances. Harlow’s investment management process includes an initial assessment, recommendations, implementation, monitoring, and ongoing management. Harlow also meets with clients periodically to proactively identify and plan for any changes that could influence their overall financial situation. Harlow will tailor its services to the client’s stated goals, needs and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Any specific requirements will be detailed in writing before the engagement begins. Harlow reserves the right to decline an account if the restriction(s) imposed unduly restrict the Firm’s ability to manage the account. Harlow is a registered investment adviser and is required to meet certain fiduciary standards when providing investment advice. As such, Harlow is required to act in a client’s best interest and not put the Firm or its Financial Advisor’s interest ahead of a client’s, even though our compensation creates some conflicts with your interests in that the more you have us manage, the more we can earn. Third Party Money Managers Harlow typically recommends its clients utilize the services of one or more unaffiliated investment managers (“Sub-Advisors”) who offer advisory services through AEWM’s Wrap Fee program. The Sub-Advisors invest client assets in portfolios modeled to be consistent with their investment objectives and financial needs. Clients are not obligated to accept Harlow’s recommendation to use a particular Sub-Advisor(s). Prior to using any Sub-Advisor, Harlow will review the Sub-Advisor’s backgrounds and consider factors, such as fees, reputation, performance, financial strength, management, price, reporting capabilities. A Financial Advisor will then present the client with one or more recommendations based on their specific financial situation, goals, needs, and investment objectives. Each recommended Sub-Advisor is a registered investment adviser1 who manages your investments in one or more model portfolios. Where applicable, clients will be provided with the Sub-Advisor’s written disclosure brochure describing its services, fees, and other important information, by the Sub-Advisor on an annual basis. In addition, Harlow will provide clients with its written disclosure which describes the Firm’s relationship with Sub-Advisors used by the Firm as well as information regarding the compensation the Firm receives from the Sub-Advisor. Generally, the Sub-Advisor is responsible for portfolio management, portfolio design, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations, but Harlow may supplement client accounts with other holdings. Harlow’s agreements with Sub- Advisors usually require us to maintain a relationship with each client to ensure that information about the client’s specific goals, financial situation and risk preference remain current, to assist the client in determining appropriate allocation models, to review account activity periodically, to meet with clients annually, and to respond to client inquiries. If a client implements their plan’s investment management recommendations or insurance recommendations through Harlow, the Firm may receive other compensation and benefits related to implementing these recommendations. Additional compensation may present a conflict of interest in that there is an incentive to make a recommendation based on the compensation and/or benefits received, rather than on your needs. Harlow addresses this conflict through disclosures, such as this Disclosure Brochure or 1 We will not refer a client to a Sub-Advisor unless the Sub-Advisor is registered, notice-filed, or exempt from registration as an investment adviser in the client’s state of residence. other materials discussing the products and/or services offered. For additional information, see “Advisory Business” above and “Other Financial Industry Activities and Affiliations” below Harlow has entered into a sub-advisory relationship with AE Wealth Management, LLC (“AEWM”) to provide Sub-Advisory investment management services to our clients. This arrangement allows us to access model portfolios, model managers,

strategists, third party money managers, trading services and investments through AEWM’s managed account program. Additional Sub-Advisory Services Harlow has engaged the services of AE Wealth Management LLC (“AEWM”) as a Sub-Advisor to assist in the provision of investment management services for the client. Harlow has entered into a sub-advisory relationship with AE Wealth Management, LLC (“AEWM”) to provide Sub- Advisory investment management services to our clients. This arrangement allows us to access model portfolios, model managers, strategists, third party money managers, trading services and investments through AEWM’s managed account program. When you sign an investment management agreement, AEWM will provide you with a copy of their disclosure brochure which contains a detailed description of AEWM’s services. Harlow provides clients and prospects with a variety of educational resources such as articles, e- newsletters, and e-seminars to anyone visiting its web site (www.harlowwealth.com). Content is intended to be timely, and to help readers understand their investment needs. Harlow is not compensated for this service. From time to time, Harlow Wealth Management, Inc. holds events designed to provide clients and prospective clients with information about investing, taxes, and other applicable topics. There is no charge or obligation to those attending the events. IRA Rollovers As part of our advisory services, Harlow may provide recommendations and advice concerning your employer retirement plan or other qualified retirement account. 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 to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). When Harlow provides rollover advice to a client or prospect regarding a retirement plan account or individual retirement account, the Firm 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. If Harlow recommends that a client roll over their retirement plan assets or transfer an IRA into an account to be managed by Harlow, the Firm will earn an advisory fee on the rolled over assets, that recommendation creates a conflict of interest. Accordingly, Harlow operates under a special rule that requires the Firm to act in the client or prospect’s best interest and not put its own interest ahead of the client’s or prospects. No client is under any obligation to roll over retirement plan assets or transfer IRA assets to an account managed by Harlow. Harlow’s Chief Compliance Officer is available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such rollover recommendation. Wrap Fee Programs Although Harlow does not sponsor a wrap fee program, the Firm does utilize AEWM’s wrap fee program and may delegate a client’s account to a Sub-Advisor participating in that program. Further information pertaining to AEWM’s wrap fee program is available in AEWM’s Form ADV Part 2A which is provided to clients who are utilizing investments through this program.
• Financial Planning: Harlow’s financial planning services typically involve providing targeted services, such as analysis of taxes, investments, retirement distributions, retirement, and estate planning. A Financial Advisor will meet with a client to discuss their current financial situation, gathering information about the client’s investment understanding, risk tolerance, income, tax bracket, liquidity, time horizons, etc. Harlow will then analyze the client’ current portfolio, which may include an analysis of the client’s investment portfolio and estimating a historic rate of return. Harlow will follow up by giving clients a review of their findings. Throughout the process, Financial Advisors make certain assumptions regarding interest and inflation rates and the use of past trends and performance of the market and economy. It is important to remind our clients that past performance is in no way an indication of future performance, and that Harlow does not offer any guarantees or promises that a client’s financial goals and objectives will be met. Harlow can provide a client with a comprehensive financial plan or a plan that is focused on specific areas. Either way, Harlow designs the plan to be consistent with each client’s stated financial goals and objectives. Clients Assets Managed As of December 31, 2023, Harlow managed $315,949,895 of discretionary client assets.