BLAKELY WALTERS WEALTH MANAGEMENT

Blakely Walters Wealth Management 3333 N Hayden Road Scottsdale, AZ 85251 E: info@blakelywalters.com T: (480) 776-5897 www.BlakelyWalters.com Form ADV Part 2A Firm Brochure April 2026 Item 1 – Cover Page This brochure provides information about the qualifications and business practices of Blakely Walters Wealth Management, LLC. (“BWWM or “Firm”). If you have any questions about the contents of this brochure, please contact us at info@blakelywalters.com or (480) 776-5897. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Blakely Walters Wealth Management (CRD# 324410) is a registered investment advisor with the SEC. Registration of an investment advisor does not imply any certain level of skill or training. Additional information about Blakely Walters Wealth Management also is available on the SEC’s website at www.adviserinfo.sec.gov. i  Blakely Walters Wealth Management ADV Part 2A April 2026 Item 2 – Material Changes Since the annual update of this brochure on 3/19/2026, no material changes have occurred. ii  Blakely Walters Wealth Management ADV Part 2A April 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 ..................................................................................................................2 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 4 Item 7 – Types of Clients .............................................................................................................................. 4 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ..................................................... 4 Item 9 – Disciplinary Information................................................................................................................ 9 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 9 Item 11 – Code of Ethics, Participation or Interest in Client Transaction, and Personal Trading .............. 11 Item 12 – Brokerage Practices ..................................................................................................................... 13 Item 13 – Review of Accounts ...................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation .................................................................................. 14 Item 15 – Custody ........................................................................................................................................ 14 Item 16 – Investment Discretion ................................................................................................................. 14 Item 17 – Voting Client Securities ............................................................................................................... 14 Item 18 – Financial Information ................................................................................................................. 15 iii  Blakely Walters Wealth Management ADV Part 2A April 2026 Item 4 – Advisory Business Blakely Walters Wealth Management (“BWWM” or the “Firm”) is an investment advisor firm registered with the United States Securities and Exchange Commission since June 2023. The principal owners of Blakely Walters Wealth Management are Sloan Walters and James Blakely, Managing Partners. The Firm is based in Scottsdale, Arizona. Advisory Services WEALTH MANAGEMENT SERVICES BWWM provides Wealth Management Services to advisory clients. Wealth Management Services combine Asset Management Services with Financial Planning Services. ASSET MANAGEMENT SERVICES BWWM will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. Discretionary Management When the Client elects to use BWWM on a discretionary basis, the Client will sign a limited trading authorization or equivalent allowing BWWM to determine the securities to be bought or sold and the amount of the securities to be bought or sold. BWWM will have the authority to execute transactions in the account without seeking Client consent on each transaction. BWWM may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to Client’s Account without prior consultation with or the prior consent of Client. Such Sub-Advisor Services will be as determined by BWWM. Such Sub-Advisor(s), in providing Sub-Advisor Services, shall have all of the same authority relating to the management, including fee deduction authority, of Client’s Account as is granted to BWWM in this Agreement. In addition, at BWWM’s discretion, BWWM may grant such Sub-Advisor(s) full authority to further delegate such discretionary investment authority to other Money Managers. All fees paid by Client to BWWM are exclusive and in addition to the fees paid to Sub-Advisor. However, the total fee paid by the Client will never exceed the agreed upon fee as outlined below. FINANCIAL PLANNING SERVICES Services include an evaluation of a client’s current and future financial state using currently known variables to predict future cash flows, asset values, recommend purchase and sales, and withdrawal plans. BWWM will use current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial plans. Topics for planning may include, but are not limited to: • Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring progress towards financial goals. • Cash flow analysis: An income and spending plan determines how much can be set aside for debt repayment, savings, and investing each month. • Retirement strategy: A strategy for achieving retirement independent of other financial priorities. Including a strategy for accumulating the required retirement capital and its planned lifetime distribution. • Long-term investment plan: Build a customized asset allocation strategy based on specific investment objectives and a risk profile. This strategy sets guidelines for selecting, buying, and selling investments and establishing benchmarks for performance review. 4  Blakely Walters Wealth Management ADV Part 2A April 2026 • Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible by the tax code. The strategy should include identification of tax favored investment vehicles that can reduce taxation of investment income. • Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life insurance, provide a second look at your current estate planning documents, and prompt you to update your plan when the legal environment changes or you have major life events such as a marriage, death, or births. If a conflict of interest exists between the interests of BWWM and the interests of the Client, the Client is under no obligation to act upon BWWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to affect the transaction through BWWM. Client-Tailored Services and Client-Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. These restrictions, however, may prohibit engagement with BWWM. Wrap Fee Programs BWWM does not participate in a Wrap Program. Assets under Management As of December 31, 2025, our firm manages $173,704,025. All assets were managed on a discretionary basis, and no assets were managed on a non-discretionary basis. Item 5 – Fees and Compensation WEALTH MANAGEMENT FEES Blakely Walters Wealth Management charges an annual fee for wealth management. These fees are payable monthly in arrears, based on the value of portfolio assets of the account on the last business day of the billing period. New account fees will be pro-rated from the inception of the account to the end of the first billing period. Wealth Management fees range from 0.5% to 1.5%, depending on the type and complexity of the wealth management strategy employed as well as the size of the account or overall client relationship. These fees are negotiable. Asset management fees will be directly deducted from the client account on a monthly basis by the qualified custodian. The custodian will send a statement at least quarterly to the client. Lastly, please note that BWWM may group certain related Client accounts, often known as “householding,” for the purposes of achieving the minimum account size and determining the annualized fee. For fee calculation purposes, a client’s managed assets are combined with those of their immediate family, defined as spouse or partner and dependent children (collectively, a “household’). FINANCIAL PLANNING FEES BWWM charges an hourly or fixed fee for financial planning and consulting. Prior to the planning process, the Client will be provided with an estimated plan fee based on the complexity of the engagement. For hourly and fixed fee arrangements, services will be completed and delivered within 180 days, contingent upon the timely delivery of all required documentation. BWWM reserves the right to waive the fee should the Client implement the plan through BWWM. 5  Blakely Walters Wealth Management ADV Part 2A April 2026 FIXED FEES Fixed fee services are offered based on a fixed fee to never exceed $10,000, depending on the complexity of the engagement. Fees are billed 50% in advance, with the balance due upon plan delivery. Payment of Fees Asset Management Fees are generally deducted directly from the Client’s Account. Financial Planning Fees (Stand-alone service) are invoiced directly to the Client. Financial Planning fees are paid 50% in advance, and 50% due at plan delivery. Plans are delivered within 180 days. Fees will never be billed $1,200 or more six months or more in advance. BWWM, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). For all services, Clients may terminate their engagement with BWWM within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial five (5) business days, the Agreement may be terminated by BWWM with thirty (30) days written notice to Client and by the Client at any time with written notice to BWWM. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. In the case of hourly engagements, fees will be prorated based on the work completed at the stated hourly rate. All unpaid earned fees will be due to BWWM, and all unearned fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Additional Fees Custodians and sub-advisors may charge brokerage commissions, transaction fees, and other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. BWWM does not directly receive any compensation from these fees. All of these fees are in addition to the management fee you pay to BWWM. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Fees Financial Planning fees are paid in advance, either annually, semi-annually, or quarterly, depending on the fee amount. Fees will never be billed over $1,200 six months or more in advance. External Compensation for the Sale of Securities Certain Investment Advisor Representatives of BWWM may also be registered as Registered Representatives of a broker-dealer, which allows them to perform brokerage services for Clients by executing security transactions. This practice represents a conflict of interest because the Investment Advisor Representatives are able to choose between offering clients’ fee-based programs and services (as is typical of an advisory relationship) and/or commission-based products and services (as is typical of a brokerage relationship). While a Client generally pays a fee to their Investment Advisor Representatives on an advisory account based on the value of account assets and not the number of transactions, in their capacities as Registered Representatives, an Investment Advisor Representative can offer securities and receive a commission, markup, or markdown on each transaction. An example of this may be a transaction commission on a mutual fund purchase, with additional compensation paid from an ongoing 12b-1 trailing 6  Blakely Walters Wealth Management ADV Part 2A April 2026 commission compensation directly from the mutual fund company during the period that the Client maintains the mutual fund investment. Our Investment Advisor Representatives do not receive these 12b- 1 fees in relation to managed investment advisory accounts in their role as Registered Representatives. This conflict is mitigated by disclosures, procedures, and BWWM’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the broker-dealer or its representatives if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. Item 6 – Performance-Based Fees and Side-By-Side Management Fees are not based on a share of the capital gains or capital appreciation of managed securities. BWWM does not use a performance-based fee structure nor “side-by-side” management because of the conflict of interest. Performance-based compensation may create an incentive for BWWM to recommend an investment that may carry a higher degree of risk to the Client. Item 7 – Types of Clients BWWM’s Clients are generally individuals, high-net-worth individuals, trusts, estates, charitable organizations, corporations, and other businesses. Client relationships vary in scope and length of service. Clients are not required to have a certain amount of investment experience or sophistication. BWWM requires a minimum account size of $250,000 for opening and maintaining an account. However, BWWM retains the discretion to lower or waive said minimum. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis and Investment Strategies Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Security analysis methods may include: 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. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns, and if these patterns can be identified, then a prediction can be made. The risk is that markets do not always follow patterns, and relying solely on this method may not take into account new patterns that emerge over time. 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. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to BWWM. Each Client executes a client profile form or similar form that documents their objectives and their desired investment strategy. 7  Blakely Walters Wealth Management ADV Part 2A April 2026 Risks of Investments and Strategies Utilized Investing in securities involves risk of loss that Clients should be prepared to bear. BWWM’s investment approach constantly keeps the risk of loss in mind. Investors may face the following investment risks: General Investment and Trading Risks. Clients may invest in securities and other financial instruments using strategies and investment techniques with significant risk characteristics. The investment program utilizes such investment techniques as option transactions, margin transactions, short sales, leverage, and derivatives trading, the use of which can, in certain circumstances, maximize the adverse impact to which a client may be subject. 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. Inflation Risk. When any type of inflation is present, a dollar today will buy more than 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. Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed-income securities. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Management Risk. The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. Cybersecurity Risk. BWWM and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information, and various other forms of cybersecurity breaches. Cybersecurity attacks affecting BWWM and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject BWWM to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients may invest in, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including, for example, financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although BWWM has established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that BWWM does not directly control the cybersecurity measures and policies employed by third-party service providers. Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices 8  Blakely Walters Wealth Management ADV Part 2A April 2026 may not correlate perfectly with changes in the underlying reference units; and (ii) the risk of possible trading halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable. Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the overall stock market. Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices of common stock react to the economic condition of the company that issued the security, industry and market conditions, and other factors that may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity- related securities, including preferred stock, warrants, and options, may also vary widely. Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers. Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be followed by fewer investment research analysts, and may be subject to wider price swings, and thus may create a greater chance of loss than when investing in securities of larger-cap issuers. The market prices of securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, to corporate developments, and to market rumors than are the market prices of large-cap issuers. Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities, commodities contracts, and/or derivative instruments, including futures, options, and swap agreements. The prices of commodities contracts and derivative instruments, including futures and options, are highly volatile. Payments made pursuant to swap agreements may also be highly volatile. Price movements of commodities, futures and options contracts, and payments pursuant to swap agreements are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. The value of futures, options, and swap agreements also depends upon the price of the commodities underlying them. In addition, Client assets are subject to the risk of the failure of any of the exchanges on which its positions trade or of its clearinghouses or counterparties. Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of forward and other derivative contracts are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary, and exchange control programs and policies of governments, and national and international political and economic events and policies. Clients are also subject to the risk of failure of any of the exchanges on which their positions trade or of its clearinghouses. Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in securities of non-U.S. issuers pose a range of potential risks, which could include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains, or other income, political or social instability, illiquidity, price volatility, and market manipulation. In addition, less information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing, and financial reporting standards and requirements comparable to or as uniform as those of U.S. issuers. 9  Blakely Walters Wealth Management ADV Part 2A April 2026 Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In addition to the risks associated with investments outside of the United States, investments in emerging markets (i.e., the developing countries) may involve additional risks. Emerging markets generally are not as efficient as those in developed countries. In some cases, a market for the security may not exist locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in developed countries. When seeking to sell emerging market securities, little or no market may exist for the securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and financial reporting standards, practices, and requirements comparable to those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive practices. Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk that the category may be out of favor due to current market conditions or investor sentiment. Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the Companies, which could have an adverse effect on each of them. If the securities of the Companies experience poor liquidity, investors may be unable to transact at advantageous times or prices, which may decrease the Company’s returns. In addition, there is a risk that policy changes by central governments and governmental agencies, including the Federal Reserve or the European Central Bank, which could include increasing interest rates, could cause increased volatility in financial markets, which could have a negative impact on the Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other events could have a significant impact on the Companies. For example, the rapid and global spread of a highly contagious novel coronavirus respiratory disease, designated COVID-19, has resulted in extreme volatility in the financial markets and severe losses; reduced liquidity of many Companies’ securities; restrictions on international and, in some cases, local travel; significant disruptions to business operations (including business closures); strained healthcare systems; disruptions to supply chains, consumer demand and employee availability; and widespread uncertainty regarding the duration and long-term effects of this pandemic. Some sectors of the economy and individual issuers have experienced particularly large losses. In addition, the COVID-19 pandemic may result in a sustained economic downturn or a global recession, domestic and foreign political and social instability, damage to diplomatic and international trade relations, and increased volatility and/or decreased liquidity in the securities markets. The Companies’ values could decline over short periods due to short-term market movements and over longer periods during market downturns. Alternative Investments. When appropriate for a client’s objective, risk tolerance, and qualifications, BWWM recommends the Client participate in private issues, such as single-purpose vehicles, funds of funds, private equity, and hedge funds. These are usually structured as limited partnerships with differing minimum investments, liquidity, fees, and carriers. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment with BWWM. Item 9 – Disciplinary Information BWWM and its management have not been involved in any criminal or civil actions, administrative or self- regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a client’s or prospective Client’s evaluation of BWWM or the integrity of its management. 10  Blakely Walters Wealth Management ADV Part 2A April 2026 Item 10 – Other Financial Industry Activities and Affiliations Neither BWWM nor its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither BWWM nor its management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. Investment Advisor Representatives of BWWM are also registered as Registered Representatives of a broker-dealer, which allows them to perform brokerage services for Clients by executing security transactions. This practice represents a conflict of interest because the Investment Advisor Representatives are able to choose between offering Clients’ fee-based programs and services (as is typical of an advisory relationship) and/or commission-based products and services (as is typical of a brokerage relationship). While a Client generally pays a fee to their Investment Advisor Representatives on an advisory account based on the value of account assets and not the number of transactions, in their capacities as Registered Representatives, an Investment Advisor Representative can offer securities and receive a commission, markup, or markdown on each transaction. An example of this may be a transaction commission on a mutual fund purchase, with additional compensation paid from an ongoing 12b-1 trailing commission compensation directly from the mutual fund company during the period that the Client maintains the mutual fund investment. Our Investment Advisor Representatives do not receive these 12b-1 fees in relation to managed investment advisory accounts in their role as Registered Representatives. This conflict is mitigated by disclosures, procedures, and BWWM’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the broker-dealer or its representatives if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. Investment Advisor Representatives of BWWM receive external compensation from sales of investment- related services as Insurance Agents. This represents a conflict of interest because it gives an incentive to recommend services based on the fee amount received. This conflict is mitigated by disclosures, procedures, and BWWM’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage the Agent or Agency if they do not wish to. More information on this can be found in the respective Investment Advisor Representative’s Form U4 and ADV 2B. Investment advisor representatives of Blakely Walters Wealth Management, James (Jim) Blakely and Sloan Walters, are also owners of Planning Grounds LLC, which provides employers with centralized consultative services to deliver financial wellness benefits to their employees. These services are considered general financial education and do not include any investment advice. Planning Grounds LLC sources relationships through marketing and may refer clients to Blakely Walters Wealth Management. Clients are not obligated to use the service referrals made by Planning Grounds LLC, but if the client utilizes BWWM for its services, these services will be contracted directly through BWWM and billed separately, and all of the fees or commissions associated with the services, as well as the business affiliation, will be disclosed to the client in advance. BWWM may select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to Client Accounts. When selecting Sub-Advisors, the Client’s best interest will be the main determining factor of BWWM. BWWM ensures that Sub-Advisors are properly licensed or registered as investment advisors before selecting them to serve as Sub-Advisors. 11  Blakely Walters Wealth Management ADV Part 2A April 2026 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The affiliated persons (affiliated persons include employees and/or independent contractors) of BWWM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of BWWM affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of BWWM. The Code reflects BWWM and its supervised persons’ responsibility to act in the best interest of their client. One area that the Code addresses is when affiliated persons buy or sell securities for their personal accounts, and how to mitigate any conflict of interest with our clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients. BWWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer, or director of BWWM may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. BWWM’s Code is based on the guiding principle that the interests of the Client are our top priority. BWWM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Client's purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. BWWM will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Recommendations Involving Material Financial Interests Neither BWWM nor its related persons recommend to Clients, or buy or sells for Client accounts, securities in which BWWM or a related person has a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest BWWM and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options, or futures) that BWWM or an affiliated person recommends to Clients. In order to mitigate conflicts of interest, such as frontrunning, BWWM’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage Clients of BWWM. 12  Blakely Walters Wealth Management ADV Part 2A April 2026 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest BWWM and its affiliated persons may recommend securities, or buy or sell securities for Clients accounts, at or about the same time, that they also buy or sell the same securities in their own account(s). BWWM, for instance, will place trades in an account in an attempt to earn better than money market rates. In order to mitigate conflicts of interest, such as frontrunning, BWWM’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated persons does not disadvantage Clients of BWWM. Item 12 – Brokerage Practices Factors Used to Select or Recommending Broker-Dealers BWWM does not recommend custodians or broker-dealers. Research and Other Soft Dollar Benefits BWWM does not receive soft dollar benefits. Brokerage for Client Referrals BWWM does not receive Client referrals from any custodian or third party in exchange for using that broker-dealer or third party. Directed Brokerage BWWM does not allow client-directed brokerage. Aggregating Trading for Multiple Client Accounts BWWM does not manage any assets; therefore, trade aggregation does not apply. Item 13 – Review of Accounts Frequency and Nature of Periodic Review and Who Makes Those Reviews Account reviews are performed on an ongoing basis by the Firm’s Investment Advisor Representatives. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client-documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria; a review of target allocations for each asset class to identify opportunities for rebalancing; and a review of accounts for tax loss harvesting opportunities. Financial plans are updated as requested by the Client, and pursuant to a new or amended agreement, BWWM suggests updating at least annually. Factors That Will Trigger a Non-Periodic Review of Client Accounts Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a client’s own situation. Content and Frequency of Regular Reports BWWM provides performance reports upon the client's request. Clients also receive written account statements no less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client receives confirmations of each transaction in the account from the Custodian and an additional statement during any month in which a transaction occurs. Clients should compare the BWWM 13  Blakely Walters Wealth Management ADV Part 2A April 2026 performance reports to their custodial statements for accuracy and alert BWWM to any discrepancies immediately. BWWM has access to reporting tools and can provide account summaries and reports upon client request. Item 14 – Client Referrals and Other Compensation BWWM and/or its Dually Registered Persons are incentivized to join and remain affiliated with LPL Financial. LPL provides other compensation to BWWM and its Dually Registered Persons, including but not limited to bonus payments, repayable and forgivable loans, stock awards, and other benefits. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL Financial as custodian for the assets in your advisory account. BWWM does not recommend LPL as an account custodian for any accounts managed by BWWM. However, IARs of BWWM, in their role as Registered Representatives of LPL, may recommend clients open up brokerage accounts or direct business accounts to manage variable annuities at LPL. BWWM does not compensate for Client referrals Item 15 – Custody All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by BWWM. BWWM is deemed to have limited custody solely because advisory fees are directly deducted from the Client’s accounts by the custodian on behalf of BWWM. Additionally, BWWM is deemed to have custody of funds for certain accounts where clients have established a standing letter of authorization (“SLOA”) that allows BWWM to disburse funds upon the client's direction to one or more third parties designated by the client. BWWM follows seven conditions set forth in the SEC's No-Action Letter on Custody, dated 2/21/2017, which allow BWWM to avoid an annual surprise custody examination of those accounts. BWWM is not affiliated with the custodian. The custodian does not supervise BWWM, its employees, or activities. Item 16 – Investment Discretion Clients authorize BWWM discretionary authority, via the Advisory Agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. BWWM allows Clients to place certain restrictions. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to BWWM in writing. The Client approves the custodian to be used, and the commission rates paid to the custodian. BWWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17 – Voting Client Securities Clients will receive proxy voting information directly from the issuer and/or custodian of the security. Clients will not receive any such proxy voting material from BWWM. When assistance on voting proxies is requested by the Client, BWWM will provide recommendations to the Client. However, BWWM will not have the authority to vote proxies on behalf of the Client. If, in the future, BWWM obtains authority to vote proxies, this Brochure will be appropriately amended. 14  Blakely Walters Wealth Management ADV Part 2A April 2026 Item 18 – Financial Information BWWM does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in advance. BWWM nor its management persons have any financial conditions that are likely to reasonably impair its ability to meet contractual commitments to Clients. BWWM has not been the subject of a bankruptcy petition in the last ten years. 15