A. Firm Information Key Wealth Advisors LLC (“Key Wealth Advisors” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company under the laws of the State of Delaware. Key Wealth Advisors was founded in October 2021 and is a wholly owned subsidiary of Key Wealth Management LLC. The Principal Officers of Key Wealth Advisors are Carl Versella (Managing Member and CEO/CCO) and David A. Elfenbein (Member and President). This Disclosure Brochure provided information regarding the qualifications, business practices, and the advisory services provided by Key Wealth. B. Advisory Services Offered Key Wealth Advisors offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts of interest. Key Wealth Advisors’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Key Wealth Advisors provides customized investment management solutions for its clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Key Wealth Advisors collaborates closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. Key Wealth Advisors will then construct an investment portfolio, consisting of exchange-traded funds (“ETFs”), individual equity securities, individual fixed income securities, mutual funds and/or private investments, as appropriate for the Client. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Key Wealth Advisors’ investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Key Wealth Advisors will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Key Wealth Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Key Wealth Advisors may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Key Wealth Advisors may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Key Wealth Advisors may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Use of Independent Managers – Key Wealth Advisors may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the Page 5 strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement

account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Key Wealth Advisors will typically provide a variety of financial planning and consulting services to Clients. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such financial planning and consulting services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, rates and other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to, the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs or seek new financing partners. Key Wealth Advisors may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial planning and consulting engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not provide a written summary. Project-based financial plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Key Wealth Advisors provides non-discretionary retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:  Vendor Analysis  Plan Participant Enrollment and Education Tracking  Investment Policy Statement (“IPS”) Design and Monitoring  Investment monitoring and oversight  Performance Reporting Page 6  Ongoing Investment Recommendation and Assistance  ERISA 404(c) Assistance These services are provided by Key Wealth Advisors serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Key Wealth Advisors’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Key Wealth Advisors to provide advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include:  Establishing an Investment Strategy – Key Wealth Advisors, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.  Asset Allocation – Key Wealth Advisors will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client or unique client goal.  Portfolio Construction – Key Wealth Advisors will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.  Investment Management and Supervision – Key Wealth Advisors will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Assets Under Management As of December 31, 2023, Key Wealth Advisors manages approximately $71,000,000 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.