Cjc Wealth Management

CJC Wealth Management LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of CJC Wealth Management LLC. If you have any questions about the contents of this brochure, please contact us at (301) 761-3880 or by email at: info@cjcwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about CJC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. CJC Wealth Management LLC’s CRD number is: 325288. 3470 Olney-Laytonsville Rd, #277 Olney, MD 20832 (301) 761-3880 info@cjcwealth.com https://cjcwealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 07/10/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of CJC Wealth Management LLC on January 08, 2026, are described below. Material changes relate to CJC Wealth Management LLC’s policies, practices or conflicts of interests. • CJCWM has successfully transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................8 Item 7: Types of Clients ..........................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................8 Item 9: Disciplinary Information .........................................................................................................................12 Item 10: Other Financial Industry Activities and Affiliations .........................................................................13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............14 Item 12: Brokerage Practices ................................................................................................................................15 Item 13: Review of Accounts ................................................................................................................................17 Item 14: Client Referrals and Other Compensation ..........................................................................................18 Item 15: Custody ....................................................................................................................................................18 Item 16: Investment Discretion ............................................................................................................................19 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................19 Item 18: Financial Information .............................................................................................................................19 iii  Item 4: Advisory Business A. Description of the Advisory Firm CJC Wealth Management LLC (hereinafter “CJCWM”) is a Limited Liability Company organized in the State of Maryland. CJCWM was formed and first registered to conduct investment advisory services in February 2023. The principal owners are Ace 3 Holdings LLC, Mel CK Consulting Inc, and CK79, LLC. The principal owner of Ace 3 Holdings LLC is Christopher John Campbell. The principal owner of Mel CK Consulting Inc is Melissa Ayn Caro. The principal owner of CK79, LLC is John Christopher King. B. Types of Advisory Services Portfolio Management Services CJCWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CJCWM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring CJCWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CJCWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CJCWM’s economic, investment or other financial interests. To meet its fiduciary obligations, CJCWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CJCWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CJCWM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Selection of Other Advisers CJCWM may direct clients to use Orion Portfolio Solutions, LLC (CRD #107975) as a third- party adviser. CJCWM and Orion are not affiliated. Before selecting other advisers for 2  clients, CJCWM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where CJCWM is recommending the adviser to clients. Orion makes available to CJCWM various models and strategies that CJCWM may select on behalf of clients after gathering sufficient evidence from the client to make a determination. CJC then monitors these accounts to ensure they align with the client’s investment profile and track performance. CJCWM meets with the client periodically to review the account(s) managed by the third-party manager. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. In formulating a financial plan, CJCWM will first meet with the client to gather all of the necessary information needed to create the plan. After the plan is created, we typically meet with the client to discuss the plan, as well as their goals, and will make updates to the plan, if needed. All financial planning engagements will be tailored to the client’s specific situation, complexity and needs. CJCWM will deliver the initial financial plan within three months of the commencement of the engagement, provided the client has furnished all requested information in a timely manner. Following delivery of the initial financial plan, the engagement automatically renews on an annual basis (each, a “Renewal Term”) unless terminated by either party in accordance with the termination provisions of the agreement. During each Renewal Term, CJCWM will review the client’s financial plan and provide an updated version of such plan within three months of the commencement of the applicable Renewal Term. Clients are responsible for promptly notifying CJCWM of any material changes to their financial situation, goals, or objectives so that such information can be incorporated into the financial planning process. The accuracy and completeness of the financial plan depend on the information provided by the client. Financial planning services are provided based on the scope of services agreed upon with each client and do not include implementation of recommendations unless separately agreed. Educational Seminars/Workshops literacy-based content but educational in nature, CJCWM offers educational seminars which are web based and provided to Federal agencies who request them, and occasionally to clients. They are all retirement planning/financial i.e. no recommendations. Services Limited to Specific Types of Investments CJCWM generally limits its investment advice to mutual funds, fixed income securities, inflation including annuities, equities, ETFs and insurance products treasury 3  protected/inflation linked bonds. CJCWM may use other securities as well to help diversify a portfolio when applicable. CJCWM may recommend third-party investment advisers to manage all or a portion of the client’s portfolio. Before recommending a third- party investment advisor, CJCWM will conduct due diligence to ensure the recommendation is in the client’s best interest. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions CJCWM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CJCWM on behalf of the client. CJCWM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CJCWM from properly servicing the client account, or if the restrictions would require CJCWM to deviate from its standard suite of services, CJCWM reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. CJCWM does not participate in wrap fee programs. 4  E. Assets Under Management CJCWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $121,906,496.00 $ 0 June 2026 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $3,000,000 1.00% $3,000,001 - UP 0.75% An average of the daily balance in the client’s account throughout the billing period is used to determine the market value of the assets upon which the advisory fee is based. These fees are negotiable. The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of CJCWM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Selection of Other Advisers Fees CJCWM will be compensated for its services by the third-party adviser. These third-party investment advisers charge fees that range from 0% to 0.50% of assets under management. Clients will pay CJCWM its standard portfolio management fee as described above in addition to the standard fee for the advisers to which it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will be withdrawn by the custodian who will pay each party its portion of payment of fees. The terms for termination and whether or not fees for third-party advisers will be paid in advance will be dictated by the third-party adviser selected. CJCWM does not change its fee schedule as a result of its arrangement with any third- party advisors. 5  Financial Planning Fees CJCWM offers financial planning services for an annual fee (the “Annual Planning Fee”). The Annual Planning Fee generally ranges from $1,500 to $10,000, depending on the scope and complexity of the services to be provided, the client’s financial situation, and other relevant factors. The specific fee will be agreed upon with the client in advance and documented in the client’s agreement. In addition to the Annual Planning Fee, clients will be charged a separate, one-time initial financial planning fee (the “Initial Planning Fee”) in connection with the development and delivery of the client’s initial financial plan. The Initial Planning Fee generally ranges from $1,500 to $10,000 and is based on similar factors, including the scope and complexity of the planning engagement. The Initial Planning Fee is charged only during the first year of the engagement and is in addition to the Annual Planning Fee. In subsequent years, clients are charged only the Annual Planning Fee for ongoing financial planning services, which include an annual review and update to the client’s financial plan. The fees are negotiable, and the final fee schedule will be disclosed in the Financial Planning Agreement. Educational Seminars/Workshops Fees CJCWM does not charge for educational seminars that they offer. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. For fees deducted directly from client accounts, in states that require it, CJCWM will use the safeguards below: 1. CJCWM will have written authorization from the client to deduct advisory fees from the account held with a qualified custodian. 2. The custodian will send statements, at least quarterly, to the client showing all disbursements for the custodian account, including the amount of the advisory fees. 3. Each time a fee is deducted CJCWM will send the qualified custodian notice of the amount of the fee to be deducted and will also send the client an invoice itemizing the fee including the formula used to calculate the fee, the amount of assets under management upon which the fee is based, and the period covered by the fee. 6  Payment of Selection of Other Advisers Fees Fees are paid monthly in arrears. The fees will be withdrawn by the custodian who will pay each party its portion of payment of fees. Payment of Financial Planning Fees The Initial Planning Fee is a one-time fee paid 100% in advance. The Annual Planning Fee may be paid either in advance on an annual basis or in installments on a monthly basis, as agreed upon in the agreement. These fees are charged in advance, but never more than three months in advance. Financial planning fees are paid via check, cash, wire, or by debit or credit card using AdvicePay. Payment using AdvicePay, a third-party vendor, is not required in order to provide financial planning services. The client, if they elect, will be invoiced through and payment made directly within the vendor’s secure site. The client will authorize and direct the fee to be paid to CJCWM. CJCWM and AdvicePay are separate entities and there is no material conflict of interest for the use of this service. AdvicePay does charge a fee for the services, but the client will not bear these costs. CJCWM will pay all fees associated with the client’s use of this payment vendor. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CJCWM. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees CJCWM collects its financial planning fees in advance, but never more than three months in advance. Fixed fees that are collected in advance, but unearned at the time termination becomes effective (if any), will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients Some investment advisor representatives of CJCWM, in their outside business activities, (see Item 10 below) are licensed to accept compensation for the sale of insurance products to CJCWM clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of insurance products for which the 7  supervised persons receives compensation, CJCWM will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase CJCWM -recommended products and, if purchasing, have the right to purchase those products through other insurance agents that are not affiliated with CJCWM. Commissions are not CJCWM s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management CJCWM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. The firm does not engage in side-by-side management. Item 7: Types of Clients CJCWM generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There are no requirements for opening or maintaining an account. There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CJCWM’s methods of analysis include, fundamental analysis, quantitative analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. 8  Modern portfolio theory is an investment approach that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Investment Strategies CJCWM uses long term trading and selection of other investment advisers. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis. Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Inflation Risk, also known as Purchasing Power Risk, arises from the decline in value of securities cash flow due to inflation, which is measured in terms of purchasing power. Inflation Protection Bonds such as TIPS are the only protection offered against this risk. Floaters, the resetting of the interest rates, can help reduce inflation risk. All other bonds have fixed interest rates for the life of the bond, which exposes the investor to this risk. Economic Risk is the chance that macroeconomic conditions like exchange rates, government regulation, or political stability will affect an investment, usually one in a foreign country. 9  Political Risk, also known as geopolitical risk, is risk an investment's returns could suffer as a result of political changes or instability in a country. This becomes more of a factor as the time horizon of an investment gets longer. Instability affecting investment returns could stem from a change in government, legislative bodies, other foreign policy makers or military control. Regulatory Risk is the risk that a change in laws and/or regulations will materially impact a security, business, sector or market. These changes can increase the costs of operating a business, reduce the attractiveness of an investment, or change the competitive landscape, and are made by either the government or a regulatory body. Call Risk is the risk that a bond may be “called” before its maturity date. Credit and Default Risk traditionally refers to the risk that a lender may not receive the owed principal and interest, which results in an interruption of cash flows and increased costs for collection. Credit risk is the probable risk of loss resulting from a borrower's failure to repay a loan or meet contractual obligations. While impossible to know exactly who will default on obligations, with proper assessment and credit risk management, the severity of loss can be lessened. A lender's or investor's reward for assuming credit risk include the interest payments from the borrower or issuer of a debt obligation. Currency investments, including related financial instruments with primary exposure to currencies, entail significant price fluctuation. Currency values change quickly and frequently based on numerous factors, including but not limited to interest rates, monetary policy, broader government actions, changes in national or local economic conditions, political events, economic news, liquidity concerns, ratings agency updates, and the movement of other currencies throughout the world. Currency trading also entails transaction risk (the possibility of exchange rates changing before a trades has settled) and, if engaging in trades on a lightly regulated exchange, significant counterparty risk. If employed, leverage will amplify these risks. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Selection of Other Advisers: Although CJCWM will seek to select only money managers who will invest clients' assets with the highest level of integrity, CJCWM’s selection process cannot ensure that money managers will perform as desired and CJCWM will have no control over the day-to-day operations of any of its selected money managers. CJCWM would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. In monitoring and analyzing the third-party advisers, CJCWM uses benchmarking analysis, assessing 10  whether the adviser’s performance has met, exceeded, or fallen short of comparable benchmarks (e.g., Russell 2000, S&P 500, etc.), together with comparison against any stated benchmarks the adviser has set for itself. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your 11  portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings 12  There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CJCWM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CJCWM nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Christopher John Campbell is the Founder and CEO of Ace 3 Holdings, LLC. Ace 3 Holdings, LLC is an owner of CJC Wealth Management, LLC. Insurance Agency Some investment advisor representatives of CJCWM are also independent licensed insurance agents for CJ Campbell and Associates. CJCWM and CJ Campbell and Associates are under common control and ownership. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of CJCWM are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. CJCWM addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. CJCWM periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. CJCWM will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices 13  and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by CJCWM’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CJCWM may direct clients to third-party investment advisers. Clients will pay CJCWM its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. CJCWM will always act in the best interests of the client, including when determining which third party investment adviser to recommend to clients. CJCWM will ensure that all recommended advisers are exempt, licensed or notice filed in the states in which CJCWM is recommending them to clients. This may cause a conflict of interest. The conflicts of interest that exists with the firm and its third-party investment advisers regarding the firm recommending a particular third-party investment adviser over another for whom the firm has more favorable compensation arrangements with. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CJCWM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. CJCWM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests CJCWM does not recommend that clients buy or sell any security on any proprietary products. in which a related person to CJCWM or CJCWM as there would be no material financial interest. C. Investing Personal Money in the Same Securities as Clients 14  From time to time, representatives of CJCWM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CJCWM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. CJCWM will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of CJCWM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CJCWM to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, CJCWM will never engage in trading that operates to the client’s disadvantage if representatives of CJCWM buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on CJCWM’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a client on terms that are the most favorable to the client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and CJCWM may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of CJCWM. CJCWM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. CJCWM will have an incentive to recommend a broker-dealer based on its interest in receiving the research or other products or services rather than on clients’ interest in receiving most favorable execution. CJCWM will require clients to use Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits 15  CJCWM has access to research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. CJCWM benefits by not having to produce or pay for the research, products or services, and CJCWM will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that CJCWM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. With respect to Schwab, CJCWM receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For CJCWM client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to CJCWM other products and services that benefit CJCWM but may not benefit its clients’ accounts. These benefits may include national, regional or CJCWM specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of CJCWM by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist CJCWM in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of CJCWM’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of CJCWM’s accounts. Schwab Advisor Services also makes available to CJCWM other services intended to help CJCWM manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, 16  insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to CJCWM by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to CJCWM. CJCWM is independently owned and operated and not affiliated with Schwab. 2. Brokerage for Client Referrals CJCWM receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use CJCWM will require clients to use specific broker-dealer(s) to execute transactions and it is CJCWM’s policy that all clients must utilize a broker-dealer approved by CJCWM. Not all advisers require their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If CJCWM buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, CJCWM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. CJCWM would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with CJCWM’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). When CJCWM does not or cannot aggregate trades, clients may receive less favorable prices, pay higher brokerage commissions, or experience less efficient trade execution. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for CJCWM's advisory services provided on an ongoing basis are reviewed at least quarterly by Christopher Campbell, CEO and Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at CJCWM are assigned to this reviewer. 17  All financial planning accounts are reviewed upon financial plan creation and plan delivery by the client’s assigned investment adviser representative. Thereafter, they are typically reviewed annually. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, CJCWM’s services will generally include an annual review and update of the plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of CJCWM's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. The firm will not provide its own separate report to clients. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) In addition to the soft dollar benefits described in Item 12 above, CJCWM may refer clients to unaffiliated attorneys for estate planning services. Any engagement is between the client and the attorney. CJCWM is not compensated for these referrals. Clients are free to use any attorney of their choosing and are not required to use any law firm recommended by CJCWM. B. Compensation to Non – Advisory Personnel for Client Referrals CJCWM does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, CJCWM will be deemed to have limited custody of client's assets and must have written authorization from 18  the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion CJCWM provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, CJCWM generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. In some instances, CJCWM’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to CJCWM). Item 17: Voting Client Securities (Proxy Voting) CJCWM will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of security. Item 18: Financial Information A. Balance Sheet CJCWM neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither CJCWM nor its management has any financial condition that is likely to reasonably impair CJCWM’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years CJCWM has not been the subject of a bankruptcy petition in the last ten years. 19