A. Firm Information Gold Medal Waters, Inc. (“GMW” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission. GMW is organized as a corporation under the laws of Colorado. GMW was founded in 2004 and is owned and operated by Matthew J. Kelley, CFP® (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by GMW. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. GMW’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. B. Advisory Services Offered GMW offers investment advisory services to individuals, high net worth individuals, retirement plans, charitable organizations and corporations or other businesses (each referred to as a “Client”). Wealth Management Services GMW may provide Clients with wealth management services, which generally include a broad range of comprehensive financial planning and consulting services in connection with discretionary and non-discretionary management of investment portfolios pursuant to the terms of the agreement. Services included in a wealth management engagement are described below. Investment Management Services - GMW provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non- discretionary investment management and related advisory services. GMW works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. GMW will then construct a portfolio consisting of mutual funds offered primarily by Dimensional Fund Advisors LP (“DFA”), or utilize the services of an unaffiliated investment manager to achieve the Client’s investment goals. In certain instances, the Advisor may also utilize mutual funds from the Vanguard Group, Inc. or any other family of mutual funds to help the Client meet their needs and objectives. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. GMW’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. GMW will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. DFA funds are exclusively made available through a registered investment advisor, therefore a Client may not invest in these funds in their independent capacity. GMW evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. GMW may recommend, on occasion, redistributing investment allocations to diversify the portfolio. The Advisor may recommend employing cash positions as a possible hedge against market movement. GMW may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 5 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will GMW accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information,

please see Item 12 – Brokerage Practices. Use of Independent Managers - GMW will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services - Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. Clients may also engage the Advisor for ongoing financial planning as a separate service, pursuant to a written agreement. This planning may encompass one or more areas of need, including but not limited to, asset allocation planning, risk analysis, education planning, cash flow planning, expense planning, emergency fund planning, student loan planning, disability insurance planning, retirement fund planning, home purchase planning, life insurance planning, net worth analysis, estate planning, retirement income planning, risk analysis, tax planning, investment planning, business planning and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and charitable giving programs. GMW may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Page 6 Retirement Plan Advisory Services GMW provides advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● Plan Participant Enrollment and Education Tracking ● Investment Due Diligence and Oversight ● Ongoing Investment Recommendation and Assistance ● Vendor Analysis ● Investment Policy Statement (“IPS”) Design and Monitoring ● Performance Reporting ● ERISA 404(c) Assistance ● Benchmarking Services These services may be provided by GMW in their capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of GMW’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging GMW to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – GMW, in connection with the Client, will develop an investment strategy for the Client that is targeted to achieve the Client’s objectives. ● Asset Allocation – GMW will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – GMW will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – GMW will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs GMW does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by GMW. E. Assets Under Management As of March 4, 2024, GMW manages $193,623,148 in Client assets, $185,722,195 of which are managed on a discretionary basis and $7,900,953 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.