Information about Our Firm Coulter & Justus Financial Services, LLC is a Tennessee limited liability company doing business as C & J Wealth Advisors. Our firm is an independent, fee-based wealth management firm serving the greater Knoxville and Oak Ridge, TN communities. Our focus is in helping clients achieve their goals through the development and implementation of financial plans, combined with a value-based investment discipline that protects and grows client wealth. C&J Wealth Advisors is not a subsidiary of, nor do we control, another entity. Our firm does not have a reportable threshold, per SEC guidance, of its members’ (shareholders) equity interests. As an independent, fee-based wealth management firm, we do not have an incentive to generate commissions, nor do we have an incentive to sell proprietary products and services. Our focus is simply to give you objective, experienced advice that puts your interests first. When we act as your investment adviser, we must act in your best interest, and we do not put our interest ahead of yours. At the same time, the method by which we are compensated creates some conflicts with your interests. The following items outline our activities and address conflicts associated with those activities. You should understand and ask us about these potential conflicts because they can affect the investment advice we provide you. We provide a broad range of investment advisory services to our clients. Approximately 80% of our business involves providing ongoing and continuous supervision of our client’s portfolio (termed investment supervisory services). Approximately 10% of our business finds us engaged in furnishing investment advice through periodic consultations (termed investment consultation), which does not include ongoing supervision or management of an investment account. The remaining 10% of our efforts are focused on financial planning services; working with our clients in such areas as cash flow and budgeting, retirement planning, risk management and estate planning. As of our December 31, 2023, fiscal year-end, our firm had over $269,854,719 of client assets under its management; over $264,100,258 million on a discretionary basis and $5,754,461 in non-discretionary accounts (investment authority is defined in Item 16). Getting Started An initial complimentary interview is conducted by a representative of our firm to determine the scope of services to be provided. We will ensure material conflicts of interest are disclosed regarding our firm and its employees that could be reasonably expected to impair the rendering of unbiased and objective advice. Should you wish to engage our firm, we must first enter into a written agreement; thereafter, discussion and analysis will be conducted to determine your financial needs, goals, holdings, etc. Depending on the scope of the engagement, we may require current copies of the following documents early in the process:
• Wills, codicils and trusts
• Insurance policies
• Mortgage information Page 5 of 28
• Tax returns
• Current financial specifics including W2s or 1099s
• Information on current retirement plans and benefits provided by your employer
• Statements reflecting current investments in retirement and non-retirement accounts
• Completed risk profile questionnaires or other forms provided by our firm It is important that the information and financial statements you provide are accurate. We may, but are not obligated to, verify the information you have provided, which will then be used in the financial planning or investment advisory process. Financial Planning Services Our services may involve consultation, analysis, and recommendations in the six areas of financial planning, which include (1) financial situation, (2) income taxes, (3) insurance, (4) investments, (5) retirement planning, and (6) estate planning. In order to determine a suitable course of action for an individual client, our investment advisor representatives will meet with you to gather all pertinent information and will assist you in determining your financial goals and objectives and the level of financial planning service that may best fit your needs. This review may include, but would not necessarily be limited to, investment objectives, consideration of your overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to your particular circumstances. We offer our financial planning services in the following forms: (1) a comprehensive financial plan, (2) a segmented financial plan, (3) an ongoing financial plan, and (4) individual consultations. Under each of these financial planning options, we will generally issue a written analysis and report of recommendations in accordance with your goals and objectives. Depending on the level of your financial planning needs, our written financial plans may include but would not be limited to the following topical areas:
• Prepare an annual net worth statement
• Create a cash flow statement
• Review current investments
• Review client’s most recent tax returns
• Review client’s life and disability insurance
• Review client’s estate plan
• Complete a retirement analysis
• Provide education planning advice We may offer projections of your likelihood of achieving your financial goal(s), including but not limited to retirement, education funding, charitable giving and wealth transfer. For situations in which projections show less than the desired results, we may make recommendations that include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the Page 6 of 28 likelihood of running out of money or having to adversely alter your spending during your retirement years. We will provide you with written recommendations and deliverables as specified in your engagement agreement. These recommendations or services may be broad-based or more narrowly focused, as you desire. Note that when these services focus only on certain areas of your interest or need, your overall financial situation or needs may not be fully addressed due to the limitations you may have established. In all instances, you will retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Further, it remains your responsibility to promptly notify us if there is any change in your financial situation or investment objectives for the purpose of our reviewing, evaluating, or revising previous recommendations and/or services. Upon completion of our presentation or delivery of advice, our financial planning engagement is typically concluded (unless we are engaged under an ongoing financial plan agreement); however, you are encouraged to contact our firm at any time in the future to re-engage our services. Individual Consultations We also provide advisory or consulting services not involving the other services previously described but still pertaining to investments or investment-related matters. As part of these services, we may or may not provide any written documentation or other work product. Such services may include the following:
• Insurance-related services and planning
• Consultation involving 401(k) or other forms of retirement plans
• One-time analysis of investment accounts/portfolios
• Telephonic, electronic, or in-person consultations/communications regarding investments or investment-related matters
• Serving as an expert witness in judicial or arbitration proceedings
• Conferring with other professionals or service providers (i.e., accountants, attorneys, etc.) regarding investments or investment-related matters on your behalf
• Other service as may be specifically requested We will not possess or exercise investment discretion with respect to this service offering. Depending upon the particular engagement, we may or may not produce written documentation that supports recommendations or conclusions reached as a result of carrying out these services. If you wish to engage us for services not specifically mentioned or referred to in the services noted above, you may provide us with guidance as to the scope of the engagement. Regardless of the services ultimately requested, the specific services and corresponding fees will be set forth in your engagement agreement. Page 7 of 28 Investment Supervisory Services You may also choose to engage our firm to implement the investment strategies we have recommended to you. Our strategies and primary choice of investment vehicles are described in further detail in Item 8 of this brochure. We provide our investment supervisory services under either a discretionary or non-discretionary account authority agreement (defined in Item 16), and our services generally include the following:
• Investment strategy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring
• Periodic rebalancing Where applicable, we will assist you in preparing an investment policy statement, or similar document, reflecting your investment objectives, time horizon, tolerance for risk, as well as any account constraints. Your investment policy statement will be designed to be specific enough to provide future guidance while concurrently allowing flexibility to respond to changing market conditions. Since the investment policy statement, to a large extent will be a product of information and data you have provided,

you will be responsible for reviewing and providing final approval of the document/plan. Retirement Plan Consulting Services We assist fiduciaries to and sponsors of 401K plans (“Sponsors”) in carrying out their duties to manage their 401K plan (“Plan”) in the best interests of plan participants. We provide fiduciary and non-fiduciary services tailored to each client we serve. This involves assisting plan fiduciaries with a systematic, objective approach to benchmarking the plan’s various service providers’ value relative to what is being provided for a plan of similar size and complexity. The Firm also performs consultative reviews of client’s fiduciary practices to assess whether the plan operates in accordance with sound fiduciary practices. These comprehensive assessments include reviews of the plan’s Investment Policy Statement (“IPS”), transparency of fees, and plan and trustees’ conflict of interest policies, among other items. Our services are provided based on the specific needs and characteristics of the 401K plan. If requested, we could serve as a 3(21) fiduciary or 3(38) fiduciary to the plan as defined under the Employee Retirement Income Security Act of 1974 (“ERISA”). We will not serve as the “administrator” of the client’s retirement plan as defined in ERISA. Fiduciary services may include:
• Work with the Sponsor to help coordinate the functions and activities of the Plan Investment Committee, including, ensuring that proper adherence to fiduciary obligations is met, including helping with the Plan Investment Committee’s agendas, minutes, coordinating functions and activities, and creating and establishing an IPS, if needed. Sponsor shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. Page 8 of 28
• Provide the Sponsor with general, non-discretionary investment advice regarding asset classes, vendors, platforms, and investment alternatives available for the Plan that are consistent with the Plan’s IPS. Sponsor shall have the final decision-making authority regarding the selection, retention, removal, and addition of any investment options.
• Recommend for selection by the Sponsor, specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, offered as investment options under the Plan consistent with the Plan’s IPS or other relevant guidelines, as applicable. We will recommend, for selection by the Sponsor, investment replacements if an existing investment is no longer suitable, and will assist in the transition to the replacement investment if requested by the Sponsor.
• Offer to meet with participants during scheduled meetings on a periodic basis. Based on the information provided by a participant concerning his or her retirement investments, time horizon, risk tolerance and investment goals, we will provide investment advice in the form of a recommendation to invest in a particular option under the Plan.
• Assist the Sponsor in monitoring investment options by reviewing investment reports, if available, that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. We will meet with Sponsor on a periodic basis to discuss the reports and the investment recommendations. In the event the Firm serves as a 3(21) fiduciary as defined under ERISA Section 3(21)(A)(ii), we will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause the Firm to be a fiduciary as a matter of law. However, in providing 3(21) fiduciary consulting services, the Firm has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of the client’s retirement plan documents. Clients who elect to implement any recommendations made by the Firm are solely responsible for implementing all transactions. In the event we serve as a 3(38) investment manager as defined under ERISA Section 3(38), we will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause the Firm to be a fiduciary as a matter of law. Non-fiduciary services include:
• Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Such education services may include providing Plan participants with information about the Plan, such as the overall benefits of Plan participation, the impact of preretirement withdrawals on retirement income, investment objectives and philosophies, and risk/return characteristics, as well as, general financial and investment information such as diversification and dollar cost averaging, educational Page 9 of 28 information about asset allocation models for hypothetical investors, and interactive investment materials to assist Plan participants in assessing their future retirement income needs.
• Assist with the annual plan design to determine if there are efficiencies that can be gained by plan design changes.
• Assist Client with group enrollment meetings designed to increase Plan participation among employees and investment and financial understanding by the employees. These meetings do not include recommendations with respect to any specific investment alternatives or options available to participants.
• Assist the Plan Fiduciary in the preparation, distribution, and evaluation of the request-for- proposal (RFPs), coordinate the finalist interviews, negotiate proposals, and facilitate the change of vendor (if changing vendors).
• Arrange for the Plan’s other third-party service providers to offer these services, as agreed upon between Adviser and Client. In such cases, Adviser acts only in accordance with instructions from the Client and shall not exercise any independent judgment or discretion. Customization of Our Advisory Services To the fullest extent possible, we will endeavor to tailor our advisory services to meet your specific needs. In order to determine a suitable course of action, we will perform a review of your financial circumstances and the review may include, but would not necessarily be limited to, investment objectives, consideration of your overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to your particular situation. You are free to impose reasonable restrictions or other conditions with regard to how we provide our advisory services. If we agree to such restrictions and/or conditions, be advised that your restrictions and guidelines may affect the composition and performance of your portfolio. General Information We do not provide legal or accounting services. With your consent, we may work with your other advisors (i.e., attorneys, accountants, etc.) to assist with coordination and implementation of accepted strategies. You should be aware that these other advisors will likely bill you separately for their services and these fees will be in addition to those of our firm. Our firm will use its best judgment and good faith effort in rendering its services. C & J Wealth Advisors cannot warrant or guarantee the achievement of a planning goal or any particular level of account performance or that your account will be profitable over time. Past performance is not necessarily indicative of future results. Clients should be aware of certain conflicts of interest that exist when we provide advice regarding qualified retirement plans. Our firm and our financial professional staff may recommend that the client withdraw the assets from their employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that C&J Wealth Advisors (or another adviser) will manage. If the plan participant elects to roll the assets to an IRA managed by our firm, the client will be charged an asset- based fee. This practice presents a conflict of interest because our firm and our financial professionals have a financial incentive to recommend the rollover to the client based on the potential revenues rather than solely on the client’s needs. Consequently, clients are never obligated to roll over their Page 10 of 28 qualified retirement plan assets, nor are they obligated to transfer the assets to our firm. Your financial professional should perform an analysis of the benefits of the rollover as well as what you will lose or the additional costs of a rollover. Ask your financial professional to go over this analysis with you before you make your final decision. Except as may otherwise be provided by law, our firm will not be liable to the client, heirs, or assignees for any loss that an account may suffer by reason of an investment decision made or other action taken or omitted in good faith by our firm with the degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use; any loss arising from our adherence to your direction or that of your legal agent; any act or failure to act by a service provider maintaining an account. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith, therefore, nothing contained in this document or client agreement shall constitute a waiver of any rights that a client may have under federal and state securities laws.