A. Firm Description and Principal Background Broadwater Capital Management LLC (“Broadwater”) was founded in 2003 and has continuously operated since then. Broadwater is a small family-owned firm with a single advisor, Brent Garcia. Brent Garcia. Brent Garcia also owns the firm. i. Brent Garcia Background Brent Garcia, Principal, founded Broadwater Capital Management LLC, (formerly known as ABG Management, LLC) and as a Principal of the firm will be responsible for investment advisory services. Prior to forming Broadwater, Mr. Garcia worked in the equity research department of Smith Barney from 1994 through 2001 (previously Salomon Smith Barney). Mr. Garcia joined Smith Barney in 1994 as an assistant aiding the research effort of both the Industrial and Consumer Generalist research teams. In 1996, Mr. Garcia joined the newly formed Educational Services group as its associate. Mr. Garcia assumed the lead analyst position for the group in 1999 and remained in this position until his departure in 2001. In this role, he was responsible for all investment research and recommendations for Educational Services. During his employment with Smith Barney, Mr. Garcia earned the Charted Financial Analyst designation as well as passing the NASD series 7 and 63 examinations. Mr. Garcia graduated from the University of Pennsylvania in 1992, earning a Bachelor of Arts with a major in Economics and English and a minor in International Relations. Mr. Garcia is a member of the Boston Security Analysts Society and of the CFA Institute. Mr. Garcia was born in Boston, Massachusetts, in 1970. B. Types

of Advisory Services Offered Broadwater provides investment advisory services to individuals and small institutions. Each account is managed separately and is invested according to the needs of each client. The firm does not specialize in a particular area but invests across a range of asset classes and security types to achieve well diversified and balanced portfolios for its clients. Securities may include but are not necessarily limited to stocks (domestic and foreign), bonds (US, municipal, and corporate), mutual funds, exchange traded funds, exchange traded notes, partnership shares, options, and warrants. C. How Broadwater Tailors Advice to Individual Clients Broadwater provides individualized investment advisory services. Broadwater develops a portfolio for each client suited to the needs and objectives of that client. Broadwater attempts to evaluate the client’s investment risk tolerance, time horizon, income needs, and goals to determine an investment plan. Broadwater can tailor its advice depending on the wishes and requirements of the client. However, if client information is limited, clients must understand that comprehensive investment needs and objectives may not be fully considered due to the lack of information received and/or lack of client disclosure. D. Wrap Fee Programs Broadwater does not participate in wrap fee programs. E. Assets Under Management Client assets managed on a discretion basis: $151.585,557.00 Client assets managed on a non-discretionary basis: $ 0.00 Assets under management were calculated as of December 31, 2023.