Owned by Darren Munn, CFA and David Munn, Munn Wealth Management, LLC (“MWM”) has been in business since 2002. David Munn is also the President of MWM. MWM provides a broad range of services to private wealth management clients, including asset management, financial planning, and tax preparation. In addition to Camelot Portfolios, MWM is an affiliate of Atlantis Wealth Advisors LLC, and Camelot Event Driven Advisors, LLC, all of which are registered investment advisers. Camelot Portfolios designs, implements and monitors various model strategies. Many MWM clients have assets managed using one or more of these proprietary models. The models are more fully discussed in Item 8 herein. Financial Planning In most cases, the client will supply to MWM 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. We determine these objectives by reviewing new client questionnaires and then interviewing the client for additional background and clarity so we can gather a more complete picture of a client’s needs. 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. Investment Advisory Services – Custom Accounts MWM provides investment advice to individuals, trusts, foundations, and corporations. MWM clients are direct relationships with the firm, who place their assets with the firm to be managed by the MWM investment team. As discussed above, the assets these clients place with Munn Wealth Management are typically, but not always, managed utilizing one or more of Camelot’s proprietary investment models. As part of their investment advisory services and upon engagement, each client will complete an Investor Profile and Application, which utilizes time horizon and risk tolerance questionnaires to give MWM a clearer picture of each client’s needs and risk tolerance. The results of these questionnaires are the basis for determining the client’s investment strategy. MWM will from time to time perform a mathematical projection of a client's present and future capital needs based upon facts, assumptions, and risk tolerance provided by the client via the Investor Profile and Application form completed by the client. While the Investor Profile and financial projections may assist the client in making decisions as to investment strategy, amount to invest, or investment pattern, it is only part of the process, which may require expert assistance in the field of tax, legal or financial planning. If you request, MWM 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. If you engage any professional recommended by MWM, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Asset management services are generally provided on a “discretionary” or “non-discretionary” basis. When a client of Munn Wealth Management engages the firm 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 reasonable restrictions on the types of investments we may use on your behalf, or on the allocations to each security type, though as more fully discussed in Item 8, such restrictions may limit the potential performance of your portfolio. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements directly 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 the firm. In certain limited circumstances, and in the discretion of the firm, a client may engage the firm to provide investment management services on a non-discretionary basis. This means the firm monitors the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have confirmed with you (either verbally or in writing) that our proposed change is acceptable to you. Asset Management Services – Wealth Builder We have agreements with several custodial service providers to service client accounts including, but not limited to Goldman Sachs, Fidelity, Interactive Brokers, and TradePMR. We routinely recommend the services of TradePMR, Inc., an unaffiliated and independent registered securities broker/dealer, and member of FINRA and SIPC. TradePMR utilizes First Clearing (Wells Fargo Clearing Services dba First Clearing) as their clearing service provider We, and not the custodians, are the client’s investment advisor and primary point of contact. We are solely responsible for determining the appropriateness of the models for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. Additionally, the commission/transaction fees charged by Trade-PMR may be higher or lower than those charged by other broker-dealer/custodians. You may utilize the broker/dealer of your choice and have no obligation to purchase or sell securities through such broker as we recommend. We do not share or receive commission from the fees issued from our recommended list of custodians. Munn Wealth Management may receive an economic benefit from our agreements with the custodians in the form of access to research, investment consultants, software, various products, and services that provide lawful and appropriate assistance to our firm. Associates of Munn Wealth Management may be invited to attend conferences offered by various vendors and/or wholesalers associated with our recommended custodians, at a discounted price or no cost. Tax Preparation MWM also offers tax preparation services in addition to comprehensive financial planning and investment management. Munn Wealth Management’s tax services are designed to make the tax filing process simple and stress free for each client, while also working to reduce a client’s tax liability on current and future returns. Charitable Giving Options Charitable Pooled Trust (aka Pooled Income Fund) In making their financial and estate plans, some affluent individuals choose to utilize a structure involving a charitable remainder

trust (frequently referred to as a “CRUT”). The basic concept of these trusts is that the individual creating them can (and must) take certain distributions of income from the CRUT, but the remainder (what is left after the person who created the trust dies) is donated to a predetermined charity. Because these CRUTs require legal documents related to formation, ongoing administration and tax preparation, forming a CRUT can be too expensive for some individuals and families. The Charitable Pooled Trust is an example of one attempt to make the benefits of a CRUT available to more people. The Pooled Income Fund, which is also referred to as a Charitable Pooled Trust (“CPT”) works in much the same way as a CRUT: the client gives cash or assets to the CPT. The assets of CPT are managed to generate income for those giving the assets, and remainders are donated to predetermined charities. What is different is the pooled nature of a CPT. In a CPT, the assets of a number of grantors are pooled into one trust. That trust is in turn managed to generate income to the grantors, with the eventual remainder donated to charity. Camelot Portfolios has an arrangement with The Waterstone Foundation (waterstone.org). For clients choosing to use a CPT, assets will be transferred to Waterstone. From there, they will be designated as part of a specific group of assets among a number of options. Each group, or “pool” is intended to be managed by a professional money manager. Camelot Portfolios is the manager of “Pool C”, but there are other pools. Income generated from the pools is distributed to the grantors related to each pool in proportion to the amount of assets they contributed. Upon the death of a contributor, the assets they contributed, plus any appreciation since the date of contribution, are donated to the designated charity. Because Camelot is the manager of Pool C, Camelot Portfolios receives a fee for managing the assets in Pool C. Accordingly, there is a material conflict of interest when Camelot recommends that a client use Waterstone’s CPT, in that Camelot will earn a fee for managing the assets in Pool C, but will not earn a fee to manage the assets in another CPT the client may choose. We attempt to mitigate this conflict by disclosing it to clients, encouraging our clients to investigate Waterstone Foundation and the concept of CPTs on their own, and reminding our associated persons of their ongoing fiduciary obligations, which means placing client interests ahead of their own. Camelot Philanthropist Program The Camelot Philanthropist Program involves increasing the management fee paid to Camelot, which increase in turn is donated to a 501(c)(3) nonprofit organization that has agreed to handle the distribution of the fees paid to the nonprofit beneficiaries specified by the client/s. For example, a client whose overall fee (including their fee to their non-Camelot Portfolios advisor, which in the case of a Munn Wealth client, is Munn Wealth) was 1.50% per annum could elect to increase their management fee to 2.00% per annum. The client would then have the full 2.00% per annum debited from their account, as if that full amount was to be paid to Camelot. Instead, the incremental 50 basis points would be given by Camelot Portfolios to a charitable foundation. The potential benefit of participating in the Camelot Philanthropist Program is that (subject to applicable tax rules) the client/donor may be able to deduct the incremental amount of the management fee that is ultimately donated to the foundation even if their maximum charitable deductions are met, or if their tax return would not otherwise call for a schedule wherein contributions would be deducted. At the same time, the client can donate to charities that endeavor to improve the world in ways that match the client’s values. Clients are encouraged to speak with their own professional tax advisors, as the deductibility of these fees and subsequent donations is a matter best determined by such tax professional. Camelot has worked with the National Christian Foundation, and has also begun working with the Effective Give. The National Christian Foundation has offices across the United States, and considers its mission to “mobilize resources by inspiring biblical generosity.” Donations to the National Christian Foundation are intended to be ultimately delivered to charities whose mission is in keeping with the stated intentions of the donor. Effective Give was created by Matthew Moses, a Camelot leadership team member. Effective Give fills a need left open by the NCF program: Effective Give allows smaller donations and clients to choose a specific charity. The Effective Give screens charities whose missions match the donor/client’s stated purpose in the areas of saving lives, fighting poverty, and saving souls, in an effort to ensure the most value is realized for each dollar donated. In some instances, the client/donor chooses a specific charity. Clients choosing a specific charity should realize that their charity is their choice, and therefore not screened by either the foundation in question or Camelot. While there is never a guarantee that even with screening and diligence a charity will always maximize its potential, do good works, or lack malfeasance in their administrative efforts, we believe donating to a charity without screening or diligence increases the chances that a charity will not have a positive impact, or at least that its impact will be less than one that has been screened. Donations through the Camelot Philanthropist Program (whether the National Christian Foundation or Effective Give) are intended to be ultimately delivered to charities whose mission is in keeping with the donor’s chosen focus. For example, one such possible focus is Fight Poverty. The charities which receive the donations from the respective foundation may not be identical to any that are specifically mentioned as past recipients or others specifically mentioned in any explanatory materials provided to clients at the time the decision is made to participate in the program. This is because ultimately, the foundation has control over the precise recipients for each of their donations. Accordingly, there is no guarantee that any specific charity, even one named in previous donations, will receive donations through the Program. The exception to this is Effective Give, which allows clients to designate a specific charity. While we recognize that utilizing Effective Give for donor advised funds may present a conflict of interest, clients should be advised that neither Mr. Moses nor any other person or entity affiliated with Camelot receives any compensation related to the administration of Effective Give or the management of Effective Give assets. Clients should be aware that like many other foundations, the foundations utilized for the Camelot Philanthropist Program have their own administrative costs. Accordingly, the full amount of a donation does not necessarily go directly to the specific charity named. A setup fee or other reduction in the amount donated will be charged. The amount of this fee will vary according to the foundation in question. As of the date of this brochure, NCF, for example, charges a fee of 1.00%. Effective Give has a 10% fee, but only if the client chooses their own charity. There is no fee for donations intended for other options. If clients have any questions related to how a foundation’s administrative costs are handled, please feel free to contact your Camelot representative or the foundation directly. This program is no longer offered to clients. There are some existing clients who utilize this program. Assets Under Management MWM manages approximately $197.2 million across 1,898 accounts.