Firm Description Blue Water Capital Management, LLC (“Blue Water”) was founded in 2007. Blue Water is owned by Stephen Swift, John Paganelli, and Thomas Brown. Types of Advisory Services ASSET MANAGEMENT Blue Water offers discretionary asset management services to advisory Clients. Blue Water will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Blue Water discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Envestnet Blue Water may offer discretionary direct asset management services to advisory clients utilizing Envestnet’s wrap program described in detail in their appendix. The wrap program provides access to the portfolios on the Envestnet platform. Blue Water will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, assets allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize Blue Water discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. ERISA PLAN SERVICES Blue Water provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Blue Water may act as either a 3(21) and/or 3(38) advisor: Limited Scope ERISA 3(21) Fiduciary. Blue Water may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor Blue Water has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Blue Water can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Blue Water acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Blue Water’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Blue Water is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Blue Water may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. 3. Blue Water has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Blue Water on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ERISA 3(38) Investment Manager. Blue Water can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. Blue Water would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. 1. Fiduciary Services are:
• Blue Water has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment

options in accordance with the Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). 2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands the Blue Water’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Blue Water is not providing fiduciary advice as defined by ERISA to the Plan participants. Blue Water will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Blue Water may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Blue Water and Client. 3. Blue Water has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. FINANCIAL PLANNING AND CONSULTING We provide financial planning services. Financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client's income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client's cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Blue Water. Financial plans will be completed and delivered inside of sixty (60) days contingent upon timely delivery of all required documentation. SEMINARS AND WORKSHOPS Blue Water holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Blue Water does not sponsor any wrap fee programs. Client Assets under Management As this is the December 31, 2022, Blue Water managed $150,198,210 of clients' assets on a discretionary basis.