Firm Description Keystone Wealth Advisors, Inc. (“KWA”) was founded in 2010. The owners of KWA are Steven Douglas Carlson and Berthel Andrew Olsen, III. KWA provides personalized confidential financial planning and investment management to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. KWA is a fee based financial planning and investment management firm. KWA does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other products for commissions. KWA does not act as a custodian of client assets. The client always maintains asset control. An evaluation of each client's initial situation is provided to the client, often in the form of an Investment Policy Statement. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the event they should occur. Types of Advisory Services KWA provides investment supervisory services, also known as asset management services and furnishes investment advice through consultations. ASSET MANAGEMENT KWA offers discretionary and non-discretionary ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KWA creates an Investment Policy Statement for each client. KWA creates an Investment Policy Statement for each client, which outlines the client's current situation (income, tax levels, and risk tolerance levels) and then constructs a general plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client's specific situation. Investment Supervisory Services include, but are not limited to, the following: ● Investment strategy ● Personal investment policy ● Asset allocation ● Asset selection ● Risk Tolerance ● Regular portfolio monitoring KWA evaluates the current investment of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Discretionary When the Client provides KWA discretionary authority the Client will sign a limited trading authorization or equivalent. KWA will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use KWA on a non-discretionary basis, KWA will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, KWA will obtain prior Client approval on each and every transaction before executing any transaction. When deemed appropriate for the Client, KWA may hire Sub-Advisors to manage all or a portion of the assets in the Client account. KWA may have full discretion to hire and fire Sub-Advisors as we deem suitable. Sub-Advisors will maintain the models or investment strategies agreed upon between Sub-Advisor and KWA. Sub-Advisors execute trades on behalf of KWA in Client accounts. KWA will be responsible for the overall direct relationship with the Client. KWA retains the authority to terminate the Sub-Advisor relationship at KWA’s discretion. ERISA PLAN SERVICES KWA provides service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred compensation plans. KWA may act as a 3(21): Limited Scope ERISA 3(21) Fiduciary. KWA typically acts 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 KWA 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 KWA 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. ➢ 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 the Advisor’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 Advisor 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. Advisor 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. The Advisor has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to the Advisor under this Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. KWA will not have discretion or custody at any time of client funds and/or securities. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, the client may compensate KWA on a negotiable hourly fee basis described in detail under “Fees and Compensation” section of this brochure. Financial plans and financial planning may include, but are not limited to investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services will be based on hourly fees and the final fee structure will be documented in Exhibit II of the Financial Planning Agreement. If a conflict of interest exists between the interests of the investment advisor and the interests of the client, the client is under no obligation to act upon the investment advisor’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through KWA. Financial plans will be completed and delivered inside of 6 months. Clients may terminate advisory services with 30 days written notice. 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 KWA does not participate in wrap fee programs. Client Assets Under Management As of April 30, 2023, KWA manages approximately $136,214,554 in assets under management on a non-discretionary basis and $20,670,691 on a discretionary basis.