A. Firm Description Carolina Wealth Management, Inc. (“CWM” or the “Firm”) was founded in 2004 and is currently registered with the Securities and Exchange Commission (“SEC”). The Firm is co-owned by Derek S. Pszenny, David R. Damm and David W. Silver. CWM provides personalized confidential investment management to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the Client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. CWM is an investment management firm. The firm does not sell annuities, insurance, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities, however certain persons of the firm are insurance licensed and can offer insurance to CWM Clients CWM does not accept commissions in any form.. No finder’s fees are accepted. Investment advice is provided, with the Client making the final decision on investment selection. CWM does not act as a custodian of Client assets. The Client always maintains asset control. While a majority of clients managed by CWM are on a non-discretionary basis, CWM does provide asset management services on a discretionary basis.. B. Types of Advisory Services CWM provides investment supervisory services, also known as asset management services, manages investment advisory accounts not involving investment supervisory services, and furnishes investment advice through consultations and issues periodicals about securities. Investment Management Services CWM provides discretionary and non-discretionary portfolio management services to its clients, based on the specific needs and objectives of such persons and the suitability of products and services. When CWM is granted full discretion and authority to manage the client’s account, CWM is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or to be sold without permission from the client prior to each transaction. CWM offers non-discretionary portfolio management services. For Clients that enter into non-discretionary arrangements with our firm, we must obtain Client approval prior to executing any transactions on behalf of the Client account. Clients have an unrestricted right to decline to implement any advice provided by CWM on a non-discretionary basis. Prior to engaging CWM to provide any of the aforementioned investment advisory services, CWM requires a written investment management agreement (“IMA”) signed by the client prior to the engagement of services. The IMA outlines the services and fees the clients will incur pursuant to the IMA with CWM. Upon request, CWM will create an Investment Policy Statement for each client, which outlines the client’s current situation (goals, objectives, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Advisory Services include, but are not limited to, the following:
• Investment Strategy
• Asset Allocation
• Regular Portfolio Monitoring
• Personal Investment Policy
• Security Selection As noted, CWM’s asset management services are designed to offer portfolio construction and ongoing management of accounts with defined investment strategies to help meet the client’s personal investment goals and objectives. CWM evaluates the current investments of each client with respect to risk tolerance levels and time horizon. Risk tolerance levels may be documented in the Investment Policy Statement which is provided to our clients upon

request. CWM is responsible for providing ongoing re-balancing and continuous monitoring of our clients’ securities holdings. CWM generally limits its money management to open and closed end mutual funds, equities, bonds, fixed income and debt securities, ETFs, and REITs. CWM may use other securities as well to help diversify a portfolio when applicable, and has the ability to service annuities, 529 plans, and other non-custodial accounts. Separately Managed Accounts CWM utilizes the separately managed account (“SMA”) services of third-party investment advisory firms to aid in the implementation of an investment portfolio designed by CWM. Before selecting an SMA provider, CWM will ensure the chosen party is properly licensed or registered. Financial Planning Services CWM may provide additional advisory services in the form of financial planning services. These services are provided on a non-discretionary basis. Financial planning services do not involve the active management of client accounts, but instead focus on a client’s overall financial situation. If clients wish to execute their financial plan through our CWM, they may separately engage the Firm for asset management services, which are provided on a discretionary or non-discretionary basis. Financial planning can be described as helping individuals to determine and set their long- term financial goals through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role of the financial planner is to find ways to help the client understand his/her overall financial situation and help the client set financial objectives. An inherent conflict exists between the interests of CWM and the interests of the client. The client is under no obligation to act upon CWM’s recommendation. Should the client elect to act on any recommendation made by CWM, the client is under no obligation to affect the transaction through the Firm. C. Tailored Relationships CWM offers the same suite of services to all its clients. The management services and recommendations offered by CWM are based on the individual needs of our clients and the suitability of products and services. Each client’s current situation (income, objectives, and risk tolerance levels) will be used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs and targets. For CWM Institutional Clients, financial plans and their implementation are dependent upon the client’s Investment Policy Statement. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values and beliefs. CWM will make every effort to comply with the wishes of the client but cannot guarantee absolute adherence due to its use of indexed products, funds, and ETF’s that are controlled by third party managers. On more than an occasional basis, CWM furnishes advice to Clients on matters not involving securities, such as financial planning matters, taxation issues, and trust services that often include estate planning. D. Wrap Fee Programs CWM does not participate in and is not a sponsor of wrap fee programs. Wrap Fee Programs are arrangements between broker-dealers, investment advisers, banks and other financial institutions and affiliated and unaffiliated investment advisers through which the clients of such firms receive discretionary investment advisory, execution, clearing and custodial services in a “bundled” form. In exchange for these “bundled” services, the clients pay an all- inclusive (or “wrap”) fee determined as a percentage of the assets held in the wrap account. Due to the nature of its advisory services. E. Assets Under Management As of December 31, 2023, CWM managed $621,103,171 on a non-discretionary basis and $2,178,941 on a discretionary basis.