A. Description of the Advisory Firm CWM Partners (hereinafter “CWM”) is a Limited Liability Company organized in the State of New York. The firm was formed in July 2013, and the principal owners are Michael Warszawski and Cristina Markman. CWM Partners LLC has voluntarily subscribed to the “Real Fiduciary™ Practices” published by the Institute for the Fiduciary Standard. Real Fiduciary™ Practices offer a simple code of conduct and outline a commitment to clients of subscribing financial advisors. They seek to clearly articulate what a client can expect to receive from a subscribing financial advisor. These Real Fiduciary™ Practices do not replace our regulatory compliance obligations or duties to clients under relevant laws, rules, or regulations. The Institute for the Fiduciary Standard’s role is limited to publishing the practices as well as maintaining a corresponding register of subscribing financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our website or at the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices can be found at https://thefiduciaryinstitute.org/wp-content/uploads/2019/03/Real- Fiduciary-Practices-2019-02-22.pdf" B. Types of Advisory Services CWM offers the following services to advisory clients: Portfolio Management Services CWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CWM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring CWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CWM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CWM’s economic, investment or other financial

interests. To meet its fiduciary obligations, CWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, CWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Other Advisers CWM may direct clients to third-party investment advisers. CWM may recommend wrap fee programs when appropriate based on the client's investment objectives. Before selecting other advisers for clients, CWM will always ensure those other advisers are properly licensed or registered as investment advisers. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Services Limited to Specific Types of Investments CWM generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), non-U.S. securities, business development companies, private placements, and hedge funds. In some situations, where appropriate, CWM may use other securities to help diversify a portfolio. C. Client Tailored Services and Client Imposed Restrictions CWM offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CWM from properly servicing the client account, or if the restrictions would require CWM to deviate from its standard suite of services, CWM reserves the right to end 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. CWM does not participate in any wrap fee programs. E. Assets Under Management Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 4,442,735 $ 57,945,813 December 2023