ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... v ITEM 6 - SUPERVISION .............................................................................................................................. v Laura A. Gilman ................................................................................................................................ vi ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... vi ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... vi ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... vi ITEM 6 - SUPERVISION ............................................................................................................................ vii Nick V. Nejad .................................................................................................................................. viii ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................... viii ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................. viii ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................. viii ITEM 6 - SUPERVISION ........................................................................................................................... viii Scott C. Gaynor ................................................................................................................................. ix ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... ix ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... ix KCS Wealth Advisory Brochure Revised March 14, 2023 5 ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... ix ITEM 6 - SUPERVISION ............................................................................................................................. ix Katrina S. Soelter ............................................................................................................................... x ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................... x ITEM 3 - DISCIPLINARY INFORMATION ..................................................................................................... x ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... x ITEM 6 - SUPERVISION .............................................................................................................................. x Privacy Information .......................................................................................................................... A KCS Wealth Advisory Brochure Revised March 14, 2023 6 Description of Advisory Firm KCS Wealth Advisory, LLC dba KCS Wealth Advisory (“KCS,” “we,” “our,” or “us”), is a privately owned limited liability company headquartered in Los Angeles, CA. Dr. Kenneth B. Waltzer originally founded KCS’ predecessor firm, Kenfield Capital Strategies, in 2004. In 2014, Dr. Waltzer merged practices with Laura A. Gilman to form KCS Wealth Advisory. Fiduciary Duty Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and confidence. It encompasses a duty of care and a duty of loyalty. Duty of Care The duty of care includes, among other things, 1. the duty to provide advice that is in the best interest of the client; 2. the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades; and 3. the duty to provide advice and monitoring over the course of the relationship. The duty to provide advice suitable to each client based on a reasonable understanding of the client’s objectives is a critical component of the duty of care. Providing suitable advice includes making a reasonable inquiry into the client’s financial situation, investment experience, and financial goals and then updating this information as necessary throughout the course of the relationship to reflect the client’s changing objectives over time and adjusting the advice we provide to reflect any changed circumstances. When KCS has the responsibility to select broker-dealers to execute client trades in discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s services and so the determinative factor is not necessarily the lowest possible commission cost but whether the transaction represents the best qualitative execution. Moreover, we periodically and systematically evaluate the execution we receive on behalf of our clients. Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the best interest of the client, taking into account the scope of the agreed relationship. This scope is indicated by the duration and nature of the services as outlined in each client’s advisory arrangement and extends to all personalized advice provided to clients. Duty of Loyalty KCS adheres to a duty of loyalty where we seek to serve the best interests of our clients and never subordinate the interests of our clients to our own. Simply put, KCS cannot place its own interests ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest which might incline KCS, consciously or KCS Wealth Advisory Brochure Revised March 14, 2023 7 unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to be full and fair, it should be sufficiently specific so that each client is able to understand the material fact or conflict of interest and make an informed decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they can use the information within to decide whether or not to enter into an advisory relationship. Advisory Services Offered KCS offers the following services to advisory clients: KCS offers investment supervisory services on a discretionary basis. KCS manages money based on each client’s financial needs and desires, with attention to how KCS-managed accounts fit into the client’s overall financial plan. We seek to maximize returns for a given level of risk based on the asset classes used and each client’s needs and risk tolerance. KCS primarily utilizes the following investment types when making purchases in new discretionary client accounts: 1. Equity securities, including stocks and foreign securities listed on US exchanges (ADRs) or foreign exchanges (ordinaries) 2. Fixed income securities, including corporate and government bonds, and certificates of deposit (CDs) 3. Mutual funds 4. Exchange traded funds (ETFs) 5. Securities with equity and

debt characteristics, including convertible bonds, preferred stocks, or other preferred securities 6. Municipal securities 7. Closed-end funds 8. U.S. government securities 9. Options contracts on securities 10. Money market funds and cash Depending on the client’s individual investment objectives and needs, portfolios further include, as appropriate: 1. Exchange traded notes (ETNs) 2. Real estate investment trusts (REIT) 3. Master limited partnerships (MLPs) 4. Private Placements 5. Treasury inflation-protected securities (TIPS) 6. Inflation-indexed bonds Weightings in each investment type will vary based on the type of portfolio the client selects and whether the account is taxable or non-taxable. KCS may also occasionally utilize additional types of KCS Wealth Advisory Brochure Revised March 14, 2023 8 investments if they are appropriate to address the individual needs, goals, and objectives of the client or in response to client inquiry. KCS may offer investment advice on any investment held by the client at the start of the advisory relationship. We describe the material investment risks for many of the securities that we utilize under the heading Specific Security Risks in Item 8 below. We discuss our discretionary authority below under Item 16 - Investment Discretion. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below. We describe the fees charged for investment management services below under Item 5 - Fees and Compensation. Financial Planning Services KCS offers a range of financial planning services, from broad planning to custom planning focused on specific areas requested by the client. As part of the financial planning process, KCS collects information about the client’s financial situation and needs, which may include net worth, income, expenses, taxes, investments, retirement plans, life insurance, disability insurance, health insurance, long term care insurance, business agreements, divorce papers, pre-nuptial agreements, estate documents, and any other documents that pertain to their overall financial picture. In addition, KCS asks the client about their future goals and objectives. KCS then develops a written personalized plan including specific recommendations in all applicable areas. KCS may also work with the client to provide advice regarding a particular aspect of the client’s financial situation. Areas of focus might include: 1. Preparing for or living in retirement 2. Investment strategies 3. Estate planning strategies 4. Income tax planning 5. Stock option analysis and planning 6. Insurance: life, disability, medical, long-term care insurance 7. Family savings and cash flow planning 8. Education planning and funding 9. Charitable gifting 10. Debt management 11. Employee benefit usage 12. Other, as determined between KCS and the client A conflict exists between our interests and the interests of our clients when we make financial planning recommendations that may include other services we offer. Clients are under no obligation to act upon our recommendations. If a client elects to act on any of our recommendations, the client is under no obligation to effect the transaction through KCS. Our financial planning services do not include preparation of any kind of income tax, gift, or estate tax returns nor preparation of any legal documents, including wills or trusts. We describe fees charged for financial planning services below under Item 5 - Fees and Compensation. KCS Wealth Advisory Brochure Revised March 14, 2023 9 401k/Plan Services KCS offers the following in conjunction with our 401k/Plan Services: Fiduciary Services: KCS assists with the development of an investment policy statement (IPS) to establish the investment policies and objectives for the Plan, selection of a Custodian, Recordkeeper, and Third-Party Administrator (TPA) for the Plan and its assets. We then provide discretionary investment advice to the Plan, including providing the Plan with an initial (and ongoing) diversified platform of investment options from which Plan participants may choose. KCS monitors the Plan investment options on an ongoing and continuous basis, and is responsible for making additions/deletions, as applicable. We describe ongoing monitoring and reporting for this service under Item 13 – Review of Accounts. Non-Fiduciary Services: As agreed between KCS and each Plan Sponsor, KCS either provides or arranges for the Plan’s other providers to answer day-to-day questions from the Plan Sponsor and provide periodic education sessions to plan participants in order to assist them in the selection of investments and portfolio allocations. Pension Consulting Services Pension consulting services include assisting clients in choosing the type of pension plan for their businesses; recommending TPAs, record keepers and/or actuaries when necessary; providing participant education; helping clients choose investment options, including default investment options; reviewing the plan annually with the administrator/client. For current investment management clients, the costs for these services are generally included in our investment management fees and not charged separately. Third-Party Investment Management KCS previously offered services through third-party asset allocation or managed account programs. These programs provide for the management of client portfolios by the program provider or separate account managers, who allocate among different security types in model portfolios designed in an effort to build long-term wealth while maintaining risk tolerance and loss threshold levels based on the client’s distinct financial needs and goals. These allocation programs provide ongoing monitoring of clients’ accounts and rebalancing and/or reallocating assets on a discretionary basis in order to maintain the client’s model allocation selection. While we no longer offer this service to new clients, we still oversee some accounts through this method under existing agreements. Limitations on Investments In some circumstances, KCS’ advice may be limited to certain types of securities. Limitation by Plan Sponsor/Employer In the event KCS is managing assets within a retirement plan such as 401(k), 403(b), ORP or other employer plan, KCS is limited to those investment providers and investment options chosen by the plan administrator. Similarly, when we provide services to participants in an employer-sponsored plan, the KCS Wealth Advisory Brochure Revised March 14, 2023 10 participant is generally limited to investing in securities included in the plan’s investment options. Therefore, KCS can only make recommendations to the client from among the available options and will not recommend or invest the client’s account in other securities, even if there may be more suitable options elsewhere. Limitation by Issuer In the event KCS is managing assets within an annuity, KCS is limited to those investment options made available by the insurance company. Mutual Fund Limitations KCS generally limits mutual fund selections to no load funds or load-waived equivalents. Limitation by Client When applicable, KCS will also limit advice based on certain client-imposed restrictions. For more information about the restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this Item below. Tailored Services and Client Imposed Restrictions KCS manages client accounts based on the investment strategy the client chooses, as discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. KCS applies the selected strategy for each client, based on the client’s individual circumstances and financial situation. We make investment decisions for clients based on information the client supplies about their financial situation, goals, and risk tolerance. Our investment selections may not be suitable if the client does not provide us with accurate and complete information. It is the client’s responsibility to keep KCS informed of any changes to their investment objectives or restrictions. Clients may also request other restrictions on the account, such as when a client needs to keep a minimum level of cash in the account or does not want KCS to buy or sell certain specific securities or security types in the account. KCS reserves the right to not accept and/or terminate management of a client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or maintaining the client’s investment strategy. Wrap Fee Programs KCS does not manage accounts as part of a wrap or bundled fee program. Assets Under Management KCS manages client assets in discretionary accounts on a continuous and regular basis. As of December 31, 2022, the total amount of assets under our management was $349,656,033. KCS Wealth Advisory Brochure Revised March 14, 2023 11