Cornerstone Wealth Advisors, Inc.

Firm Brochure (Part 2A of Form ADV) February 13, 2026 Cornerstone Wealth Advisors, Inc. Address: 1808 Aston Avenue, Suite 150 Carlsbad, CA 92008 Address: 34155 Pacific Coast Highway Suite 101 Dana Point, CA 92629 this Brochure, please contact us at Telephone: (760) 476-1376 Fax: (760) 476-2718 www.cwainvestors.com Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and business practices of Cornerstone Wealth Advisors, Inc. If you have any questions about the contents of (760) 476-1376 and/or d.barrett@cwainvestors.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Cornerstone Wealth Advisors, Inc. is registered as an investment adviser with the California Department of Financial Protection and Innovation and Texas State Securities Board; however, such registration does not imply a certain level of skill or training and no inference to the contrary should be made. Additional information about Cornerstone Wealth Advisors, Inc. (CRD#309544) is also available on the SEC’s website at www.adviserinfo.sec.gov. 1  ITEM 1: COVER PAGE Please refer to previous page. ITEM 2: MATERIAL CHANGES Since the last filing of this brochure on November 4, 2025, the following changes are being made: • Item 4 has been updated to disclose our most current calculation for client assets under management. CWA will ensure that clients receive a summary of any materials changes to this Brochure within 120 days of the close of our fiscal year, along with a copy of this Brochure or an offer to provide the Brochure. Additionally, as we experience material changes in the future, we will send you a summary of our “Material Changes”, along with an offer to provide the Brochure under separate cover. For more information about CWA, please contact us at (760) 476-1376. Additional information about CWA and its investment adviser representatives is available on the SEC’s website at www.adviserinfo.sec.gov. 2  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE................................................................................................................................... 2 Item Number Page ITEM 2: MATERIAL CHANGES ...................................................................................................................... 2 ITEM 3: TABLE OF CONTENTS ..................................................................................................................... 3 ITEM 4: ADVISORY BUSINESS ...................................................................................................................... 5 ITEM 5: FEES AND COMPENSATION ........................................................................................................... 10 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................... 14 ITEM 7: TYPES OF CLIENTS ....................................................................................................................... 14 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................... 15 ITEM 9: DISCIPLINARY INFORMATION ...................................................................................................... 19 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................ 19 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .................................................................................................................................................... 20 ITEM 12: BROKERAGE PRACTICES............................................................................................................ 21 ITEM 13: REVIEW OF ACCOUNTS .............................................................................................................. 24 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................... 25 ITEM 16: INVESTMENT DISCRETION ......................................................................................................... 26 ITEM 17: VOTING CLIENT SECURITIES ..................................................................................................... 27 ITEM 18: FINANCIAL INFORMATION ......................................................................................................... 27 BROCHURE SUPPLEMENT (PART 2B OF FORM ADV) ............................................................................. 30 PRINCIPAL EXECUTIVE OFFICER ............................................................................................................... 30 MICHAEL SELLMAN, CFP® ....................................................................................................................... 30 ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ........................................................ 30 ITEM 3: DISCIPLINARY INFORMATION ...................................................................................................... 31 ITEM 4: OTHER BUSINESS ACTIVITIES...................................................................................................... 32 ITEM 5: ADDITIONAL COMPENSATION ..................................................................................................... 32 ITEM 6: SUPERVISION ................................................................................................................................ 33 BROCHURE SUPPLEMENT (PART 2B OF FORM ADV) ............................................................................. 35 PRINCIPAL EXECUTIVE OFFICER ............................................................................................................... 35 DENISE A. BARRETT .................................................................................................................................. 35 3  ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ........................................................ 35 ITEM 3: DISCIPLINARY INFORMATION ...................................................................................................... 35 ITEM 4: OTHER BUSINESS ACTIVITIES...................................................................................................... 36 ITEM 5: ADDITIONAL COMPENSATION ..................................................................................................... 36 ITEM 6: SUPERVISION ................................................................................................................................ 36 4  ITEM 4: ADVISORY BUSINESS Firm Description Cornerstone Wealth Advisors, Inc. (“CWA” or the “Firm”) is a Carlsbad, California-based investment management firm founded in 2011. The firm began offering advisory services in June of 2011 under CRD number 157771. As further detailed in Item 4.B., below, CWA offers services covering the areas of financial planning, investment management, and selection of third-party managers (“TPMs”). The Firm typically provides its services to individuals, including high net worth individuals, trusts, estates, charitable organizations, and pension and profit sharing plans. Some of the investment instruments CWA advises its clientele on include, among other things, mutual funds, exchange traded funds ("ETFs"), equities, bonds, options, treasuries, fixed and variable annuities, certificates of deposit and private placements. CWA is registered with the State of California as an investment adviser and as a corporation. As of January 2015, CWA is owned by Denise Barrett and Michael Sellman. This Form ADV brochure is part of the Firm’s succession by application filing due to this change in ownership as Sean Barrett is no longer a majority owner or otherwise affiliated with CWA or any CWA affiliated entity. For information on the Firm’s wealth advisors’ qualifications and business backgrounds, please Types of Advisory Services refer to their respective Form Adv Part 2B Brochure Supplements. CWA provides the following types of advisory services: Financial Planning Services, Investment FINANCIAL PLANNING SERVICES Management Services, and ERISA Services all of which are more fully described below. CWA’s Financial Plan is more than a retirement plan – it includes Retirement Planning, Wealth Protection, Tax management, Risk Management and Estate Planning. CWA’s Financial Planning Services include, but are not limited to, providing advice regarding: • • • • • • • • • Debt Management Strategies; Tax Management Strategies; Retirement Goal Strategies; Risk Appropriate Asset Allocation; Portfolio Management Strategy; Risk Management Strategy; Social Security Recommendations; Wealth Transfer Strategy; and Tax-Efficient Charitable Gift Planning. To begin the Financial Planning Services process, CWA will interview the client to gather certain necessary information, including pertinent documentation in order to assess the client's current financial situation. Based upon this initial interview, CWA may request that the client provide the Firm with all necessary information requested by CWA in order to assess the client’s current and anticipated investment positions and financial objectives. Such information usually includes, but not limited to current and anticipated income, expenses, income tax levels, investment and non- investment assets and liabilities, investment risk tolerance, personal goals and objectives, existing 5  insurance policies, business interests, and any other necessary financial and personal information. CWA will rely upon the information provided by the client at all times and CWA will have no liability for the client’s failure to provide accurate and complete information. Taking into account the client’s goals, risk tolerance and long-term objectives, CWA will analyze and recommend appropriate changes in strategy and suggest reallocation of assets if necessary. At the conclusion of this review, a written personal financial plan containing CWA’s recommendations is delivered to the client. Financial plans are based on the client’s current financial situation at the time the plan is presented and on that financial information which is disclosed by the client to CWA. Clients are free at all times to accept or reject any of CWA’s financial planning recommendations and are under no obligation to implement any recommendations provided in the plan. Should a client decide to implement any of CWA’s recommendations, the client may, but is not required to utilize CWA, its wealth advisors, or any broker-dealer or insurance company recommended by CWA or its wealth advisors. Clients always retain the right to select any adviser, broker-dealer, and/or insurance company, as applicable, to implement recommendations provided by CWA. Clients should be aware that such implementation represents a conflict of interest since CWA's wealth advisors will receive fees, commissions and/or other concessions for certain investment and insurance products sold, and CWA will earn advisory fees for providing Investment Management Services. The Firm’s clients should be aware of the following when CWA is providing Financial Planning Services: • • • A conflict exists between the interests of CWA and the interests of the client, The client is under no obligation to act upon the Firm's recommendations, and If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the Firm or any of its wealth advisors. CWA discloses the conflicts of interest associated with its business practices before or at the time of beginning to perform its services by delivering a copy of this brochure and one or more INVESTMENT MANAGEMENT SERVICES brochure supplements (Form ADV Part 2Bs) to its clients. Model Portfolio Program CWA offers its clients the following two types of Investment Management Services: i. Custom Portfolio Program – This program is based on a proprietary strategic asset allocation methodology developed by CWA. The Firm develops and manages several asset allocation models, including Conservative, Moderate, Moderately-Aggressive and Aggressive models. These model portfolios are typically created using separately managed accounts (SMAs), no-load mutual funds, exchange-traded funds (ETFs), equities, fixed-income products and other permitted securities. CWA assists the client with selecting one of its model portfolios based on the Firm’s understanding of the client’s specific financial circumstances, future financial goals, return objectives, and risk tolerance. The Firm, acting in a discretionary capacity, chooses when to execute any trade. A minimum of $25,000 in assets is required to participate in the Model Portfolio Program. CWA may waive such minimum at its sole discretion. ii. – CWA offers a Custom Portfolio Program to its clientele. A client’s custom portfolio is created based on the Firm’s understanding of the client’s specific financial circumstances, future financial needs, investment goals, return objectives, and 6  risk tolerance, and may be comprised of separately managed accounts (SMAs), no-load mutual funds, exchange-traded funds (ETFs), equities, fixed-income products and other permitted securities. Once a portfolio is created, decisions regarding the type, amount, and holding period of any investment are made in accordance with the client’s individual circumstances. The Firm, acting in a discretionary capacity, chooses when to execute any trade. A minimum of $1,000,000 in assets is required to participate in the Custom Portfolio Program. CWA may waive such minimum at its sole discretion. For both types of CWA’s Investment Management Services described above, CWA will recommend the services of a TPM to manage all or part of the client’s assets if the client has enough assets to maintain a diversified portfolio inclusive of the TPM, while also meeting the minimum asset requirements of the TPM. In addition, CWA will recommend a TPM to a client if the client may benefit from tax loss harvesting of individual stocks or bonds. Typically, this involves the selection of certain money managers which may enter into a sub-advisory relationship with CWA. CWA’s fees will not differ, if and when it allocates client assets to TPMs although such clients may be required to enter into an investment management agreement or similar contractual relationship ERISA PLAN SERVICES directly with the selected TPM(s). CWA 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 Limited Scope ERISA 3(21) Fiduciary. plans. CWA acts as either a 3(21) or 3(38) advisor: CWA 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 adviser CWA 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 CWA can help mitigate that plan sponsor’s liability by following a diligent process.  1. Fiduciary Services are:  Provide non-discretionary investment advice to the Plan client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Plan client will make the final decision regarding the initial selection, retention, removal and addition of investment options. CWA acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).  Assist the Plan client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. 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 client 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 Plan client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and 7   conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. Meet with Plan Sponsor 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. Plan client understands the CWA’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, CWA is not providing fiduciary advice as define by ERISA to the Plan participants. CWA 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. Depending on the needs of the Plan client, CWA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between CWA and Client. 3. CWA has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. b. c. d. e. f. Employer securities; Real estate (except for real estate funds or publicly traded REITs); Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or Other hard-to-value or illiquid securities or property. 3(38) Investment Manager. CWA can also act as an ERISA 3(38) Investment Manager in which it has discretionary management and control of a given retirement plan’s assets. CWA would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options.  1. Fiduciary Services are:  CWA has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives.  Assist the Plan client with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. Assist the Plan client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. 8   Provide discretionary investment advice to the Plan client 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 Plan client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5).  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. Plan client understands CWA’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, CWA is not providing fiduciary advice as defined by ERISA to the Plan participants. CWA 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. Depending on the needs of the Plan client, CWA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between CWA and Client. 3. CWA has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. b. c. d. e. f. Employer securities; Real estate (except for real estate funds or publicly traded REITs); Participant loans; Non-publicly traded partnership interests; Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or Other hard-to-value or illiquid securities or property. not Client Tailored Services and Client Imposed Restrictions Excluded Assets will be included in calculation of Fees paid to CWA under this Agreement. As indicated above, advisory services provided by CWA are customizable based upon the individual needs, objectives, and other financial goals of the client. Early on in the relationship, CWA will typically memorialize each client’s investment objectives, risk tolerance, time horizons and other important and necessary information, including any investment guidelines, in a client profile or similar document. This information, together with any other information relating to the client’s overall financial circumstances, will be used by the Firm to determine an appropriate asset allocation and investment strategy to help meet the client’s financial goals. Clients generally are allowed to impose reasonable restrictions on the types of securities, companies and/or industries they do not want to be included in their account or financial plan. Once this information is gathered, each client is responsible for informing us in writing of any 9  changes to these restrictions or to their overall investment objectives. There may be times when certain restrictions are placed by a client which prevent the Firm from accepting or continuing to service the client’s account. CWA reserves the right to not accept and/or terminate a client’s account if it feels that the client-imposed restrictions would limit or prevent the Firm and/or the client from meeting and/or maintaining its objectives. e.g. CWA will not assume any responsibility for the accuracy of the information provided by the client. The Firm is not obligated to verify any information received from the client or from the client’s other professionals ( , attorney, accountant, etc.) and is expressly authorized to rely on such information. Under all circumstances, clients are responsible for promptly notifying the Firm in writing of any material changes to the client’s financial situation, investment objectives, time horizon, tax status, risk tolerance or other material information that CWA may have relied upon in rendering its services. In the event that a client notifies the Firm of such changes, CWA will review the changes and may recommend revisions to the client’s financial plan and/or portfolio. Wrap-Fee Programs CWA does not provide its services to any wrap fee programs, as that term is defined in the Amount of Client Assets Managed instructions to Form ADV Part 2. As of December 3131, 2025, the following represents the amount of client assets under management by CWA on a discretionary and non-discretionary basis: Assets Under Management ("AUM") $140,130,000 $145,630,000 $5,500,000 Type of Account Discretionary Non-Discretionary Total: ITEM 5: FEES AND COMPENSATION Method of Compensation and Fee Schedule Prior to engaging CWA to provide advisory services, the client will be required to enter into a written agreement with the Firm setting forth the terms and conditions and the fees under which it will render its services. All fees are subject to negotiation under certain circumstances and at the sole discretion of the Firm. The following description of the Firm’s fees outlines the typical fee structure under which CWA renders its services. The Firm’s actual fees, as they apply to a particular client, will be clearly outlined in CWA’s Investment Advisory Agreement. While CWA believes that its fees are competitive, clients are hereby advised that lower fees for comparable COMPENSATION FOR FINANCIAL PLANNING SERVICES services are available from other sources. Upon delivery of the Client’s Financial Plan, CWA will issue an invoice to the Client, and the Client shall pay this fee within 30 (30) days of receipt of the invoice. Although CWA believes its advisory fees are competitive, clients should be aware that lower fees for comparable services may be available from other sources. If the Client cancels after five (5) business days, any unpaid earned fees will be due to CWA. 10  HOURLY FEES Financial Planning Services are offered based on an hourly fee of $250 per hour. FIXED FEES Financial Planning Services are offered based on a maximum flat fee of $10,000. In addition to Financial Planning Services fees charged to the client, CWA will earn advisory fees should a client choose to implement the investment recommendations through the Firm, as further described below. Also, a CWA wealth advisor will earn commissions and/or other fees should a client choose to purchase certain recommended investment and/or insurance products. Clients may, but are not required to utilize CWA, its wealth advisors, or any broker-dealer or insurance company recommended by CWA or its wealth advisors to implement any recommendations provided in the plan. Clients always retain the right to select any adviser, broker-dealer, and/or insurance company, as applicable, to implement recommendations provided by CWA. Please refer to Item 10 below, for information on the financial industry affiliations that CWA and its wealth COMPENSATION FOR INVESTMENT MANAGEMENT SERVICES advisors currently have, including the conflicts pertaining to these affiliations. For the Firm’s Investment Management Services, CWA charges an annual management fee based on the client’s assets under management (AUM). CWA will aggregate familial accounts for a discounted rate. This includes spouses/partners, children and grandparents. Assets Under Management Annual Advisory Fee Lower fees for comparable services may be available from other sources. Total advisory fees charged by CWA to client will never exceed the safe harbor threshold of 3% of assets under management per year. Fees are billed quarterly in advance based on the account value as of the close of business on the last business day of the preceding quarter. The account value for fee calculation will include cash, cash equivalents, accrued interest and dividends and margin debt. REITs and other illiquid investments held in Client advisory portfolios are included in our AUM calculation and fee billing because CWA continuously monitors these assets and the issuers; and under these circumstances, the commissions on such products are waived. Model Portfolio and Custom Portfolio Program fees are calculated in accordance with the fee schedules set forth below: (% AUM) $0 - $250,000.00 $250,000.01 - $500,000.00 $500,000.01 - $750,000.00 $750,000.01 - $1,000,000.00 $1,000,000.01 and Above 1.50% 1.40% 1.30% 1.20% Negotiable Rate This is a tiered or breakpoint fee schedule, the entire portfolio is charged the same asset management fee. The formula for fee calculation is Balance x (annual fee% / 4) = quarterly fee. As stated above, investment management fees are billed quarterly in advance. By engaging the Firm to perform Investment Management Services, clients authorize CWA to request that the custodian remit payment for Investment Management Services fees from the client’s account(s). If authorized to do so, CWA’s fees will be automatically deducted from client’s custodial account shortly after the end of the previous quarter. For accounts opened after the beginning of a new quarter, fees will be prorated from the date of engagement to the end of quarter. Fees will be pro- rated for deposits and withdrawals $1,000 and over. In the event that CWA’s services are terminated mid-quarter, the Firm’s fee shall be prorated through the date of termination and any unearned balance will be refunded to the client in a timely manner. 11  Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement for a full refund and no obligation. For any termination after five (5) business days, the client will be entitled to a pro rata refund for the days service was not provided in the final quarter. CWA can modify the fee schedule upon a minimum of thirty (30) days written notice to the client. CWA will remit an invoice to the custodian and client showing the amount of the fee, the value of the client’s assets on which the fee was based, and the specific manner in which the fee was calculated. It is the client’s responsibility to verify the accuracy of the fee calculation as the custodian will not determine whether the fee is properly calculated. All investment advisory fees paid directly to CWA will be reflected on the client’s account statements that are prepared and sent to the client by the custodian. Clients are urged to compare the custodian’s account statements with any statements sent by CWA. In the event CWA recommends the services of a TPM to manage all or part of the client’s assets, CWA’s fees will not differ. If and when CWA allocates client assets to TPMs, such clients may be required to enter into an investment management agreement or similar contractual relationship directly with the selected TPM(s), who may charge an additional annual management fee ranging which will be disclosed in that TPM(s) agreement. The total of CWA and the TPM(s) fees will not COMPENSATION FOR ERISA SERVICES exceed an annualized fee of 3% of the total assets managed. The annual fees are based on the market value of the Included Assets and will not exceed 1.5%. Fees are billed quarterly in arrears, depending on the Plan. The initial fee will be based on the market value of the Plan assets as calculated by the custodian or record keeper of the Included Assets on the first business day of the initial fee period and will be due on the first business day of the fee period. If the services to be provided start any time other than the first day of a quarter, the fee will be prorated based on the number of days remaining in the initial fee period. Thereafter, the fee will be based on the market value of the Plan assets on the last business day of the previous fee period (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets) and will be due the following business day. If this Agreement is terminated prior to the end of the fee period, CWA shall be entitled to a prorated fee based on the number of days during the fee period services were provided. Any unearned fees shall be refunded to the Plan or Plan Sponsor. The compensation of CWA for the services provided is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may elect to pay the fees. CWA does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, CWA will disclose this compensation, the services rendered, and the payer of compensation. CWA will Additional Client Fees Charged offset the compensation against the fees agreed upon under this Agreement. Clients will incur certain fees or charges imposed by third-parties other than CWA in connection with investments or recommendations made by the Firm. CWA does not receive any portion of these fees. These fees and charges are separate and distinct from the fees or charges stated above and may include, but not be limited to: brokerage and transactions fees, mutual fund 12b-1 fees, certain deferred sales charges on previously purchased mutual funds transferred into the account, other transaction related fees, IRA and Qualified Retirement Plan fees, interest charged on margin 12  borrowing, bank service fees, interest charged on debit balanced, “spreads” imposed by brokers and dealers representing implicit transaction costs, commissions and transfer taxes. Information regarding fees or charges assessed by any mutual funds held in client accounts is available in the appropriate prospectus. These fees are not retained by CWA. These fees are charged by the custodian and/or mutual funds who keep the fees for their services. Please also refer to Item 12 for more information on CWA’s brokerage practices. Client Payment of Fees Fees for asset management and ERISA services are deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. External Compensation for the Sale of Securities to Clients Fees for financial planning will be billed to the Client and paid directly to CWA. Michael Sellman (CA Insurance License#0G40881) and other CWA wealth advisors are licensed insurance agents of various independent insurance companies. In the course of providing investment advisory services, these individuals will recommend the purchase of various insurance products or policies underwritten by certain insurance carriers to certain clients, as applicable. Please note that a conflict of interest exists to the extent that these recommendations may result in a commission being paid to these individuals by the insurance company should a client purchase the recommended insurance products or policies. The amount paid is the normal and customary commission paid for services rendered as an insurance agent. To mitigate this conflict of interest, commissions that are paid to these individuals in their capacity as licensed insurance agents will be disclosed to the client at the time such insurance product or policy is recommended. Furthermore, clients should be aware that they are under no obligation to purchase insurance products or policies through CWA or any of the Firm’s wealth advisors. Mr. Sellman spends no more than ten percent of his time per month as licensed insurance agent. To the extent that CWA’s wealth advisors recommend the purchase of insurance or other investment products where they receive commissions for doing so, a conflict of interest exists because they will receive additional compensation should the clients elect to follow their recommendations, even if such recommendation is based on the best interest of the clients and their needs. CWA has adopted certain procedures designed to mitigate the effects of these conflicts. For example, as part of CWA’s fiduciary duty to clients, the Firm and its wealth advisors will endeavor at all times to put the interests of the clients first, and recommendations will only be made to the extent that they are reasonably believed to be suitable and in the best interests of the client. Additionally, material conflicts presented by these practices are disclosed to clients at the time of entering into any new advisory or financial planning arrangement. e.g. The advisory fees charged for CWA’s Investment Management Services and Financial Planning Services are calculated as described above and are not charged on the basis of a share of capital gains or the performance of the client’s account. Clients may purchase some investments directly without the services of CWA. In that case, the client would not receive the services provided by the Firm, which are designed, among other things, to assist the client in determining which investments may be appropriate to the client’s financial situation and objectives. Clients should review the fees charged by the investments ( mutual funds), the fees charged by the Firm, and fees charged by other third-parties to fully understand the total amount of fees being paid. Only then will the client be able to fully evaluate the advisory services being provided and the fees being paid. 13  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Sharing of Capital Gains CWA does not charge performance-based fees (i.e., fees calculated based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client). Consequently, the Firm does not engage in side-by-side management of accounts that are charged a performance-based fee with accounts that are charged another type of fee (such as assets under management). As described in Item 5, above, CWA provides its investment advisory services for a fixed fee and/or based upon a percentage of assets under management. ITEM 7: TYPES OF CLIENTS Description CWA provides its services to individuals, including high-net worth individuals, pension and profit- Account Minimums sharing plans, trusts, estates, charitable organizations and small business entities. For the Firm’s Model Portfolio Program, CWA typically requires a minimum balance of $25,000 to open an account. For the Firm’s Custom Portfolio Program, CWA typically requires a minimum balance of $1,000,000 to open an account. These minimums may be waived or varied in the Firm’s discretion. CWA also reserves the right to accept or decline a potential client for any reason. Prior to engaging CWA to provide Investment Management Services and/or Financial Planning Services described in this Brochure, the client will be required to enter into one or more written agreements with CWA setting forth the terms and conditions under which the Firm will render its ERISA Disclosures services. If a client’s account is a pension or other employee benefit plan governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), CWA will be a fiduciary to the plan, depending on the circumstances. In providing our investment management and financial planning services, the sole standard of care imposed upon us is to act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. CWA will provide certain required disclosures to the “responsible plan fiduciary” (as such term is defined in ERISA) in accordance with Section 408(b)(2), regarding the services we provide, the direct compensation we receive, and any indirect compensation that we also receive. Generally, these disclosures are contained in this Form ADV Part 2A, the client agreement and/or in separate ERISA disclosure documents, and are designed to enable the ERISA plan’s fiduciary to: (1) determine the reasonableness of all compensation received by CWA; (2) identify any potential conflicts of interests; and (3) satisfy reporting and disclosure requirements to plan participants. 14  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis Generally, CWA uses a variety of analytical information to assist with its security analysis. However, the primary methods of analysis used by CWA are fundamental and, from time to time, cyclical analysis. The sources of information used by CWA include, but are not limited to, market news reports, financial publications, corporate rating services, outside research reports, annual reports, prospectuses, SEC filings, company press releases, and interpretation of exchange market data. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Typically, where a TPM is selected for a client's investments, CWA's security analysis is limited to screening of TPM's investment process. In these cases, the TPM is responsible for security analysis and selection and the Firm does not perform these duties. CWA will review the performance of each TPM chosen, including routine due diligence on the managers, as well as a review of the client’s current asset allocation. Due diligence will include such items as a review of the TPM’s current management, disclosure documentation, investment strategy and performance comparisons to other similar management philosophies and relevant benchmarks. CWA may also utilize resources supplied by Charles Schwab & Co., Inc. (“Schwab”) to perform due diligence on TPMs. Please refer to Item 12, below, for more information on certain benefits CWA may receive Investment Strategies from Schwab. • As outlined in Item 4 above, CWA currently offers two types of investment management services. The Model Portfolio Program uses asset allocation models covering the following strategies: • Conservative: This strategy may be suitable for those investors who seek to prevent the loss of an investment’s value but still desire inflation protection. • Moderate: This strategy may be suitable for those investors whose primary investment goal is to seek to maximize the current income from their investments while reducing volatility. • Moderately- Aggressive: This strategy may be suitable for those investors who may want their investments to begin producing passive income in the near future and/or seek to balance appreciation with volatility. Aggressive: This strategy may be suitable for those investors who have a long-term time horizon and who are comfortable with significant market fluctuations. These model portfolios are typically created using separately managed accounts (SMAs), no-load mutual funds, exchange-traded funds (ETFs), equities, fixed-income products and other permitted securities. 15  The Custom Portfolio Program is customized specifically to each client’s financial circumstances, future financial needs, investment goals, return objectives, and risk tolerance, and may be comprised of separately managed accounts (SMAs), no-load mutual funds, exchange-traded funds Risk of Loss (ETFs), , equities, fixed-income products and other permitted securities. Investing in securities involves risk of loss that clients should be prepared to bear. Prior to entering into an Investment Advisory Agreement with CWA, a client should carefully consider: 1) committing to management only those assets that the client believes will not be needed for current purposes and that can be invested on a long-term basis, usually a minimum of three to five years, 2) that volatility from investing in the stock market can occur, and 3) that over time the client’s assets may fluctuate and at any time be worth more or less than the amount invested. • Some of risks of loss a client should be aware of include, but are not limited to, the following: • Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a stock, bond, mutual fund or other security may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Political and Legislative Risks: Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning and with significant impact on financial markets and securities. This is especially true for companies operating outside of the United States or that conduct a portion of their business outside of the United States. i.e. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return ( interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. Generally, business risk is that a company will go bankrupt or perform below expectations. Every company carries the business risk that it will produce insufficient cash flow in order to maintain operations. Business risk can come from a variety of sources, some systemic and others unsystemic. That is, every company has the business risk that the broader economy will perform poorly and therefore that sales will be poor, and also the risk that the market simply will not like its products. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if there is an active market for the asset. For example, Treasury Bills are highly liquid, while real estate properties are not. 16  • • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Counterparty Risk: The risk that the other party to an agreement will default or fail to perform its contractual obligations. In an options contract, counterparty risk is the risk to the option buyer that the option writer will not buy or sell the underlying as agreed. • Foreign Investment Risk: Investments in foreign securities may be riskier than U.S. investments because of factors such as, unstable international, political and economic conditions, currency fluctuations, foreign controls on investment and currency exchange, foreign governmental control of some issuers, potential confiscatory taxation or nationalization of companies by foreign governments, withholding taxes, a lack of adequate company information, less liquid and more volatile exchanges and/or markets, ineffective or detrimental government regulation, varying accounting standards, political or economic factors that may severely limit business activities, and legal systems or market practices that may permit inequitable treatment of minority and/or non-domestic investors. Investments in emerging markets may involve these and other significant risks such as less mature economic structures and less developed and more thinly-traded securities markets. • Senior Secured Debt: Because senior loans can be made to non-investment grade borrowers, the risk of default may be greater. Should a borrower fail to make a payment or default, this may affect the overall return to the lender. Interest rate is another risk as interest rate changes will affect the amount of interest paid by a borrower in a floating rate senior loan. • Non-traded REIT or Institutional REIT Funds: To the extent that a Client invests in REITs, it is subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self- liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. • Land: Investments in land have unique risks with several restrictions and challenges. Factors to consider when in investing in land are zoning restrictions with the way the land can be used, environmental issues and access to utilities. Investing in land is a speculative investment and for small investors can be a high risk gamble of earning a fair rate of return while continuing to have expenses while holding the land. Energy Infrastructure: Investments in energy infrastructure are subject to regulatory risk political risk, social risk, technological risk, climate and environmental risk and economic risk. 17  • • Hedged Equity Strategies: Hedging is a risk management strategy to offset losses by taking an opposite position in a related asset. The reduction in risk provided by hedging also typically results in a reduction in potential profits. • Managed Futures: The risks associated with managed futures strategies include returns that may be biased upwards due to the voluntary nature of self-reporting of performance. Lack of natural measuring stick or benchmark for performance rating and the potential for higher fees. Derivatives Risk: Funds in a client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the first place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. . • CWA clients may also elect to open margin accounts. Clients should be aware that there are a number of additional risks that all investors need to consider in deciding to trade securities on margin. The risks associated with margin include, but are not limited to, the following: • Clients can lose more funds than they deposit in the margin account A decline in the value of securities that are purchased on margin may require the client to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities in the account. The lending firm may be able to force the sale of securities in a margin account. If the equity in margin account falls below the maintenance requirements under the law—or the lending firm’s higher "house" requirements—the firm may be able to sell the securities in the margin account to cover the margin deficiency. Clients using margin may also be responsible for any short fall in the account after such a sale. It is important that investors take time to learn about the risks involved in trading securities on margin, and investors should consult CWA’s advisers regarding any questions or concerns they may have with their margin accounts. Depending on the sophistication and risk tolerances of its clients, CWA also recommends, as part of a client’s overall investment strategy, that a portion of such client’s assets be invested in private placements or other alternative investments. Such investments may present special risks for the Firm’s clients, including without limitation, limited liquidity, higher fees, volatile performance, heightened risk of loss, limited transparency, special tax considerations, subjective valuations and limited regulatory oversight. Therefore, private placements may not be suitable for all CWA clients and will be offered only to those qualifying clients for whom an investment is believed to be suitable. Generally, such investments are available for investment only to a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933. Private placements also often impose performance-based fees or incentive allocations payable to the fund manager or general partner. Such performance-based fee/incentive allocation structures may create an incentive for the managers of the private placement to make investments that are riskier or more speculative than would be the case in the 18  absence of a performance-based fee/incentive allocation structure. It is important that each potential qualified investor fully read each offering or private placement memorandum prior to investing to better understand the risks associated with the investment. CWA typically invests for the long-term and does not engage in high frequency trading. Nevertheless, TPMs selected or recommended by the Firm may employ such strategies, and as a result, such frequent trading may result in increased brokerage and other transaction costs. Such increased brokerage and other transaction costs generally reduce investment returns over time. Please refer to the recommended or selected TPM’s Form ADV Part 2 or similar disclosure document for additional information regarding the risks associated with their services. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisers such as CWA are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. CWA does not have any such legal or disciplinary events and thus has no information to disclose with respect to this Item. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Broker-Dealer or Representative Registration CWA is not registered as a broker-dealer and no affiliated representative of CWA are registered Futures or Commodity Registration representative of a broker-dealer Neither CWA nor its employees are registered or have an application pending to register as a Financial Industry Activities and Affiliations futures commission merchant, commodity pool operator, or a commodity trading advisor. Michael Sellman (CA Insurance License#0G40881) and other CWA wealth advisors are licensed insurance agents of various independent insurance companies. In the course of providing investment advisory services, these individuals recommend the purchase of various insurance products or policies underwritten by certain insurance carriers to certain clients. Please note that a conflict of interest exists to the extent that such recommendations, when implemented by a client results in a commission being paid to these individuals by the insurance company issuing the insurance. The amount paid is the normal and customary commission paid for services rendered as an insurance agent. To mitigate this conflict of interest, commissions that are paid to these individuals in their capacity as licensed insurance agents will be disclosed to the client at the time such insurance product or policy is recommended. Furthermore, clients should be aware that they are under no obligation to purchase any insurance products or policies through CWA, any of the Firm’s wealth advisors, or any insurance company the wealth advisors are affiliated with. To the extent that CWA’s wealth advisors recommend the purchase of insurance or other investment products where they may receive commissions for doing so, a conflict of interest exists because they will receive additional compensation should the clients elect to follow their recommendations, even if such recommendation is based on the best interest of the clients and their needs. CWA has adopted certain procedures designed to mitigate the effects of these conflicts. For example, as part of CWA’s fiduciary duty to clients, the Firm and its wealth advisors will endeavor at all times to put the interests of the clients first, and recommendations will only be made to the extent that they are reasonably believed to be suitable and in the best interests of 19  the client. Additionally, material conflicts presented by these practices are disclosed to clients at the time of entering into any new advisory or consultative arrangement. Ms. Barrett is Founder and President of Barrett Solutions Inc. and Owner and Chief Executive Officer of CFO, Inc. Barrett Solutions Inc. provides bookkeeping and payroll services for an hourly or fixed fee. CFO, Inc. provides payroll services, bookkeeping services and CFO/business consulting services (including various administrative support, such as creation of marketing collateral) to high net worth families and small businesses (including CWA), for which CFO, Inc. receives an hourly of fixed fee pursuant to the client’s written services agreement. Approximately 50% of her time is spent on these activities. There are clients of CWA that utilize these services. These practices represent conflicts of interest because it gives an incentive to recommend services based on the compensation received. These conflicts are mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any services. Clients have the option to purchase these services through Recommendation of Other Advisers another company of their choosing. Under certain circumstances, CWA will recommend or select the services of certain TPMs as part of its overall asset allocation strategy for client accounts. In these situations, CWA will not receive compensation from the TPM for the referral and the fees charged by CWA do not vary based on the TPM. Prior to referring clients to third-party advisors, CWA makes sure that they are licensed or notice filed with California’s Department of Financial Protection and Innovation or other applicable state or federal regulatory authority. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Description of Code of Ethics As a registered investment adviser, CWA is under a fiduciary obligation to act in the best interests of its clients. CWA's clients therefore entrust us to use the highest standards of integrity when dealing with their assets and making investments that impact their financial future. Our fiduciary Code of duty compels the Firm and all of its employees to act with integrity in all dealings with clients. To Ethics that end, the Firm has adopted personal securities transaction policies in the form of a (“Code”), which all CWA associated persons must follow. This Code provides personnel with guidance in their ethical obligations regarding their personal securities transactions and fiduciary duties. Specifically, the Code requires personnel to report personal trades and holdings and prohibits or requires pre-clearance for certain trades in certain circumstances. The Code also contains procedures for reporting violations and enforcement. The Code is reviewed and distributed to personnel no less than annually. CWA will provide a copy of the Code to any client or prospective client upon request. To obtain a copy of CWA’s Code, please contact the Firm at (760) 476-1376. CWA obtains information from a wide variety of publicly available resources. The Firm and its personnel do not have, nor claim to have, insider or private knowledge. 20  Participation or Interest in Client Transactions From time to time, CWA and/or its related persons take positions in the same securities as those recommended to its clients. To mitigate the conflicts of interest associated with this practice, CWA’s Code provides personnel with guidance in their ethical obligations regarding their personal securities transactions. The Firm’s Chief Compliance Officer, or his designee, will also periodically review employee transactions to help ensure compliance with the Code and fulfillment of CWA’s fiduciary obligations. ITEM 12: BROKERAGE PRACTICES Selection Criteria ® When performing Investment Management Services, CWA generally recommends that clients use Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”) or Inspira Financial as custodians of their account assets. • The Firm periodically evaluates the commissions charged and the service provided by the broker- dealer custodian and compares those with other broker-dealers to evaluate whether overall best qualitative execution could be achieved by using alternative broker-dealer custodians. Other factors the Firm may consider when evaluating its choice of broker-dealer custodian include: • Ability to trade mutual funds and other investments that CWA determines suitable for a client's portfolio; • Any custodial relationship between the client and the broker-dealer; • Quality of customer service and interaction with broker-dealer custodian; • Discount transaction rates; and Reliability and financial stability. The broker-dealer custodian recommended by the Firm may not provide the lowest commission rate available taking into consideration factors outlined above. For those clients who direct brokerage and select broker-dealers not recommended by CWA, clients should be aware that CWA may not be able to negotiate specific brokerage commission rates with the broker on the client’s behalf, or seek better execution services or prices from other broker-dealers. As a result, the client may pay higher commissions and/or receive less favorable net prices on transactions for their account than might otherwise be the case and the Firm will have limited ability to ensure that the broker-dealer selected by the client will provide best possible execution. Please Schwab Custodian Arrangement refer to Item 12.C. below, for more information on directed brokerage. Client Custody and Brokerage Costs: For CWA clients’ accounts that Schwab maintains, Schwab is compensated by charging the client commissions or other fees on trades that it executes or that settle into the client’s Schwab account. Schwab’s commission rates applicable to CWA client accounts were negotiated based on a commitment to maintain a minimum amount of clients’ assets at Schwab. This commitment benefits CWA clients utilizing Schwab because the overall commission rates a client pays can be lower than they would be if CWA had not made the commitment. In addition to commissions Schwab charges custodial clients a flat dollar amount as a “prime broker” or “trade away” fee for each trade that CWA has executed by a different broker- dealer but where the securities bought or the funds from the securities sold are deposited (settled) 21  into the client’s Schwab account. These fees are in addition to the commissions or other compensation a client can pay the executing broker-dealer. Because of this, in order to minimize Products and Services Available to CWA from Schwab: client trading costs, CWA has Schwab execute trades for client accounts maintained at Schwab. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firm. They provide CWA and the clients custodied at Schwab with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help CWA manage or administer Schwab custodied clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to CWA as long as we keep a certain minimum amount of our clients’ assets in accounts at Schwab. Here is a more detailed description of Schwab’s support services: Services that Benefit CWA Clients: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which CWA might not otherwise have access or that would require a significantly higher minimum initial investment by CWA clients. Schwab’s services described in this paragraph generally benefit CWA Schwab custodied client accounts. • Services that Do Not Directly Benefit CWA Clients: Schwab also makes available to CWA other products and services that benefit the Firm but do not directly benefit clients. These products and services assist CWA in managing and administering our clients’ accounts maintained at Schwab. They include investment research, both Schwab’s own and that of third parties. CWA can use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: Provides access to client account data (such as duplicate trade confirmations and • account statements); Facilitates trade execution and allocates aggregated trade orders for multiple client • • accounts; facilitate payment of our fees from our clients’ Provides pricing and other market data; • accounts; and Assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only CWA: Schwab also offers other services intended to help CWA manage and further develop our business enterprise. These services include: • • Educational conferences and events • Technology, compliance, legal, and business consulting; • Publications and conferences on practice management and business succession, and Access to employee benefits providers, human capital consultants and insurance providers. Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services. Schwab also discounts or waives certain of its fees for some of 22  these services or will pay all or a part of a third party’s fees. Schwab also provides us with other Soft Dollar Considerations benefits such as occasional business entertainment of our personnel. Section 28(e) of the Exchange Act (“Section 28(e)”) generally allows investment advisers to use client commissions to pay for certain brokerage and research services under certain circumstances without breaching their fiduciary duties to clients. Therefore, CWA does in circumstances in which we feel that execution is comparable, place certain trades with a third-party broker that is providing brokerage and research services to us (“Research Broker”). Brokerage and research services provided by Research Brokers include, among other things, effecting securities transactions and performing services incidental thereto (such as clearance, settlement and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical information, taxation; political developments, legal developments, technical market action, pricing and appraisal services, credit analyses; risk measurement analysis and performance analysis. Such research services can be received in the form of written reports, telephone conversations, and personal meetings with security analysts and/or individual company management and attending conferences. The research services provided by a Research Broker may be proprietary (i.e., research created by the broker) and/or provided by a third party (i.e. originates from a party independent from the broker providing the execution services, which is commonly referred to as a third-party soft dollar arrangement). In selecting a Research Broker, CWA will make a good faith determination that the amount of the commission charged is reasonable in relation to the value of the brokerage and research services received, viewed in terms of either the specific transactions our overall responsibility to the accounts for which we exercise investment discretion In accordance with Section 28(e), CWA may cause a client to pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage and/or research services provided by such broker. Research services provided by Research Brokers can be used by us in servicing any or all of our clients and can be used in connection with clients other than those making the payment of commissions to a Research Broker, as permitted by Section 28(e). In other words, there could be certain client accounts that benefit from the research services, which did not make the payment of commissions to the Research Broker providing the services. The receipt of brokerage and research services from any broker executing transactions for our clients will not result in a reduction of our customary and normal research activities, and the value of such information is, in our view, indeterminable. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit by us, and although customary, can be deemed to create a conflict of interest between CWA and our clients. Therefore, we feel it is important for clients to be aware of the issues surrounding soft dollars. To address the conflicts inherent in soft dollar arrangements, CWA monitors and reviews transaction results to evaluate the quality of execution provided in order to determine that compensation rates are competitive and otherwise to evaluate the reasonableness of the compensation paid to the executing broker-dealer(s) in light of all the factors described above and that our clients are receiving the best overall deal considering the prevailing facts and circumstances. Directed Brokerage Currently, CWA does not have any third party soft dollar arrangements in place. Under certain circumstances, CWA may allow a client to direct the Firm to execute all or a portion of client transactions through a specific broker (“Directed Brokerage”). If that is the case, the client should understand that: (1) CWA does not negotiate specific brokerage commission rates with the 23  broker on client’s behalf, or seek better execution services or prices from other broker/dealers and, as a result, the client may pay higher commissions and/or receive less favorable net prices on transactions for their account than might otherwise be the case; and (2) transactions for that account generally will be effected independently unless CWA is able to purchase or sell the same security for several clients at approximately the same time (“block trade”), in which case the Firm may include such client’s transaction with that of other clients for execution by the same broker. If transactions are not able to be traded as a block, CWA may have to enter the transactions for the client’s account after orders for other clients, with the result that market movements may work against the client. Clients should understand that he/she might not obtain commissions rates as low as it might otherwise obtain if CWA had discretion to select other broker-dealers. Consequently, Directed Brokerage may result in the client paying more money for brokerage services. Subject to its objective to achieve best execution, CWA may decline a client’s request to engage in Directed Brokerage if, in Firm’s sole discretion, such Directed Brokerage arrangements would Order Aggregation result in additional operational difficulties or violate restrictions imposed by other broker-dealers. When able to do so and deemed to be in the best interest of clients, CWA will aggregate client trades for the same security together and place as a block trade.. Trade aggregation, or “bunching of orders,” may result in better execution and/or better realized prices. Because CWA’s Investment Management Services utilize various types of investments and securities, it may not always be possible bunch orders. Alternatively, even when possible, CWA may not be able to execute all shares of an aggregated trade because of prevailing market conditions and other variables, in which case the Firm will allocate the trade among participating accounts in an equitable manner. Ordinarily, the executing broker-dealer will provide an average price, and where possible, average transaction costs that will be allocated to all accounts participating in the aggregated trade. In certain cases, the Firm may not be able to purchase or sell the same security for all clients that could transact in the security, which is generally based on various factors such as the type of security, size of the account, cash availability and account restrictions. For clients requiring directed brokerage, typically the Firm may not be able to effectively "bunch" orders on the client's Third Party Managers behalf, which could impact the possible advantage clients derive from the aggregation of orders. Generally, the TPM selected for managing a portion of a client’s assets is provided with trading authority over those assets through the applicable agreements. The TPM, like CWA, has a fiduciary duty to the CWA client to seek best execution on the trades placed on the client’s behalf. The Form ADV Part 2A for each TPM outlines, among other things, the TPM’s brokerage and best execution procedures. That document is provided to each CWA client utilizing a TPM and it is important for each such client to read the document to fully understand the TPM’s trading practices, including any associated conflicts. ITEM 13: REVIEW OF ACCOUNTS Periodic Reviews While client accounts are monitored on an ongoing basis, CWA’s Chief Executive Officer, Chief Compliance Officer and wealth advisors undertake reviews of client accounts and financial plans no less than annually. Accounts and financial plans are reviewed for consistency with the investment strategy and other parameters set forth for the client’s account and financial plan, and 24  to determine if any adjustments need to be made. Financial plans and client accounts are also reviewed upon request by the client. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events and significant additions or withdrawals from the client’s account(s). Clients are encouraged to notify CWA and its wealth advisors of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, risk tolerance, tax status, time horizon or other material information CWA may have relied upon during the course of providing its services. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by CWA’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest As more fully explained in Item 12.B, above, CWA is provided with an economic benefit through its receipt of soft dollars in accordance with Section 28(e) of the Securities Exchange Act of 1934. The Firm may enter into these “soft dollar” arrangements whereby brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services which assist CWA in its investment decision-making process. The receipt of such services may be perceived to serve as an economic benefit to CWA, and although customary, these arrangements give rise to potential conflicts of interest, including the incentive to allocate securities transactional business to broker-dealers based on the receipt of such benefits rather than on a client’s interest in receiving most the favorable execution. The potential conflict of interest is mitigated by disclosures, procedures and CWA’s fiduciary duty to its clients, to put the interest of the clients first. As noted in Item 5.D., above, Michael Sellman (CA Insurance License#0G40881) and other wealth advisors are licensed insurance agents of various independent insurance companies. In the course of providing investment advisory services, they recommend to clients the purchase of insurance products or policies underwritten by certain insurance carriers. Please note that a conflict of interest exists to the extent that when clients purchase such insurance products or policies it results in a commission being paid to these individuals by the insurance company The amount paid is the normal and customary commission paid for services rendered as an insurance agent. To mitigate this conflict of interest, commissions that may be paid to these individuals in their capacity as licensed insurance agents will be disclosed to the client at the time such insurance product or policy is recommended. Furthermore, clients should be aware that they are under no obligation to purchase insurance products or policies at all, or through CWA or any of the Firm’s wealth advisors. 25  To the extent that CWA’s wealth advisors recommend the purchase of securities, insurance or other investment products where they may receive commissions for doing so, a conflict of interest exists because they will receive additional compensation should the clients elect to follow their recommendations, even if such recommendation is based on the best interest of the clients and their needs. CWA has adopted certain procedures designed to mitigate the effects of these conflicts. For example, as part of CWA’s fiduciary duty to clients, the Firm and its wealth advisors will endeavor at all times to put the interests of the clients first, and recommendations will only be made to the extent that they are reasonably believed to be suitable and in the best interests of the client. Additionally, material conflicts presented by these practices are disclosed to clients at Advisory Firm Payments for Client Referrals the time of entering into any new advisory, brokerage or consultative arrangement. CWA may, from time to time, enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with CWA, that refer clients to CWA in exchange for compensation. All such agreements will be in writing and comply with the requirements of California law. If a client is introduced to CWA by a referring party, CWA may pay that referring party a fee. While the specific terms of each agreement may differ, generally, the compensation will be based upon CWA’s engagement of new clients and is calculated using a varying percentage of the fees paid to CWA by such clients. Any such fee shall be paid solely from CWA’s investment management fee, and shall not result in any additional charge to the client. Some parties referring clients to CWA may be tax preparers. This practice represents a conflict of interest to the referring party because it gives them an incentive to recommend CWA based on the compensation received and/or the reciprocated referral to them. These conflicts are mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the client first and the clients are not required to purchase any services. Clients have the option to purchase these services through another company of their choosing. Each prospective client who is referred to CWA under such an arrangement will receive a copy of this brochure and a separate written disclosure document disclosing the nature of the relationship between the referring party and CWA and the amount of compensation that will be paid by CWA to the referring party. The referring party is required to obtain the client’s signature acknowledging receipt of CWA’s disclosure brochure and the written disclosure statement. ITEM 15: CUSTODY Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by CWA. CWA is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of CWA. ITEM 16: INVESTMENT DISCRETION Discretionary Authority for Trading For CWA’s Investment Management Services, the Firm has discretionary authority to determine, without first obtaining client’s permission for each transaction: 1) the type of securities to be 26  bought and sold, 2) the amount of the securities to be bought and sold, 3) whether a client’s transaction should be combined with those of other clients and traded as a “block”, and 4) in some cases the brokers to use and the commission rates and/or transactions costs paid to effect the transactions. The Firm’s clients grant CWA this discretionary authority by signing the Firm’s Investment Advisory Agreement. Furthermore, when a TPM is chosen or recommended by CWA to work with the client’s account(s), the TPM will also generally have the authority to determine, without obtaining specific client consent, the securities to be bought or sold and the amount of securities to be bought or sold for the client’s account. If however, consent for discretion is not given, CWA will obtain prior client approval before executing each transaction. Investment Management Services clients are allowed to impose reasonable restrictions on the types of securities, companies and/or industries they do not want to be included in their account. Once this information is gathered, each client is responsible for informing CWA in writing of any changes to these restrictions or to their overall investment objectives. ITEM 17: VOTING CLIENT SECURITIES Proxy Votes CWA's policy and practice is to not vote proxies on behalf of its clients and therefore, shall have no obligation or authority to take any action or render any advice with respect to the voting of proxies solicited by or with respect to issuers of securities held in a client’s account. Consequently, the Firm’s clients retain the responsibility for receiving and voting all proxies for securities held within the client's account. Should proxy solicitations materials inadvertently be sent to CWA, they will be forwarded to the client for response and voting in a timely manner. CWA shall not be deemed to have proxy voting authority solely as a result of providing advice or information about a particular proxy vote to a client. For ERISA clients only, in the event that a Plan Sponsor requests CWA to vote proxies, CWA will do so. CWA typically does not advise or act for clients with respect to any legal matters, including bankruptcies and class actions, for the securities held in clients’ accounts. ITEM 18: FINANCIAL INFORMATION Balance Sheet A balance sheet is not required to be provided because CWA does not serve as a custodian for Client funds or securities and CWA does not require prepayment of fees of more than $1,200 per Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Client and six months or more in advance. Commitments to Clients CWA is committed to the supporting our employees, who are instrumental in supporting services to you, our client. On May 6, 2020, CWA received a Paycheck Protection Program (“PPP”) loan through the Small Business Administration in conjunction with the relief afforded from the Coronavirus Aid, Relief, and Economic Security Act. CWA intends to use the entire loan for qualifying (e.g., to supplement payroll and other expense items as allowed under the program). CWA currently believes that our use of the loan proceeds will meet the conditions for forgiveness of the loan. If the PPP loan is used in any manner other than allowed under the program, we believe that CWA will be able to pay back this loan with no impairments to clients as a result of the loan. 27  Bankruptcy Petitions during the Past Ten Years CWA has not had any bankruptcy petitions in the last ten years. 28  Brochure Supplement (Part 2B of Form ADV) February 13, 2026 Michael Sellman Cornerstone Wealth Advisors, Inc. 1808 Aston Avenue, Suite 150 Carlsbad, CA 92008 Telephone: (760) 476-1376 Fax: (760) 476-2718 www.cwainvestors.com This brochure supplement provides information about Michael Sellman that supplements Cornerstone Wealth Advisors, Inc.’s brochure. You should have received a copy of that brochure. Please contact us at (760) 476-1376 if you did not receive Cornerstone Wealth Advisors Inc.’s brochure or if you have any questions about the contents of this supplement. Thank you. Additional information about Michael Sellman (CRD #5261051) is available on the SEC’s website at www.adviserinfo.sec.gov. 29  Brochure Supplement (Part 2B of Form ADV) Principal Executive Officer Michael Sellman, CFP® Year of birth: 1983 ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Educational Background: Business Background: Boise State University, BA – Finance, Boise, ID (2005) • • • • • • • • Cornerstone Wealth Advisors, Inc.; Chief Compliance Officer/Investment Advisor Representative (05/2020 – Present) Cornerstone Wealth Advisors, Inc.; Chief Compliance Officer (02/2014 – Present) Cornerstone Wealth Advisors, Inc.; Investment Advisor Representative (05/2011- Present) Independent Insurance Agent (10/2010 – Present) Gradient Securities, LLC; Registered Representative (07/2012 –10/2024) Securities Equity Group; Registered Representative (10/2010 – 07/2012) Morgan Stanley Smith Barney; Registered Associate (09/2008 – 10/2010) Smith Barney; Registered Associate (11/2006 – 08/2008) Explanation of Professional Designation: Certified Financial Planner™ (CFP®) ® ® ® certification in the United States. certification is a voluntary certification; no federal or state law or regulation The CFP requires financial planners to hold CFP certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have obtained CFP ® marks, an individual must satisfactorily fulfill the • To attain the right to use the CFP following requirements: Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate conservation; 30  • ® • • Standards of Professional Conduct , a set of ® Examination – Pass the comprehensive CFP Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP professionals. ® • Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP marks: Standards of Code of Ethics Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the • and other parts of the , to maintain competence and keep up with developments in the Standards of Professional Conduct ® . professionals provide financial professionals must financial planning field; and Ethics – Renew an agreement to be bound by the ® The Standards prominently require that CFP planning services at a fiduciary standard of care. This means CFP provide financial planning services in the best interests of their clients. ® ® certification. professionals who fail to comply with the above standards and requirements may be CFP subject to CFP Board’s enforcement process, which could result in suspension or permanent ITEM 3: DISCIPLINARY INFORMATION revocation of their CFP A. Mr. Sellman has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: 1. 2. 3. 4. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; Was found to have been involved in a violation of an investment-related statute or regulation; or Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. B. Mr. Sellman never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: 31  1. 2. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his investment- related activities; or (d) imposing a civil money penalty of more than $2,500 on him. C. Mr. Sellman has never been the subject of a self-regulatory organization (SRO) proceeding in which he: 1. 2. Was found to have caused an investment-related business to lose its authorization to do business; or Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. D. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Sellman has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. In addition to his activities at CWA, Mr. Sellman is a licensed insurance agent/broker with various unaffiliated insurance companies or agencies (California Insurance License # 0G40881). To the extent that Mr. Sellman recommends the purchase of insurance products where he receives commissions for doing so, a conflict of interest exists because Mr. Sellman may have an incentive to make recommendations based on the compensation received rather than on a client’s needs. CWA has adopted certain procedures designed to mitigate the effects of these conflicts. As part of the Firm’s fiduciary duty to clients, CWA and its representatives will endeavor at all times to put the interests of the clients first, and recommendations will only be made to the extent that they are reasonably believed to be in the best interests of the client. Additionally, the conflicts presented by these practices are disclosed to clients at the time of entering into an advisory agreement. ITEM 5: ADDITIONAL COMPENSATION As described in Item 4 above, from time to time, advisory clients may implement insurance transactions through Mr. Sellman in his capacity as a licensed insurance agent appointed with various insurance companies. Accordingly, Mr. Sellman receives commissions for the sale of insurance products purchased for a client’s account. In addition, when a client chooses to make certain investments in mutual funds or other products, Mr. Sellman also receives additional ongoing 12b-1 fees or trails for those purchases during the period that the client maintains the investment or insurance product. 32  In addition, Mr. Sellman may be entitled to an end of year discretionary bonus based on ITEM 6: SUPERVISION overall firm profitability. Michael Sellman is the Chief Compliance Officer of CWA. As such, Mr. Sellman is responsible for all advice provided to the Firm’s clients. Mr. Sellman may be contacted at (760) 476-1376 or m.sellman@cwainvestors.com. 33  Brochure Supplement (Part 2B of Form ADV) February 13, 2026 Denise A. Barrett Main Office Cornerstone Wealth Advisors, Inc. 1808 Aston Avenue, Suite 150 Carlsbad, CA 92008 Telephone: (760) 476-1376 Fax: (760) 476-2718 www.cwainvestors.com This brochure supplement provides information about Denise A. Barrett that supplements Cornerstone Wealth Advisors, Inc.’s brochure. You should have received a copy of that brochure. Please contact us at (760) 476-1376 if you did not receive Cornerstone Wealth Advisors, Inc., brochure or if you have any questions about the contents of this supplement. Thank you. Additional information about Denise A. Barrett (CRD #6377547) is available on the SEC’s website at www.adviserinfo.sec.gov. 34  Brochure Supplement (Part 2B of Form ADV) Principal Executive Officer Denise A. Barrett Year of birth: 1953 Educational Background: ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE No Post Secondary Education Business Background: • • Cornerstone Family Office, Inc.; Owner/Chief Executive Officer (10/2016 - Present) • Cornerstone Wealth Advisors, Inc.; Chief Executive Officer/Investment Advisor Representative (08/2014 - Present) • Barrett Solutions Inc.; Founder/President (10/2013 – Present) • Barrett Solutions; Owner/Business Consulting (11/2006 – 10/2013) Barrett Cleere & Associates; Owner (01/1988 - 11/2006) ITEM 3: DISCIPLINARY INFORMATION A. Ms. Barrett has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which she: 1. 2. 3. 4. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; Is the named subject of a pending criminal proceeding that involves an investment- related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; Was found to have been involved in a violation of an investment-related statute or regulation; or Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, her from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. B. Ms. Barrett never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which she: 1. 2. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority(a)denying, suspending or revoking the authorization of the supervised person to act in an 35  investment-related business; (b) barring or suspending her association with an investment-related business; (c) otherwise significantly limiting her investment- related activities; or (d) imposing a civil money penalty of more than $2,500 on her. C. Ms. Barrett has never been the subject of a self-regulatory organization (SRO) proceeding in which she: 1. 2. Was found to have caused an investment-related business to lose its authorization to do business; or Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members, or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. D. ITEM 4: OTHER BUSINESS ACTIVITIES Ms. Barrett has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Ms. Barrett is Founder and President of Barrett Solutions Inc. and Owner and Chief Executive Officer of Cornerstone Family Office, Inc. (“CFO, Inc.”). Barrett Solutions Inc. provides bookkeeping and payroll services for an hourly or fixed fee. CFO, Inc. provides payroll services, bookkeeping services and CFO/business consulting services (including various administrative support, such as creation of marketing collateral) to high net worth families and small businesses (including CWA), for which CFO, Inc. receives an hourly of fixed fee pursuant to the client’s written services agreement. As an owner of these companies, Ms. Barrett is entitled to periodic distributions pursuant to the bylaws of the respective corporations. Approximately 50% of her time is spent on these activities. In addition, there are clients of CWA that utilize these services. These practices represent conflicts of interest because it gives an incentive to recommend services based on the fees received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any services. Clients have the option to purchase these services through another ITEM 5: ADDITIONAL COMPENSATION company of their choosing. see As CEO of CWA, Ms. Barrett may be entitled to an end of year discretionary bonuses based on overall firm profitability. Ms. Barrett also receives compensation in her role as President of Barrett Solutions Inc. a bookkeeping/payroll services company and CFO, Inc., which provides payroll ITEM 6: SUPERVISION services, bookkeeping services and CFO/business consulting services; Item 4 above. Denise Barrett is supervised by Michael Sellman, Chief Compliance Officer. He reviews Denise’s work through client account reviews, quarterly personal transaction reports as well as face-to- face and phone interactions. Mr. Sellman may be contacted at (760) 476-1376 or m.sellman@cwainvestors.com. 36