A. Brown Wealth Management (the “Firm”) is a limited liability company formed on January 15, 2003 in the State of Minnesota. The Firm became registered as an investment adviser on August 15, 2002 with the Minnesota Department of Commerce and has been registered with the U.S. Securities and Exchange Commission since March 26, 2018. The Firm is owned entirely by Timothy B. Brown, who is also the Firm’s Chief Compliance Officer. B. As discussed below, the Firm offers to its clients (generally, individuals, high net worth individuals, pension and profit-sharing plans) investment advisory services, financial planning and related consulting services, and retirement plan consulting services. INVESTMENT ADVISORY SERVICES The Firm provides fee-only financial planning and investment counseling services to individuals, corporations, small business, 401(k), pensions and profit-sharing plans, estates and trusts. The firm makes available financial planning to clients. This includes the five areas of financial planning which are Protection, Estate Planning, Income Tax Planning, Retirement income Planning and Investment Planning. The firm offers discretionary investment advisory services on advisory accounts. This service is generally available for clients who have $750,000 or more in investable assets. For most clients, the Firm’s compensation derives from investment advisory fees on assets that are managed by the Firm, on behalf of the client. Clients pay the Firm a management fee, also called an investment advisory fee, calculated as a percentage of the market value of the account. HERITAGE DESIGN WEALTH MANAGEMENT The Heritage Design Wealth Management (HDWM) service is designed to help families survive and thrive for generations. HDWM is intended to educate and prepare children and grandchildren to grow, manage and protect the wealth they stand to inherit. HDWM is intended to assist high net worth families with traditional wealth management with a focus on education, estate planning, asset transfers, wealth preservation, and maintaining families for generations. The fee for this service is separately negotiated and dependent on the level of assets, the number of family members, and complexity. RETIREMENT PLAN CONSULTING SERVICES The Firm also offers non-discretionary retirement plan consulting services, pursuant to which it assists sponsors of self-directed retirement plans and defined benefit plans with the selection and/or monitoring of investment alternatives from which plan participants may choose in self-directing the investments for their individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, the Firm may also provide participant education designed to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions of the engagement between the Firm and the plan sponsor shall be set forth in a Retirement Plan Consulting Agreement. MISCELLANEOUS Non-Discretionary Service Limitations. Clients that engage the Firm on a non- discretionary basis must be willing to accept that the Firm cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. For example, if securities markets experience significant volatility, and the client is unavailable to provide to consent to the Firm’s recommended transactions, the Firm will be unable to effect such transactions as it would for its discretionary clients. Limitations of Non-Investment Consulting/Implementation Services. To the extent requested by the client, the Firm may provide consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. The Firm does not serve as a law firm, accounting firm, or insurance agency, and no portion of the Firm’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, the Firm does not prepare estate planning documents, tax returns, or sell insurance products. To the extent requested by a client, the Firm may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Firm. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Client Obligations. In performing its services, the Firm shall

not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Each client is advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, and if necessary, revising its previous recommendations. Account Aggregators. The Firm may provide its clients with access to online platforms that allow a client to view their complete asset allocation, including those assets that the Firm does not manage (the “Excluded Assets”). The Firm does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, the Firm shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and their other advisor(s) that maintain management authority for the Excluded Assets, and not Firm, shall be exclusively responsible for such investment performance. The client may choose to engage the Firm to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between the Firm and the client. Finally, the Firm shall not be held responsible for any adverse results a client may experience if the client engages in other functions on any online platform without the Firm’ assistance or oversight. Trade Error Policy. The Firm shall reimburse accounts for losses resulting from Firm’s trade errors. Retirement Plan Rollovers. 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). If the Firm recommends that a client roll over their retirement plan assets into an account to be managed by the Firm, such a recommendation creates a conflict of interest if the Firm will earn a new (or increase its current) advisory fee as a result of the rollover. To the extent that the Firm recommends that clients roll over assets from their retirement plan to an IRA managed by the Firm, then the Firm represents that it and its investment adviser representatives are fiduciaries under the Employee Retirement Income Security Act of 1974 (“ERISA”), or the Internal Revenue Code, or both. No client is under any obligation to roll over retirement plan assets to an account managed by the Firm. Use of Mutual Funds. While the Firm may recommend allocating investment assets to mutual funds that are not available directly to the public, the Firm may also recommend that clients allocate investment assets to publicly-available mutual funds that the client could obtain without engaging Firm as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds without engaging Firm as an investment adviser, the client or prospective client would not receive the benefit of Firm’s initial and ongoing investment advisory services. Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are generally only available through registered investment advisers. Firm may allocate client investment assets to DFA mutual funds. Therefore, upon the termination of Firm’s services to a client, restrictions regarding transferability and/or additional purchases of, or reallocation among DFA funds will apply. Clients that determine to sell such mutual funds could experience tax consequences. Firm is not responsible for any tax consequences incurred by clients because of their decision to sell mutual funds held in their account following the termination of the Firm’s services. C. The Firm shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, Firm shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on Firm’s services. D. The Firm does not participate in a wrap fee program. E. As of January 25, 2024, the Firm had $173,270,000 in assets under management, of which $151,850,000 was managed on a discretionary basis and $21,420,000 was managed on a non-discretionary basis.