LWP offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to LWP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with LWP setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement"). LWP is owned by Andrew Ross Ramsey and Ralph Corley Watson III. As of February 10, 2023, LWP had $ 561,198,312 assets under management, $481,729,513 of which was managed on a discretionary basis and $79,468,799 of which was managed on a non-discretionary basis. While this brochure generally describes the business of LWP, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on LWP's behalf and are subject to the Firm's supervision or control. Financial Planning and Consulting Services LWP offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Education Planning While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, LWP is not required to verify any information received from the client or the client's other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. LWP recommends certain clients engage the Firm for additional related services, its Supervised Persons in their capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage LWP or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by LWP under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising LWP's recommendations and/or services. Investment and Wealth Management Services LWP provides clients with wealth management services, which include a broad range of financial planning and consulting services as well as discretionary management of investment portfolios. LWP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. LWP consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify LWP if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if LWP determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts. The Firm does not serve as the sponsor or manager of a wrap fee program (i.e., an arrangement where certain brokerage commissions and transaction costs are absorbed by the Firm). Nonetheless, the Firm principally provides investment management services through accounts available through wrap fee programs offered and administered by Raymond James & Associates ("RJA"), member NYSE/SIPC, or another of its affiliates (collectively, along with Raymond James Financial Services, Inc. ("Raymond James")) which are described below in more detail. The wrap fees for participation in such programs include many transaction costs associated with execution of securities transactions. For more information relating to the wrap programs offered by Raymond James, please refer to RJA's wrap fee disclosure brochure (the "Wrap Brochure"), which can be found at www.adviserinfo.sec.gov. The Raymond James programs require clients to sign separate agreements depending on the program. LWP will be named as the investment adviser (either directly or through its investment adviser representatives) in such agreements. The Firm expects to provide all or substantially all of its investment management services through the Raymond James Ambassador Program. The Ambassador Program utilizes a wrap fee advisory account, offered and administered by RJA, in which the client is provided with ongoing investment advice and monitoring of securities holdings by the Firm. The Firm provides discretionary or non-discretionary management of the Ambassador Account according to the client's

objectives. The Ambassador Account offers Clients the ability to pay an Asset-based Fee in lieu of a commission for each investment. The Firm invests client assets among various mutual funds, ETFs, individual debt and equity securities, options, and independent investment managers ("Independent Managers") in accordance with their stated investment objectives. Where appropriate, LWP also recommends that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can also engage LWP to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, LWP recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider. Use of Independent Managers As mentioned above, LWP selects certain Independent Managers to actively manage a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. LWP evaluates a variety of information about Independent Managers, which includes the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance and risk results in relation to its clients' individual portfolio allocations and risk exposure. LWP also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. LWP continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. LWP seeks to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. The Firm expects to engage the Independent Managers through one or more of Raymond James's programs. The Independent Managers can be affiliated with Raymond James which results in a conflict of interest for Raymond James to approve and favor these Independent Managers in their programs. The Firm does not, however, receive any additional compensation if a Raymond James affiliate is selected as the Independent Managers. Clients will sign a separate agreement with Raymond James that names LWP (either directly or through an investment adviser representative of LWP) as the investment adviser. Clients should review the Wrap Brochure for more information on the RJCS Program. Retirement Plan Advisory Services LWP offers investment advisory services to qualified retirement plans including fiduciary advice, 3(21), and discretionary management, 3(38), defined under the Employee Retirement Income Securities Act [“ERISA”]. Through our 3(21) arrangement, LWP provides non-discretionary fiduciary advice services to retirement plan clients which may include development and implementation of an investment policy statement IPS [“IPS”], investment due diligence, ongoing performance reporting, and documentation of these services to plan fiduciaries for a fee. Through our 3(38) arrangement, LWP offers discretionary investment management services provided through an agreement with Raymond James and Associates. LWP works with our retirement plan clients to establish an IPS, review a diversified investment menu, meet annually or more often to provide updates and account monitoring, a client service plan, and ongoing investment due diligence. ERISA and Individual Retirement Account Disclosure When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.