LWMG offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to LWMG rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with LWMG setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). LWMG filed for registration as an investment adviser in May 2022 and is owned by Todd Gillingham, Gary Tangwall, Thomas Selbo, Jennifer Beyl-Lee, Chad Broberg, and Bjorn Nesvold. As of December 31, 2023, LWMG had $824,391,424 in assets under management, of which $794,000,213 was managed on a discretionary basis and $30,391,211 was managed on a non-discretionary basis. While this brochure generally describes the business of LWMG, 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 LWMG’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services LWMG offers personal comprehensive financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the comprehensive financial plan may include:  Business Planning  Trust and Estate Planning  Employee Benefits Planning  Investment Management  Insurance Planning  Retirement Accumulation Planning  Risk Management  Charitable Giving  Retirement Income Distribution Planning  Tax 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). LWMG prepares and provides the financial planning client with a written comprehensive financial plan and performs periodic reviews of the plan with the client, as agreed upon with the client. In addition, LWMG provides financial planning services that are completed upon delivery of the financial plan to the client. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have LWMG implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. LWMG cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. In performing these services, LWMG is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. LWMG recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual 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 LWMG 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 LWMG 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 LWMG’s recommendations and/or services. Investment and Wealth Management Services LWMG manages client investment portfolios on a discretionary or non-discretionary basis. In addition, LWMG provides certain clients with wealth management services which include a broad range

of financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. LWMG primarily allocates client assets primarily among various mutual funds and exchange-traded funds (“ETFs”). The Firm also allocates assets among independent investment managers (“Independent Managers”), and individual debt and equity securities when it deems it appropriate. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage LWMG to manage and/or 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, LWMG directs or 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. LWMG 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. LWMG 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 LWMG 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 LWMG 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. Use of Independent Managers As mentioned above, LWMG 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. LWMG 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. LWMG also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. LWMG continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. LWMG seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Note for IRA and Retirement Plan Clients: When LWMG provides investment advice to you regarding your retirement plan account or individual retirement account, LWMG is a fiduciary 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 LWMG makes money creates some conflicts with your interests, so LWMG operates under a special rule that requires LWMG to act in your best interest and not put LWMG’s interest ahead of yours.