Firm Description CTA Wealth Advisors, Inc. (originally Cameron Thornton Associates) (“CTA”) was founded in 1982. CTA is a SEC Registered Investment Adviser with its principal place of business located in Burbank, CA. Investment advisory services are offered through its Investment Advisory Representatives (Advisory Representatives). CTA provides personalized confidential financial planning and investment management to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. Our core investment strategies are based on the concepts of Modern Portfolio Theory, which we believe identifies the most efficient combination of assets to establish a growth or income portfolio that will help preserve assets with a risk level appropriate for each individual investor we serve. Once the asset mix has been determined, the Adviser may either manage the assets directly or recommend one or more third-party money managers to help implement the allocation strategy. While our goal is to help clients achieve investment success, we offer no guarantee that our advice will result in profit or provide protection from a loss. Separate and apart from their registration as Advisory Representatives of CTA, all Advisory Representatives of CTA are also Registered Representatives of Cetera Advisor Networks LLC (Cetera), a non-affiliated broker/dealer and member of SIPC that is also an SEC Registered Investment Adviser. Most client securities transactions do not involve Cetera; however, select securities may be offered to a limited number of legacy clients through Cetera Advisor Networks LLC. Cetera is also a member of the Financial Industry Regulatory Authority (FINRA) and various other regulatory bodies. Advisory Representatives of CTA and Cetera are subject to certain FINRA supervisory obligations. Cetera does not provide any investment advisory services in conjunction with or as part of the financial planning and/or investment advisory services provided by CTA. Securities execution, custodial and other administrative services are provided primarily by Charles Schwab & Company, Inc. or Pershing LLC. However, certain services may be provided to a limited number of legacy clients by Cetera. The brokers and custodians utilized by CTA may also include other firms, such as variable annuity sponsors, variable life insurance sponsors, mutual fund companies, and others. In no event will CTA accept or maintain custody of a client’s funds or securities (please see the discussion under “Types of Advisory Services”). Advisory Representatives of CTA may sell annuities, insurance, individual stocks, individual bonds, mutual funds, limited partnerships, or other commissioned products. CTA does not compensate individuals for client introductions. For non-discretionary accounts, investment advice is provided with the client making the final decision on the initial investment selection and maintaining asset control. For discretionary accounts, CTA will make investment selections and maintain asset control. CTA does not act as a custodian of client assets. CTA may provide a written evaluation of each client's initial situation, often in the form of an Executive Summary. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (i.e., lawyers, accountants, insurance agents, etc.) may be engaged directly by the client on an as-needed basis. We believe that collaborative teams of professionals can and should exist for the sole benefit of the client. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. CTA reserves the right to charge a fee for the initial client meeting, which may be by telephone. CTA employs an exploratory interview process to determine if our services provide a benefit for both the client and CTA. Principal Owners Cameron M. Thornton, CFP® is the President and CEO of CTA Wealth Advisors, Inc. and the Principal of Cameron Thornton Associates (tax preparation and consulting services). Trevor M. Cole, CFP® is the Secretary and Director of Compliance of Types of Advisory Services CTA provides advisory services through our proprietary program known as The Wealth Development System™. The Wealth Development System is a customized and wide-ranging wealth growth and preservation process that enables CTA to assist its clients in trying to achieve their lifetime goals by eliminating the guesswork from financial planning. The Wealth Development System preaches discipline, diversification, patience, and adherence to long-term investment principles. Through implementation of The Wealth Development System, CTA follows a general process, enumerated in the individual components of The Wealth Development System not limited to data gathering, identifying client goals, analyzing relevant information, identifying problems, writing recommendations and implementing an investment strategy. Specific services provided by CTA include, but are not limited to:
• Assisting the client in setting and monitoring goals and objectives
• Building a risk management profile for the client
• Reviewing the client’s present financial condition
• Issuing a written report of recommendations as necessary
• Monitoring and tracking assets under management
• Providing the client with financial statements for specific time periods
• Advising the client on steps necessary to maintain the existing asset allocation strategy through the repositioning of assets, when appropriate
• Quarterly market commentaries
• Periodic newsletters on current topics of interest
• Other services, as may be requested by the client These services are broken down into the following individual components of The Wealth Development System™: The Strategic Profile Process™ - The Strategic Profile Process is a data-gathering discovery methodology that clearly identifies crucial financial issues to be evaluated during a 12 to 36-month period. This will involve one-on-one consultation from an Advisory Representative of CTA, which may be completed in person, virtually (i.e., Zoom) or over the phone. The Critical Factors Analysis™ - The Critical Factors Analysis is a strategic evaluation of a client’s strengths and critical weaknesses. This process whittles down gathered information to clearly identify relevant factors of a client’s financial situation. This may involve the delivery of a written plan and/or an Executive Summary specific to your financial situation. The Breakthrough Blueprint™ - The Breakthrough Blueprint is an easy-to- follow roadmap designed to lead the client to the potential achievement of life goals. The Breakthrough Blueprint is developed after the completion of The Strategic Profile Process and The Critical Factors Analysis. This process results in the development of a personalized Investment Policy Statement and Asset Allocation analysis, and includes implementation of recommendations. The Strategic Monitoring System™ - The Strategic Monitoring System provides for the planned periodic review and evaluation of client investment assets under management and client estate planning goals. CTA offers multiple investment supervisory services, also known as asset management services (discussed below under “Advisory Service Agreement”). The Retirement Feasibility Solution™ - The Retirement Feasibility Solution is a system through which CTA calculates projected retirement cash flow based upon employer pension programs and an individual’s working capital. We define working capital to be assets available for funding future cash flow. The Entrepreneur’s Business Enhancement Process™ - The Entrepreneur’s Business Enhancement Process provides one-on-one and team coaching to successful entrepreneurs and their management teams. This process is designed to provide dynamic strategies to position businesses for successful long-term growth and profitability. On more than an occasional basis, CTA furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues and trust services that often include estate planning. All material conflicts of interest are disclosed regarding CTA, its representatives and any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. As of December 31, 2023, CTA managed approximately $8,801,523 in discretionary and $127,737,961 in non-discretionary assets through our proprietary Investment Update Service™ program and our Buckingham Strategic Partners program. These investment management programs are discussed in detail later under the heading “Advisory Service Agreement.” Clients may participate in more than one investment advisory program. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. If CTA is ultimately responsible for managing your investment assets, we will create an Investment Policy Statement and may create a Breakthrough Blueprint report. The Breakthrough Blueprint™ is an asset allocation analysis based on your investment objectives and experience, time horizon, risk tolerance, and financial situation. Investment policy statements are created to help establish parameters around your investment assets and to help further explain the investment philosophy we employ. Restrictions on investing in certain securities or types of securities may be imposed. Agreements may not be assigned without client consent. Types of Agreements The following agreements define our typical client relationships:
• Financial Planning Service Agreement
• Advisory Service Agreement
• Retainer Engagements
• Tax Preparation
• Hourly Planning Engagements Financial Planning Service Agreement CTA offers financial planning services to select individuals, families, pension and profit-sharing plans, trusts, corporations, and others. As CERTIFIED FINANCIAL PLANNERS, Cameron M. Thornton and Trevor M. Cole lead the planning process, responsibly assisting clients to identify their individual goals and objectives. Clients sign a Financial Planning Service Agreement prior to the onset of CTA’s research and evaluation. The Financial Planning Service Agreement describes, in detail, the scope of each client’s individual plan and other important aspects of the planning process. Termination of the Financial Planning Service Agreement may be made in writing by either party. Upon termination, CTA will refund any unused portion of the fee, if applicable. CTA offers a wide range of financial planning services to clients in the form of The Wealth Development System, as discussed above under the heading “Types of Advisory Services.” The financial planning work for a client will usually include general recommendations for a course of activity or specific actions to be taken by a client. Recommendations may be made that clients obtain insurance or revise existing coverage, establish retirement accounts, increase or decrease funds in savings accounts or invest in securities. CTA may also develop or recommend certain retirement, estate or tax plans or refer clients to an accountant or attorney. As part of the financial planning analysis and engagement, CTA and its Advisory Representatives may assist clients in determining their investment goals and objectives along with risk tolerance and retirement time horizons. CTA may recommend an initial asset allocation to fund certain long-term objectives such as buying a home, planning for college or retirement, etc. For retirement assets held outside the control of CTA, such as external pension, profit sharing, 401(k) and 403(b) plans, clients will be responsible for implementing all recommendations.

Further, CTA will neither provide Continuous Supervisory or Portfolio Monitoring services for such accounts nor receive ongoing asset-based compensation. However, clients will be able to engage Advisory Representatives to conduct a review of such accounts on a periodic or annual basis for an hourly or fixed-fee. Financial planning services may or may not result in the establishment of an ongoing investment management relationship after the financial plan is completed. Detailed investment advice and specific recommendations may be provided as part of a financial plan. Implementation of any recommendations is at the discretion of the client. The professional fees for financial planning, including components of estate planning range from $100 per hour to $750 per hour, but may also be billed on a flat per- project basis. Such flat per-project fees will typically range between $2,500 and $10,000, subject to negotiation. Fees for financial planning will vary according to the complexity of the engagement. In the event that the client’s situation is substantially different than disclosed during our initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. After delivery of a financial plan, and in the absence of an Advisory Service Agreement, future face-to-face meetings may be billed separately at our hourly rates discussed below with a minimum fee of $575. Advisory Service Agreement Most clients choose to have CTA manage their investment assets in order to obtain ongoing in-depth advice and life planning services. CTA’s proprietary fee-based investment asset management program is known as the Investment Update Service™. Services offered through this platform will be provided on a discretionary or non-discretionary basis. Clients are involved in the management of their accounts to the degree they choose, and are free to impose reasonable investment restrictions. CTA welcomes calls from clients at the office any time during normal business hours. It is the responsibility of each client to keep CTA informed of his or her financial situation to the extent that changes in that situation may affect the most prudent course of investment action. CTA will provide investment supervisory services based on a prior-established client profile, typically documented in what is known as an Investment Policy Statement. Investment policy is determined through personal discussions in which goals and objectives based on particular circumstances are established. In general, accounts are managed in accordance with the client’s individual needs, risk tolerance, objectives and reasonable investment restrictions by purchasing and/or selling securities. The Investment Update Service™ allows the client to maintain investments in cash and cash-equivalent assets, stocks, stock options, bonds, institutional class, no-load or load-waived mutual funds, load mutual funds, variable annuity sub-accounts, variable life insurance sub-accounts and other asset types. As previously mentioned, securities execution, custodial and other administrative services are provided primarily by Charles Schwab & Company, Inc. or Pershing LLC. However, certain services may be provided to a limited number of legacy clients by Cetera. The brokers and custodians utilized by CTA may also include other firms, such as variable annuity sponsors, variable life insurance sponsors, mutual fund companies and others. Investors who participate in the Investment Update Service™ are individuals who invest with a long-term focus. These investors understand the long-term nature of an investment plan and understand that patience is an important virtue when seeking to achieve financial goals. It is important that CTA be aware of a client’s financial situation and investment objectives as they may change along the way. Each client participating in the Investment Update Service will receive confirmations from account custodians, of every transaction within the account. They will receive monthly statements directly from the custodian for any month in which there was account activity. They will also receive detailed investment reports directly from CTA that include data provided by sources deemed to be reliable by CTA in accordance with the client report cycle. Fees for the execution of transactions in Investment Update Service accounts may be higher than other advisory accounts available through Cetera, directly with mutual fund or annuity companies, or through unrelated broker/dealers. The annual management fee for the Investment Update Service is negotiable and based on the value of assets in the account (not including the value of any limited partnership or similar illiquid investment). Fees typically run between 0.6% and 1.0% per year. Annualized investment advisory fees are described in detail in the Investment Update Service™ Agreement signed by each client. The client should review, in detail, the Agreement for specific charges related to the client’s account. Investment Update Service account fees are paid in arrears, upon receipt of an invoice, following every investment cycle. Cycles are quarterly or semi-annually as described in the Investment Update Service Agreement. The fee is payable following the first investment cycle. The fee is based on the account value at the end of the cycle. Thereafter, fees are payable following each successive investment or billing cycle. Additional deposits to the account are subject to the same fee procedures. Other fees unrelated to the account’s investment advisory/management services may include retirement plan administration fees or account termination fees and will vary from account to account. In all instances, CTA will provide the client with appropriate documentation to explain advisory fees. Fees will not be charged on a performance basis. Clients should also note that fees for comparable services vary and lower fees for comparable services may be available from other sources. CTA may not change the account fees payable by a client for an Investment Update Service account without 30 days prior written notice. CTA retains an independent third-party account administrator BAM Advisor Services, LLC d/b/a Buckingham Strategic Partners (BSP) that performs certain services such as account administration, portfolio allocation analysis and non- discretionary implementation, back-office fulfillment, report and statement production, and billing services. Services are paid for directly through advisory fees billed to the client or are indirectly paid by CTA. Buckingham is an investment adviser registered with the Securities and Exchange Commission. Buckingham Strategic Partners (BSP) does not have investment discretion over client assets. However, CTA may have discretion over client assets on this platform. The client directs and designates the broker-dealer and custodian to execute transactions in his/her account from among those broker-dealer custodians that have an existing relationship with BSP. Buckingham Strategic Partners requires that a client designate a custodian from among Pershing Advisor Solutions LLC (“Pershing”), Fidelity Brokerage Services LLC (“Fidelity”), or Charles Schwab & Company, Inc. (“Schwab”). Pershing, Fidelity, and Schwab are unaffiliated SEC registered investment advisers and FINRA member broker dealers. Each offers to independent advisor’s services which include custody of securities, trade execution, clearance and settlement of transactions. Neither CTA nor BSP seeks better execution services or prices from brokers or dealers other than that chosen by the client, which may result in the client paying higher commissions, transaction costs or spreads, or receiving less favorable net prices on transactions for the client’s account. Buckingham Strategic Partners (BSP) may also sponsor educational seminars for the benefit of CTA and its clients. Such educational seminars provide CTA with access to information and ideas regarding practice development, client servicing, investment strategy, relationship management and financial planning. Attendance expenses associated with such educational seminars may be paid or reimbursed, either in whole or in part, by BSP. CTA Wealth Advisors, Inc. may recommend, where appropriate, that clients invest in shares of the SA Funds – Investment Trust (the “SA Funds”), a family of asset class mutual funds that are advised, managed, and administered by Buckingham Strategic Partners. Buckingham does not charge fees directly on investments into the SA Funds because Buckingham receives certain fees and expenses directly from the SA Funds, as disclosed in each SA Fund’s prospectus. For Buckingham Strategic Partners’ accounts, we charge the following fees, subject to negotiation: Advisor Management Fee Schedule for Buckingham Strategic Partners’ accounts (graduated fee): Annual Fee Amounts from $0.00 to $1,000,000.00 1.00% Amounts between $1,000,000.01 to $2,000,000.00 0.80% Amounts above $2,000,000.01 0.60% Buckingham Strategic Partners Administration and Servicing Fees (graduated fee): Annual Fee Accounts valued from $0.00 to $500,000.00 0.50% Accounts valued from $500,000.01 to $1,000,000.00 0.20% Accounts valued from $1,000,000.01 to $5,000,000.00 0.15% Accounts valued above $5,000,000.01 0.10% Retainer Engagements In some circumstances, a retainer-based relationship is established when it is more appropriate to work on a fixed-fee basis. In this instance, CTA will execute a Financial Planning Service Agreement to reflect such an engagement. The fee for a retainer engagement is based on our hourly planning fees discussed below and is negotiable. Hourly Planning Engagements CTA provides hourly planning services for clients who need advice on a limited scope of work. The current hourly fees charged by CTA are summarized as follows: Advisory Supervisor Cameron M. Thornton, CFP® - an hourly fee range between $350 to $750 per hour. The actual fee to be charged for Mr. Thornton’s professional time will be determined based on the scope and risk of the engagement. Advisory Representative and CERTIFIED FINANCIAL PLANNER™ Trevor M. Cole, – an hourly fee of $225 per hour. Staff Paraplanner – an hourly fee of $125 per hour. Other support staff, including Database Manager and Case Writer – an hourly fee of $100 per hour. Asset Management Assets are invested primarily in no-load or low-load mutual funds and exchange- traded funds, through Pershing LLC, Charles Schwab, or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Transaction fees may be charged for the purchase of some funds. Stocks and bonds may be purchased or sold through a brokerage account with Pershing LLC or Charles Schwab. Fees may be charged for stock and bond trades placed through them. Investments may also include: equities (stocks), stock options, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, and interests in master limited partnerships. Initial public offerings (IPOs) are not available through CTA. Termination of Agreement A client may terminate any of the aforementioned agreements at any time by notifying CTA in writing without penalty. Clients have the right to terminate Agreements without penalty or incurring advisory fees within five (5) business days of the date the Agreement is signed. If an Agreement is terminated after five (5) business days, any earned fees will be due and all unearned fees will be returned on a pro-rata basis. CTA may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, CTA will refund any unearned portion of the advance payment.