A. Description of Your Advisory Firm Southern Wealth Management, LLP (“Southern Wealth” or “the firm”), is a limited liability partnership formed under the laws of the state of Texas and is principally owned by Richard Jones, Thomas Gile, and Michael Olson. Southern Wealth is an independent wealth management firm that has been offering investment advisory and financial planning services since April 2005.
B. Description of Advisory Services Offered Southern Wealth is an independent investment advisory, financial planning, and tax firm offering a variety of financial services to individuals and high-net-worth individuals, trusts, retirement plans, pension and profit sharing plans, charitable organizations, tax exempt, corporations, and other business entities. Advisory services may include investment strategy, portfolio management, financial and estate planning, accounting, tax preparation, tax compliance, business valuation, selection of other advisers, and consulting services. Southern Wealth provides its investment advisory services on a non-discretionary basis. Portfolio Management Services Southern Wealth provides continual advice to clients regarding investment of funds based on their individual needs. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, Southern Wealth develops a personal investment policy and creates and manages a portfolio based on that policy. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). Southern Wealth will create a portfolio consisting of one or all of the following: individual equities, bonds, other investment products, and no-load and load-waived mutual funds. Southern Wealth will allocate the client's assets among various investments, taking into consideration the overall management style selected by the client. Mutual funds will be selected on the basis of any or all of the following criteria: ▪ the fund's performance history ▪ the industry sector in which the fund invests ▪ the track record of the fund's manager ▪ the fund's investment objectives ▪ the fund's management style and philosophy ▪ the fund's management fee structure Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments that will be made on their behalf. Clients will retain individual ownership of all securities. When appropriate to the needs of the client, Southern Wealth may recommend the use of option writing. Because this investment strategy involves certain additional degrees of risk, it will only be recommended when consistent with the client's stated tolerance for risk. In addition to its own portfolio management services, Southern Wealth provides access to investment service programs in which client accounts are managed by independent third-party investment advisers. These programs provide additional investment opportunities among mutual funds, variable annuities, stocks, bonds and additional securities. Based on a client's individual circumstances and needs, Southern Wealth will recommend an appropriate investment program to the client. Factors considered in making this recommendation include account size, risk tolerance, the opinion of each client, and the investment philosophy of the third-party independent adviser. Southern Wealth will assist the client in reviewing the client's income and expenditures, investment objectives, risk tolerance, liquidity requirements, investment restrictions, and other relevant factors. Southern Wealth will provide this information to program sponsors selected by the client. Southern Wealth will meet with the client on a regular basis as determined by the client to review the account. Southern Wealth will contact the client on at least an annual basis to review the client's investments. Southern Wealth will also provide updated information about clients' financial circumstances as necessary to program sponsors. During regular account reviews, if Southern Wealth believes a different program becomes more suitable for a client's particular needs, then the firm may suggest that the client contract with a different program sponsor. In such a case, Southern Wealth will assist the client in selecting a new program. However, any move to a new program is solely at the discretion of the client. Third-party investment programs generally include services by independent investment advisers consisting of proprietary model portfolios. The independent investment advisers manage model portfolios based on the goals of the portfolio rather than the individual circumstances of any client account. Model portfolios may include mutual funds and/or insurance products, or also individual stocks and bonds. The investment

adviser representative of Southern Wealth may assist the client to determine the appropriate asset allocation among available portfolios. In addition to providing Southern Wealth with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. On a quarterly basis, Southern Wealth’s reports to clients will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. Southern Wealth will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Financial Planning Services Southern Wealth also provides advice in the form of a financial plan. Clients purchasing this service will receive a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the financial plan will address any or all of the following areas of concern: ▪ General Financial Planning: Includes professional services such as estate and gift planning, tax projections, long-term cash flow planning, and charitable planning. Fees for such services are assessed on an hourly basis. ▪ Personal: Family records, budgeting, personal liability, estate information, and financial goals. ▪ Tax & Cash Flow: Income tax and spending analysis and planning for past, current, and future years. Southern Wealth will illustrate the impact of various investments on a client's current income tax and future tax liability. ▪ Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning, and disability income analysis. ▪ Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. ▪ Investments: Analysis of investment alternatives and their effect on a client's portfolio. ▪ Bill Payment Services: For certain of its family office clients, as mutually agreed between the client and SWM, the firm will provide bill paying services. Such services will be billed in accordance with the firm’s financial planning fee arrangements. Southern Wealth gathers required information through in-depth personal interviews. Information gathered includes a client's current financial status, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed and an appropriate document is prepared. Should a client choose to implement the recommendations contained in the plan, Southern Wealth suggests the client work closely with his or her attorney, accountant, insurance agent, and/or stockbroker or investment adviser. Implementation of financial plan recommendations is entirely at the client's discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Please note: While some of our advisory professionals are CPAs, Southern Wealth is not a CPA firm and does not provide accounting or attest services. Consulting Services Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area of concern, such as estate planning, retirement planning, reviewing a client's existing portfolio, or any other specific topic. Southern Wealth also provides specific consultation and administrative services regarding the investment and financial concerns of the client. Additionally, Southern Wealth provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Valuation Services The firm offers valuation services primarily for family limited partnerships, trust and related entities. The firm does not offer valuation services for businesses in the M&A context. C. Client-Tailored Services and Client-Imposed Restrictions Clients’ accounts will be managed on the basis of their financial situation and investment objectives, and in accordance with any reasonable restrictions they have imposed on the management of their accounts—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs Southern Wealth does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) E. Client Assets Under Management As of December 31, 2022, Southern Wealth managed $1,816,152,410 of discretionary assets and $520,749,509 of non-discretionary assets.