CRAVENS BROTHERS PRIVATE WEALTH MANAGEMENT LLC

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 Cravens Brothers Private Wealth Management LLC Office Address: 1801 N. Lamar St., Suite 550 Dallas, TX 75202 Tel: 214-234-9503 JCravens@CravensBrothers.com Website: www.CravensBrothers.com A P R I L 8 , 2 0 2 6 This brochure provides information about the qualifications and business practices of Cravens Brothers Private Wealth Management LLC. Being registered as a registered 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 214-234-9503. 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 Cravens Brothers Private Wealth Management LLC (CRD #162673) is available on the SEC’s website at www.adviserinfo.sec.gov i  Item 2: Material Changes Annual 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. Material Changes since the Last Update Since the last filing on March 6, 2026, the following has been amended: • The document has been updated throughout for the switch from state to SEC registration. Full Brochure Available 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 Item 2: Material Changes .................................................................................................................... ii Annual Update ........................................................................................................................................ ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii 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 Client Assets Under Management .............................................................................................................................. 1 Item 5: Fees and Compensation ....................................................................................................... 2 Method of Compensation and Fee Schedule .......................................................................................................... 2 Client Payment of Fees ................................................................................................................................................... 3 Additional Client Fees Charged ................................................................................................................................... 3 Prepayment of Client Fees ............................................................................................................................................ 3 External Compensation for the Sale of Securities to Clients ........................................................................... 3 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4 Sharing of Capital Gains ................................................................................................................................................. 4 Item 7: Types of Clients ....................................................................................................................... 4 Description .......................................................................................................................................................................... 4 Account Minimums .......................................................................................................................................................... 4 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 4 Methods of Analysis ......................................................................................................................................................... 4 Investment Strategy ........................................................................................................................................................ 5 Security Specific Material Risks .................................................................................................................................. 5 Item 9: Disciplinary Information ..................................................................................................... 7 Criminal or Civil Actions ................................................................................................................................................ 7 iii  Administrative Enforcement Proceedings ............................................................................................................. 7 Self-Regulatory Organization Enforcement Proceedings ................................................................................ 8 Item 10: Other Financial Industry Activities and Affiliations ............................................... 8 Broker-Dealer or Representative Registration .................................................................................................... 8 Futures or Commodity Registration ......................................................................................................................... 8 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 8 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................................................................................................... 8 Code of Ethics Description ............................................................................................................................................ 8 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 9 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 9 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ..................................................................................................................... 9 Item 12: Brokerage Practices ........................................................................................................... 9 Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 9 Aggregating Securities Transactions for Client Accounts ............................................................................. 10 Item 13: Review of Accounts ........................................................................................................... 10 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 10 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11 Content of Client Provided Reports and Frequency ........................................................................................ 11 Item 14: Client Referrals and Other Compensation ................................................................ 11 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 11 Advisory Firm Payments for Client Referrals .................................................................................................... 11 Item 15: Custody .................................................................................................................................. 11 Account Statements ...................................................................................................................................................... 11 Item 16: Investment Discretion ..................................................................................................... 11 Discretionary Authority for Trading...................................................................................................................... 11 Item 17: Voting Client Securities ................................................................................................... 12 Proxy Votes ...................................................................................................................................................................... 12 Item 18: Financial Information ...................................................................................................... 12 Balance Sheet .................................................................................................................................................................. 12 iv  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 12 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 12 v  Item 4: Advisory Business Firm Description Cravens Brothers Private Wealth Management LLC (“Cravens”) was founded in 2012. John Cravens is 100% owner. Types of Advisory Services ASSET MANAGEMENT Cravens offers non-discretionary asset management services to advisory Clients. Cravens 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 Cravens discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Non-discretionary When the Client elects to use Cravens on a non-discretionary basis, Cravens will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, Cravens will obtain prior Client approval on each and every transaction before executing any transaction. FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics including but not limited to, Wills, Estate Plans and Trusts, Investments, Taxes, Qualified Plans, Insurance, Retirement Income, Social Security, and College Planning will be reviewed. If a conflict of interest exists between the interests of Cravens and the interests of the Client, the Client is under no obligation to act upon Cravens’ recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Cravens. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Cravens does not sponsor any wrap fee programs. Client Assets Under Management Cravens has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $0 $139,300,000 Date Calculated: December 31, 2025 - 1 -  Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT Cravens offers non-discretionary direct asset management services to advisory Clients. Cravens charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management First $5,000,000 Next $10,000,000 Next $35,000,000 Above $50,000,000 Equity/Balanced 0.90% 0.75% 0.50% 0.40% Fixed Income Only 0.50% 0.40% 0.30% 0.25% This is a blended fee schedule; the asset management fee is calculated by applying different rates to different portions of the portfolio. Cravens may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example, a Client with $10,000,000 under management would pay $82,500 on an annual basis. First $5,000,000 x .0090 = $45,000 Next $5,000,000 x .0075 = $37,500 The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed monthly in arrears based on the average daily balance of the account for the billing period. 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. Clients may terminate advisory services with thirty (30) days written notice. For accounts opened or closed mid- billing period, any unpaid earned fees will be due to Cravens. 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. FINANCIAL PLANNING AND CONSULTING Cravens charges either an hourly, fixed, or ongoing fee for financial planning. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Cravens. Cravens reserves the right to waive the fee should the Client implement the plan through Cravens. Fees for fixed and hourly financial plans are billed upon delivery of the completed plan. Fees for ongoing planning services are billed monthly and in arrears. - 2 -  HOURLY FEES Hourly Financial Planning Services are offered based on an hourly fee of $300 per hour. FIXED FEES Fixed Fee Financial Planning Services are offered based on a flat fee between $1,000 and $20,000. ONGOING SERVICES Ongoing Financial Planning Services are offered on an ongoing basis and will remain in effect year over year unless cancelled in writing by either party by giving the other party thirty (30) days written notice. The fee for this service will be based on fixed annual rate between $1,000 and $20,000 or on the Client’s Net Asset Level as follows: Asset Level First $10,000,000 Next $15,000,000 Over $25,000,000 Fee 0.45% 0.35% 0.20% Client Payment of Fees Investment management fees are billed monthly in arrears Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for fixed and hourly financial plans are billed upon delivery of the completed plan. Fees for ongoing planning services are billed monthly and in arrears. Cravens, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Cravens does not require any prepayment of fees. External Compensation for the Sale of Securities to Clients Cravens does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of Cravens. - 3 -  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. Cravens does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for Cravens to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description Cravens generally provides investment advice to individuals, high net worth individuals, charitable organizations and business organizations. Client relationships vary in scope and length of service. Account Minimums Cravens does not require a minimum to open an account. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis, technical analysis, and Monte Carlo analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Carlo methods are used in finance to value and Monte analyze (complex) instruments, portfolios and investments by simulating the various sources of uncertainty affecting their value, and then determining their average value over the range of resultant outcomes. This is usually done by help of stochastic asset models. The advantage of Monte Carlo methods over other techniques increases as the dimensions (sources of uncertainty) of the problem increase. The Monte Carlo method encompasses any technique of statistical sampling employed to approximate solutions to quantitative problems. Essentially, the Monte Carlo method solves a problem by directly simulating the underlying (physical) process and then calculating the (average) result of the process. - 4 -  In finance, the Monte Carlo method is used to simulate the various sources of uncertainty that affect the value of the instrument, portfolio or investment in question, and to then calculate a representative value given these possible values of the underlying inputs. ("Covering all conceivable real-world contingencies in proportion to their likelihood.") In terms of financial theory, this, essentially, is an application of risk neutral valuation. When creating a financial plan, the Monte Carlo planning technique is used to calculate the percentage probability of specific scenarios that are based upon a set group of assumptions and standard deviations. This method of calculation has often been used in investment and retirement planning to project the likelihood of achieving one's financial or retirement goals and whether or not a retiree will have enough income to live on for life, given a wide range of possible outcomes in the markets. While there are no absolute parameters for this type of projection, the underlying assumptions for these calculations typically include such factors as interest rates, the client's age and projected time to retirement, the amount of the investment portfolio that is spent or withdrawn each year and the portfolio allocation. In developing a financial plan for a Client, Cravens’ analysis may include cash flow analysis, investment planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the Client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). Security Specific Material Risks 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 risks and should discuss these risks with Cravens: • Market Risk: The prices of securities held by mutual funds 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 should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. - 5 -  • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Equity 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. lower trading volume, which may Smaller companies may also have a disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: 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 interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: 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 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 - 6 -  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: Long-term investments are those vehicles purchased with the intension 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 purchases: 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 inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Options Trading: The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. • Trading on Margin: 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. Item 9: Disciplinary Information Criminal or Civil Actions Cravens and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Cravens and its management have not been involved in administrative enforcement proceedings. - 7 -  Self-Regulatory Organization Enforcement Proceedings Cravens and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Cravens or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Cravens is not registered as a broker- dealer and no affiliated representatives of the firm are registered representatives of a broker-dealer. Futures or Commodity Registration Neither Cravens 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. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Cravens does not have any material relationships to disclose. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Cravens 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 Cravens have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Cravens affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of Cravens. The Code reflects Cravens 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. Cravens’ policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Cravens may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Cravens’ Code is based on the guiding principle that the interests of the Client are our top priority. Cravens’ 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 - 8 -  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. Cravens will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Cravens 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 Cravens 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 Cravens with copies of their brokerage statements. The Chief Compliance Officer of Cravens is John Cravens. 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 Cravens does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. 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 Cravens with copies of their brokerage statements. The Chief Compliance Officer of Cravens is John Cravens. He reviews all employee trades 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. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions Cravens may recommend the use of a particular broker-dealer. Cravens will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. Cravens relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may - 9 -  be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by Cravens. • Directed Brokerage Cravens does not allow directed brokerage accounts. • Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. 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. The firm does not receive any portion of the trading fees. • Soft Dollar Arrangements The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by Cravens from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, Cravens receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of Cravens. These benefits include both proprietary research from the broker and other research written by third parties. A conflict of interest exists when Cravens receives soft dollars. This conflict is mitigated by the fact that Cravens has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. Cravens utilizes the services of custodial broker dealers. Economic benefits are received by Cravens which would not be received if Cravens did not give investment advice to Clients. These benefits include: A dedicated trading desk, a dedicated service group and an account services manager dedicated to Cravens’ accounts, ability to conduct "block" Client trades, electronic download of trades, balances and positions, duplicate and batched Client statements, and the ability to have advisory fees directly deducted from Client accounts. Aggregating Securities Transactions for Client Accounts Cravens is not authorized to aggregate purchases and sales and other transactions. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed quarterly by the Chief Compliance Officer of Cravens. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk - 10 -  tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bans of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, Cravens suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by Cravens’ custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Cravens receives additional economic benefits from external sources as described above in Item 12. Advisory Firm Payments for Client Referrals Cravens does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians. Cravens is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Cravens. Item 16: Investment Discretion Discretionary Authority for Trading Cravens accepts non-discretionary authority to manage securities accounts on behalf of Clients. Cravens will obtain prior Client approval before executing each transaction. The Client approves the custodian to be used and the commission rates paid to the custodian. Cravens does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. - 11 -  Item 17: Voting Client Securities Proxy Votes Cravens 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, Cravens will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Cravens does not serve as a custodian for Client funds or securities and Cravens 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 Cravens has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years Cravens has not had any bankruptcy petitions in the last ten years. - 12 -