MWM Group LLC (“MWM Group”) has been in business since 2012. The firm is owned by RAM Asset Trust. Sara Glaz Aloni is the firm’s Chief Compliance Officer. MWM Group provides personalized financial planning and/or investment management services. Clients advised may include individuals, trusts, estates, pension and profit sharing plans, foundations, and corporations. Financial Planning Some clients may elect to engage MWM Group to provide financial planning services. For these engagements, the client will supply to MWM Group information including income, investments, savings, insurance, age and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs and goals with you, and compare your current financial situation with the goals you state. Once these are compared, we will create a financial and/or investment plan to help you meet your goals. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is very important that you accurately and completely communicate to us the information we need. Also, your circumstances and needs may change as your engagement with us progresses. It is very important that you continually update us with any changes so that if the updates require changes to your plan, we can make those changes. Otherwise, your plan may no longer be accurate. Asset Management MWM Group requires each client to place at least $25,000 with the firm. This minimum may be waived in the discretion of MWM Group. Asset management services will generally be provided on a “discretionary” basis. When MWM Group is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and MWM Group. In limited circumstances and as a courtesy to certain clients, some clients may be permitted to have MWM Group manage their accounts on a non-discretionary basis. Non-Discretionary accounts require the client’s pre-approval before any trade is implemented in the account. If you request MWM Group may recommend the services of other professionals for implementation purposes.

You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from MWM Group. If you engage any professional recommended by MWM Group, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Assets Under Management As of December 31, 2023, MWM Group had $306,266,048 in discretionary assets under management. Wrap Program For some clients, MWM Group may include certain transactional costs in the client’s management fee. Fees included in the wrap fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than Schwab Advisor Services. Because MWM Group manages client assets both directly (where MWM Group makes and implements recommendations involving the purchase or sale of securities) and indirectly (involving the selection, hiring and termination (where applicable) of one or more managers), the fees covered in the wrap program may differ according to the investment style(s) in which the client is participating. To the extent a third party manager is utilized, the fees payable to such managers will be in addition to the fees payable to MWM Group, and therefore not included in the wrap program. Therefore, there is no difference between how MWM Group manages wrap free accounts and how MWM Group manages other accounts. Because of the nature of a wrap fee program, the wrap fee program client may pay more or less than if the client had compensated MWM Group outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. MWM Group receives a portion of the wrap fee for our services. For clients in the wrap program whose assets are managed directly by MWM Group and not by a third party manager, transaction fees are paid to various broker-dealers, mutual funds and ETFs. The remainder of the wrap fee is the management fee payable to MWM Group. The amount payable to MWM Group varies depending upon the amount of trading in a client's account. The more transactions in the account, the greater the amount of transaction fees, and therefore the less compensation to MWM Group. Accordingly, MWM Group has a financial incentive to avoid trading the account. This creates a conflict of interest between the firm and its wrap clients. MWM Group attempts to mitigate this conflict by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own and by periodically comparing wrap program client performance against any clients who are not in the wrap program. MWM Group will receive no additional compensation for offering the wrap fee program. Clients should refer to the accompanying Wrap Brochure.