JWCA is a Florida corporation that has been registered with the SEC as an investment adviser, since November 9, 2000. Our headquarters are in Tampa, Florida. JWCA is wholly owned by JWC Wealth Partners, Inc. (“JWC Wealth Partners"). As of January 1, 2024, JWC Wealth Partners was owned by two (2) shareholders, R.J. Wood and Craig Towle. Mr. Carlson was the founding Principal, President, Chief Executive Officer, and Chief Financial Officer of JWCA. During 2023, Mr. Wood and Mr. Towle purchased the entirety of Mr. Carlson’s shares in JWC Wealth Partners. Accordingly, Mr. Wood and Mr. Towle are now the sole shareholders of JWC Wealth Partners, each owns 50% of the corporation. Mr. Carlson has resigned from JWCA and Mr. Wood has assumed Mr. Carlson’s former roles. Accordingly, Mr. Carlson is no longer associated with JWC Wealth Partners or JWCA. JWCA has an expense sharing agreement with J.W. Cole Financial, Inc. ("JWCF"), a registered broker-dealer Member Financial Industry Regulatory Association (“FINRA”)/Securities Investors Protection Corporation (“SIPC”), for access to staff, office space, supplies, etc. As part of the expense sharing agreement, JWCA pays JWCF for such services. Both JWCA and JWCF are wholly owned by JWC Wealth Partners and, as such, are affiliated companies. Mr. Wood is JWCF’s CEO. However, JWCA and JWCF are separate business entities with different management structures. JWCA conducts its investment advisory business through a network of over 400 independent Investment Adviser Representatives (“IAR’s”). IARs operate in offices located throughout the United States. IARs may operate under their own business name(s) or DBA name(s), and their business name(s) and logos may appear on their sales and marketing materials. All sales and marketing materials used by IARs are reviewed and approved by JWCA. The business name(s) and DBA name(s) used by IARs are separate from and not owned and/or controlled by JWCF or JWCA. IARs may also offer and provide other services through their business name(s), however, with limited exceptions, investment advisory services offered by IARs must be provided through JWCA. Information about the IAR’s other businesses can be found in each IARs’ Form ADV Part 2B Brochure Supplement. A majority of JWCA’s IARs are also dually registered as registered representatives to solicit, offer, and sell securities through JWCF. IARs may also be licensed as independent insurance agents through various insurance companies to solicit, offer, and sell fixed and/or property and casualty insurance products in the states in which they conduct business. Therefore, IARs can potentially be acting in multiple capacities when soliciting, offering, and selling products, investment advisory services, and/or insurance products to the client. IARs also registered as registered representatives, and/or licensed as independent insurance agents, have conflicts of interest when they solicit, offer, and sell securities and insurance products to clients while also providing investment advisory services. For instance, an IAR may sell securities through JWCF and receive commissions, sell insurance products through an insurance carrier and receive additional compensation, and also provide investment advisory services and charging a separate JWCA Advisor Fee, all to the same client. As such, IARs have a conflict of interest to advise advisory clients to purchase products from which the IAR receives compensation in addition to his/her advisory fee. Our IARs manage assets on either a discretionary or non- discretionary basis. As of December 31, 2023, JWCA manages $4,182,933,687 in client assets on a discretionary basis, and $1,522,934,326 on a non- discretionary basis. The Types of Advisory Services We Offer JWCA and its IARs may solicit, offer, sell and charge for fee-based investment advisory services (“Advisor Fee”) including fee-based financial planning, the use of Third-Party Advisers, or other third-party advisory services, and/or for managing clients' accounts as further detailed below. IARs, when also acting as RRs of JWCF, may also solicit, offer, and sell securities, including but not limited to individual stocks and bonds, mutual funds, closed end funds, Exchange Traded Funds ("ETFs"), as well as non-traded alternative products, including but not limited to Real Estate Investment Trusts ("REITs") and private placements, Hedge Funds and Private Equities. IARs that are licensed as insurance agents may also solicit, offer, and sell fixed and/or property and casualty insurance products. Usually, the client will be charged a commission when purchasing securities through JWCF or variable insurance products. IARs of JWCA may also offer fixed insurance through insurance companies unaffiliated with JWCA, therefore neither JWCA nor JWCF supervises the solicitation or sale of these products. Thus, an IAR may receive an Advisor Fee and a commission from the same client. Our advisory services consist of advice regarding various types of public and private securities. These include, but are not limited to equities, corporate debt, government obligations, municipal securities, exchange-traded funds, unit investment trusts, mutual funds or other pooled investments, options/derivatives, alternative investments, interests in real estate or oil and gas partnerships, annuities/insurance products, and other investment instruments. In certain arrangements, you have the ability to impose restrictions on a particular security or asset category. Please understand JWCA does not guarantee or promise that your financial goals and objectives will be met. It is your obligation to review any analysis and advice, and provide updates whenever your financial situation, goals, objectives, or needs change, so your IAR can adjust his/her advice and your plan accordingly. A.) Managed Programs We offer four types of managed programs: 1. Transaction-Based Advisory Account Programs – This is a fee-based investment advisory account, in which your IAR will directly manage your investment account based on your financial profile and investment objectives. You will pay an ongoing, asset-based advisor fee based on the market value of billable assets being managed at an account-level (“Advisor Fee”), and nominal transaction fees for each transaction. Most accounts also incur a program fee imposed by the custodian and/or JWCA. (“Program Fee”).1 The Advisor Fee and Program Fee are payable quarterly, in advance/arrears. For accounts with advance billing, the initial Advisor Fee is due upon execution of Assets Under Management (AUM) Agreement and is pro-rated for the number of days remaining in the calendar quarter. For accounts with arrears billing, the initial Advisor Fee is due at the end of the calendar quarter and is prorated for the number of days invested in the prior quarter. Subsequently, the Advisor Fee will be billed based upon the billable value of the account on the last business day of the preceding calendar quarter. Total account and billable value of the account is determined by Black Diamond Wealth Platform, a product of SS&C Advent,, after reconciliation of data provided by the custodian. Certain assets may be excluded from the Advisor 1 For more information the Advisor Fee, Program Fee and other fees and charges, see Item 5 “Fees and Compensation.” Fee by the Client. These are called “excluded assets” which are not considered part of the advisory relationship with JWCA and are not considered billable assets for determining an Advisor Fee. As such, neither JWCA nor your IAR will provide any investment advice on excluded assets. Please note that unlike the Advisor Fee, the Program Fee is billed based on the total account value, inclusive of both billable and excluded assets, and thus may differ from the billable value when the Program Fee is billed simultaneously with the Advisor Fee. Your JWCA IAR may or may not pay for transaction costs. If the IAR does not pay for such costs, you will incur additional costs each time your JWCA IAR recommends the purchase and sale of a security. This will increase the costs associated with such account, as compared to a Wrap Account (see below). However, if your IAR elects to pay transaction charges, while you will not pay such costs, your IAR is incented to either not recommend transactions, in order to avoid having to pay such transaction costs, or may recommend investments which have lower transaction costs, but which may be more expensive to you. Your IAR will deliver regular investment advice and monitoring of your security holdings. You have the option to allow your IAR to manage your assets on a non-discretionary basis, wherein you must contemporaneously approve each transaction recommended by your IAR, or you may authorize, in writing, that your account be managed on a discretionary basis, if certain qualifications are met. Certain minimum fees apply. In a discretionary account, your IAR makes investment decisions on your behalf, without your contemporaneous approval. In no case, however, can your IAR withdraw funds or securities without your approval (Please see Item 16 for further details). Please note that in addition to the Advisor Fee, you will pay other certain fees, such as service charges. 2. Asset-Based Advisory Account Program – This legacy program is designed as a “wrap” fee investment advisory account, in which your IAR will manage your investment account based on your financial profile and investment objectives and is only available to existing investors. In exchange, you will pay an ongoing advisor fee. The Advisor Fee and Program Fee are payable quarterly, in advance. The initial Advisor Fee and minimum Program Fee are due upon execution of the AUM Agreement and are pro-rated for the number of days remaining in the calendar quarter. Subsequently, the Advisor Fee will be billed based upon the billable value of the account on the last business day of the preceding calendar quarter. Billable value of the account is determined by Black Diamond after reconciliation of data provided by the custodian. Excluded assets are not included in the Advisor Fee. The Program Fee is billed based on the total account value, inclusive of both billable and excluded assets, and thus may differ from the billable value. See below for additional details relating to management fees and program fees. While you will pay a Program Fee, similar to a transaction-based advisory account, the asset-based Program Fee includes certain transaction costs not covered under a transaction-based Advisory Account. However, the Program Fee for JWCA’s Asset-Based offerings is higher than the Program Fee for the Transaction-Based Advisory Programs. Thus, if you are a client that intends to engage in, and receive advice on, multiple securities transactions, the Wrap Account may be more beneficial. However, if you intend to engage in fewer transactions, but sill desire ongoing investment advice, a Transaction-Based Advisory Account may be more appropriate for you given the lower Program Fee. Understand that in a Wrap account, JWCA and the JWCA IAR have a conflict of interest in that they are incented to not recommend transactions since JWCA pays for the costs of such transactions which thereby reduces the profitability of the Wrap Account to them. Your IAR will deliver ongoing investment advice and monitoring of your security holdings. You have the option to allow your IAR to manage your assets on a non- discretionary basis, or they may be managed on a discretionary basis, if certain qualifications are met and upon your written authorization. Note, there is no cost for the initial 50 trades placed in your account, however in the event trading activity exceeds that number on a rolling 12-month period (each 12-month period begins at your Anniversary date), you will be charged a transaction fee for each trade after the 50 trades. For further information please refer to the JWCA Form ADV Part 2A Appendix Wrap Fee Program Brochure. 3. Managed Account Solutions Program - The Managed Account Solutions (MAS) is a limited program that allows certain IARs the option to provide you advisory services by using a third-party advisory service. Depending on the particular MAS advisory solution selected, the day-to-day management of the advisory account may be performed by the IAR, a third-party manager, or a combination of the two. This is a tri-party investment advisory platform that is sponsored by Envestnet Asset Management, Inc. (Envestnet) and the clearing custodial firms, Institutional Wealth Services (IWS). A custodian is the entity that actually holds your securities and other investments on behalf of JWCA. The MAS program consists of an extensive range of investment advisory services, including: Separately Managed Accounts, Wrap Strategist Solutions comprised of Mutual Funds and ETFs, Unified Managed Accounts, Multi-Manager Accounts and an IAR Managed Model Program. Clients who select the MAS program will also receive Envestnet’s Form ADV Part 2A, which provides greater detail regarding the program sponsor. Each investment advisory service offered through the MAS program has distinct fees and charges such as platform, custody and clearing and are outlined in the Statement of Investment Selection (SIS) that is provided to you prior to investing as are the minimum fee amounts by fee type. Your IAR can provide you a copy of the SIS and discuss the features of each program with you so that you may determine your preferred cost option that best suits your investment style. Note that certain services may result in additional costs such as transaction charges. 4. FMAX – The Fidelity Managed Account Xchange – is an advisory platform that allows your IAR the option to provide advisory solutions by using a third-party service. Depending on the particular FMAX solution selected, the day-to-day management of the advisory account may be performed by the IAR, a third-party manager, or a combination of the two. This is a tri-party investment advisory platform is sponsored by Fidelity Institutional Wealth Advisers, LLC (“FIWA” or “program sponsor”) and a clearing

custodial firm, National Financial, LLC (NFS). A custodian is the entity that actually holds your securities and other investments on behalf of JWCA. The FMAX program is a wrap program and consists of an extensive range of investment advisory services, including Separately Managed Accounts, Wrap Strategist Solution of Mutual Funds and ETFs, Unified Managed Accounts, Multi-Manager Accounts and an IAR- Managed Model Program. Clients who select the FMAX program will also receive FIWA Form ADV Part 2A, which provides greater detail regarding the program sponsor. Each of these programs has distinct minimum account fee and other fees and charges such as platform, custody and clearing and are outlined in the Statement of Investment Selection (SIS) that can be provided to you by your IAR prior to investing. In certain instances, additional costs may be incurred such as an asset-based surcharge for mutual funds that are deemed by the Custodian to be nonrevenue paying to the Custodian. Please note that the cut- off time for entering transactions to be executed on a particular trading day is 1:00 p.m. Eastern time. Transactions entered after 1:00 p.m. Eastern will likely be executed the next trading day. Your IAR can discuss the features of each program with you so that you may determine your preferred cost option that best suits your investment style. Unlike the other JWCA wrap programs mentioned above, there is no limit to the amount of transactions without a transaction fee in an FMAX account. Remember, if you are a client that intends to receive advice on multiple securities transactions, a Wrap Strategist Solution may be beneficial. However, if you intend to engage in fewer transactions, but sill desire ongoing investment advice, a Transaction-Based Solution may be more appropriate for you. Understand that in a Wrap account, JWCA and the JWCA IAR have a conflict of interest in that they are incented to not recommend transactions since the costs of such transactions reduces the profitability of the Wrap Account to them. B.) Third-Party Investment Advisers We also offer advisory services through Third-Party Investment Advisers (TPIAs) (also known as, “third- party asset managers,” or, “unaffiliated investment advisers”) who manage your assets on a day-to-day basis. These TPIA programs offer clients access to a variety of portfolio managers who create model portfolios with varying levels of risk from which you may choose. When working with a TPIA, JWCA acts as either a “Promoter” (formerly known as “Solicitor”) or as a Co- Advisor or advisor when making these programs available to clients. When JWCA acts as compensated promoter for the TPIA Program sponsor, neither JWCA nor your IAR provides investment advice, but instead assists you in selecting one or more TPIA Programs. When JWCA and your IAR act as a Co-Advisor we will help you determine your risk tolerance, investment goals and other relevant guidelines to help you choose a suitable TPIA Program. Your IAR helps you select the appropriate TPIA program and particular investment strategy offered by the TPIA consistent with your financial profile and investment objectives. However, the TPIA is responsible for the day-to-day advice and execution of transactions in your account. We maintain an approved list of TPIAs who are available for your IAR to recommend. On a regular basis, your IAR monitors changes to your financial profile and the TPIA you selected and provides advice for you to adjust the strategy or TPIA if necessary. The TPIA will assess you an Advisor Fee as outlined in their document(s). A portion of this Advisor Fee will be retained by the TPIA, a portion will cover the transaction costs, and a portion will go to your IAR and JWCA. A TPIA generally provides a range of services to IARs and clients to help them meet portfolio management needs; including building various investment strategies, providing access to various asset managers and custodians, providing due diligence and research, portfolio construction, proposal generation, account rebalancing, account monitoring, performance reporting, account support, and other tools designed to manage and invest your assets. Depending on your particular TPIA relationship, the JWCA IAR may have discretion to switch Strategies and/or managers within the particular TPIA, without your contemporaneous approval acting as a co- advisor or Advisor. However, any such discretion must be consistent with your investment objectives. Please note, such co-advisory relationship does not give JWCA or the JWCA IAR discretion over the management of your assets on a day-to-day basis; such authority remains with the TPIA Consistent with your financial profile and investment objectives, this discretionary authority allows your IAR to change strategies, as well as investment managers within the TPIA. The discretionary authority does not give JWCA or your IAR the authority to withdraw your funds or assets or move your account to another TPIA. However, by granting discretion to JWCA and your IAR you are specifically consenting and agreeing that all your account information with the TPIA may be shared with investment managers who are different than the account managers initially utilized when you opened the TPIA. Remember, the TPIA manages your advisory account on a day-to-day basis. Digital Advice JWCA has entered into various selling agreements with digital advice providers to provide clients the opportunity to receive advice regarding financial goal setting and investment planning tools through a web-based portal that covers particular financial topics, including a combination of interaction with a IAR and access to written materials. JWCA nor your IAR will have discretion of the assets managed by a digital advice provider. Through the use of algorithms, although neither JWCA nor your IAR have discretion, providers advise clients and manage their accounts on a discretionary basis. These algorithms are developed, overseen, and monitored by personnel of the provider. When a Retail Client or Retirement Plan Participant creates an account, identifies their investment objective, time horizon, and provides investment risk tolerance data, an algorithm, developed by the providers personnel, determines which investment allocation is appropriate based on these inputs from the Client or their financial professional. Please note, the client survey process does not always appropriately capture a client’s risk tolerance, it could result in advice to invest in securities that are not aligned with the client’s goals. To help reduce this risk, the financial professional attempts to determine whether the suggested investment allocation determined by the algorithm is appropriate. Algorithms from some digital advice providers also generate advice regarding other investment decisions, including but not limited to allocation, savings and withdrawal rates, automatic rebalancing, and account type selection. When clients make deposits or withdrawals, elect to change portfolio strategies, or donate shares, the digital advice provider will utilize its algorithm to determine how to allocate or liquidate positions within the portfolio. These allocations may result in tax consequences including, but not limited to, short-term capital gains, long-term capital gains, wash rules, etc. Certain conflicts of interest may exist with the digital advice provider of such service and clients should carefully review all materials provided by the provider. While clients directly own all the securities in the portfolio, clients should be aware that you cannot generally create restrictions by designating particular securities or types of securities that should not be purchased or that should be sold if held in the account. The process for accommodating such requests varies based on the platform provider. It is important to note that Clients may make requests to impose new, or modify existing, reasonable restrictions after the account is established. Each digital advice provider has their own disclosure forms that provide additional information regarding their various costs for services and outline specifics relating to investment management, e.g., algorithms, that investors should review these closely in addition to what’s provided here. In addition to the cost assessed by the digital advice provider, clients typically pay a separate fee to their IAR in the form of an investment management fee. The amount of the investment management fee is negotiated between the IAR and the client. To achieve the desired target asset allocation for you (as determined by the digital service provider based on your data input, and overall risk assessment, and ongoing rebalancing of the portfolio), tax consequences may result. Tax consequences can include both short-term and long-term gains. Rebalancing to achieve the stated target asset allocation may not include consideration of such tax consequences. C.) Financial Planning and Consulting: We also offer financial planning and consulting services regarding securities and non-securities topics, for which we charge either an hourly rate or a flat fee. In addition, you may elect to engage in an ongoing financial planning arrangement for which you will pay a recurring fee. Financial planning topics may include, but are not limited to: tax planning, asset allocation, estate planning, investment planning, risk management, retirement planning, and college planning. Your IAR will consult with you to discuss your goals, objectives, risk tolerance, and any special circumstance unique to you. After performing this analysis, your IAR will present recommendations to you, either verbally or in a written financial analysis. Your IAR may prepare other special reports on these matters for you at your request. To implement the planning advice you receive from your IAR, your IAR may recommend that you work with other professionals, such as other broker-dealers (including JWCF), investment advisers (including JWCA), attorneys, property and casualty professionals or accountants. Your IAR may also recommend that you utilize various financial products to assist with helping to meet your financial goals. You are under no obligation to act on any of the financial planning recommendations provided to you by your IAR, and you may choose to implement the recommendations through other service providers. Please note that your IAR is incented to recommend products and services in your financial plan for which he/she receives additional compensation. Specifically, your IAR may recommend that you use advisory products from which he/she receives a portion of the Advisor Fee and/or brokerage or insurance products from which your IAR receives a portion of the commission. These fees and commissions are in addition to the financial planning fee that you pay to JWCA and your IAR. Your IAR will base the financial planning recommendations on your initial profile provided at the time of engagement. D.) Variable Annuity Sub-Account Management: We offer advisory services to help manage variable annuity insurance products that you may currently own. Variable annuity insurance products contain sub-accounts, which are portfolios of investment assets. Based upon your financial profile, your IAR will recommend an advisory service designed to assist you with selecting which sub-accounts help you meet your financial goals. In some instances, your IAR may manage the investments in those sub-accounts. This includes variable annuity contracts you purchase through your IAR in their capacity as a registered representative of JWCF for which your IAR, as a registered representative, may have also received a commission. Alternatively, your IAR may recommend that you select a TPIA who will manage the sub- accounts according to your financial profile. This advisory service by the TPIA is separate from our other JWCA services and is pursuant to a written Annuity Advisory Agreement with the TPIA. In this case, JWCA and your IAR will receive a promoter’s fee for the referral to the TPIA. Both your IAR and JWCA will receive a portion of the fee charged to manage your sub-accounts. In addition, your IAR may recommend fee-only variable annuities. For further information on Variable Annuity Sub-Account Management, please refer to Section 5. E.) Asset Management for Participants in Held-Away Employer-Sponsored Plans JWCA utilizes an unaffiliated third-party platform which enables a JWCA IAR to manage a client’s retirement plan assets that are held at the custodian for the client’s employer-sponsored retirement plan. Such management occurs on a discretionary basis. Through this platform, JWCA does not take custody of your funds and does not have direct access to your accounts. You are not required to, and should never, provide log in credentials to your accounts to JWCA or your IAR. The third-party platform provides a link to you, allowing you to connect your account at your employer- sponsored retirement plan to the platform. Once your account(s) is connected to the third-party platform, your IAR will then be able to review the current account(s) allocations and when necessary, will make any changes in the allocations based on your financial profile and investment objectives. To participate you must acknowledge that JWCA’s investment advice is limited based on the options made available by the employer-sponsored plan and that such limitations may impact the IARs ability to effectively manage the assets. You will be charged an Advisor Fee and a Program Fee. A portion of the Program Fee is paid to the third- party in exchange for access to their system. Fees are assessed quarterly, in advance and determined based on the total account value. Fees cannot be debited directly from the employer-sponsored plan. You are required to provide an alternative billing method. In the event of an account closure or termination of the agreement, Advisor fees will be rebated based on the remaining days in the period. However, Program Fees are not rebated. Advisor fees and Program Fees are not pro-rated for additions and withdrawals that occur during a billing cycle. Neither JWCA nor your IAR has the ability withdraw funds or securities from your retirement plan account.