ALWM is owned by Robert J. Lucia and ALWM has been providing advisory services since 2004. As of December 31, 2023, ALWM managed $456,071,682 on a discretionary basis and $0 on a nondiscretionary basis. Investment Management Services: ALWM manages investment portfolios for individuals, qualified retirement plans, trusts and small businesses. ALWM will work with a client to determine the client's investment objectives and investor risk profile, and will design a written investment policy statement. ALWM uses investment and portfolio allocation software to evaluate alternative portfolio designs. ALWM evaluates the client's existing investments with respect to the client's investment policy statement. ALWM works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by ALWM. ALWM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. ALWM will typically create a portfolio of no-load mutual funds, and may use model portfolios if the models match the client's investment policy. ALWM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. ALWM primarily recommends portfolios consisting of passively managed asset class and index mutual funds. ALWM primarily recommends mutual funds offered by Dimensional Fund Advisors (DFA). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. ALWM manages portfolios on a discretionary basis. A client may impose any reasonable restrictions on ALWM’s discretionary authority, including restrictions on the types of securities in which ALWM may invest client’s assets and on specific securities, which the client may believe to be appropriate. ALWM may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. ALWM will request discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a third-party fixed income manager. ALWM will prepare a Fixed Income Investment Policy Statement for any client qualifying for separate fixed income portfolio services. Pursuant to its discretionary authority, ALWM will retain a fixed income securities manager. The fixed income securities manager will be provided with the discretionary authority to invest client assets in fixed income securities consistent

with the client’s Fixed Income Investment Policy Statement. The manager will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost basis information). The manager will obtain ALWM’s consent prior to the sale of any client securities. On an ongoing basis, ALWM will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. ALWM will periodically, and at least annually, review clients’ investment policy, risk profile and discuss the re- balancing of each client's accounts to the extent appropriate. ALWM will provide to investment manager any updated client financial information or account restrictions necessary for investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, ALWM may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: ALWM also provides advisory services to participant-directed retirement plans through third party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. ALWM will analyze the plan's current investment platform, and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. ALWM will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. ALWM will recommend changes in the plan's investment vehicles as may be appropriate from time to time. ALWM generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, ALWM also works in coordination and support with Buckingham Strategic Partners, LLC. Retirement plan clients will engage both ALWM and Buckingham Strategic Partners, LLC. Buckingham Strategic Partners, LLC will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintain the plans’ investments according to the goals and investment objectives of the plan. ALWM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan.