FWAM, branded as FamilyWealthsm, is a registered investment adviser that offers investment advice, portfolio management, securities and other financial services to Clients. FWAM is registered through and regulated by the SEC. FWAM was founded with a vision to provide wealth management solutions through registered investment advisors (“RIAs”) and investment adviser representatives (“IARs”) to its Clients, which includes individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments, corporations and small businesses (collectively, “Clients”). FWAM uses the FamilyWealth™ platform (“Platform”) to provide its IARs with a comprehensive view of Clients’ portfolios. The Platform is built upon third-party software, with additional Client Relationship Management (“CRM”) functionality. The Platform also contemplates and makes available the Turnkey Asset Management Program models it offers, as explained in the subsection below entitled “Investment Programs.” The Platform enables the provision of risk management techniques, facilitates a broad range of investment options, and supports better relationships with Clients. The integrated Platform makes it easy to execute, manage and track Client portfolios with:
• Client management: CRM technologies, Client profiling and asset allocation review;
• Investment management: Research, rebalancing, trade order and portfolio management;
• Performance monitoring: Data aggregation, reconciliation, performance reporting;
• Operational support: Back-office support, billing, compliance tools, websites and consultants; and
• Advisory Services Offerings. The integrated Platform generally provides IARs:
• Access to multiple institutional asset allocation strategists (“Institutional Strategists”);
• Model portfolios designed to cover a number of standard risk/return profiles;
• Access to systems including tools for set-up of Client accounts, Client proposals, investment policy statements, Client agreements and the ability to view and manage Client data;
• Research, timely information and recommendations regarding the qualifications, investment philosophies, policies, and performance; and
• Preparation of periodic performance measurement reporting regarding Clients’ assets invested through the Platform. Dynamic asset management is a cornerstone of FWAM’s investment philosophy. In practice, this means that FWAM creates investment strategies that cross over single asset class boundaries. This allows FWAM to offer portfolios that are structured so that a lack of performance in one asset class is offset by over- performance in another asset class. We can invest in, and/or seek market opportunities in domestic and international companies and markets, via direct or indirect market exposure/participation, to help FWAM achieve global diversification with the objective that no one market or asset impairs Clients’ ability to grow their capital. By pairing dynamic asset management with the FamilyWealth™ Platform, we can better allocate a Client’s investments across different classes and use excess returns in one asset class to protect against the downsides in another asset class, without resorting to classes that have much higher volatility to achieve desired returns. The FamilyWealth™ Platform also provides retirement plan consulting and retirement plan management services. These services encompass plan design, investment policy reviews, ERISA fiduciary services and participant services, among other services. We also may recommend insurance products as part of our overall advisory service. We manage accounts on a discretionary and non-discretionary basis. If we manage your account on a discretionary basis, then you have given us the authority to determine the following without your consent for each transaction:
• Securities to be bought or sold for the account; and
• The amount of securities to be bought or sold for the account. While we may have trading discretion on your account (e.g., placing trades in your account without your approval), we are not authorized to withdraw any money, securities or other property from your account. We may have to trade in your account to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after your request for a withdrawal that requires liquidation of a position. Also, if there is inadequate cash balance in your account to pay for our investment adviser fees, other liquidations may need to occur. Aside from deductions from the account for our fees, any monies or securities withdrawn from the account may only be sent to you, for your benefit. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your investment program allocation. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice; however, we will work with your tax professionals to assist you with tax planning. You will have the opportunity to meet with us periodically to review the assets in your account. 1. Asset Management Services Asset management is the professional management of securities (stocks, bonds, mutual funds, Exchange- Traded Funds (“ETFs”) and other securities) and advice on non-securities assets (e.g., real estate), which form part of your overall wealth/financial condition, in order to meet your specified investment goals. With a Separately Managed Account (“SMA”), Clients engage us to assist in developing a personalized asset allocation program and portfolio designed to meet the Client’s investment objectives. The investments in the SMA may include, but are not limited to, mutual funds, stocks, bonds, equity options and ETFs. We provide investment advisory services to both retail Clients (smaller accounts of individuals, IRAs, trusts & employee benefit plans) and institutional Clients (larger accounts of corporate pension plans, public funds, foundations, & other tax-exempt entities). We believe that a flexible and opportunistic investment approach is vital for investors seeking a balance of risk and return. We also believe that a multi-asset class investment solution that dynamically adjusts to global market conditions fills this need. Investment Philosophy When the outlook for fundamental investment strategies evolves, portfolios must be able to evolve and adjust in an opportunistic and flexible manner to take advantage of market conditions. Portfolio Managers (“Managers”) need to deliver expertise and utilize sophisticated technology systems that can manage risk on an intraday basis, with deep, high-quality research across asset classes. Managers with multi-asset expertise are especially relevant in today’s environment when investors are confronted with low expected returns, low growth, and relatively over-valued assets with higher levels of volatility. One of our objectives is to construct portfolios in a manner similar to pension funds, by thinking about the objective of payment liabilities. Our focus is not only on accumulation, but distribution, and whether the Client’s asset level will meet their income objective as well as their objective for asset transfer to their heirs or charity. To achieve this goal, our philosophy is to blend passive, active, and alternative strategies. Passive investing offers the advantage of cost efficiency and ease of understanding, while active and alternative investments have the opportunity to generate excess return against its objective benchmark over time but are more expensive and complicated. Based upon the Client’s risk exposure, we allocate into a passive exposure with low cost and pair it with a high conviction, high active-share strategy. We use passive strategies in markets where there is potentially less excess return opportunity – for instance, U.S. Large cap stocks. Then, we “spend” or apportion both risk and fee budget in parts of the market where there is opportunity – emerging markets, small cap and alternative investments. The potential for outperformance is not merely because the market (i) misprices small caps or emerging market stocks and (ii) is less efficient. It is predominantly dispersion. Dispersion can be thought of as the spread between the best and the worst performance in the market. Active management allows us to manage risk and downside protection. Investors can get the benefit of lower fees in their core assets and pay active management fees for true active management that may produce returns that exceed the market or allow for downside protection. Our investment philosophy allows for a shift toward considering absolute risk and return, and active and passive strategies can be used together to produce returns with appropriate risk. We believe absolute risk is more important than relative risk when moving to a higher conviction equity strategy. Advisory Services The FamilyWealth™ Platform will assist clients and investment advisers in providing the following services when contracted to do so by the Client:
• Review your present financial situation;
• Monitor and track assets under management;
• Provide portfolio statements, periodic rate of return reports, asset allocation statements and rebalancing activity as needed;
• Advise on asset selection;
• Determine market divisions through asset allocation models;
• Provide research and information on performance and fund management changes;
• Build a risk management profile for you;
• Assist you in setting and monitoring goals and objectives; and
• Provide personal consultations as necessary upon your request or as needed. The Client shall have the ability to impose reasonable restrictions on the management of accounts, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may relate to a specific company security, industry sector, asset class, or any other restriction requested that can be implemented in practice. The more specific the request, the more effective any implementation could be. For example, rather than instructing us to avoid investing in “sin stocks,” it would be easier to obtain specific industry guidance such as avoiding investment in tobacco companies. Also, since mutual funds have broad exposure in many cases, it would be useful to know whether an investment that creates investment exposure to the tobacco industry that is less than some de minimis percentage (e.g., less than 5% of gross income of the operating company invested in ….) would still be acceptable. The Client must notify FWAM promptly when such Client’s financial situation, goals, objectives, or needs change. Under certain conditions, securities from outside accounts may be transferred into your advisory account. However, we may recommend that the Client sell any security if FWAM believes that such security is not suitable for the current recommended investment strategy. The Client and FWAM may agree to exclude such “legacy” assets from FWAM’s fee invoice if such assets are not subject to ongoing advice and management but are rather assets that the Client does not want to sell for personal reasons. However, if the Client agrees to sell such assets, then the Client is responsible for any taxable events in these instances. We do not provide tax advice or tax management services. While your account can be managed in a tax- sensitive manner, and since we do not provide tax advice or tax management services, Clients should always consult with a tax advisor for specific tax advice. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. However, past performance is not a guarantee of future performance. If the Client decides to implement our recommendations, we will help the Client complete the necessary paperwork to open custodial account(s). Clients must send funds directly to the custodian. The identity of your custodian will be communicated to you before the account is opened. You will enter into a separate custodial agreement with the custodian. This agreement, among other things, authorizes the custodian to take instructions from us regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. The custodian will effect transactions, deliver securities, make payments and do what FWAM instructs regarding transactions. The ability to change your address shall, however, remain within your control, and, for regulatory reasons, FWAM shall take the necessary steps to prevent it from having the authority to change your address- of-record with the custodian; such instructions should come directly from you. Also, for regulatory reasons, you should forward any payments and securities directly to the custodian, and NOT to FWAM. All checks and payment orders should be made payable to the custodian or the issuer (such as a mutual fund, if FWAM operationally enables such “Application-Way” business). You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. You will receive, at least quarterly, a statement containing a description of all the activity in your account. This statement lists the total value at the start of the month, itemizes all transaction activity during the month, and specifies the types, amounts, and total value of securities held as of the end of the month. Your statement may be in either printed or electronic form based upon your preferences. Clients are encouraged to review the statements from the custodians and inform FWAM if any errors or anomalies are found. Also, any statement provided by FWAM is NOT the official statement of your investments (e.g., such as the quarterly performance statements referenced below), but are provided as a courtesy. The statement provided by the custodian(s) are your official statements of your investment positions and you are encouraged to review them upon receipt. When reviewing your account with your IAR, you may be provided a quarterly performance report. These statements give you additional feedback regarding performance, and helps your IAR educate you about our long-term investment philosophy, describe any changes in current strategy and allocation, along with the reasons for making any changes. We are available during normal business hours either by telephone, email, or in person by appointment to answer your questions. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. Our meeting will include your completion of a Risk Tolerance Questionnaire and providing other information in order to generate an Investoment Policy Statement, which will assist us in defining/ascertaining your financial objectives and other relevant parameters for us to advise or manage your account. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information as applicable. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy using the Platform. Once accounts have been set up, we have access to comprehensive data, and can track Clients’ portfolios against their own goals, rather than just broad benchmarks, while enhanced reporting allows us to revise or redirect plans and strategies along the way. Our recommendations and ongoing management are based upon your investment goals, objectives, risk tolerance, and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in quarterly and annual account reviews by your IAR. These reviews will be conducted in person, by telephone conference, and/or via a written inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation, as well as rebalance your portfolio when warranted to maintain alignment with your investment objectives. If the IAR determines that your portfolio materially deviates from the target allocation or an allocation deemed more desirable in light of current market conditions, the IAR may rebalance your portfolio. 2. Investment Programs The Platform offers IARs an opportunity to provide Clients with an effective and efficient asset management system and allows them to focus on Client service functions instead of managing individual investments. Our investment programs can be considered as falling into the following service models: The Platform helps IARs and advisers to deliver customized solutions, ranging from adviser–managed or third-party managed solutions, including strategists and separate account managers. As a one stop platform, the Platform makes it easy to execute, manage and track Client portfolios with:
• Quarterly performance reports (branded with IAR or registered investment adviser firm information when applicable);
• Investment Policy Statements (“IPS”) and proposal generator;
• Advisor as manager, including model level management; and FamilyWealth™ Portfolio Manager TAMP Third Party Institutional Strategists Third Party Separate Account Managers Overlay Management Family CIO Services Solicitors Institutional Services Financial Planning/Consulting
• Online pre-populated paperwork. We obtain information from a wide variety of publicly available sources. We do not have any inside, non- public information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. If your account is management on a “non-discretionary” basis, choosing which advice to follow is your decision. Also, for accounts managed on a discretionary basis, you can choose which discretion, and how much discretion to provide to your IAR, and can revoke such decisions at any time by written notification. FamilyWealth™ Portfolio Manager FamilyWealth offers access to several levels of asset management through the FamilyWealth™ Portfolio Manager, also known as Rep as Portfolio Manager (“RPM”). These options offer greater or lesser degrees of management and sophistication, and differ in terms of type of investments offered, the asset management firm’s responsibilities, overlay capabilities, and costs. By offering each of these options through a single platform, advisers and firms can efficiently service a broad spectrum of Clients, from mass-market to mass-affluent and all the way up to ultra-high- net-worth individuals and households. The FamilyWealth™ Platform makes sophisticated solutions a realistic option for nearly any investor and provides IARs with the tools they need to reach many segments of the market with a high degree of choice. In using the Platform, Clients pay a fee to use the Platform to FWAM. FWAM provides certain services to Clients’ accounts that are opened through the Platform. These services generally include:
• Exercising discretion on whether, how and when to implement transactions in a Client’s account based on the Strategist(s), Manager(s), and type of account(s) selected by IAR and Client; and
• Arranging for the execution of trades in Clients’ accounts (except for accounts invested in Separately Managed Account Portfolios. A Client’s IAR is generally responsible for:
• Ensuring Client portfolios are not only suitable for the Client, but designed for the best interests of the Client, considering the investment objectives, goals, risk tolerance, liquidity needs, etc., both initially and going forward; and
• Selecting and changing the Strategists and Managers in Clients’ accounts that we make available through the Platform in accordance with such objectives and goals. Clients should carefully review the executed investment management agreement with their IAR, FWAM’s disclosure brochure, and the brochure supplement of the IAR. Also, you should receive and review our Form CRS, which is a succinct disclosure form required of registered investment advisers. The IAR is responsible for delivering these items to each Client, in addition to determining the suitability of Platform services, Strategists, Managers, and the type of accounts listed below for their Clients. Mutual Fund Allocation Portfolio Strategy: The most basic type of portfolio is the mutual fund allocation, in which multiple mutual funds are selected from a broad array (based on asset allocation guidelines) and managed as a single account. This method provides transparency and simplicity, offering an alternative to upfront commissions or surrender charges. In this approach, our investors may utilize the mutual fund/TAMP platform of FWAM and pay a platform fee to FWAM to access those mutual funds and any associated investment models and/or support services. Exchange-Traded Fund (ETF) Allocation Portfolio Strategy: The next level of an outsourced portfolio solution is the ETF portfolio strategy. In this type of account, investments are held solely in ETFs, while portfolio construction is based on an asset allocation model and is monitored in light of market changes. The fee is asset-based, and the adviser typically pays for transaction costs. ETFs often have lower expense ratios than mutual funds and offer added benefits such as intraday trading and tax efficiencies. Separately Managed Account (SMA): SMA is a portfolio of individual securities managed by a single investment manager in a particular type of style and offered to the investor by a sponsoring firm. A fee- based SMA program can utilize multiple SMAs, while a single SMA can also form a single “sleeve” within a Unified Managed Account structure (discussed below). In general, the main difference between an SMA and a mutual fund is that, in the former, the investor directly owns the securities instead of owning a share in the pool of securities. Unified Managed Account (UMA): Offering a much higher level of sophistication is the UMA, which is a single fee-based account that combines numerous investment products within separate account sleeves. Offering a UMA requires that the IAR manage the Client on a platform optimized for UMAs. Management between sleeves can then be determined by an overlay process to help gain tax and trading efficiencies. UMAs typically are held by a single custodian, but the FamilyWealth™ Platform allows for aggregation across multiple custodians. Unified Managed Household Account (UMHA): The last level is the UMHA, which is similar to the UMA except that it brings together all aspects of a Client household’s wealth, not just that of a single individual. UMHA platforms allow for a more holistic approach that better mirrors how a wealthy household tends to think about its wealth. It can encompass all of the following: qualified and nonqualified accounts; alternative investments; real estate; collectibles; oil and gas partnerships; limited partnerships; managed futures accounts; and more. The UMHA has a single registration and can aggregate across multiple custodians and could be considered as the pinnacle of service in managed accounts. The holistic view that is provided by this aggregation can allow advisers or IARs to charge fees on held-away assets that come under their reporting and overview capabilities/responsibilities. Growth

in both UMAs and UMHAs will likely accelerate among high-net-worth Clients due to their preference for and the benefits of holistic wealth management. Turnkey Asset Management Program Clients who use the FWAM Turnkey Asset Management Program (“TAMP”) models are often clients of our affiliated registered investment advisor firm FamilyWealth Advisers, LLC (“FWA”) and will be considered Clients of both FWAM and FWA. FWAM operates the models and FWA either (i) serves as a portfolio manager for the Clients using the models, or (ii) FWA could merely conduct initial Client profiling. Both FWAM and FWA provide continuous and regular supervisory services. The Client can defer to FWAM for ongoing services, such as acting as the portfolio manager and operator of the models. In other words, when FWA recommends a Client use the FWAM TAMP program, IARs of FWA may serve as a portfolio manager to make their own product recommendations to fulfill the model parameters (developing customized portfolios), or may defer to FWAM (a) to manage the accounts according to the model’s parameters and (b) select the products determined by FWAM to fulfill the model parameters. In both cases, FWA would take care of the Client “onboarding,” assessment of the investment objectives, risk tolerance and other customers-specific needs, whereas FWAM would have a relationship with the Client insofar as it would implement the models for each account that utilizes the models. The TAMP helps advisers/IARs to deliver customized solutions, whether they are adviser-managed or third-party managed, including strategists and separate account managers. The TAMP makes it easy to execute, manage and track Client portfolios with:
• Professional, private-labeled Website, plus proposals and quarterly performance reports branded with separate registered investment adviser’s data or may be personalized for IARs of FWAM/FWA Clients;
• Private-labeled proposal generator;
• IAR as manager, including model level management;
• Innovative time-savers, including an online proposal generator and pre-populated paperwork; and
• Dynamic, private-labeled performance reporting. Through this TAMP, we provide the following areas of expertise and the ability for registered investment advisers to use in delivering high quality services to Clients:
• Client management: CRM technologies, Client profiling and asset allocation review;
• Investment management: Research, rebalancing, trade order and portfolio management;
• Performance monitoring: Data aggregation, reconciliation, performance reporting; and
• Operational support: Back-office support, billing, compliance tools, websites and leads to consultants for additional support. The Platform generally includes:
• Access to multiple Institutional Strategists;
• Model portfolios designed to cover a number of standard risk/return assumptions;
• Access to software including tools for onboarding Client accounts, Client proposals, Investment Policy Statements, Client agreements and the ability to view and manage Client data;
• Research, timely information and recommendations regarding the qualifications, investment philosophies, policies and performance;
• Preparation of periodic performance measurement reporting regarding Clients’ assets invested through the TAMP. FWAM provides certain services to the Client accounts that are opened through the TAMP. These services include:
• Exercising discretion on whether, how and when to implement transactions in a Client’s account based on the model(s) selected by adviser or IAR and the Client; and
• Arranging for the execution of trades in Client’s accounts (except for accounts invested in SMA portfolios. A Client’s IARs are generally responsible for:
• Ensuring Client suitability and determining Client investment objectives and goals, both initially and on an ongoing basis; and
• Selecting and changing the individual securities or model portfolio(s) in Client's account(s) that we make available through the TAMP in accordance with such objectives and goals. Clients should carefully review the executed investment management agreement with their IAR, as well as the brochure for the registered investment adviser that introduced the account to FWAM and the TAMP models. The IAR is responsible for delivering these items to each Client. FWAM manages the TAMP models. FWAM’s Investment Committee evaluates and selects the investments to be used by the models, including target allocation and cash levels as determined by the portfolio’s investment guidelines. These models offer investment opportunities for particular asset allocation strategies. Assets may be invested in a range of market sectors and/or asset classes (e.g., large cap, small/med cap, international or high yield income) represented by any number of underlying funds (typically at least five at any given time). It is anticipated that any given time, the underlying funds in which the model invests may fall anywhere on the entire spectrum of asset classes and sectors currently available. At any given time, an underlying equity fund in which the models invest may buy “growth” or “value” stocks, or some combination of both. FWAM reviews and rebalances the underlying funds in which the model invests, as may be necessary, to reflect its current analysis of the approximate mix of assets among and within asset classes and sectors. FWAM monitors the investment objectives at the model level and assesses model effectiveness and predictable and reliable investment results. As a means to pursue various investment objectives, the models themselves are intended to be used so that invested assets remain fully invested in shares of underlying investment companies at all times, unless or until, of course, they are no longer suitable for the underlying investor. The models may, however, pursue an investment strategy of investing its assets directly in securities in lieu of indirect investment through other investment companies. The model’s direct investment will remain consistent with its asset allocation strategy and, in the case of collectively managed investments such as mutual funds, will typically be close or identical to those securities held by one or more of the underlying funds in which the models currently invest. In addition, under adverse market or other conditions, the models may adopt a temporary defensive position and invest a portion of its assets in cash or similar investments. These models may be appropriate for advisers and Clients that do not have the time or the experience to choose from a list of mutual funds and create their own portfolios that offer a single investment option blended with stocks, bonds, and short-term investments. Choosing a managed portfolio can provide an easy solution to Clients who want the convenience of professional management, including asset rebalancing and professional oversight. Third Party Institutional Strategists Some of the Managers available on the Platform are accessed through the use of Third-Party Institutional Strategists (“Strategists”) where an asset manager constructs an asset allocation and selects the investments for each portfolio model. FWAM may provide overlay management by implementing trade orders and periodically updating and rebalancing the models per the direction of the third-party manager. Strategists are subject to change and may not always be available on the Platform. Third Party Separate Account Managers SMA Managers construct portfolios of individual securities with a specific objective, style and risk. Clients may utilize multiple SMA Managers, while a single SMA can also form a single “sleeve” within an UMA structure. FWAM may provide overlay management by implementing trade orders and periodically updating and rebalancing the models per the direction of the third-party manager. Third Party SMA Managers are subject to change and may not always be available on the Platform. Overlay Management FWAM provides overlay management services utilizing the Platform to track a Client’s combined position from the separately managed accounts. Clients utilizing different Managers can create inefficiencies and increase the risk to the overall portfolio, have negative tax effects, or unbalance the Client’s positions. Any possible portfolio adjustment will be analyzed by the Platform, which ensures the overall portfolio will remain in balance and prevent any inefficient transactions from occurring. Family CIO Services By monitoring the household account, FWAM can address the complexities of high-net-worth families working with different custodians and advisers. We will diligently advise and manage aggregate household wealth as well as serve as sleeve and portfolio managers in each account. FWAM may or may not make tactical investment allocations for certain parts of the overall household assets, but by maintaining a view of how the disparate parts are affecting each other, we can help families make important decisions for household asset allocation. Solicitors For Clients referred to us by a solicitor, the Client will typically enter into an investment management agreement directly with FWA and FWA will be the adviser. If FWA utilizes a solicitor, and pays a fee for such solicitations, then you should receive from the IAR/solicitor a separate “Solicitor Disclosure Statement” regarding the arrangement and the fees. For these Clients, FWAM will provide the services outlined above, which include, but are not limited to:
• Providing tools to assess suitability of the Strategist(s), Manager(s), and type of accounts selected by the investment advisor and Client;
• Exercising discretion regarding whether, how and when to implement transactions in a Client’s account based on the Strategist(s) and Manager(s) selected by the Client;
• Arranging for the execution of trades in Clients’ accounts (except for accounts invested in SMAs, as described above); and
• The complete services provided by FWA as the adviser will be explained in the
• Agreement executed between FWA and the Client. Depending on the type of arrangement made between FamilyWealth℠ and the Solicitor, the Solicitor may assist the Client in completing account applications and other applicable forms and submit them to FWA/ FWAM. The Solicitor, if properly licensed to provide advice, may obtain information from the Client regarding the Client’s investment objectives and financial situation and may assist the Client in determining a suitable Strategist(s), Manager(s), and type of account(s) based on such objectives and financial information. On the other hand, if the Solicitor is not registered (meaning the Solicitor is not an IAR), then the Solicitor may only provide Solicitor disclosure information and then “step away” – referring the Client to FWA/ FWAM. In either case, the Client is ultimately responsible for making the final selection of Strategist(s), Manager(s), and type of account(s). The Client is further responsible for promptly notifying FamilyWealth℠ in writing of any change in the Client’s investment objectives, financial situation, and/or the selection of Strategist(s), Manager(s) and type of account(s). For Clients referred to FWA/ FWAM by a Solicitor, both FWA and FWAM reserve the right not to accept and/or terminate the account if FWA/ FWAM believes at any time, based on information provided by the Client, that the Strategist(s), Manager(s), and type of account(s) selected by the Client is neither suitable, nor in the best interest of the Client. Furthermore, FWA/ FWAM will honor the Client’s decision to not change the selection of Strategist(s), Manager(s), or account types, at the Client’s sole discretion. Institutional Services If you are an institutional Client, your accounts are managed in accordance with the investment objectives, guidelines & restrictions you establish. Purchases and sales of securities for your accounts are executed by either broker-dealer firms we select or broker-dealers that you request. We generally impose a minimum dollar amount of $500,000 of assets for institutional accounts, although smaller accounts may be accepted depending upon the specific circumstances of an account. Financial Planning/Consulting We do not have a significant amount of Clients seeking comprehensive financial planning, but, in select cases, we provide comprehensive financial planning, estate planning, business planning and educational planning. Fee-based financial planning is a comprehensive relationship that incorporates many different aspects of your financial status into an overall plan that is tailored to meet your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.), as necessary. If you utilize only financial planning services, and not continuous and regular management services, then the fiduciary duty of FWAM ceases upon the delivery of the financial plan. If FWAM is being requested to make an initial asset allocation based upon the financial plan, but not provide continuous and regulatory management services, then the fiduciary duty ceases upon making the initial asset allocation. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. If we engage in such services in the future, and if you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. Other Services Through our IARs who may be licensed independently as an insurance agent, or through Family Wealth Agency, LLC (“FW Agency”), Client may purchase insurance products. FW Agency is a separate, but affiliated company of FWA. Through one of those two (2) avenues, our personnel may recommend and sell life, annuity, disability, and long-term care insurance. In those cases, either the IAR, as an independent insurance agent, or FW Agency will receive the usual and customary commissions associated with these sales from the insurance company. You will not pay a separate investment advisory fee for these assets/products. Also, your advisory fee will not be reduced by any payments we receive from these sales. 3. Retirement Plan Consulting For FWAM’s Retirement Plan accounts, our service begins with an analysis of the current retirement plan structure, custodian, third party administrator, daily recordkeeper, investments, managed investment models, and fees. The analysis is designed to determine if we are able to add value to the plan and, if so, in what areas. We also comment if we feel the plan maybe deficient from both a regulatory perspective and from a financial advisory perspective. We will offer you one or more of the following services:
• Plan design and asset selection consultation;
• Develop and annually review an IPS;
• Develop an investment menu according to the IPS;
• Review plan sponsor’s stated financial criteria for each investment option;
• Monitor each investment option according to the IPS;
• Quarterly portfolio statements, rate of return reports, asset allocation statements;
• Provide investment research and performance information on investment options;
• Investment option replacement guidance;
• Personal consultations with the plan sponsor, as necessary;
• Advise on or develop and plan the Investment Committee Charter, as needed;
• Fiduciary due diligence assistance;
• Attendance at Plan Committee and other meetings;
• Annual Fiduciary Plan Review;
• Fiduciary education services to Plan Committee;
• Participant education, guidance, and enrollment;
• Vendor coordination assistance; and
• Benchmarking services. ERISA Fiduciary Services When delivering Employee Retirement Income Security Act of 1974, as amended (“ERISA”) fiduciary services, we will perform those services for the retirement plan (“Plan”) as a fiduciary under ERISA Section 3(21)(A)(ii) or 3(38) and will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Such Plan fiduciary designation must be reflected by the Plan Administrator or by the Plan itself in a formal designation of role, and, in those cases, FWAM requires a separate Plan Fiduciary Agreement. In our capacity as an ERISA Plan fiduciary, we will conduct research to determine the core investment options for the Plan. We will consider the size of the Plan, number of participants, and the demographics of the employees to assist the Plan sponsor in determining the appropriate investment(s) options for the Plan. In our capacity as a Plan fiduciary, we will select a diverse core of investment options. We will monitor and change the investment options included in the Plan offered to Plan Participants from time-to-time as determined by us, solely in our discretion. The investment options will generally include multiple asset classes of mutual funds, SMAs and ETFs. We also encourage Plan sponsors to consult with other professional advisors since we do not provide tax or legal advice that may affect asset classes or allocations. We will apply any guidelines our Client supplies, as directed. However, compliance with these restrictions or guidelines is our Client’s responsibility. Plan Structure We will assist our Client in evaluating the current Plan’s structure to determine if a change in the design of the Plan better suits the needs of Plan participants. We will facilitate any changes with the appropriate parties, including the third-party administrator, recordkeeper, and custodian, as well as facilitating the execution of the required Plan document amendments or new Plan documents. However, we will not draft any Plan amendments; a Third-Party Administrator (“TPA”) will need to perform this service. Investment Committee If FWAM deems that the establishment of an Investment Committee (“Committee”) is appropriate for you, FWAM will assist you in establishing such Committee, in addition to establishing a formal Committee Charter, delineating Committee responsibilities, determining fiduciary roles and the scope of such roles. The Committee may be charged with the fiduciary responsibility of the prudent selection and oversight of the investment options, selecting and retaining professional advisors for the Plan, including investment managers, recordkeeper, custodians, TPAs, and the establishment, execution, and interpretation of an IPS for the Plan. Investment Policy Statement Service FamilyWealth’s Investment Policy Statement Service is designed to assist you in creating a written IPS to document the Plan’s investment criteria, demographics, goals and objectives, as well as certain policies governing the investment of assets. The IPS serves as a guide to assist the Committee in effectively supervising, monitoring, and evaluating the investment of the Plan’s assets. It is the Client’s responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. It is the Client’s responsibility to confirm the Committee’s acceptance of the IPS, and it is the Committee’s responsibility to adhere to the IPS in managing the Plan. We encourage you to review accounts periodically to verify Committee’s compliance with the IPS. Investment Selection, Monitoring, and Replacement As the fiduciary under ERISA Section 3(21)(A)(ii) or 3(38) to the Plan, we will assist the Committee in selecting the core investment line up, including evaluating SMA Managers, mutual funds, ETFs, Collective Investment Trusts and money market funds which may be retained or replaced. Past performance of the core investment options and the indices that correspond to the core investment options may not be representative of actual performance, or indicative of future performance. Before a specific investment is selected, other factors such as fiscal and economic trends, which may influence the choice of investments and risk tolerance, should be considered. We have the responsibility and authority to recommend the investment options/recommendations, including evaluating investment managers and SMA Managers, mutual funds, ETFs, Collective Investment Trusts, and money market funds, which may be retained or replaced. The Plan sponsor has the responsibility and authority to make the final decision regarding which investments to include in the model portfolio and when to add or exclude a specific security. It is the Client’s responsibility to select the final mix and to determine whether to implement any strategy. We will apply guidelines you supply, as directed; however, compliance with these restrictions or guidelines is the Client’s responsibility. We will also monitor the current core investment options, including the investment’s performance, performance compared to an applicable benchmark index, fees, management changes, style and fundamental investment strategy changes, and fund composition to determine if an investment no longer meets the criteria defined in the IPS. If the Committee determines that a core investment option no longer meets the IPS criteria, we will advise the Committee on possible alternatives and assist in the selection of a replacement investment. Participant Meetings We may conduct Plan participant meetings when a change is made either to the structure of the Plan or if the investment options being recommended/considered would change as a result of the decisions of the Committee. We will:
• detail the changes being made or proposed;
• assess how they affect the current participants;
• review the current investment opportunities;
• assess how participants may make changes to their investment selections; and
• Strive to provide meaningful answers to any and all questions a participant may have. Reporting We will send an annual Plan criteria report detailing the overall performance of the Plan’s core investment options and a detailed list of investments passing or failing the IPS criteria. 4. Assets Under Management As of December 31, 2023, we had approximately $175,053,546 in assets under management, of which $152,030,333 were managed in a discretionary manner, and $23,023,212 were managed in a non- discretionary manner. 5. ERISA Fiduciary FWAM understands and attests that they are an ERISA fiduciary as defined in the Fiduciary Rule under ERISA and the Internal Revenue Code of 1986. FamilyWealth™ adheres to Best Interest and Impartial Conduct Standards. FWAM may act as a discretionary investment manager of a Plan as defined in Section 3(38) of ERISA. FWAM may act as a non-discretionary investment manager of a Plan as defined in Section 3(21) of ERISA.