A. Description of the Advisory Firm Tumwater Wealth Management, LLC (hereinafter “TWM”) is a Limited Liability Company organized in the State of Idaho. The firm was formed in November 2018, and the principal owners are Benjamin C Warren and Kirsten A Warren. B. Types of Advisory Services Portfolio Management Services TWM provides ongoing portfolio management based on each client’s individual goals, time horizon, and risk tolerance. TWM works with each client to determine the most appropriate portfolio for their situation (income, net worth, tax levels, risk tolerance, etc.). Portfolio management includes the following:
• Determining the appropriate mix of stocks, bonds, and cash equivalents
• Determining the appropriate mix of US vs. international vs. emerging markets
• Determining the appropriate mix of large, mid-size, and small Companies
• Determining the appropriate mix of value stocks vs. growth stocks
• Determining the specific stocks, bonds, cash equivalents, mutual funds, and exchange traded funds (ETFs) to provide the desired investment exposures.
• Monitoring each portfolio’s adherence to the determined target allocations
• Rebalancing when appropriate
• Monitoring and minimizing portfolio costs
• Monitoring the ongoing appropriateness of each specific investment in the portfolio
• Etc. TWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TWM takes on discretionary authority from clients in order to manage the portfolio (select securities, execute transactions, etc.) in an efficient manner without requiring permission from the client prior to each transaction. TWM seeks to make investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of TWM’s economic, investment or other financial interests. To meet its fiduciary obligations, TWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TWM’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 TWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Comprehensive Financial Planning Financial plans and financial planning may include, but are not limited to: retirement planning, behavioral investment coaching, education planning and analysis, diversification and asset allocation analysis, risk management planning including life insurance analysis, disability insurance analysis, and long term care insurance analysis, liability planning and analysis including existing mortgage and financing analysis and benchmarking, real estate investment analysis including both short term and long term rental options, budgeting coaching, charitable and personal gifting

guidance and analysis, basic estate planning, basic tax planning, debt reduction strategies and analysis, etc. Pension Consulting Services TWM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve plan objectives
• monitoring performance of money managers and investment options and making recommendations for changes when appropriate
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension investment policy statement
• providing plan benchmarking
• providing employee investment education and advice
• providing regular fiduciary plan and investment reviews These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments TWM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors) and treasury inflation protected/inflation linked bonds. TWM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions TWM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by TWM on behalf of the client. TWM develops customized investment portfolios for each client based on a comprehensive financial planning process including goals, time horizons, return requirements, investment experience, balance sheet analysis, income sources analysis, safe distribution rates, etc. TWM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 TWM from properly servicing the client account, or if the restrictions would require TWM to deviate from its standard suite of services, TWM 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, and certain other administrative fees. TWM does not participate in wrap fee programs. E. Assets Under Management TWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 268,002,002.00 $ 37,306,481.00 December 2023