Colburn Wealth Management, LLC

Item 1: Cover Page F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 3989 Broadway Tel: Grove City, OH 43123 Email: (740) 831-4004 Website: Info@colburnwm.com www.colburnwm.com June 23, 2026 This brochure provides information about the qualifications and business practices of Colburn Wealth Management, LLC. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at (740) 831-4004. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by ADDITIONAL INFORMATION ABOUT COLBURN WEALTH MANAGEMENT, LLC (CRD any state securities authority. #157870) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV i  Item 2: Material Changes Annual Update Material Changes since the Last Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. • Since the last update of this brochure on March 24, 2026, the following has been updated: Full Brochure Available The firm is seeking SEC registration. This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page .................................................................................................................................. i Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Full Brochure Available .................................................................................................................................................. ii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 1 Wrap Fee Programs ......................................................................................................................................................... 1 Item 5: Fees and Compensation ....................................................................................................... 1 Client Assets Under Management .............................................................................................................................. 1 Method of Compensation and Fee Schedule .......................................................................................................... 1 Client Payment of Fees ................................................................................................................................................... 2 Additional Client Fees Charged ................................................................................................................................... 2 Prepayment of Client Fees ............................................................................................................................................ 2 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 3 External Compensation for the Sale of Securities to Clients ........................................................................... 2 Item 7: Types of Clients ....................................................................................................................... 3 Sharing of Capital Gains ................................................................................................................................................. 3 Description .......................................................................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 3 Account Minimums .......................................................................................................................................................... 3 Methods of Analysis ......................................................................................................................................................... 3 Investment Strategy ........................................................................................................................................................ 3 Item 9: Disciplinary Information ..................................................................................................... 6 Security Specific Material Risks .................................................................................................................................. 3 Criminal or Civil Actions ................................................................................................................................................ 6 iii Administrative Enforcement Proceedings ............................................................................................................. 6  Item 10: Other Financial Industry Activities and Affiliations ............................................... 6 Self- Regulatory Organization Enforcement Proceedings ............................................................................... 6 Broker-Dealer or Representative Registration .................................................................................................... 6 Futures or Commodity Registration ......................................................................................................................... 6 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 6 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 6 Trading ..................................................................................................................................................... 6 Code of Ethics Description ............................................................................................................................................ 6 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 7 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 7 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Item 12: Brokerage Practices ........................................................................................................... 8 Transactions and Conflicts of Interest ..................................................................................................................... 7 Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 8 Item 13: Review of Accounts ............................................................................................................. 9 Aggregating Securities Transactions for Client Accounts ................................................................................ 9 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ................................................................................................................................................................................ 9 Review of Client Accounts on Non-Periodic Basis .............................................................................................. 9 Item 14: Client Referrals and Other Compensation .................................................................. 9 Content of Client Provided Reports and Frequency ........................................................................................... 9 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest .................................................................................................................................................................................. 9 Item 15: Custody .................................................................................................................................... 9 Advisory Firm Payments for Client Referrals ....................................................................................................... 9 Item 16: Investment Discretion ..................................................................................................... 10 Account Statements ......................................................................................................................................................... 9 Item 17: Voting Client Securities ................................................................................................... 10 Discretionary Authority for Trading...................................................................................................................... 10 Item 18: Financial Information ...................................................................................................... 10 Proxy Votes ...................................................................................................................................................................... 10 Balance Sheet .................................................................................................................................................................. 10 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 10 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 10 v  Item 4: Advisory Business Firm Description was formed in March 2012. Previously the business operated as Colburn Investments, LLC which was in business since June 2011. Colburn Wealth Management, LLC (“CWM”) Dan Colburn is the principal owner and Ed Daniels is the Chief Compliance Officer Types of Advisory Services . ASSET MANAGEMENT CWM offers discretionary asset management services to advisory Clients. CWM will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize CWM discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Client Tailored Services and Client Imposed Restrictions As part of the recommendations provided, the Client may have a financial plan completed. This may include but is not limited to a thorough review of all applicable topics such as insurance assessments, retirement planning, estate planning, secondary education planning, or other general personal finance advice. Financial plans and financial planning may include, but are not limited to: investment planning, life insurance, tax concerns, retirement planning, college planning, and debt/credit planning.. If a conflict of interest exists between the interests of CWM and the interests of the Client, the Client is under no obligation to act upon CWM’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through CWM. This service will be provided at no additional cost to the Client. Wrap Fee Programs The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Client Assets Under Management CWM does not sponsor any wrap fee programs. CWM has the following Client assets under management: Discretionary Amounts: $116,170,000 Non-discretionary Amounts: $0 Date Calculated: June 22, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT CWM offers discretionary direct asset management services to advisory Clients. CWM charges an annual investment advisory fee based on the total assets under management as follows: - 1 -  Assets Under Management Quarterly Fee First $1,000,000 .25% .1875% Second $1,000,000 Annual Fee 1.00% ($2,500 Minimum) .75% .125% Next $3,000,000 .50% .0625% Over $5,000,000 .25% The fee structure is designed such that as the portfolio grows and passes into the next tier, those next tier dollars are billed at a lower rate. For example, on a $2,000,000 client account, the client would expect to pay an annual fee of .875% (the first $1,000,000 billed at 1%, the second $1,000,000 billed at .75% for an average of .875%). Fees are calculated based on the previous quarters’ average daily balance. These fees are negotiable depending upon the needs of the client and complexity of the situation. Fees are paid quarterly in arrears, and clients may terminate their contracts with thirty days’ written notice. Because fees are charged in arrears, no refund policy is necessary. Client Payment of Fees Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After the initial five (5) business days, the agreement may be terminated by CWM with thirty (30) days written notice to Client and by the Client at any time with written notice to CWM. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to CWM. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. • Fees for asset management services are: Additional Client Fees Charged Deducted from a designated Client account. The Client must consent in advance to direct debiting of their investment account. Prepayment of Client Fees Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. CWM does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to CWM. For more details on the brokerage practices, see Item 12 of this brochure. External Compensation for the Sale of Securities to Clients CWM does not require any prepayment of fees. CWM does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of CWM. - 2 -  Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. CWM does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for CWM to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description Account Minimums CWM generally provides investment advice to individuals and high net worth individuals. Client relationships vary in scope and length of service. CWM requires a minimum of $500,000 to open and maintain an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods used include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Investment Strategy 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. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to CWM. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases, short-term purchases and option writing (including covered options, uncovered options or spreading strategies). All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment • Market Risk risks and should discuss these risks with CWM: : The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors - 3 -  • should have a long-term perspective and be able to tolerate potentially sharp declines Interest-rate Risk in market value. • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less Inflation Risk attractive, causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as • Reinvestment Risk exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid- cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal Investment Companies Risk: interest rate is the sum of a real interest rate and an expected inflation rate. When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net - 4 -  • Cash and Cash Equivalents Risk: asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Long-term purchases Cash and cash equivalents consist of investments like money market funds, certificates of deposit (CDs), Treasury bills, and short-term government bonds. They are generally considered low-risk compared to other asset classes. While they offer safety, liquidity, and stability, they come with certain risks, such as inflation, interest rate fluctuations, and opportunity costs. • Short-term purchases : Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with • Trading risk inflation. : Investing involves risk, including possible loss of principal. There is no • Options Trading assurance that the investment objective of any fund or investment will be achieved. • Trading on Margin: : The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. Clients should be aware that the use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. In such case, the security may be called away and the account will no longer hold the security. When purchasing options there is the risk that the entire premium paid for the option can be lost if the option is not exercised or otherwise sold prior to the option’s expiration date. When selling (“writing”) options, the risk of loss can be much greater if the options are written uncovered (“naked”). The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. In a cash account, the risk is limited to the amount of money that has been invested. In a margin account, risk includes the amount of money invested plus the amount that has been loaned. As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin account depreciates, the client will be required to deposit additional cash or make full payment of the margin loan to bring account back up to maintenance levels. Clients who cannot comply with such a margin call may be sold out or bought in by the brokerage firm. - 5 -  Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings CWM and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings CWM and its management have not been involved in administrative enforcement proceedings. CWM and its management have not been involved in any self-regulatory organizational enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of CWM or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Futures or Commodity Registration CWM is not registered as a broker-dealer and no affiliated representatives of CWM are registered representatives of a broker-dealer. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither CWM nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Neither CWM nor its representatives have any material relationships to this advisory Recommendations or Selections of Other Investment Advisors and Conflicts of Interest business that would present a possible conflict of interest. CWM does not select or recommend other investment advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of CWM have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of CWM affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of CWM. The Code reflects CWM and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. CWM’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other affiliated person, officer or director of CWM may recommend any transaction in a security or its derivative to advisory Clients - 6 -  or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. CWM’s Code is based on the guiding principle that the interests of the Client are our top priority. CWM’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. CWM will provide a copy of the Code of Ethics to any Client or prospective Client upon Investment Recommendations Involving a Material Financial Interest and Conflict of request. Interest CWM and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest CWM and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide CWM with copies of their brokerage statements. The Chief Compliance Officer of CWM is Ed Daniels. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest CWM does not have a material financial interest in any securities being recommended. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide CWM with copies of their brokerage statements. The Chief Compliance Officer of CWM is Ed Daniels. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. - 7 -  Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions CWM will require the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. CWM will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees, reporting ability, execution capability (speed and accuracy), financial stability and reputation, access to markets, technology and reporting platforms, quality of client service and availability of investment research and other brokerage services. CWM relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by CWM. CWM does not receive any portion of the trading fees. • Research and Other Soft Dollar Benefits CWM will require the use of Charles Schwab & Co., Inc. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by CWM from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although CWM has no formal soft dollar arrangements, CWM may receive products, research and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, CWM receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of CWM. CWM cannot ensure that a particular client will benefit from soft dollars or the client’s transactions paid for the soft dollar benefits. CWM does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. • Brokerage for Client Referrals A conflict of interest exists when CWM receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that CWM has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Directed Brokerage CWM does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. CWM does not allow directed brokerage accounts. Not all advisors require their clients to direct brokerage. - 8 -  Aggregating Securities Transactions for Client Accounts CWM maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing CWM the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Review of Client Accounts on Non-Periodic Basis Client accounts are reviewed at least quarterly by one or more Investment Adviser Representatives. Account reviews may be conducted more frequently when market conditions or other circumstances warrant. As part of the quarterly review process, accounts are evaluated to ensure that portfolio allocations remain aligned with the investment strategy selected by the Client and are rebalanced, as necessary, in accordance with the terms of the Client's Investment Advisory Agreement. Reviews may also include monitoring for tax-loss harvesting opportunities and other portfolio management considerations. All client accounts are assigned to an Investment Adviser Representative for ongoing oversight. Content of Client Provided Reports and Frequency Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by CWM’s custodian. Client receives confirmations of each transaction in account from custodian and an additional statement during any month in which a transaction occurs. CWM does not provide additional reports to Clients. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals CWM receives additional economic benefits from external sources as described above in Item 12. CWM does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which provide account statements directly to Clients at least quarterly, Statements are delivered either to the Client's address of record or electronically, based on the delivery preferences established with the custodian. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by CWM. - 9 -  CWM is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of CWM. Item 16: Investment Discretion Discretionary Authority for Trading CWM requires discretionary authority to manage securities accounts on behalf of Clients. CWM has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize CWM discretionary authority as stated within the Investment Advisory Agreement. CWM allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. These restrictions must be provided to CWM in writing. The Client approves the custodian to be used. CWM does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes CWM does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, CWM will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because CWM does not serve as a custodian for Client funds or securities and CWM does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Bankruptcy Petitions during the Past Ten Years CWM has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. CWM has not had any bankruptcy petitions in the last ten years. - 10 -