WMBC is an SEC registered investment adviser with its principal place of business located in California. WMBC began conducting business in 2001. David Scott Coles, President, is the firm's sole owner. WMBC offers the following advisory services to our clients: MODEL PORTFOLIO MANAGEMENT Our firm provides continuous supervisory investment management of portfolio securities services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. The model allocation portfolios are listed below with a description of each:
• Tax-Exempt - The primary investment objective for this portfolio is to seek tax-exempt investments producing capital preservation and/or current income. The risk posture for this portfolio is conservative, indicating a preference for low risk and volatility in return for accepting potentially lower returns.
• Tax Advantage - The primary investment objective for this portfolio is to seek tax-efficient investments producing current income and/or capital preservation, with some emphasis on growth of capital. The risk posture for this portfolio is moderately conservative, implying a willingness to take some risk to seek enhanced returns while preferring to reduce exposure of principal to loss or fluctuation.
• Income - the primary investment objective for this portfolio is to produce current income and/or capital preservation, with some emphasis on growth of capital. The risk posture for this portfolio is moderately conservative, implying a willingness to take some risk to seek enhanced returns while preferring to reduce exposure of principal to loss or fluctuation.
• Balanced - the primary investment objective for this portfolio is conservative long-term growth of capital with some emphasis on current income. Assets will be deployed in a manner to produce both capital appreciation and income in the form of interest or dividends. The risk posture for this portfolio is moderately conservative, implying a willingness to take some risk to seek enhanced returns while preferring to reduce exposure of principal to loss or fluctuation.
• Growth & Income - The primary investment objective for this portfolio is long-term growth of capital with some emphasis on current income. Assets will be deployed in a manner to produce both capital appreciation and income in the form of interest or dividends. The risk posture for this portfolio is moderate, implying a willingness to assume an average amount of market risk and volatility or loss of principal for higher returns.
• Growth - The primary investment objective for this portfolio is long-term growth of capital with volatility below that of the stock market. Assets will be deployed in a manner most likely to produce capital appreciation with little emphasis placed on generating income in the form of interest or dividends. The risk posture for this portfolio is moderately aggressive; an above-average amount of risk and volatility or loss or principal is tolerated to take advantage of potentially higher return opportunities.
• Aggressive Growth - The primary investment objective for this portfolio is to maximize long-term growth of capital. Assets will be deployed in a manner most likely to produce capital appreciation with little emphasis placed on generating income in the form of interest or dividends. The risk posture for this portfolio is aggressive, implying a willingness to sustain substantial volatility or loss of principal and assume a high level of risk in pursuing higher returns. Through personal discussions with the client in which the client's goals, objectives and strategy are established, we initially determine whether the model portfolio is suitable to the client's circumstances. Once we confirm suitability, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. WMBC clients have the option to select different investment strategies depending on suitability driven by their risk threshold, investment goals and objectives. Clients can select one of the following WMBC platform strategies: WMBC’s legacy Core Strategic Hold, LTAM Tactical Management, WMBC Quantitative and Alternative Income Reduced Correlation. The management of clients’ accounts within these different investment program platform strategies require a different amount of time, research and reporting which carry a separate fee. (See Item 5 Fees and compensation section below for additional information.) We offer these services on a discretionary and non-discretionary basis and currently manage existing advisory accounts on a non-discretionary basis. Account supervision is guided by the client's stated investment strategy and objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Client permission is sought prior to all transactions WMBC implemented on the client’s behalf. Once the client's portfolio has been established, we review the portfolio quarterly, and if necessary, rebalance the portfolio on an annual basis, based on the client's strategy and individual needs. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests 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 strategy, objectives, tolerance for risk, liquidity and suitability. To reasonably ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's strategy and financial circumstances, we will: 1. Send quarterly written reminders to each Model Portfolio Management Services client requesting any updated information regarding changes in the client's financial situation and investment objectives; 2. At least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. Periodic reporting; 4. Be reasonably available to consult with the client; and 5. Maintain client suitability information in each client's file. FINANCIAL PLANNING We provide two variations of financial planning services. Financial planning, in general, 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. The second type of financial planning services we offer is called Human Wealth Planning. We meet with clients at least quarterly basis and take them through our 4 steps of Human Wealth Planning, which are Discover Wellbeing, Explore Resources, Design Systems, and Implement Plan, as more fully described below. 1. Discover Wellbeing - Human Wealth™ begins with understanding the composition of your subjective wellbeing. Subjective wellbeing is how we perceive the areas of our lives that contribute to us feeling well. Our science-based model of wellbeing comprises four components: personal resources, external conditions, proper functioning, and experience of life. These four components of wellbeing are interconnected, each playing a vital role in our overall sense of wellness. Our proprietary Discover Wellbeing questionnaire captures your subjective responses and transforms them into quantitative metrics that we can track over time. We also use your responses to produce your individual Wellbeing Profile, providing you a visual summary of your subjective wellbeing. Together, you and your advisor will review your profile and identify key wellbeing attributes to guide the creation of your Human Wealth Plan™ 2. Explore Resources - To bring about change or growth, you rely on your available resources; financial, personal, and social. In this phase we explore the objective state of all three types of resources, allowing for the intentional and sustainable use of each. Through our proprietary science-based Explore Resources questionnaire we will take a comprehensive account of your financial resources, understand the state of your health, and map out your immediate social network. 3. Design Systems - With your Wellbeing Profile in hand and resources fully examined, we use our 40 years of experience to design your unique financial systems. While also collaborating with your other professional advisors to ensure cohesion across your entire financial situation. In your annual Design Systems meeting we will review all your financial systems–including securities, insurances and annuities– to make certain that they continue to support you in a feasible way. Your Human Wealth Plan™ may include financial systems such as: Estate Planning, Tax Planning, Business Consulting*, Investment Management, Retirement Planning, Risk Management, Resource Flow, & Special Family Needs (Business Consulting may incur an additional fee). 4. Implement Plan - In the final phase of Human Wealth™ we make sure the financial systems we designed together are integrated into your life properly. We work with your other professional advisors to develop a implementation timeline providing your team clarity and allowing you to focus on what really matters–living a happy fulfilling life. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. WMBC offers a hybrid product that combines both Model Portfolio Management and Human Wealth Planning delivering combined investment advisory services for a uniform advisory fee described below in Item 5. Fees and Compensation at a discount to our standard Model Portfolio Management only fee schedule. PENSION CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals, trusts, businesses, estates and charitable organizations. Pension Consulting Services are comprised of four distinct services. Clients may choose to use any or all of these services. Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) to determine which investments are appropriate to implement the client's IPS. The number of investments to be recommended will be determined by the client, based on the IPS. Monitoring of Investment Performance: We monitor client investments continually, based on the procedures and timing intervals delineated in the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the client’s portfolio and will make recommendations to the client as market factors and the client’s need indicate. Employee Communications: For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control over assets in their own account (''self-directed plans''), we may also provide quarterly educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. AMOUNT OF MANAGED ASSETS As of December 31, 2022, we were actively managing $60,537,790 of clients' assets on a non-discretionary basis and $37,562,692 on a discretionary basis with $98,100,482 in total assets under management. The amount of Assets Under Advisement was $374,514,985 for this same time in connection with financial Human Wealth Planning.