A. Description of Advisory Firm Wealthway Financial Advisors is a comprehensive financial planning and investment management firm organized in the Commonwealth of Virginia. The firm was formed in September, 1995 by Daniel C. Bunting as Bunting Capital Management. He retired December 31, 2015 and sold the firm to Kevin J. Zywna who is the sole owner. The name was changed from Bunting Capital Management to Wealthway Financial Advisors in March, 2018. B. Types of Advisory Services Investment Supervisory Services Wealthway Financial Advisors (“Wealthway”) offers financial advice and services tailored to the individual needs of clients. Each engagement typically begins with an understanding of the client’s particular situation and an articulation of goals and values or principles that will serve to guide the process and outcome of the engagement. Wealthway may consult with and coordinate the services of outside legal, tax and risk management advisors to provide these services. Wealthway also offers administrative services such as recordkeeping and financial reporting. Education and communication are an important component of all services. Comprehensive Financial Planning, which could include but may not be limited to any of the following: Summary of goals and objectives Current and projected net worth statements Current and projected tax analysis Cash flow analysis Review of investment portfolios Review and analysis of insurance related areas Estate planning projections Projected annual progress toward stated goals Conclusions and recommendations Hourly consultation: pertaining to specific requests and individual needs Investment Management Services: Wealthway will assist clients in determining the appropriate asset allocation, taking into consideration the client’s goals, investment objectives, risk tolerance, planning horizon, liquidity needs, tax situation and personal preferences. Wealthway prepares a written Investment Policy Statement which guides the management of the portfolio. Wealthway will evaluate the money managers and recommend an appropriate investment vehicle that could include mutual funds, exchange traded funds (ETFs), and separately managed accounts. Wealthway provides financial planning and investment management services that we anticipate will account for 95% of advisory billings. All clients enter into a written agreement with Wealthway. Either party may cancel the agreement at any time by providing written notice. Typically, the investment management services are offered on a discretionary basis. Investment clients usually authorize Wealthway to withdraw fees directly from the account. Clients may authorize Wealthway to take the fees from one or more accounts. Clients may also authorize Wealthway to move funds from one account to another account in a different financial institution, provided the account is in their name or for their benefit. Occasionally, Wealthway may manage investment advisory accounts that do not involve investment supervisory services. For example, a client may request that Wealthway track a security and buy or sell shares at the direction of the client. Or, a client may request that Wealthway keep records of a portfolio and report investment results without providing investment supervisory services. Wealthway expects these services to account for less than 1% of client billings. Fees for these services are negotiable and charged quarterly in advance. Wealthway does not issue periodicals about securities by subscription. Nor does Wealthway issue, separately from the services described above, any charts, graphs, formulas, or other devices which clients may use to evaluate securities. Wealthway does not provide a timing service or furnish advice about securities in any manner not described

above. Wealthway provides ongoing supervision of the assets, generally reviewing the accounts quarterly for rebalancing. When appropriate, given the size of the account and the tax situation, accounts will be reviewed periodically for tax management opportunities, such as tax loss selling and short-term capital gain avoidance. However, tax management plays a secondary role to investment performance. Wealthway reserves the right to make this determination. Wealthway does not generally advise on specific stock selection. However, Wealthway may advise on strategies for diversification of stock holdings, including strategies for managing risk and minimizing taxes. Wealthway may evaluate existing stock holdings and from time to time may give general opinions about specific securities. Wealthway will regularly furnish advice to clients on matters broadly classified as financial planning. These services may include retirement, tax, college, and estate planning, risk management analysis and philanthropic consulting. These services may be charged on a fee only basis and may be billed separately or furnished as part of an integrated package of services that includes investment supervisory services. Wealthway may also consult on special projects as requested. Wealthway anticipates the above services will represent approximately 5% of advisory billings. Wealthway does not offer or sell any type of products other than investment advice; however, its representatives may offer or sell insurance products through separate licenses as insurance agents. Individual representatives of Wealthway may be licensed agents for insurance companies (life/health). As a licensed agent, the representatives may receive commissions on insurance products sold. As a result of commissions received, a potential conflict of interest may exist with advisory client's interests. Client will be under no obligation, contractual or otherwise, to engage applicant as an insurance agent, though it is possible that client may choose to do so. Services Limited to Specific Types of Investments Wealthway may offer advice on the following: ❑ Exchange-listed equity securities ❑ Exchange Traded Funds (ETFs) ❑ Corporate debt securities (other than commercial paper) ❑ Certificates of deposit ❑ Municipal securities ❑ Investment company securities:
• mutual fund shares
• variable annuities
• variable life insurance ❑ United States government securities C. Client Tailored Serviced and Client Imposed Restrictions Wealthway generally offers the same suite of services to all its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s investment objectives (time horizon, tax treatment, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, goals, and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Wealthway from properly servicing the client account or if the restrictions would require Wealthway to deviate from its standard suite of services, Wealthway reserves the right to terminate the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Wealthway does not participate in any wrap fee programs. E. Amounts Under Management As of December 31, 2023, Wealthway managed approximately $190 million in assets for 173 client relationships. All client accounts are managed on a discretionary basis.