CAIN, WATTERS & ASSOCIATES, LLC

Cain, Watters & Associates, LLC 17 Cowboys Way, Suite 300, Frisco, TX 75034 Phone (972) 233-3323 Fax (972) 943-0670 www.cainwatters.com August 26, 2025 Form ADV Part 2A Brochure Cain, Watters & Associates, LLC is an investment adviser registered with the Securities and Exchange Commission (hereinafter “SEC”). An "investment adviser" means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Cain, Watters & Associates, LLC. If you have any questions about the contents of this brochure, please contact us at (972) 233-3323. 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. Additional information about Cain, Watters & Associates, LLC is available on the SEC’s website at www.adviserinfo.sec.gov.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 2 Material Changes - Item 2 The purpose of this page is to inform you of any material changes since the previous version of this brochure. On August 26, 2025, we submitted an other-than-annual update. As part of the update, we amended the following sections of our Form ADV Part 2 Brochure: Item 5 – Item 5 was amended to disclose that as of 08/26/2025, CWA has adjusted the fees for clients engaged separately for investment management programs to include additional tiers and fee breakpoints. In addition, CWA is disclosing that in certain cases at CWA’s sole discretion, CWA will aggregate the assets under management of related accounts for purposes of determining which tiered breakpoint applies. We review and update our brochure at least annually to make sure that it remains current. If you would like to receive a copy of the most recent version of our ADV Part 2 Brochure, please call us at (972) 233- 3323.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 3 Table of Contents - Item 3 Contents Material Changes - Item 2 ............................................................................................................................. 2 Table of Contents - Item 3 ............................................................................................................................ 3 Advisory Business - Item 4 ............................................................................................................................ 4 Fees and Compensation - Item 5 ................................................................................................................ 11 Performance-Based Fees and Side-By-Side Management - Item 6 ............................................................ 17 Types of Clients - Item 7 .............................................................................................................................. 17 Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ....................................................... 17 Disciplinary Information - Item 9 ................................................................................................................ 21 Other Financial Industry Activities and Affiliations - Item 10 ..................................................................... 21 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ............... 24 Brokerage Practices - Item 12 ..................................................................................................................... 25 Review of Accounts - Item 13 ..................................................................................................................... 29 Client Referrals and Other Compensation - Item 14 .................................................................................. 30 Custody - Item 15 ........................................................................................................................................ 30 Investment Discretion - Item 16 ................................................................................................................. 31 Voting Client Securities - Item 17................................................................................................................ 31 Financial Information - Item 18 .................................................................................................................. 31 Requirements for State-Registered Advisors - Item 19 .............................................................................. 31  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 4 Advisory Business - Item 4 Cain, Watters & Associates, LLC (“CWA”) is a registered investment advisor based in Frisco, Texas. We are a Limited Liability Company organized under the laws of the State of Texas. We have been providing investment advisory services since 1984. We provide broad based financial planning services geared toward dental healthcare professionals. CWA teaches a philosophy of consistently investing money for the long term. Currently, CWA provides various financial planning, retirement planning and investment management services. Each investment advisory service is listed below. Also, clients may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Financial Planning Services This broad-based planning process begins by executing a financial planning agreement specific to the types and level of planning services desired and, for our more comprehensive financial planning services, preparing the client for a one-day meeting at our office located in Frisco, Texas. The initial consultation meeting is structured to assess the client’s objectives and financial status both personally and professionally. Together with the client, we formulate a plan which can include initial goal setting and various Business Planning, Basic Retirement Planning and Personal Financial Planning services. Our full, comprehensive Financial Planning clients have the opportunity to participate in the various investment programs recommended by CWA for a reduced fee. These programs and associated fees are described in further detail below. Participation in these investment programs for other financial planning clients may require the execution of an additional investment agreement which will provide further details regarding fees and services. Subsequent consultations will include updates, assessments of progress, and revisions to the client’s financial plan. The financial plan and the meetings are tailored to the individual and their business and personal circumstances, examples of topics that are covered initially and annually include: Business Planning Business Planning services include: • Tax planning strategies; • Corporate entity structure; • Design of efficient pension plan; • Planning for practice expansion, transition, or the addition of a possible associate; • Production analysis and goal setting; • Practice overhead & profitability; • Practice breakeven analysis; and • Efficient debt structure. Basic Retirement Planning If client is a trustee or sponsor to a retirement plan, and so chooses, CWA will advise the Trustee and/or sponsor, by conferring periodically, no less than annually, or as often as requested, regarding the following services:  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 5 • Review of the Plan design and, if needed, provide recommendations on changes to design of the Plan; • Review of the overall allocation of investments and assets of the Plan; • CWA will make recommendations on estimated annual funding to the Plan; • On request, CWA will help plan timing of distributions to retired participants of the Plan; and • CWA can act as liaison between the Plan’s attorneys and third-party pension administrator. Personal Planning Personal Financial Planning services include: Income tax planning; • • Planning and goals for retirement; • Educational savings for children; • Investment portfolio analysis; • Management of student loan debt; • Insurance coverage; • Asset allocation; and • Estate planning review. Special Project Work: Some clients may need additional special project work above and beyond the scope of services covered in the Financial Planning & Basic ERISA Plan Services Agreement. Such clients will be presented with an estimate of the scope of work and additional cost and will sign an addendum to their Services Agreement. Advisory Services Provided to Pension & Retirement Plans Invested in Recommended Investment Programs In addition to the Basic Retirement Planning services described in the Financial Planning section above, CWA will provide additional services which are advisory in nature to both trustee directed and participant directed pension and retirement plans invested in CWA Recommended Investment Programs. These services are provided pursuant to the Trustee Directed Program Agreement (for trustee directed plans custodied at Schwab or T Bank) or the T Bank Participant Directed Program Agreement (for participant directed plans). The services are as follows: • Provide advice to the plan trustee(s) on Investment Model Allocation selections; • Perform periodic investment and asset manager review (quarterly and intra-quarterly); • Build relationships with investment and asset managers; • Perform new investment and asset manager searches for inclusion in CWA Recommended Investment Program; • Review quarterly performance reports from custodians, overlay managers, and other investment service providers. • Construct and manage asset allocation models utilizing the investments options that were selected to be designated investment alternatives by the Plan’s fiduciaries; and • Make specific recommendations regarding the “qualified default investment alternative(s)” (“QDIAs”) to be made available under the Plan.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 6 For a complete description of fees and charges please refer to the section titled Fees and Compensation within this disclosure Brochure. CWA represents that it is not subject to any disqualification as set forth in Section 411 under the Employee Retirement Income Security Act (“ERISA”). To the extent CWA performs Fiduciary Services, CWA is acting as a fiduciary of the Plan as defined in Section 3(21) or Section 3(38) under ERISA. Note regarding participant directed plans: To the extent the Plan contains a self-directed brokerage account, our services (and fiduciary obligations) will not apply to such self-directed brokerage account and no services will be provided in connection with self-directed brokerage accounts. CWA Recommend Investment Programs CWA offers both discretionary and non-discretionary investment management services to our clients. Discretionary services means that we have authority to decide which securities to purchase and sell on behalf of a client. Non-discretionary services mean that client consent must be obtained before securities are purchased or sold in client accounts. Currently, we offer the following Investment Programs: • Pooled Investment Program through an affiliated National Bank (Participant and Trustee Directed) • Unified Managed Account Platform for Individuals, Trusts, Retirement Plans, Corporations, Partnerships and other Legal entities ("UMA") • Separately Managed Account Programs ("SMA") • Donor Advised Fund Services Each program is described in further detail below: Pooled Investment Program through an affiliated National Bank CWA offers its clients access to discretionary advisory services provided by its affiliated bank, T Bank, N.A. (T Bank) through the bank’s Collective Investment Funds (“CIF”). Investment advisory clients have the option to invest personal trust assets (i.e., non-retirement accounts, etc.) and qualified plan trust assets (i.e., 401Ks, etc.) in the T Bank CIFs. The bank’s Trust Department will act as trustee for personal asset accounts and custodian for qualified plan assets accounts established with the bank. CWA provides investment advisory services to the Plan trustee/sponsor; as well as Investment Management Services to the Plan and its participants through the construction and management of asset allocation models. The bank requires a signed trust or custodial instrument from the client, appointing the bank as trustee or custodian under the pooled investment program, depending on the type of assets to be invested (personal or qualified plan) as well as other account opening documents. CWA provides clients with asset allocation models based on various investment objectives. The allocation models consist of varying allocations among the Collective Investment Funds made available under the Plan. Each Allocation Model seeks to balance risk and reward by apportioning the assets from conservative to aggressive. In the case of participant directed plans, the participant may choose according to his or her own goals, risk tolerance and investment time horizon.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 7 Currently, T Bank offers the following Collective Investment Funds: International Equity Fund • Core Fixed Income Fund • Fixed Income ETF Fund • Equity Fund • Equity ETF Fund • • Real Asset Fund The bank offers all funds for qualified plan trust assets and the Core Fixed Income Fund and the Equity Fund for personal trust assets. Each fund is managed by one or more managers or invested in mutual funds or exchange traded funds (ETFs). The investment managers are recommended to the bank by Tectonic Advisors, LLC (hereafter “Tectonic”), an affiliate of both T Bank and CWA (Tectonic and the Bank are commonly owned. See Other Financial Industry Activities and Affiliations for additional information regarding conflicts). T Bank has contracted Tectonic to act as lead investment advisor and has granted Tectonic discretionary authority to utilize or not utilize approved investment managers and to reallocate fund assets among them in accordance with the approved Investment Policy Statement for each fund. Decisions related to the purchase and sale of securities are made by the individual investment managers. Purchase of pooled investment funds must be made in cash or wire transfer and will appear on the client’s bank statement. In-kind transfers of securities cannot be invested in the pooled investment funds but may be held in the same bank account with the pooled fund investment. This security information will also appear on the client’s bank statement. Tax issues relating to the client’s liquidation of an investment in a previous investment program are considered during the financial planning and tax planning advice that the client receives from us. Withdrawals of cash can occur up to, and including, the amount of the free cash balance in the trust or custodial account. To the extent that additional cash is required by a client, an appropriate amount of assets held in the fund will then have to be liquidated. It is important to note that liquidation in a qualified plan can occur daily; in a personal trust account however, liquidation can only occur once a week, generally on Fridays. Our investment advisory clients should consider this liquidity timing when investing in the pooled investment funds. Units of the funds can only be purchased or sold on valuation dates. The cash credit balance will earn a market rate of interest until such balance is invested. Unified Managed Account Platform ("UMA") CWA, in conjunction with Tectonic Advisors, LLC (“Tectonic”), offers its clients access to the Unified Managed Account (“UMA”) Platform. The UMA Platform provides clients with access to a diversified suite of certain portfolio models ranging from preservation of capital to aggressive growth. These models were developed in conjunction with one or more professional money managers that manage different components of a client’s targeted asset allocation based upon the client’s financial circumstances, goals and investment objectives. Tectonic operates technology platforms that are used to manage the models, including trading, rebalancing, billing, performance reporting, and certain other administrative services. In addition, Tectonic provides asset allocation advice, and model provider due diligence and recommendations to CWA regarding model construction and management. In some cases, Tectonic serves as one of the model providers available to CWA clients via the UMA Platform. (Tectonic is affiliated with CWA. See Other Financial Industry Activities and Affiliations for additional information regarding  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 8 conflicts of interest associated with the recommendation and use of affiliated adviser services.) Clients in UMAs grant investment discretion to CWA. This means that CWA may make changes to client allocations, in keeping with previously agreed upon account objectives, without prior consent from the client. UMAs at CWA are single accounts in which a client will have multiple managers and asset classes. Each manager and/or asset class can be managed via a separate account or “sleeve” of the account. Depending on a variety of factors including, but not limited to client risk tolerance and client asset size, a UMA account could include one or more money managers in the equity, fixed income and/or alternatives space, that are run in a separate account or “sleeve.” The rest of the UMA will be invested with mutual funds and ETFs. The resulting portfolio will be a mixture of individual equities and/or individual bonds, ETFs, and mutual funds, and will represent a complete asset allocation for the client based upon their risk tolerance and investment needs. The transactions in client accounts will be executed by Charles Schwab & Co., Inc. (“Schwab”). Please see Item 12 – Brokerage Practices for further information on brokerage and transaction costs. Clients should note that Schwab has waived transaction fees for many equities and investment company securities. However, Schwab still charges a separate transaction fee for certain securities, such as institutional class shares of mutual funds, non-US securities, etc. CWA clients can allocate their assets among various investment models, depending on account size, managed by a selection of money managers and/or mutual funds, within a UMA account. Models are recommended based on a client’s risk profile, investment goals and objectives. The UMA program requires the approved model providers to meet certain due diligence criteria established by CWA and to operate pursuant to certain operational and technological constraints as prescribed by Tectonic and/or the custodian. Given differences in the ways in which a client’s individual circumstances are identified and in which those circumstances are interpreted by different Associated Persons of CWA, different clients having the same or closely related personal circumstances and risk profiles may receive somewhat different asset allocation recommendations and, as a result, different investment manager or mutual fund recommendations. In most cases, the money manager will provide Tectonic with asset allocation models along with buy or sell signals and Tectonic will maintain the authority to execute trades. However, in some cases, the money manager will take discretionary authority to transact in the UMA account directly. In addition to the diversified suite of portfolio models noted above, we offer two additional customizable options which are designed to accommodate specific needs of certain clients. O’Shaughnessy Asset Management, L.L.C.’s CANVAS® Program The CANVAS® platform is an interactive, web-based investment platform developed by O’Shaughnessy Asset Management, L.L.C. (“OSAM”) that permits CWA to devise a customized investment strategy or strategies (each a “Strategy”) for the client. The CANVAS® platform employs modeling techniques that specify the securities to be held in a portfolio that are consistent with the Strategy. The output from the CANVAS® platform will be employed by OSAM to implement the Strategy by causing securities to be purchased and sold in the client’s portfolio, so that the client’s holdings will substantially match the model portfolio. These holdings will be periodically rebalanced by OSAM to remain consistent with the Strategy. CWA primarily uses CANVAS® to devise Tax loss harvesting strategies designed to reduce a client’s tax bill  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 9 by capturing investment losses and investing proceeds in similar securities, keeping accounts fully invested. Capital Integration Systems LLC UMA Platform clients may request that CWA and Tectonic consider certain investments offered on the Capital Integration Systems LLC (“CAIS”) Alternative Investments Portal as potential investments for the client’s UMA Account. (Please see Item 8 below for information about risks associated with alternative investments.) In the event that CWA and Tectonic determine that one or more such investments may be appropriate for the client’s UMA Account, the client will be provided a copy of such investment’s offering documents, and CWA and Tectonic will assist the client in reviewing and completing such offering documents. However, neither CWA nor Tectonic will have discretionary authority to select any CAIS investment on behalf of a UMA client; rather, CWA and Tectonic will be authorized only to make recommendations regarding any such CAIS investment, and each such client will be solely responsible for the decision to invest in any CAIS investment. Please refer to important risk disclosures pertaining to alternative investments in Item 8 below. Separately Managed Account Program Certain of CWA’s clients have opted to receive portfolio management services through the firm’s Separately Managed Accounts Program (“SMA Program”). Currently our SMA Program is offered in conjunction with various investment managers, including Tectonic and Sanders Morris LLC, our affiliated investment advisers. (See Other Financial Industry Activities and Affiliations for additional information regarding conflicts of interest associated with the recommendation and use of affiliated adviser services.) These other investment advisers are responsible for the research and security selection within model portfolios, day-to-day trading within the models, and other back-office operations. CWA is responsible for the supervision of the account, portfolio reallocations and rebalancing, and ongoing client interaction and servicing. Investments and allocations are determined and based upon the client’s predefined objectives, risk tolerance, time horizon, financial horizon, financial information, and other various suitability factors. Investments may include various types of securities such as equity securities, ETFs, mutual funds, corporate debt securities, municipal securities, and U.S. Government securities. Other types of investments may also be recommended where such investments are appropriate based on the client’s stated goals and objectives. Further restrictions and guidelines imposed by the client may affect the composition and performance of a client’s portfolio. For these reasons, performance of the portfolio may not be identical to other clients of CWA. On an ongoing basis, we review the client’s financial circumstances and investment objectives, and instruct the sub adviser to make the necessary adjustments to the client’s portfolio. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction costs. Clients should note that some custodial broker dealers have waived transaction fees for many equities and investment company securities. However, most custodial broker dealers still charge a separate transaction fee for certain securities, such as institutional class shares of mutual funds, non-US securities, etc. Where Sanders Morris acts as executing broker-dealer for CWA client accounts, Sanders Morris will receive advisory fees along with commissions, rebates and trails for securities purchased in the client’s  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 10 account. Please refer to Item 12 of this document for information about conflicts of interest associated with this arrangement. Clients are advised to provide the firm with prompt notice of any changes in their personal financial circumstances, investment objectives, goals, and tolerance for risk. In addition, CWA will contact the client at least annually to determine whether there have been any changes in the client's personal financial circumstances, investment objectives, and tolerance for risk. Donor Advised Fund Services CWA also provides the Schwab Charitable Donor Advised Fund (“DAF”) to clients via Schwab Charitable, a web-based interface and administrative solution for charitable giving to philanthropic vehicles via the Schwab Charitable Fund (“SCF”), an IRS approved philanthropic vehicle established for the purpose of managing charitable donations contributed by or on behalf of donor clients. The DAF allows CWA to actively manage assets that have been donated to and are owned by SCF, while charging an investment management fee. CWA’s DAF participation is in conjunction with approval by the SCF Investment Committee for CWA to operate as an advisory manager on the platform. The Schwab Charitable Fund is an independent company and is unaffiliated with CWA. IRA Rollover Considerations As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Assets Under Management As of 12/31/2024, the total amount of assets under management at CWA is $4,237,891,281. We manage $1,924,847,993 in client assets on a discretionary basis and $2,313,043,287 in client assets on a non- discretionary basis.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 11 Fees and Compensation - Item 5 CWA charges fixed fees, hourly charges and a percentage of assets under management for its advisory services. At the sole discretion of CWA these fees are negotiable. Business and Personal Financial Planning Fees The fee for full, comprehensive planning services performed up to and including the initial consultation meeting is $10,000 for a one-professional household or $12,000 for a two-professionals household. A deposit of up to 50% will be due and payable to CWA at the time the Agreement is signed, with the balance due and payable the day of the initial consultation meeting. If the client wishes to cancel the initial consultation meeting after it has been scheduled, the deposit will be returned, pro-rated based on any work already performed on the client’s behalf. Client’s on-going planning relationship will begin on the first day of the month following 30 days after the date of the initial consultation meeting, if applicable. In exchange for these ongoing services and updates, and for a year end annual consultation, CWA’s annual fee for financial planning services range from $3,000 up to $14,700 for a one-professional household, depending on the types and level of planning services selected, or up to $14,700 plus an additional $2,900 for additional businesses owned within the same household (the “Annual Fee”). Fees may be paid in monthly payments or quarterly payments. Payments may be made by check or credit card. We may recommend other professionals in the financial industry to assist the client in the implementation of the financial plan and to carry out its objectives. The fees or charges for their services are paid directly by the client to the professional. These professionals may include third party pension administrators, attorneys, financial institutions, and healthcare practice consultants. In some cases, the client may need services outside of the scope of work specified in the effective Financial Planning Services Agreement. In such cases, additional hourly fees will be charged at a rate of $500 per hour. CWA will provide the Client with an estimated number of hours to complete the out-of-scope work, and an upfront retainer of 50% shall be due in advance and the remainder of out-of-scope hourly fee balance to be due within 30 days of Client’s receipt of the balance due invoice. These additional out-of- scope services will be discussed with the client prior to billing and the Client will be required to sign an amendment and supplement to their existing agreement. Basic ERISA Plan Services Fee If the individual client is a trustee/sponsor of established pension plan or becomes one during the course of an engagement, the annual on-going business and personal financial planning program and fee described below applies. Fees related to Basic Pension and Retirement Plan Services are based on the number of trustees, fiduciaries and/or sponsors of the Plan (the “Plan Representative”). For each such person comprising the Plan Representative, the fee is $300.00 annually (the “Flat Fee”). The Flat Fee will be payable in monthly payments of $25.00 and will begin the month following the Client’s decision to establish a Plan, but not sooner than the beginning of the on-going services. If Plan is already established at the time of execution, the Flat Fee will begin at the same time as monthly billing for the Annual Fee.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 12 Recommended Investment Program Fees Pooled Investment Program Trustee Directed Plan Fees (T Bank and Schwab UMA) For global services to trustee directed pension and retirement plans, CWA receives an annual fee of 0.20% of assets under management, out of the 0.65% investment program fee charged by the custodian to the account under the terms of the custodian’s custody agreement with the plan trustee. The total investment management fee is broken down as follows: CWA Fee: 0.20% (This fee is deducted by Tectonic as a paying agent for CWA) Tectonic Fee: 0.34% T Bank Custodial Fee (for T Bank plans): 0.11% Total Fee: 0.65% This fee is based on the most recent valuation of investments and assets of the Plan, which the Plan owns, and holds in the investment program. This fee will be billed and collected monthly, in arrears, based on monthly average daily balance, adjusted for contributions and withdrawals. Plan trustees authorize the fee to be paid from plan assets. Clients invested in the Unified Managed Account Program (UMA) should refer to the UMA program fee description below for information about their fees. Participant Directed Plan Fees (T Bank) For Participant Directed Plans, CWA receives an annual fee of 0.20% of assets under management, out of the 0.65% investment program fee charged by the custodian to the account under the terms of the custodian’s custody agreement with the plan trustee. The total investment management fee is broken down as follows: CWA Fee: 0.20% (This fee is deducted by Tectonic as a paying agent for CWA) Tectonic Fee: 0.34% T Bank Custodial Fee: 0.11% Total Fee: 0.65% This fee is based on the most recent valuation of investments and assets of the Plan, which the Plan owns, and holds in the investment program. This fee will be billed and collected quarterly, in arrears, based on average daily balance, adjusted for contributions and withdrawals. For client relationships established prior to April 1, 2024, the CWA fee is payable by the Plan Sponsor. For client relationships established after April 1, 2024, the CWA fee is deducted from each participant’s account(s). The CWA Fee calculation does not take into account assets that are not invested through the T Bank Program, such as investments in self-directed brokerage accounts. CWA will rely on the market values of the investments and assets the Plan owns and holds through the Program, as such market values have been determined by the record keeper or custodian. Personal Trust Asset Management Fees Clients who have engaged CWA for Business and Personal Financial Planning Services can opt to invest Personal Trust Asset in the T Bank Program. In such cases, CWA receives an annual fee of 0.20% of assets  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 13 under management, out of the 0.65% investment program fee charged by the custodian to the account under the terms of the custodian’s custody agreement. The total investment management fee is broken down as follows: CWA Fee: 0.20% (This fee is deducted by Tectonic as a paying agent for CWA) Tectonic Fee: 0.34% T Bank Custodial Fee: 0.11% Total Fee: 0.65% This fee is based on the most recent valuation of investments and assets in the investment program. This fee will be billed and collected monthly, in arrears, based on monthly average daily balance, adjusted for contributions and withdrawals. The Client authorizes the fee to be paid from personal trust assets. Clients who have not engaged CWA for Business and Personal Financial Planning services will pay a fee based on a percentage of total portfolio assets under management, in accordance with the following tiered schedule: Assets Under Management First $1,000,000 Next $2,000,000 Next $2,000,000 Next $5,000,000 Next $5,000,000 Next $5,000,000 Next $5,000,000 Over $25,000,000 Applied Annualized AUM Fee 1.00% 0.80% 0.75% 0.60% 0.50% 0.45% 0.40% 0.35% For example, if a client has $2,000,000 in assets under management with CWA, the tiered breakpoints will be calculated at 1.00% up to the first $1,000,000 – or $10,000 in annual assets under management fees – and then 0.80% for the assets above $1,000,000 – or $8,000 in annual assets under management fees – for a total annualized effective rate of 0.90%. This rate would be applied to the assets in each account to determine the final amount billed. As mentioned above, at CWA’s sole discretion, these fees are negotiable at the sole discretion of CWA, and in certain cases CWA aggregates the assets under management of related accounts for purposes of determining which breakpoint applies. This fee is based on the most recent valuation of investments and assets in the investment program. This fee will be billed and collected monthly, in arrears, based on monthly average daily balance, adjusted for contributions and withdrawals. The Client authorizes the fee to be paid from personal trust assets. Participants in the Pooled Investment Program will incur other fees charged by affiliated and unaffiliated service providers (e.g., the record keeper, custodian, third-party administrator, etc.). Participants will incur direct and indirect investment fees related to the investment options held in their account. There are investment advisory fees for each of the collective investment funds that are paid by each Participant. In addition, each fund incurs costs related to the administration and the investment management of the fund. These costs are paid directly by the fund itself and not by investors in the fund. Fund costs and  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 14 expenses reduce the net asset value of the fund and are reported as a percentage of the fund’s assets and referred to as the fund’s expense ratio, which is disclosed in the enrollment materials for the trustee and participant directed programs. The indirect cost incurred by each Participant will differ, depending on how their portfolio is allocated among the investment options. Unified Managed Account Program (UMA) Fees With respect to the UMA Platform, CWA’s fees will be based on a percentage of total portfolio assets under management (AUM), in accordance with the following tiered schedule: Assets Under Management First $1,000,000 Next $2,000,000 Next $2,000,000 Next $5,000,000 Next $5,000,000 Next $5,000,000 Next $5,000,000 Over $25,000,000 Applied Annualized AUM Fee 1.00% 0.80% 0.75% 0.60% 0.50% 0.45% 0.40% 0.35% For example, if a client has $2,000,000 in assets under management with CWA, the tiered breakpoints will be calculated at 1.00% up to the first $1,000,000 – or $10,000 in annual assets under management fees – and then 0.80% for the assets above $1,000,000 – or $8,000 in annual assets under management fees – for a total annualized effective rate of 0.90%. This rate would be applied to the assets in each account to determine the final amount billed. As mentioned above, at CWA’s sole discretion, these fees are negotiable at the sole discretion of CWA, and in certain cases CWA aggregates the assets under management of related accounts for purposes of determining which breakpoint applies. Clients who have engaged CWA for Business and Personal Financial Planning Services will pay a discounted flat rate of 0.55%. The above fee schedule includes the advisory fee payable to CWA and the overlay management fee of 0.35% payable to Tectonic. However, this fee does not include fees charged by model providers under the UMA program. Such model provider fees generally range from 0.25% to 0.70% are only charged to the portion of the account under the model provider’s management. For each client account, CWA provides the client a separate fee table/Statement of Investment Selection that discloses the model provider fees at the inception of service. A revised fee table/Statement of Investment Selection will be provided to the client whenever the model provider lineup is modified, the client’s asset allocation between model providers is changed, and/or the account fee rate changes. The UMA Program Fee (including the model provider fee) is calculated by Tectonic and debited by CWA from the client’s Accounts on a quarterly basis in arrears. The fee is debited from the client’s account by the custodian at the end of each quarter, at the instruction of CWA, based upon the average daily balance of the account. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Advisory fees for alternative investments offered on the Capital Integration Systems LLC (“CAIS”) Alternative Investments Portal will be based on quarter end value. Advisory fees for assets managed through CAIS and/or CANVAS® will be  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 15 directly deducted separately by CAIS and/or CANVAS®. Clients may choose to direct CWA and Tectonic to charge fees for a specific account in a client’s portfolio from a single, specified portfolio account. In some cases, in lieu of allocating the account between one or more model provider, the account will be allocated between various mutual funds, ETFs and private funds, depending on the model chosen. In such cases, in lieu of a model provider fee, the fees are deducted at the mutual fund, ETF or private fund level and are not directly invoiced to client accounts. These fees do, however, represent an additional cost to the performance of the account. Detailed information on acquired funds fees in each model is available to the client so that they can assess their true economic expense for CWA UMA accounts. We encourage clients to ask the Associated Person assigned to their account any questions they have about our fee calculation and deduction process. In addition, we encourage clients to review all account statements provided by the custodian to verify advisory fee calculations. Either party may terminate a Unified Managed Account Program Agreement at any time by giving written notice to the other party not less than 30 calendar days before the effective date of termination. Refunds are not applicable because the fee is payable in arrears. Fees for Participation in the SMA Program are as follows: Generally, CWA charges a fee of up to 0.60% of assets under management for services it renders to participants in the various SMA programs. The fee can be shared with affiliates, such as Tectonic, that provide due diligence and certain back-office services to CWA. In addition to this fee, clients participating in the SMA program will pay the various investment managers (including Sanders Morris) a fee of up to 0.50% of assets under management. This fee is based on the most recent valuation of investments and assets in the investment program. This fee will be billed and collected monthly or quarterly, in arrears, adjusted for contributions and withdrawals. The Client authorizes the fee to be paid from their custodial account. The exact fee and payment arrangement will be listed in the agreement signed by CWA and the client. Custodian and brokerage services are provided by Sanders Morris and its custodian Pershing, LLC, and/or Schwab. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction costs. Clients should note that some custodial broker dealers have waived transaction fees for many equities and investment company securities. However, most custodial broker dealers still charge a separate transaction fee for certain securities, such as institutional class shares of mutual funds, non-US securities, etc. If investment company securities are chosen to be included in a SMA, the client will incur additional fees at the mutual fund level. These fees represent an additional cost to the client and affect the performance of the account. Sanders Morris offers six (6) cash management portfolio models to clients of CWA. These accounts include, Cash Management, Treasuries, Enhanced Short Term Fixed Income, Core, Performance (Bespoke Enhanced Security Tactics aka “B.E.S.T.”) and Custom (a customized account to meet the needs of individual clients). Cash Management, Treasuries, Enhanced Short Term Fixed Income, and Performance portfolios are not charged a fee by CWA. However, Sanders Morris charges fees of up to 0.25% of assets under management. Clients should also note that Performance portfolios (Bespoke Enhanced Security Tactics aka “B.E.S.T.”) charge a performance-based fee. This performance-based fee is charged directly by Sanders Morris and not shared with CWA. The exact fee schedules along with payment terms is clearly  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 16 listed in the advisory agreement signed by the client with Sanders Morris. Clients should also refer to the Form ADV Part 2 Brochure provided by Sanders Morris for detailed information about Sanders Morris’s services, billing arrangements and associated conflicts of interest. Clients should contact us promptly if they have not received Sanders Morris’s Form ADV Part 2 Brochure. Important Disclosures About the Recommendation of Affiliates Implicit in a decision to participate in the Pooled Investment Program through an affiliated National Bank, the Unified Managed Account Platform, or the Separately Managed Accounts Program, is the recommendation of T Bank, Tectonic and Sanders Morris LLC (“Sanders Morris”). T Bank, Tectonic, and Sanders Morris are affiliates of CWA through common ownership and control. Specifically, the eleven of the thirteen owners of CWA also have an ownership interest in Tectonic Financial, Inc., a publicly traded entity that owns T Bank, Tectonic and Sanders Morris LLC (“Sanders Morris”). CWA utilizes the services of Tectonic to conduct due diligence, research, and model management. T Bank utilizes the services of Tectonic to recommend managers to T Bank’s Trust Committee for consideration. The securities held in the Pooled Investment Program are managed by managers not affiliated with T Bank or Tectonic. However, one of the managers in the Pooled Investment Program utilizes the services of Sanders Morris, to execute trades in certain Funds. Sanders Morris receives commissions from the Funds for the transactions placed on behalf of the Funds. Assets in the Funds are held by a third-party custodian, U.S. Bank, N.A. In addition, Tectonic and Sanders Morris will receive compensation for managing portions of client accounts in the UMA and SMA Programs. The eleven CWA owners holding an interest in Tectonic Financial, Inc. receive additional indirect compensation in the form of a share of profits from these entities. These recommendations present a conflict of interest for CWA because Tectonic and Sanders Morris receive compensation for services rendered to clients of CWA. This creates an incentive for CWA to recommend Tectonic and Sanders Morris over other model portfolio managers. In order to address this conflict, CWA has adopted a code of ethics that obliges all associated persons to; (i) deal fairly with all clients when making investment decisions; (ii) to always uphold their fiduciary duty; and (iii) to put the client's interest first. Clients are not required to use the services of any affiliated advisers recommended by CWA. Additional Fees and Expenses The fees CWA charges may be negotiable at the sole discretion of CWA based on the amount of assets under management, complexity of client goals and objectives, and level of services rendered. Fees are not based on a share of capital gains of the funds of an advisory client. All fees paid to CWA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds to their shareholders. These fees and expenses are described in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without the services of CWA. In that case, the client would not receive the services provided by CWA which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by CWA to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Compensation for the Sale of Investment Products  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 17 Certain affiliated entities and Associated Persons of CWA are licensed insurance agents and can effect transactions in insurance products and earn commission based compensation for these activities. Clients are instructed that the fees paid to the firm for advisory services are separate and distinct from the commissions earned by our affiliated entities and dually licensed Associated Persons. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. Therefore, Associated Persons who are licensed insurance agents have an incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs. We address this conflict by informing clients that they are under no obligation to purchase insurance products through any individual associated with our firm. The sale of annuity contracts or insurance products offered by Associated Persons are intended to complement our advisory services. CWA has policies and procedures in place to monitor all client transactions and all client transaction costs will be disclosed to the client. Clients to whom the firm offers advisory services are informed that they are under no obligation to use the firm’s affiliated entities or Associated Persons for insurance services and may use the insurance brokerage firm and agent of their choice. Performance-Based Fees and Side-By-Side Management - Item 6 Performance based fees are based on a share of capital gains on or capital appreciation of the client’s assets. CWA and its Associated Persons do not accept performance-based fees. Types of Clients - Item 7 We provide fee-only personal financial counseling and investment advisory services to individuals, professional entities and trustees/plan sponsors of pension and profit-sharing plans; a majority of which are involved either directly or indirectly with the healthcare profession, but not exclusively. We do not require an account minimum to retain our firm for advisory services. However, certain programs offered by our firm have their own account minimum requirements. For example, the SMA program has a minimum investment requirement of $100,000. Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 As described under Advisory Services above, CWA offers Investment Management Services by referring clients to Pooled Investment, UMA, SMA, and Participant Directed programs. We will assist our clients in selecting an appropriate allocation and determining an investor profile. The investor profile and the entire financial planning process will help us recommend an asset allocation strategy. Our affiliate, Tectonic provides a variety of financial management research services to us. All investment advice given to our clients shall be deemed to be investment advice rendered by us for the benefit of our clients. The financial management research services and due diligence includes but is not limited to the following: a. Asset allocation analysis; b. Research on investments and securities including alternative forms of investments (i.e. commodities or real estate, etc.);  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 18 c. Due diligence research on investment, securities and asset management companies and managers; d. Periodic monitoring of investment, securities and asset management companies and managers; e. Assistance in selection of investment, securities and asset management companies and managers; f. Research on specific investments and securities in whatever form they may take; g. General research about investment, securities and asset allocation; h. Global investment services; i. Model portfolio In addition, Tectonic will provide due diligence and ongoing monitoring of its affiliated bank, T Bank, N.A. (T Bank) for its Pooled Funds and other third-party providers utilized by Tectonic and/or CWA as applicable to ensure such providers meet certain minimum qualitative and quantitative standards adopted by Tectonic and/or CWA. This arrangement is described in further detail in Item 10 below. The investment advice provided along with the strategies suggested by CWA will vary depending on each client’s specific financial situation and goals. This brief statement does not disclose all of the risks and other significant aspects of investing in financial markets. In light of the risks, clients should fully understand the nature of the contractual relationship(s) into which they are entering and the extent of their exposure to risk. Certain investing strategies may not be suitable for many members of the public. Clients should carefully consider whether the strategies employed will be appropriate for them in light of their experience, objectives, financial resources and other relevant circumstances. General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks, including complete possible loss of principal plus other losses and may not be suitable for many members of the public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk. Clients should familiarize themselves with the risks involved in the particular market instruments they intend to invest in. Accounts May Lose Value: There can be no assurance that a Fund will achieve its investment objectives and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise, and investors may not recoup the original amount invested in a Fund. An investment in a Fund may also be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and government, economic or monetary policies. Interest Rate Risk: A Fund that invests in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer term debt securities are usually more sensitive to interest rate changes. Credit Risk: A Fund that invests in bonds and other fixed income securities is subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 19 to sell. Funds investing in lower quality debt securities are more susceptible to these problems and their value may be more volatile. Futures and Options in Funds: Funds may invest in options and futures on securities, indices and interest rates for the purpose of efficient portfolio management. Also, Funds may invest in futures, options or forward foreign exchange contracts to hedge market and currency risks. Transactions in futures carry a high degree of risk. The amount of the initial margin is small relative to the value of the futures contract so that transactions are "leveraged" or "geared". A relatively small market movement will have a proportionately larger impact which may work for or against the investor. The placing of certain orders which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. Transactions in options also carry a high degree of risk. Selling ("writing" or "granting") an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. Sector Risk: Funds which concentrate their portfolio in a specific sector may carry a higher degree of risk due to lower diversification and sector-specific risks. Because these investments are limited to a relatively narrow segment of the economy, the Funds' investments are not as diversified as most funds. This means that these Funds tend to be more volatile than other funds and their portfolio values can increase or decrease more rapidly. The performance of each Fund may differ in direction and degree from that of the overall stock market. Small Capitalization: Funds which include smaller capitalization companies may involve greater risk than Funds investing in larger, more established companies. For example, small capitalization companies may have limited product lines, markets and financial or managerial resources. As a result, price movements in securities of smaller capitalization companies may be more volatile. Transaction costs in securities of smaller capitalization companies can be higher than those of larger capitalization companies and there may be less liquidity. Non-Investment Grade Debt: Credit risk is more pronounced for investments in fixed-income securities that are rated below Investment Grade or which are of comparable quality. The risk of default may be greater and the market for these securities may be less active, making it more difficult to sell the securities at reasonable prices, and also making valuation of the securities more difficult. A Fund may incur additional expenses if an issuer defaults and the Fund tries to recover some of its losses in bankruptcy or other similar proceedings. Risks Associated with Capital Integration Systems LLC Investments: CAIS sources and selects various private funds for its platform through a due diligence process conducted by Mercer Investment Consulting (“Mercer”). Products that are appropriate and desirable for the platform are subject to internal committee reviews by CAIS and a fully independent review by Mercer. Product onboarding occurs only following the successful completion of these processes. In addition to reviewing the risk disclosure contained herein, clients participating in the UMA Program with respect to certain alternative investments available to them through the Capital Integration Systems LLC (“CAIS”) Portal should closely read the relevant prospectus  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 20 or private placement memorandum prior to investing. Such documents are intended to include all material risks of such investments, and are hereby incorporated herein by reference. Alternatives Risk: Non-traded REITs, business development companies, limited partnerships, and direct alternatives are subject to various risks such as devaluation based on adverse market conditions and may not be suitable for all investors. A prospectus that discloses all risks, fees, and expenses may be obtained from your investment adviser representative. Read the prospectus carefully before investing. This disclosure is not a solicitation or offering which can only be made in conjunction with a copy of the prospectus. Investors considering an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature; and, such investments involve a high degree of risk, particularly if concentrating investments in one or few alternative investments. Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private investment company at an advantageous price and time, and investments in a private investment company routinely include a “lock up” period, during which investors are not permitted to withdraw their funds from such private investment company. Since shares of private investment companies are not publicly traded, from time to time it may be difficult to establish a fair value for the client’s investment in these companies. In addition, private investment companies may employ leverage, including the use of borrowed funds. While such strategy may increase the opportunity to achieve higher returns on the amounts invested, it also increases the risk of loss. Illiquid securities: Illiquid securities involve the risk that investments may not be readily sold at the desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which no market is currently available may be difficult to purchase or sell, which may impact the price or timing of a transaction. An inability to sell securities can adversely affect an account's value or prevent an account from taking advantage of other investment opportunities. Lack of liquidity may cause the value of investments to decline and illiquid investments may also be difficult to value. A client may not be able to liquidate investment in the event of an emergency or any other reason. Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private equity and real estate. Investment in an illiquid asset vehicle poses similar risks as direct investments in illiquid securities. In addition, investment in an illiquid asset vehicle will be subject to the terms and conditions of the illiquid asset vehicle’s investment policy and governing documents that often include provisions that may involve investor lock-in periods, mandatory capital calls, redemption restrictions, infrequent valuation of assets, etc. In addition, investments in illiquid securities or vehicle may normally involve investment in non-marketable securities where there is limited transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid securities or vehicles may include restrictions on withdrawal rights and shares may not be freely transferable.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 21 Cybersecurity Risks – CWA and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber- attacks are deliberate, however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While our firm has established business continuity plans, incident response plans and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks also are present for issuers of securities in which we invest, which could result in material adverse consequences for such issuers and may cause a client’s investment in such securities to lose value. Disciplinary Information - Item 9 Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to clients' evaluation of CWA or the integrity of CWA's management. There is no history of reportable legal or disciplinary events by CWA, our principals or advisory representatives. Other Financial Industry Activities and Affiliations - Item 10 CWA is also a Certified Public Accountancy firm and as such offers accounting and tax services to clients. It is expected that clients for whom accounting and tax services are offered are also financial planning and advisory clients. The fees for accounting and tax services are separate and distinct from the fees charged for financial planning and advisory services. CWA anticipates that of the total revenue of the firm, 10% involves accounting services, 19% involves tax services, and 5% involves other non-advisory services. Eleven of the thirteen owners of CWA have an ownership interest in Tectonic Financial, Inc., a publicly traded entity that owns the following financial industry affiliates: • Tectonic Advisors, LLC • HWG Insurance Agency, LLC • Sanders Morris LLC • T Bank, N.A. Said individuals receive additional indirect compensation in the form of a share of profits from these entities. In order to address this conflict of interest, CWA has adopted a code of ethics that obliges all associated persons to; (i) deal fairly with all clients when making investment decisions; (ii) to uphold their fiduciary duty at all times; and (iii) to put the client's interest first. Clients are not required to use the services of any affiliated advisers recommended by CWA. We have provided further detail about these affiliates in the below paragraphs.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 22 CWA is affiliated with, T Bank, N.A., a national bank, (“T Bank”) through common control and ownership. Specifically, the owner partners of CWA have an ownership interest in Tectonic Financial, Inc, which owns T Bancshares, Inc., the entity that owns T Bank. Although CWA believes T Bank to be an appropriate and suitable provider of trust services, please be advised that recommendations by CWA, their affiliates, officers, directors and employees to clients concerning T Bank and the pooled investment program is regarded as a conflict of interest, by virtue of their ownership in T Bank. CWA has performed appropriate due diligence of T Bank Trust services, including comparison pricing and has concluded that T Bank provides quality services and competitive pricing. Another service offered by T Bank is pension administration. Such services are offered under the name The Nolan Company. CWA expects that clients to whom it offers advisory services may receive pension administration services from The Nolan Company. Clients are instructed that the fees paid to CWA for advisory services are separate and distinct from the compensation earned by The Nolan Company for pension administration services. Clients to whom the firm offers advisory services are informed that they are under no obligation to use The Nolan Company for pension administration services and may use the pension administration service of their choice. Tectonic Advisors, LLC (“Tectonic”) is a SEC registered investment adviser that has been contracted by T Bank to provide certain investment advisory services to T Bank. Specifically, a material part of Tectonic’s business is to serve as lead investment advisor to the Pooled Funds (Pooled Investment Program), and with respect to certain of such Pooled Funds, to also serve as manager. Implicit in a CWA recommendation of T Bank is a recommendation of Tectonic. This presents a conflict in that CWA has an incentive to recommend the pooled fund program over an alternative. In addition, this represents a conflict in that a recommendation of T Bank can be regarded as being influenced by the affiliate relationship between Tectonic and CWA, and the contractual relationship between T Bank and Tectonic. To mitigate these conflicts, in addition to the firm’s code of ethics policies, CWA Compliance reviews and works with CWA owners and the Investment Committee to resolve potential conflicts. Additionally, CWA can recommend clients include Tectonic model portfolios in their UMA allocation. This recommendation presents a conflict of interest for CWA as Tectonic receives compensation on the allocated assets. This creates an incentive for CWA to recommend Tectonic over other model portfolio advisors. To mitigate this conflict, in addition to the firm’s code of ethics policies, CWA Compliance reviews and works with CWA owners and the Investment Committee to resolve potential conflicts. CWA Risk Solutions LLC (“Risk Solutions”) is a Texas based insurance agency related to CWA through common control and ownership. Risk Solutions’ services are actively marketed to CWA clients and CWA expects that clients to whom it offers advisory services will purchase insurance products from Risk Solutions. Clients are instructed that the fees paid to CWA for advisory services are separate and distinct from the commissions earned for placing the client in insurance products. Clients to whom the firm offers advisory services are informed that they are under no obligation to use Risk Solutions for insurance services and may use the insurance brokerage firm and agent of their choice. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. This creates a conflict of interest because Associated Persons have an incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 23 CFO Ortho, LLC (“CFO Ortho”) is a Utah based tax and accounting firm wholly owned by CWA. Certain of our Associated Persons also provide tax and accounting services through CFO Ortho and receive compensation for these activities. CWA’s services are actively marketed to CFO Ortho clients. Clients are instructed that the fees paid to CWA for investment advisory services are separate and distinct from the compensation earned by CFO Ortho for bookkeeping, tax and accounting services. Clients are under no obligation to obtain bookkeeping, tax and accounting services through any person or entity affiliated with our firm. Sanders Morris LLC (“Sanders Morris”) is a dually registered broker dealer and investment adviser. T Bank utilizes the services of Sanders Morris to execute trades in certain Pooled Funds recommended to clients by CWA. Sanders Morris receives commissions for the transactions placed on behalf of the funds. Additionally, Sanders Morris acts as a model provider for certain CWA clients. This recommendation presents a conflict of interest for CWA as Sanders Morris receives both fee based and commission-based compensation on the allocated assets. This creates an incentive for CWA to recommend Sanders Morris over other model portfolio advisors. To mitigate this conflict, in addition to the firm’s code of ethics policies, CWA Compliance reviews and works with CWA owners and the Investment Committee to resolve potential conflicts. Managing members of CWA, CWA, or its related persons have an economic, management or other beneficial or contractual interest in several entities in which certain CWA clients are also investors. CWA managing members, employees, or other parties related to CWA may act in one or more of the following capacities in these entities, (i) managing members (ii) general partners, (iii) limited partners, (iv) service providers, or (v) investors of these partnerships or other ventures. Other related entities for which CWA employees have an economic interest include: III to I Foundation, Inc. – Charitable foundation offering seminars financial education and scholarships. Annual and lifetime membership fees from individual donations and registrations fees; approximately 20% of CWA clients are subscribers or donors. Elite Dental Alliance, LLC (EDA) – EDA is a membership organization in the business of providing cost savings for members through volume and loyalty discounts on products and services. Membership is primarily marketing to dentists. Eleven of the thirteen owners of CWA have an ownership intertest in EDA. Elite Dental Alliance primarily markets its services to clients of CWA. EDA receives its revenue primarily from membership fees and administrative fees from vendors. A conflict exists in that the Planners (which could include the CWA owners) have an incentive to refer a client for EDA membership rather than an EDA competitor and it is possible that such a competitor could provide services to CWA clients at the same or preferable cost. EDA is owned equally (8.33%) by eleven of the thirteen owners of CWA and Brett Pierce. NDP, LLC dba NDP (fka National Dental Placements, LLC) – Formed in order to provide a variety of services related to the needs of dentists seeking to sell all or transition a portion of their practice. The major services provided by NDP include: practice listings (e.g., finding potential buyers for such practice sales), practice valuation and transition consulting services related to such practice sales. CWA may offer its services to clients of NDP, and CWA and NDP may at times share certain personnel. In addition, CWA Planners may refer CWA clients to NDP or to certain entities with which NDP has established a relationship, and in such cases, the Planners (which could include CWA owners) may receive a referral fee  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 24 from NDP. These referral relationships may create a conflict in that the Planners would have an incentive to refer clients to NDP rather than one of NDP’s competitors and it is possible that such a competitor could provide services to CWA clients at the same or preferable cost. CWA believes the services of NDP to be very competitive in price and quality. NDP is owned equally (8.33%) by eleven of the thirteen owners of CWA and Christy Ratcliff. 7P Dental Transition Services, LLC dba 7 Pillars – Formed in order to provide a variety of services related to the needs of dentists seeking to sell all or transition a portion of their practice to a Dental Service Organization (DSO) or private equity vehicle. The major services provided by 7 Pillars include: the financial analysis and calculation of EBITDA, finding potential buyers for such practice sales, as well as negotiate and facilitate their practice transition and post close terms. CWA may offer its services to clients of 7 Pillars, and CWA and 7 Pillars may at times share certain personnel. In addition, CWA Planners may refer CWA clients to 7 Pillars, and in such cases, the Planners (which could include CWA owners) may receive a referral fee from 7 Pillars. These referral relationships may create a conflict in that the Planners would have an incentive to refer clients to 7 Pillars rather than one of 7 Pillar’s competitors and it is possible that such a competitor could provide services to CWA clients at the same or preferable cost. CWA believes the services of 7 Pillars to be very competitive in price and quality. 7 Pillars is owned equally (7.69%) by the eleven of the thirteen owners of CWA, Christy Ratcliff, and Brett Pierce. Our affiliates are separately compensated if clients use their services. While we believe that the compensation charged by our affiliates is competitive, the fees charged may be higher than other firms that provide similar services. Clients are not required to use our affiliates’ services and may contract with other providers. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 Description of Our Code of Ethics CWA has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes CWA’s policies and procedures developed to protect client’s interests in relation to the following topics:  The duty at all times to place the interests of clients first;  The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the code of ethics.  The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s position of trust and responsibility;  The fiduciary principle that information concerning the identity of security holdings and financial circumstances of clients is confidential; and  The principle that independence in the investment decision-making process is paramount. A copy of CWA’s Code of Ethics is available upon request to the Chief Compliance Officer at CWA’s principal office address on the cover of this brochure. Participation or Interest in Client Transactions Clients of CWA may have been presented investment by partnerships or other ventures in which CWA, its related entities, related persons, and managing members may act in one or more of the following  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 25 capacities, (i) managing members, (ii) general partners, (iii) limited partners, (iv) service providers, or (v) investors of these partnerships and other ventures. There is an inherent conflict of interest in that managing members or employees of CWA, and its related persons may have an ownership, controlling, beneficial, or managerial interest in the aforementioned entities, and may provide services to these entities for which they may be compensated. However, such current investments are no longer open to new investors or open to any additional capital and are in a distribution stage in advance of preparations for eventual winddown. Personal Trading Practices At times CWA and/or its Associated Persons may take positions in the same securities as clients, which may pose a conflict of interest with clients. We will not violate our fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading. Brokerage Practices - Item 12 Brokerage Recommendations Accounts managed by our affiliated investment adviser/broker dealer, Sanders Morris LLC (“Sanders Morris”), use Sanders Morris and Pershing, LLC (“Pershing”) for brokerage and custody. Sanders Morris has an introducing broker arrangement with Pershing, a clearing broker and custodian, and receives a portion of Pershing’s brokerage fees as a result. For certain transactions, including those directly done with a mutual fund company or insurance company issuing a variable product, the use of a clearing firm is not necessary, allowing Sanders Morris to act alone on the transaction without Pershing. When Sanders Morris acts as broker-dealer on a transaction in a client’s account, Sanders Morris will receive commissions, rebates and trails as a result of the transaction. The possibility of such compensation creates an economic incentive and a conflict of interest for Sanders Morris. Sanders Morris’s recommendation of Pershing is affected by its financial interests in seeking to increase its broker-dealer business by increasing the number of transactions Pershing processes as its clearing firm and increasing the value of its clients’ assets custodied in accounts at Pershing. Sanders Morris can also receive other payments and credits from Pershing based on a percentage of the interest paid by clients on margin account balances, a percentage of interest earned on customer “free credit balances,” a percentage of the interest earned on sweep account balances maintained by Pershing or its affiliates, and a percentage of IRA account fees. These payments or credits to Sanders Morris from Pershing will grow as the amount of assets maintained in our clients’ Pershing accounts increases. As an investment adviser, CWA has a significant interest in encouraging clients to open and maintain accounts with Pershing because of its affiliation with Sanders Morris. Sanders Morris receives the following services from Pershing at no charge: • Access to institutional trading desks; • Duplicate client confirmations and bundled duplicate statements; • Ability to have investment advisory fees deducted directly from client accounts; • Access to an electronic communications network for client account information;  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 26 • Receipt of compliance publications; • Access to mutual funds otherwise available for significantly higher minimum initial investments or only to institutional investors; and • Access to educational events or occasional business entertainment of our personnel. CWA and Sanders Morris rely on Pershing’s systems that provide access to client account information and records, including duplicate and batched client statements, confirmations, and year-end summaries; pricing information and other market data; and recordkeeping and client reporting assistance. Some of these services may be used to service all of our accounts, including accounts not maintained with Pershing. The existence of these products and services from Pershing influences our recommendation of Pershing to clients and creates a significant conflict of interest that clients should consider when evaluating whether to accept our recommendation of Sanders Morris’s and/or Pershing’s services. We offer no assurance that the costs clients will incur by using Sanders Morris as investment adviser and Sanders Morris and Pershing as broker-dealers will be as low as the costs charged by other firms for similar services; it is likely that lower costs are available for similar services from other broker- dealers or custodians. Because of the incentive we have to recommend Pershing, we have adopted policies and procedures to monitor and mitigate this conflict by periodically analyzing the Pershing programs we recommend for our clients, evaluating the usefulness of the services received in relation to the costs of such services, and assessing the overall quality of the services. Clients are under no obligation to buy any security or insurance product recommended in any financial plan or consulting service. If the client elects to implement any such recommendation, the client is under no obligation to purchase the product through Sanders Morris or any other broker-dealer that we may recommend; they may purchase such product through any licensed agent or financial services firm of their choosing. Brokerage and Custodial Services Offered by Schwab For CWA’s asset management programs, we recommend and request clients to implement trades and maintain custody of assets through discount brokers. Currently, we recommend the services of Schwab for the UMA, SMA, and participant directed programs. Schwab are members of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). Schwab offer independent investment advisers services, which include custody of client securities, trade execution, clearance and settlement of transactions, and daily research and investment information. We are not affiliated with Schwab. Our Investment Adviser Representatives are not registered representatives of Schwab and do not receive commissions or other compensation from recommending these services. CWA affiliate, Tectonic has been engaged by T Bank to act as their lead investment advisor for the collective investment funds used for qualified plan assets and the common trust funds maintained for their personal trust assets (the “Funds”), and with respect to certain of such Pooled Funds, to also serve as manager. This arrangement is described in further detail in Item 10 above.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 27 Each fund is either managed by one or more independent, third-party money managers, invested in mutual funds, or managed by affiliate advisor, Tectonic. Decisions related to the purchase and sale of securities are made by the individual money managers or mutual funds. Brokerage and Custodial Services Offered by Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us. We are independently owned and operated; and, we are not affiliated with Schwab. Schwab will hold assets in a brokerage account and will buy and sell securities in your account(s) upon our instructions. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and you will open your account with Schwab by entering into an account agreement directly with them. Services that Benefit You: 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 generally benefit you and your account. Services that Do Not Directly Benefit You: 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 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: • provide access to client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple client accounts facilitate payment of our fees from our clients’ accounts • • provide pricing and other market data • • assist with back-office functions, recordkeeping, and client reporting Services that Generally Benefit Only Us: 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 • Consulting on legal and compliance-related needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support • Recruiting and custodial search consulting 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 for our personnel. If you did not maintain your account with Schwab, we would be required to pay for those services from our own resources.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 28 Our Interest in Schwab’s Services 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. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf once the value of our clients’ assets in accounts at Schwab reaches certain thresholds. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a 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 recommendation 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 “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. CWA understands its duty for best execution and considers all factors in making recommendations to clients. These research services may be useful in servicing all CWA clients and may not be used in connection with any particular account that may have paid compensation to the firm providing such services. While CWA may not always obtain the lowest commission rate, CWA believes the rate is reasonable in relation to the value of the brokerage and research services provided. Some of the programs offered in our portfolio management services are only available to accounts custodied at one or more of the broker-dealers that we recommend. For other programs, we have the capability of working with other custodians upon the client’s request. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements with any broker-dealer. Through our relationships with broker-dealers, we or our affiliates receive research or other services at no charge. However, the receipt of such research and additional benefits is not contingent upon us committing any specific amount of business to the providing broker-dealer. We do not use client brokerage commissions paid to the broker- dealer for the purposes of obtaining research or other services. Nonetheless, a conflict exists between the interests of our clients in receiving best execution (and lower transaction costs) and our interest in receiving research and/or other services and recommending the broker-dealers who provide us with such research and services. We do not attempt to put a dollar value on the services received by each account, nor do we attempt to allocate or use the services received for the benefit of specific accounts or attempt to use any particular item to service all accounts. We will use the services we receive to assist in managing accounts not maintained with the broker-dealer whose commissions were used to pay for such services. The services and support we receive from broker-dealers are used to help our firm to fulfill its overall client obligations. To address this conflict of interest, we have adopted policies and procedures to conduct periodic best execution reviews to monitor and mitigate this conflict. When conducting a best execution review and/or otherwise reviewing the broker-dealers, we consider the transaction costs (including commissions or spreads, market impact costs, and opportunity costs), as well as the full range and quality of the broker- dealer and related services the broker-dealer provides. We consider the speed, certainty, consistency and  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 29 accuracy of execution, responsiveness to our inquiries and requests, willingness and speed in resolving errors or other discrepancies, access to financial products and markets, and research, analyses, and various electronic products and services provided by the broker-dealer. We periodically evaluate the usefulness of the services the broker-dealer provides in relation to transaction costs. CWA will continue to review periodically its determination that the costs and quality of services from the broker-dealers we recommend are reasonable in relation to the value of the services provided, viewed in terms of the overall relationship. Best Execution In recommending broker-dealers, we consider the full range and quality of the broker-dealer’s services, including, among other things, execution capability, cost, financial responsibility, responsiveness, and the value of research and other services provided. CWA will not recommend a broker-dealer solely on the basis of the lowest possible commission cost, but rather, will determine whether the broker-dealer has the ability to provide the best qualitative execution. The reasonableness of a broker-dealer’s compensation is based on the broker-dealer's ability to provide professional services, competitive commission rates, research, and other services which will help us in providing investment services to clients. Consequently, we may recommend a broker-dealer that provides useful research and brokerage services, even though a lower commission may be charged by a different broker-dealer. As a fiduciary, we recognize our duty to seek best execution. We regularly evaluate all broker-dealers recommended and utilized. In doing so, we consider all of the products, services, and benefits that we and our clients receive as well as the cost and quality of the custodial or brokerage services a broker provides. We continue to believe that our use of the recommended broker dealers is consistent with our fiduciary responsibilities. Brokerage for Client Referrals We do not receive client referrals from broker-dealers and custodians in which we have an institutional advisory arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals. Directed Brokerage Depending on the program selected, clients for whom we provide portfolio management services may be required to direct us to execute transactions through a specified broker-dealer. Not all investment advisers require their clients to direct the use of a particular broker. When clients direct brokerage, we may not be able to achieve most favorable execution of client transactions. Certain cost-reducing measures, such as volume discounts or aggregate trading, may not be available, and we may receive less favorable pricing. As a result, directing brokerage may cost clients more money. Review of Accounts - Item 13 Clients that have signed up for ongoing services are typically provided with periodic reviews of their investment accounts and a review of the overall financial objectives and situation. Annual reviews are held with clients for a complete review of their financial situation. Other items that may trigger a more frequent review of the client portfolios are changes in cyclical or market conditions and sudden changes  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 30 in the client’s financial situation. Each client is assigned a financial planning team, headed by an adviser that oversees the preparation of all reports, performs specific client reviews and is the primary contact with the client. The reviews described above are conducted by the CWA financial planner/investment adviser representative assigned to the client. The financial planner/investment adviser representative is subject to the supervision by the Partner in Charge of Operations and the general authority of the Chief Compliance Officer. Reviewers also are responsible for ensuring that any significant change in a client’s investment strategy or concentration of a client’s assets in a speculative or risky asset class is appropriate for and has been reviewed with the client. Clients are provided an annual performance review of their accounts at the time of the annual on-going business and personal financial planning meeting. Custodians for the assets provide monthly and/or quarterly statements directly to the client. Client Referrals and Other Compensation - Item 14 Please refer to Item 12 for further information about the products, services, and economic benefits we receive from broker-dealers. CWA does not receive additional economic benefits from unaffiliated third parties for providing investment advice or other advisory services to clients. CWA, through its related persons and entities, indirectly participate in client referral arrangements. The conflicts of interest and specifics of these arrangements are fully described in Item 10 & 11. Associated Persons of CWA are eligible to receive a bonus payment for each prospect or client referred to CWA or its affiliated entities by clients serviced by the Associated Person. As described in Item 10, CWA can recommend clients include Sanders Morris and Tectonic model portfolios in their UMA allocation. This recommendation presents a conflict of interest for CWA as Sanders Morris and Tectonic receive compensation for the management of the allocated assets. Additionally, Tectonic provides CWA with asset management services, investment manager oversight, management and trading of model portfolios, and other related services. CWA and Tectonic, as affiliates and related parties, and by means of an agreement between both parties, may receive mutual economic benefit for these services and client recommendations of the models. Custody - Item 15 CWA is deemed to have custody of client funds because T Bank, an affiliated party, acts as a qualified custodian for certain client accounts. Fund assets are held in custody with the following T Bank approved Custodian: US Bank Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s account assets. CWA urges the client to carefully review these statements.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 31 As a condition of participating in the Separately Managed Account (“SMA”) investment programs, clients will be required to use Charles Schwab & Co., Inc. (“Schwab”) for trade execution and custodial services. As a condition of participating in the Unified Managed Account (“UMA”) Platform, clients will be required to use Schwab for trade execution and custodial services. However, there is no guarantee that these custodians provide the best value or is the low-cost solution. Related persons to CWA act as General Partners to III to I Emerging Market Partners Real Estate Investment Fund I, LP; CWA could be deemed to have custody over this partnership because of the relationship between CWA and the General Partners to the partnerships. Investment Discretion - Item 16 CWA provides portfolio management services to its advisory clients on both a discretionary and a non- discretionary basis. Please see Item 4, Advisory Services for a full description of CWA’s services. Voting Client Securities - Item 17 Proxy Voting CWA does not exercise the authority to vote proxies on behalf of client securities. Financial Information - Item 18 CWA does not have reportable financial disclosures in which CWA’s financial condition would impair CWA’s ability to meet contractual commitments to clients. Requirements for State-Registered Advisors - Item 19 This section is intentionally left blank- Our firm is SEC registered. Miscellaneous Privacy Policies CWA views protecting its customers' private information as a top priority and pursuant to the requirements of the federal Gramm-Leach-Bliley Act, CWA has instituted policies and procedures to ensure that customer information is kept private and secure. CWA does not disclose nonpublic personal information about its customers or former customers to nonaffiliated third parties, except as permitted by law. In the course of servicing a client's account, CWA may share some information with its service providers, such as custodians or broker-dealers. Additionally, CWA may share nonpublic personal information about its customers or former customers with its affiliates for marketing purposes. This practice is disclosed in the firm’s privacy notice and clients have the ability to opt out of this practice by providing written notice to the firm. CWA restricts internal access to nonpublic personal information about clients to those employees or investment advisory representatives who need access to that information in order to provide services to the client.  Cain, Watters & Associates, LLC Form ADV Part 2A Page | 32 A copy of CWA’s privacy policy notice will be provided to each client prior to, or at the time the advisory agreement is executed. Thereafter, CWA will deliver a copy of the current privacy policy notice to its clients on an annual basis. Clients who have questions about this policy, may contact us at the phone number listed on the cover of this brochure.