1. Description of the Advisory Firm PWA Financial is a Limited Liability Company organized in the state of Pennsylvania. The firm was formed in January 2013, and the principal owners are Michael David Carlucci and Kenneth Charles Coniglio. PWA Financial is a financial advisory services firm located in the Newtown-Yardley area of Lower Bucks County Pennsylvania offering investment management and strategic planning services for moderate to high-net-worth individuals, their families, and their businesses throughout the Delaware Valley. PWA Financial believes that effective investment management starts with a comprehensive client profiling process designed to clearly identify each individual’s goals, time horizon, tolerance for risk and prior investment experience. Once an investor profile is developed a simple Investment Policy Statement is created, which after being agreed upon, becomes the foundation for the investment process. PWA Financial incorporates the traditional “Modern Portfolio Theory” of Asset Allocation and the Efficient Frontier in executing each client’s investment policy. Portfolios are built using traditional publicly traded investment instruments such as: individual common stock, Government and Agency Bonds, Corporate Bonds, Municipal Bonds, Mutual Funds – closed and open ended, and Exchange Trade Funds (ETF). The firm believes that true diversification will often incorporate the use of non-traditional and alternative asset classes for certain clients. These products will include publicly and non-publicly traded: long/short and hedged equity strategies, managed futures products, opportunistic fixed income, REITS, and separately managed accounts. All client advisory relationships are fee based and the firm offers a variety of traditional proprietary SMA (separately managed accounts) including: All Cap Value, Large Cap Growth, and Global Allocation strategies, and most are offered in equity as well as balanced versions. The firm utilizes the services of outside sub-advisors for the management of certain specialized investment strategies. The firm also offers managed mutual fund strategies which can be incorporated for accounts as small as $5,000 in value. The firm’s primary custodian will be TD Ameritrade Institutional. TD Ameritrade Institutional will be responsible for all custody services, monthly account statements and client billing, and year-end tax reporting. All performance reporting will be provided through Evestnet/Tamarac. B. Types of Advisory Services PWA Financial (hereinafter “PWA”) offers the following services to advisory clients: Investment

Supervisory Services PWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring PWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. PWA 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. Services Limited to Specific Types of Investments PWA generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, private placements, and government securities. PWA may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions PWA offers the same suite of services to all of its clients. However, specific client financial plans 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) and is used to construct a client specific plan to aid in the selection of a portfolio that matches 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 PWA from properly servicing the client account, or if the restrictions would require PWA to deviate from its standard suite of services, PWA 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. PWA does not participate in any wrap fee programs. E. Amounts Under Management PWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $205,700,997.00 $0.00 December 2022