MWM is a SEC-registered investment adviser with its principal place of business located in Durango, Colorado. MWM began conducting business as a registered investment adviser in 2008. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company):
• David S. McAlvany, General Partner
• David S. McAlvany Irrevocable Trust, Limited Partner MWM offers Individual Portfolio Management, Money Manager Search and Monitoring services to its advisory clients. MWM also sponsors educational seminars that are open to clients and the public. Please see the disclosure below in this Item for additional information regarding these services. As of December 31, 2023, MWM was managing $88,866,698 of client assets on a discretionary basis and $3,065,503 of client assets on a non-discretionary basis. MWM also offers a Short Selling Strategy and a Tactical Negatively Correlated Strategy to clients when appropriate to the client’s individual situation and tolerance for risk. Information about those strategies is available in a separate Form ADV Part 2A brochure for each, which is available upon request. INDIVIDUAL PORTFOLIO MANAGEMENT MWM offers portfolio management services to its advisory clients on a separately managed account basis. We will provide continuous advice to a client regarding the investment of client funds based on the client’s individual needs. Through personal discussions with our clients, we develop a client's personal investment policy. We then create and manage a portfolio based on that policy. During this data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We currently offer our portfolio management services on a discretionary basis only. Account supervision is guided by the client's stated objectives (e.g., growth, income or a balance between growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Our client portfolios will consist primarily of the following: stocks, options, bonds and other fixed income securities, exchange-traded funds (“ETFs”), and no-load mutual funds. Client portfolios may also include limited partnerships, private placement partnerships, and precious metals. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. MONEY MANAGER SEARCH AND MONITORING We may also perform management searches of various independent registered investment advisers, on behalf of a client. Based on a client's individual circumstances and needs, we will determine which independent adviser's portfolio management is appropriate

for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the independent adviser. Clients should refer to the independent adviser's Firm Brochure (Form ADV Part 2) for a full description of the services offered. We will meet with the client at least annually to review the account. If we believe that an independent adviser is performing inadequately, or if we believe that a different manager is more suitable for a client's particular needs, then we will suggest that the client contract with a different adviser. Under this scenario, we will assist the client in selecting a new adviser, and then monitor that adviser's performance. However, any move to a new manager is solely at the discretion of the client. SEMINARS MWM sponsors educational seminars on various investment topics including technical portfolio analysis. The investment information provided under this service does not purport to meet the objectives or needs of each individual client. The seminars will provide participants with discussions on asset allocation strategies, estate and retirement planning, and general educational topics. Our seminars are open to the public. ERISA FIDUCIARY Retirement Rollovers: The Department of Labor’s Prohibited Transaction Rule 3.0 establishes that advice to rollover or transfer an account is fiduciary advice even though the prospect is not a client. ERISA fiduciaries are subject to the prohibited transaction rules, primarily 2020-02 which prohibits self- dealing. The Prohibited Transaction Rule 3.0 requires four elements of disclosure: 1. Affirmation of ERISA fiduciary duty 2. Description of services to be provided 3. Disclosure of material conflicts of interest 4. Explanation of the reasons for the recommendation and how it is in the Retirement Investor's best interest Before making a recommendation to execute a rollover, MWM will consider the following factors when evaluating whether a rollover is in the best interest of our client: the alternatives to a rollover including leaving the money in the plan or account type, comparative fees or expenses, whether an employer or other party pays for some or all administrative expenses. Depending on the circumstances, MWM may identify other factors relevant to this analysis as well. McAlvany Wealth Management, LLC has and always will act as a fiduciary for clients and prospective clients when reviewing a retirement rollover or transfer of account. Information related to tax and legal consequences that is provided as part of the financial plan is for informative purposes only and should not be considered tax or legal advice. Clients should contact their tax and/or legal advisor for personalized advice. Wrap Fee Programs. MWM does not participate in any wrap fee programs. Important Note: It is the Client’s responsibility to ensure that MWM is promptly notified if there are ever any significant changes to their financial situation, goals, objectives or needs so we can review our previous recommendations and make any necessary adjustments.