4a: Firm Description Lewis Asset Management was established in February 2007 by David W. Lewis, Jr. Our main office is located in Lafayette, California. 4a1: Principal Member David W. Lewis, Jr., Chief Compliance Officer: Mr. Lewis may be contacted by email at dave@lewisam.com or by telephone at (925) 284-4033. 4b: Types of Advisory Services Investment/Portfolio Management Lewis Asset Management offers a variety of investment advisory services to our clients. We work with our clients to identify their investment goals and objectives as well as risk tolerance in order to create an initial portfolio allocation designed to complement their clients’ financial goals and objectives. We may create a portfolio, consisting of, but not limited to individual stocks or bonds, exchange traded funds, no-load funds and/or load-waived funds (front-end commissions will not be charged). In certain circumstances, fees may be negotiable Each portfolio will be initially designed to meet a particular investment goal, which Lewis Asset Management has determined to be suitable to our client’s circumstances. Once the appropriate portfolio has been determined, we will review the portfolio and rebalance the account based upon our client’s individual needs, stated goals and objectives. Lewis Asset Management’s strategy, generally, will be to seek to meet client investment objectives while providing clients with access to personal advisory services. Our services may include: ▪ Quarterly asset allocation ▪ Security research and selection ▪ Trade execution ▪ Portfolio rebalancing ▪ Quarterly portfolio appraisal and reporting 4c: Client Tailored Relationships and Restrictions As a fiduciary, Lewis Asset Management always acts solely in your best interests. Your portfolio is customized based on your investment objectives. You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best interest cannot

be honored and if forced may result in the termination of our agreement. Similarly, you are under no obligation to act upon Lewis Asset Management 's or associated person's recommendations. If you elect to act on any of the recommendations, you are under no obligation to effect the transaction through Lewis Asset Management or its associated person when the person is an agent with a licensed broker-dealer or through any associate or affiliate of such person. 4d: Wrap Fee Program Lewis Asset Management does not sponsor nor provide portfolio management services to a wrap fee program. 4e. Written Acknowledgement of Fiduciary Status 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 ADV PART 2 A BROCHURE PAGE 5 OF 13 special rule that requires us to act in your best interest and not put our interest 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. 4f: Assets under Management (AUM) Lewis Asset Management, as of December 2023, has $ 166,938,761.000 in discretionary reportable Assets under Management and $ 8,956,537.00 in non-discretionary reportable Assets under Management for a total of $ 175,895,298.00.