BCS WEALTH MANAGEMENT, LLC

BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 BCS Wealth Management, LLC CRD #115489 541 Sid Martin Road, Suite A Johnson City, Tennessee 37615 423-283-9821 www.bcswealth.com March 12, 2026 This Brochure provides information about the qualifications and business practices of BCS Wealth Management. If you have any questions about the contents of this Brochure, please contact us at 423- 283-9821 or LOlander@bcswealth.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. BCS Wealth Management is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about BCS Wealth Management is also available on the SEC’s website at www.adviserinfo.sec.gov. i  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Item 2 – Material Changes This Brochure is prepared in the revised format required beginning in 2011. Registered Investment Advisers are required to use this format to inform clients of the nature of advisory services provided, types of clients served, fees charged, potential conflicts of interest and other information. The Brochure requirements include the annual provision of a Summary of Material Changes (the “Summary”) reflecting any material changes to our policies, practices, or conflicts of interest made since our last required “annual update” filing. In the event of any material changes, such Summary is provided to all clients within 120 days of our fiscal year-end. Our last annual update was filed on March 11, 2025. If you would like a copy of the updated Brochure, please contact us at 423-283-9821 or LOlander@bcswealth.com. Our office address has changed to 541 Sid Martin Road, Suite A, Johnson City, TN 37615. ii  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Item 3 – Table of Contents Item 1 – Cover Page…………………………………………………………………………………………………………i Item 2 – Material Changes .................................................................................................................................... ii Item 3 – Table of Contents ................................................................................................................................... iii Item 4 – Advisory Business .................................................................................................................................. 4 Item 5 – Fees and Compensation ....................................................................................................................... 7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................... 8 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 8 Item 9 – Disciplinary Information ................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ........................................................... 11 Item 11 – Code of Ethics ...................................................................................................................................... 11 Item 12 – Brokerage Practices .......................................................................................................................... 12 Item 13 – Review of Accounts ........................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation .............................................................................. 15 Item 15 – Custody .................................................................................................................................................. 15 Item 16 – Investment Discretion ..................................................................................................................... 15 Item 17 – Voting Client Securities ................................................................................................................... 16 Item 18 – Financial Information ...................................................................................................................... 16 iii  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Item 4 – Advisory Business ® BCS Wealth Management, LLC (“BCSWM”) was formed in May 1998. Originally, the partners of the accounting firm Blackburn, Childers & Steagall, PLC decided to create a firm that could assist their clients with financial planning and investment management. This decision was based on years of clients requesting advice and to launch guidance in this important area of their lives. To that end, the firm partnered with Michael Alread, CFP BCSWM. Brochure Supplements Nicholas Clay, Nathan Goodwin, Myra O’Dell, and SCB Partnership are Members and owners of BCSWM. Please see for more information on these principal owners and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. As of December 31, 2025, BCSWM managed approximately $897,051,000 on a discretionary basis and $90,321,000 in non-discretionary assets. The total firm assets under management were approximately Services Provided $987,372,000. At the outset of each client relationship, BCSWM spends time with the client asking questions, discussing the client’s investment experience and financial circumstances, and broadly identifying major goals of the client. Clients may elect to retain BCSWM to prepare a financial plan as described below. This written report is presented to the client for consideration. In most cases, clients subsequently retain BCSWM to manage the investment portfolio on an ongoing basis. • For those financial planning clients making this election, and for other clients who do not need financial planning but retain BCSWM for portfolio management services, based on all the information initially gathered, BCSWM generally develops with each client: • a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile” or “Profile”); and the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments BCSWM will make or recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. Clients may impose restrictions on investing in certain securities or types of securities based on a client’s values or beliefs. While clients may impose these restrictions, BCSWM retains the right to terminate the agreement if the restrictions prevent proper servicing of the client’s account(s). Financial Planning One of the services offered by BCSWM is financial planning, described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial planning generally includes advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design. Depending on a client’s particular situation, financial planning may include some or all of the following: • • • Gathering factual information concerning the client's personal and financial situation; Assisting the client in establishing financial goals and objectives; Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives; 4  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 • • • • • • Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; Making recommendations to help achieve retirement plan goals and objectives; Designing an investment portfolio to help meet the goals and objectives of the client; Providing estate planning; Assessing risk and reviewing basic health, life, and disability insurance needs; or Reviewing goals and objectives and measuring progress toward these goals. Once financial planning advice is given, the client may choose to have BCSWM implement the client’s financial plan and manage the investment portfolio on an ongoing basis. However, the client is under no obligation to act upon any of the recommendations made by BCSWM under a financial planning engagement and/or to engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, BCSWM meets with the client, gathers information, and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan will be updated from time to time when requested by the client or when determined to be necessary or advisable by BCSWM based on updates to the client’s financial or other circumstances. To implement the client’s Investment Plan, BCSWM will manage the client’s investment portfolio on a discretionary or a non-discretionary basis. As a discretionary investment adviser, BCSWM will have the authority to supervise and direct the portfolio without prior consultation with the client. Under a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the account(s) under management. This can result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. Item 10 – Other Financial Family Office Industry Activities and Affiliations BCSWM also offers services as a part of our marketed Still Waters Family Office (see ). At the heart of family office services is investment management, but a fully holistic family office can provide and coordinate a number of other services that are typically needed and desired for high net worth and ultra-high net worth clients. These services include, but are not limited to, financial planning, philanthropy management, business strategy, estate and wealth transfer, family education, governance, and succession planning. Separately Managed Accounts (SMAs) BCSWM may utilize the services of a professional investment firm for clients. Independent professional managers can offer the flexibility to structure an investment portfolio to the varying needs and goals of the client. Partnering with an independent professional manager, for a certain investment style and discipline, can provide further diversification and added expertise. Typically, accredited clients who require more customization and/or more specific investments goals as part of their overall investment strategy may benefit from SMAs. The adviser will discuss this option if he/she feels it is in line with the client’s objectives. Schwab Personalized Indexing (SPI) is an SMA managed by Schwab Asset Management and may be utilized for clients. Held Away Accounts BCSWM uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to effect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is(are) connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations 5  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least annually, and allocation changes will be made as deemed necessary. 529 College Savings Plans (529) As part of a client’s portfolio management, BCSWM may open and service 529 Plans for college savings. A 529 is a state sponsored investment account that is tax-advantaged and designed specifically for education expenses. The funds in a 529 grow tax-free and withdrawals for qualified education expenses are also tax-free. 529s can be opened for children, grandchildren, or other family members. Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. BCSWM will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, BCSWM will be considered a fiduciary under ERISA. To the extent that the Plan Fiduciaries retain BCSWM to act as an investment manager within the meaning of ERISA § 3(38), BCSWM will provide discretionary investment management services to the Plan. To the extent that the Plan Fiduciaries retain BCSWM to act as an investment adviser within the meaning of ERISA § 3(21), BCSWM will provide non-discretionary investment monitoring Consulting services to the Plan. • Non-discretionary Investment Monitoring Services Fiduciary Services Management When retained as an investment adviser within the meaning of ERISA § 3(21), BCSWM will assist in monitoring the plan’s investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and BCSWM will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the engagement agreement between the parties. • Discretionary Management Services Fiduciary Services • Discretionary Investment Selection Services When retained as an investment manager within the meaning of ERISA § 3(38), BCSWM provides continuous and ongoing supervision over the designated retirement plan assets. BCSWM will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, BCSWM will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets. BCSWM will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. BCSWM will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants. 6  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Non-Fiduciary Services • Participant Education Written Fiduciary Acknowledgment BCSWM will provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided unless a Plan Participant separately engages BCSWM for such services. In certain circumstances, Plan Participants are responsible for implementing transactions in their own accounts. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:       Item 5 – Fees and Compensation Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. Item 12 – Brokerage Practices BCSWM’s asset management fees are exclusive of brokerage commissions, transaction fees, and other related for additional costs and expenses which shall be incurred by the client. Please see information. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds (“ETFs”) also charge internal management fees which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to BCSWM’s fee. Financial Planning Fees Basic fee schedule: Fees are determined based on the estimated number of hours spent to develop and deliver the plan or based on a fixed fee. Hourly rates range from $100 - $550 with a minimum total fee of $750. Compensation is due in full upon the delivery of the plan. If an engagement is not completed, there will be a pro- rata charge made for planning services actually rendered. If Portfolio Management services are engaged within 90 days of the completed Financial Plan, the client will be credited back the Plan’s fee. The manner in which fees are credited will be specified in the client’s written agreement for the services. quarterly advance Portfolio Management Fees The specific manner in which fees are charged by BCSWM is established in a client’s written agreement with BCSWM. This agreement may be terminated at any time by either party hereto giving to the other written notice of such termination. basis, in BCSWM will bill fees on a of each calendar quarter, based on the value of the account at the end of the prior quarter. Management fees are directly debited from client’s custodial accounts, unless otherwise agreed, and are not prorated for each capital contribution and withdrawal made during the applicable calendar quarter. Fees for Held Away Accounts will be deducted directly from Client’s taxable Account. If Client Accounts opened during a calendar does not have a taxable account, then the fee will be direct billed to the Client. 7  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 quarter will not be charged a fee for the initial partial quarter but will be billed on the next quarterly billing cycle, unless noted in the written agreement or a signed addendum. Upon termination of any account, any prepaid fees will be promptly refunded. Fees paid in advance will be prorated to the date of termination and any unearned portion thereof will be refunded to client’s account(s). Assets Under Management Annual Percentage Fees Fees are assessed as a percentage of assets under management (AUM), based on the following schedule: $0 - $500,000 Next $500,000 ($500,000.01 - $1,000,000) Next $1,500,000 ($1,000,000.01 - $2,500,000) Next $2,500,000 ($2,500,000.01 - $5,000,000) Next $5,000,000 ($5,000,000.01 - $10,000,000) All Assets over $10,000,000.01 1.25% 1.00% 0.90% 0.75% 0.65% 0.55% The fee schedule can be negotiated based on circumstances applicable to the client's level of services required and particular situation. A client’s specific fee schedule will be identified in the advisory agreement. This fee schedule uses a tiered calculation. For example, the effective annual fee rate for a client with $3,000,000 in AUM would be 0.95% with the annual fee calculated as follows: ($500,000 x 1.25%) + ($500,000 x 1.00%) + ($1,500,000 x 0.90%) + (500,000 x 0.75%) = $28,500. quarterly arrears Accounts utilizing an independent professional manager (SMAs) will pay our agreed upon fee as well as the fee for the managed account professional firm. The fee for the managed account professional firm will be discussed with the client before entering an agreement. This fee will also be deducted directly from the client’s account unless otherwise discussed. basis in . The annual fee is 1.00% and is negotiable based on client’s 529 Plans are billed on a circumstance. quarterly arrears Retirement Plan Advisory Services Fees The specific fee schedule and manner in which fees are charged by BCSWM is established in a client’s written agreement with BCSWM. This agreement may be terminated at any time by either party hereto giving to the other Item 6 – Performance-Based Fees and Side-By-Side Management written notice of such termination. Fees will be paid directly to BCSWM on a basis in . BCSWM does not have any performance-based fee arrangements (fees based on a share of capital gains on or capital appreciation of the assets of a client). “Side by Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time performance-based fee manages other accounts for which fees are assessed on a performance fee basis. Because BCSWM has no Item 7 – Types of Clients accounts, it has no side-by-side management. BCSWM provides portfolio management services to individuals, high net worth individuals, trusts, corporate pension and profit-sharing plans, business owners and business retirement plans, as well as charitable organizations and foundations. BCSWM has a minimum portfolio value for our portfolio management services of $350,000. The minimum is an aggregate of a household’s accounts and not a per account minimum. At BCSWM’s Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss discretion, we may waive the minimum value based on other factors. When calculating an investment strategy for a client, BCSWM first attempts to determine the client’s risk tolerance. This is partially accomplished by having the client complete a risk tolerance questionnaire. Once this information is collected and a time frame of when the client will need to use the money has been determined, 8  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 BCSWM constructs a portfolio. This portfolio is intended to provide the client with a return they can accept without having to sell when the market takes a downturn. BCSWM has several different strategies, and these strategies will vary depending on the adviser and needs of the client. In most cases, we attempt to purchase a diversified portfolio of no-load, commission free mutual funds or ETFs. A mutual fund brings together money from many investors and purchases stocks, bonds, or other assets. One mutual fund or ETF can have from a few to several thousand individual securities. A typical portfolio will be comprised of an equity allocation, a bond allocation, and a cash (i.e., money market accounts, CDs, etc.) allocation. The equity mutual fund/ETF allocations may include U.S. and International funds, large capitalization (well established companies) and small capitalization (small developing companies) funds. Some advisors may use REITs (real estate investment trust), emerging markets, natural resources, or precious metals among other asset classes. This allocation generally provides the growth of the portfolio as well as the most potential risk. In the bond portion of the portfolio, BCSWM may purchase municipal (city or other local government), corporate, high-yield, and U.S. government bond funds with varying maturities and qualities. Bonds with shorter maturities and higher quality are less prone to market fluctuations as compared to longer maturities and lower quality bonds which can experience significant market swings. This allocation generally provides stability and income to the portfolio. Below is a sample of our investment allocation strategies. Aggressive Strategy: These portfolios tend to have anywhere from 80% - 100% equity exposure with the remainder in bonds and cash. They have historically provided investors with the highest returns as well as the largest losses. Typically this strategy is best suited for an investor with a long term time frame, 15 or more years, and a willingness to accept significant short term losses and volatility. Moderate Strategy: These portfolios tend to have anywhere from 40% - 60% equity exposure with the remainder in bonds and cash. They have historically provided investors with reasonable returns for the amount of risk taken. Typically this strategy is best suited for an investor with a shorter time frame than the “aggressive” investor or an investor that is in or nearing retirement. Conservative Strategy: These portfolios tend to have anywhere from 0% - 20% equity exposure with the remainder in bonds and cash. They have historically provided investors with lower returns but generally have not suffered the losses experienced in the other strategies. Typically this strategy is best suited for an investor that is concerned with preservation of capital or needs income for living expenses. Risk of Loss While BCSWM seeks to diversify clients’ investment portfolios across various asset classes consistent with their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no assurance that client investment portfolios will be able to fully meet their investment objectives and goals or that investments will not lose money. Management Risks. Below is a description of several of the principal risks that client investment portfolios face. While BCSWM manages client investment portfolios, based on BCSWM’s experience, research and proprietary methods, the value of client investment portfolios will change daily based on the performance of the underlying securities in which they are invested. Accordingly, client investment portfolios are subject to the risk that BCSWM allocates client assets to individual securities and/or asset classes that are adversely affected by unanticipated market movements and the risk that BCSWM’s specific investment choices could underperform Risks of Investments in Mutual Funds, ETFs, and Other Investment Pools. their relevant indexes. As described above, BCSWM may invest client portfolios in mutual funds, ETFs, and other investment pools (“pooled investment funds”). Investments in pooled investment funds are generally less risky than investing in individual securities because of their 9  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills of their particular managers and their performance in managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of Equity Market Risks. 1940. BCSWM will generally invest portions of client assets directly into equity investments, primarily into pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets and that stock values will decline over longer periods (e.g., bear markets) due to general market declines in the stock Fixed Income Risks. prices for all companies, regardless of any individual security’s prospects. BCSWM may invest portions of client assets directly into fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the Foreign Securities Risks. time of issuance to maturity). BCSWM may invest portions of client assets into pooled investment funds that invest internationally. While foreign investments are important to the diversification of client investment portfolios, they carry risks that may be different from U.S. investments. For example, foreign investments may not be subject to uniform audit, financial reporting or disclosure standards, practices or requirements comparable to those found in the U.S. Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in investment or exchange control regulations. Finally, foreign investments may involve currency risk, which is the risk that the value of the foreign security will decrease due to changes in the relative value of the U.S. dollar Alternative Investment Risks and the security’s underlying foreign currency. . BCSWM may invest portions of client assets into alternative investments which provide access to different strategies and return profiles. These investments are typically available to those that are considered accredited investors, meaning the client has a net worth of more than $1 million, excluding the client’s primary residence and/or having income over $200,000 (individually) or $300,000 (with spouse or partner) in each of the prior two years, and reasonably expects the same for the current year, Alternative investments do not typically correlate with the stock market which helps add diversification to a client’s portfolio and potentially mitigate volatility. While alternative investments may have benefits of diversification, potential for higher returns, and tax benefits, there are also potential risks specific to these investments. These investments are not as liquid as other traditional investments as most can only be liquidated at set times that may be a monthly, quarterly, or even yearly basis. Alternative investments are also more complex, and, in some instances, there may be a lack of transparency and regulation. There may also be higher fees and costs associated with alternative investments. Accounts that utilize an independent professional manager (SMAs) provide broad based diversification that matches appropriate levels of risk and investment goals for a respective client. Employing an independent investment firm allows the flexibility for more specific investment strategies with professional managers that can prove valuable to a client’s portfolio. Selection of independent managers includes research, due diligence, and approval from BCSWM’s investment committee. Independent managers are managed ongoing as part of client account reviews as well as in depth semi-annual reviews of the professional investment firm. 10  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of BCSWM or the integrity of BCSWM. Currently, BCSWM has no Item 10 – Other Financial Industry Activities and Affiliations information applicable to this item. BCSWM is partially owned by SCB Partnership, the Partners of which also own a public accounting practice, Blackburn, Childers & Steagall, PLC. In addition, SCB Partnership also owns interest in First Covenant Trust & Advisors (“FCTA”). FCTA is a South Dakota State-Chartered Trust Company that serves as trustee or executor for individuals and estates. The partners of Blackburn, Childers & Steagall, BCSWM, and FCTA have consolidated each of their entity’s services to assist high net worth clients under the marketing name of Still Waters Family Office. BCSWM and its affiliates may recommend clients utilize the services of the other entity. There is no requirement that any client of one firm use the services of the other. The services of each are separate and are performed for separate and typical compensation. These affiliations create a potential conflict of interest and may influence BCSWM’s choice of accounting or trust- related services. Clients are not required to use the services of BCSWM’s affiliate companies. Certain individuals are licensed to sell insurance in Tennessee and are entitled to receive commissions or other remuneration on the sale of insurance products. As such, these individuals are able to effect insurance transactions, although the customary compensation goes directly to BCSWM and not to the individuals themselves. To protect client interests, BCSWM’s policy is to disclose all forms of compensation before any such transaction is executed. Under no circumstance will the client pay both a commission to BCSWM for insurance products and a management fee to BCSWM on the same pool of assets. BCSWM has a partnership with Financial Insurance Group Benefits, LLC where we receive a percentage from referrals for group insurance products. In addition, certain BCSWM employees are also Registered Representatives of Purshe Kaplan Sterling Investment (“PKS”), a FINRA and SIPC member, and registered broker-dealer. As such, they are entitled to receive commissions or other remuneration on the sale of insurance as well as other products. To protect client interests, BCSWM’s policy is to disclose all forms of compensation before any such transaction is executed. Clients will not pay both a commission to these individuals and also pay an advisory fee to BCSWM on the same pool of assets. These fees are exclusive of each other. As a result of this relationship, these employees may have access to certain confidential information (e.g., financial information, investment objectives, transactions, and holdings) about BCSWM clients, even if the client does not establish any account through PKS. If you would like a copy of PKS’s privacy notice, please contact Nicholas Clay Item 11 – Code of Ethics, Participation or Interest in client Transactions and Personal Trading at (423)283-9821 or NClay@bcswealth.com. BCSWM has adopted a Code of Ethics (“the Code”) for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts, and personal securities trading procedures, among other things. All supervised persons at BCSWM must acknowledge the terms of the Code. BCSWM anticipates that, in appropriate circumstances, it will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which BCSWM and/or clients, directly or indirectly, have a position of interest. BCSWM’s employees and persons associated with BCSWM are required to follow BCSWM’s 11  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 Code. Subject to satisfying this policy and applicable laws, partners, and employees of BCSWM may trade for their own accounts in securities which are recommended to and/or purchased for BCSWM’s clients. The Code is designed to assure that the personal securities transactions, activities, and interests of the employees of BCSWM will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of BCSWM’s clients. Nonetheless, due to the fact that the Code in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Under the Code, employee trading is monitored in order to reasonably prevent conflicts of interest between BCSWM and its clients. Employees must report certain personal investment holdings and trading activity to the Chief Compliance Officer on a quarterly basis. Because client accounts are invested almost exclusively in open-end mutual funds and ETFs, there is little opportunity for a conflict of interest between personal trades by BCSWM associated persons and trades in client accounts, even when such accounts invest in the same securities. However, in the event of other identified potential trading conflicts of interest, BCSWM’s goal is to place client interests first. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Lauren Olander at Item 12 – Brokerage Practices 423-283-9821 or LOlander@bcswealth.com. When given discretion to select the brokerage firm that will execute orders in client accounts, BCSWM seeks “best execution” for client trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided, and commission rates. Therefore, BCSWM may use or recommend the use of brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination) and may be used in servicing any or all of BCSWM’s clients. Therefore, research services received may not be used for the account for which the particular transaction The custodian and brokers we use was effected. Our primary custodian is Charles Schwab & Co., Inc. Item 15—Custody BCSWM does not maintain custody of your assets that we manage, although we may be deemed to have custody ). Your assets of your assets if you give us authority to withdraw assets from your account (see must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. BCSWM requires that clients establish brokerage accounts with Charles Schwab & Co., Inc. (together with its affiliates, “Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. Item 14 – Client referrals and other compensation We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we request that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in . You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab, then we cannot manage your account. Not all advisors require their clients to use a particular Your brokerage and custody broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, we costs can still use other brokers to execute trades for your account as described below (see How we select brokers/custodians ). 12  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 We seek to use a custodian/broker that will hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices Products and services available to us from Schwab • Reputation, financial strength, security, and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see Your brokerage and trading costs ) For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, to minimize your trading costs, we have Schwab execute most trades for your account. How we select brokers/custodians We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trade through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see ). By using another Products and services available to us from Schwab broker or dealer you may pay lower transaction costs. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally Services that benefit you available at no charge to us. Following is a more detailed description of Schwab’s support services: . 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 we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph Services that do not directly benefit you generally benefit you and your account. . Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and 13  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third-parties. We use this research to service all or a 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: Services that generally benefit only us • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, record keeping, and client reporting . Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Publications and conferences on practice management and business succession • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third-party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from Our interest in Schwab’s services our own resources. How we select brokers/custodians The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to require the use of Schwab rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see ) and not Schwab’s services that benefit only us. Business retirement plans may use another custodian outside of Schwab as discussed between the Client and Advisor, which may include but are not limited to Capital Group, Fidelity, John Hancock, T. Rowe Price, Voya, and Empower. 529 Plans may utilize custodians outside of Schwab as well. Directed Brokerage BCSWM does not generally allow directed brokerage accounts. Aggregated Trade Policy BCSWM typically directs trading in individual client accounts as and when trades are appropriate based on the client’s Investment Plan, without regard to activity in other client accounts. This lack of aggregation may result in Item 13 – Review of Accounts higher execution charges. Investments held in accounts are reviewed on an ongoing basis. Each client’s portfolio is reviewed at least annually by the primary advisor for adherence to the Investment Plan that has been developed for the portfolio. Changes to the portfolio will be approved by the adviser in charge of that account. Other factors may trigger a review including changes to a client’s financial situation (such as retirement, job change, risk tolerance or account objectives). For those clients to whom BCSWM provides separate financial planning, reviews are conducted on an 14  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 as needed or agreed upon basis. Such reviews are conducted by one of BCSWM’s investment adviser representatives or principals. Account statements are sent to clients from the account custodian no less frequently than quarterly. Account custodians also provide prompt confirmation of all trading activity and year-end tax statements, such as 1099 Item 14 – Client Referrals and Other Compensation forms. Item 12 - Brokerage Practices. As noted above, BCSWM receives an economic benefit from Schwab in the form of support products and services it makes available to BCSWM and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangements because the cost of these services would otherwise be borne directly by us, and this creates a conflict of interest. You should consider these conflicts of interest when selecting a custodian. These products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described The availability to us of Schwab’s products and services is not based above under on us giving particular investment advice, such as buying particular securities for our clients. Schwab is not paid to refer clients to BCSWM. BCSWM receives commissions from Financial Insurance Group Benefits, LLC for group insurance products provided to clients referred by us. These commissions create a conflict of interest and may influence BCSWM’s Item 15 – Custody choice of group insurance and other related products to clients. Under securities regulations, we are deemed to have custody of a client’s assets if, for example, the client authorizes us to instruct Schwab to deduct our advisory fees directly from the client’s account or if the client grants us authority to move their money to another person’s account. Schwab maintains actual custody of clients’ assets. Clients will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address the client provides to Schwab. Clients should carefully review those statements promptly when received. We also urge clients to compare Schwab’s account statements to any reports clients receive from us. Minor discrepancies may occur due to timing of dividends, trade settlements, or other issues. In addition, BCSWM retains an independent public accountant to perform a “surprise examination” on certain client accounts of which our affiliate, FCTA, or an employee of one of our affiliates, acts as trustee, executor, or another role which allows them control over the account. Client Accounts that have a third-party Standing Letter of Authorization (SLOA) which do not meet the SEC’s 7 conditions will also be subject to the surprise examination. First-party SLOAs are transfers that occur between accounts owned by the same individual(s) or entity where the taxpayer ID number(s) associated with each account are the same. First-party SLOAs are not subject to the Item 16 – Investment Discretion surprise examination but are considered custody. Item 4 - Advisory Business discretionary accounts non-discretionary , BCSWM will accept clients on either a discretionary or non- As described in , a Limited Power of Attorney (“LPOA”) is executed by the client, discretionary basis. For giving BCSWM the authority to carry out various activities in the account, generally including the following: trade execution; the ability to request checks on behalf of the client; and the withdrawal of advisory fees directly from the account. BCSWM then directs investment of the client’s portfolio using its discretionary authority. The client may limit the terms of the LPOA to the extent consistent with the client’s investment advisory agreement with BCSWM and the requirements of the client’s custodian. For accounts, the client also generally executes a LPOA, which allows BCSWM to carry out trade recommendations and approved actions in the portfolio. However, in accordance with the investment advisory agreement between BCSWM and the client, BCSWM does not implement trading recommendations or other 15  BCS Wealth Management, LLC Part 2A of ADV: Firm Brochure – March 12, 2026 actions in the account unless and until the client has approved the recommendation or action. As with discretionary accounts, clients may limit the terms of the LPOA, subject to BCSWM’s agreement with the client and the requirements of the client’s custodian. Item 17 – Voting Client Securities Where we have authority to vote proxies, BCSWM will seek to vote proxies in the best interest of the client(s) holding the applicable securities. In voting proxies, BCSWM considers factors that BCSWM believes relate to the client’s investment(s) and factors, if any, that are set forth in written instructions from the client. for : • • • • • • against In general, BCSWM believes that voting proxies in accordance with the following guidelines, with respect to such routine items, is in the best interests of our clients. Accordingly, BCSWM generally votes The election of directors (where no corporate governance issues are implicated); Proposals that strengthen the shared interests of shareholders and management; The selection of independent auditors based on management or director recommendation, unless a conflict of interest is perceived; Proposals that BCSWM believes may lead to an increase in shareholder value; Management recommendations adding or amending indemnification provisions in charter or by-laws; and Proposals that maintain or increase the rights of shareholders. any proposals that we believe will have a negative impact on shareholder BCSWM will generally vote value or rights. If BCSWM perceives a conflict of interest, our policy is to notify affected clients so that they may choose the course of action they deem most appropriate. As stated earlier, BCSWM’s goal is to vote proxies in the best interest of the client(s). To that end, BCSWM has engaged Broadridge Financial Solutions, Inc., a Voting Agent Service, to facilitate BCSWM’s proxy voting service. A copy of our complete policy, as well as records of proxies voted, is available to clients upon request. As required under the Advisers Act, such records are maintained for a period of five (5) years. Clients can obtain a complete copy of BCSWM’s Proxy Voting Policies and Procedures, as well as ascertain how Item 18 – Financial Information particular proxies were voted, by contacting Lauren Olander at 423-283-9821 or LOlander@bcswealth.com. BCSWM does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore has no disclosure with respect to this item. BCSWM has no financial conditions that impairs its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding. 16