J. W. COLE ADVISORS, INC.

FORM ADV PART 2A DISCLOSURE BROCHURE COVER PAGE March 2026 J.W. Cole Advisors, Inc. 4301 Anchor Plaza Parkway Suite #450 Tampa, FL 33634 www.jw-cole.com 1  This brochure provides information about the qualifications and business practices of Jonathan Roberts Advisory Group, Inc. d/b/a J.W. Cole Advisors, Inc., (Jonathan Roberts Advisory Group, Inc. and J.W. Cole Advisors, Inc. are hereinafter collectively referred to as “JWCA“ or the “Firm”). If you have any questions about the contents of this brochure, please contact us at (866) 592‐6531. 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. The use of the term “Registered” throughout this brochure indicates a licensing qualification. The term is not intended to imply a certain level of skill. Additional information about JWCA is also available on the SEC’s website at www.adviserinfo.sec.gov. SEC File No: 801‐60722 CRD No: 112294 Item 2: Material Changes There have been no material changes since the previous filing. 2  Contents COVER PAGE ................................................................................................................................................. 1 Item 2: Material Changes ............................................................................................................................. 2 Item 4: Description of Our Advisory Business ............................................................................................. 4 Item 5: Fees and Compensation ................................................................................................................ 12 Item 6: Performance-Based Fees and Side-by-Side Management ........................................................... 19 Item 7: Types of Clients .............................................................................................................................. 19 Item 8: Methods of Analysis, Investment Strategies and Risk Loss ......................................................... 20 Item 9: Disciplinary Information ................................................................................................................ 23 Item 10: Other Financial Industry Activities and Affiliations .................................................................... 23 Item 11: Code of Ethics .............................................................................................................................. 24 Item 12: Brokerage Services ...................................................................................................................... 25 Item 13: Review of Accounts ..................................................................................................................... 30 Item 14: Client Referrals and Other Compensation .................................................................................. 31 Item 15: Custody ........................................................................................................................................ 32 Item 16: Investment Discretion ................................................................................................................. 32 Item 17: Voting Client Securities ............................................................................................................... 33 Item 18: Financial Information .................................................................................................................. 33 3  Item 4: Description of Our Advisory Business JWCA is a Florida corporation that has been registered with the SEC as an investment adviser since November 9, 2000. Our headquarters are in Tampa, Florida. JWCA is wholly owned by JWC Wealth Partners, Inc. (“JWC Wealth Partners"). JWC Wealth Partners is owned 50% by Wood Family Holdings, LLC and 50% by Towle Family Holdings, LLC. Those two entities are the sole shareholders of JWC Wealth Partners. JWCA has an expense sharing agreement with J.W. Cole Financial, Inc. ("JWCF"), a registered broker‐dealer Member Financial Industry Regulatory Association (“FINRA”)/Securities Investors Protection Corporation (“SIPC”), for access to staff, office space, supplies, etc. As part of the expense sharing agreement, JWCA pays JWCF for such services. Both JWCA and JWCF are wholly owned by JWC Wealth Partners and, as such, are affiliated companies. Mr. Wood is JWCF’s CEO. However, JWCA and JWCF are separate business entities with different management structures. JWCA conducts its investment advisory business through a network of over 400 independent Investment Adviser Representatives (“IAR’s”). IARs operate in offices located throughout the United States. IARs may operate under their own business names or DBA names, and their business names and logos may appear on their sales and marketing materials. Sales and marketing materials used by IARs are reviewed and approved by JWCA. The business names and DBA name(s) used by IARs are separate from and not owned and/or controlled by JWCF or JWCA. IARs may also offer and provide other services through their business name(s), however, with limited exceptions, investment advisory services offered by IARs must be provided through JWCA. Information about the IAR’s other businesses can be found in each IARs’ Form ADV Part 2B Brochure Supplement. A majority of JWCA’s IARs are also dually registered as registered representatives to solicit, offer, and sell securities through JWCF. IARs may also be licensed as independent insurance agents through various insurance companies to solicit, offer, and sell fixed and/or property and casualty insurance products in the states in which they conduct business. Therefore, IARs can potentially be acting in multiple capacities with Clients by providing advisory services as IARs; soliciting, offering, and selling securities, as registered representatives; and/or offering and selling insurance products as independent licensed insurance agents. Accordingly, IARs have conflicts of interest when they solicit, offer, and sell securities and insurance products while also providing investment advisory services to Clients. For instance, an IAR may sell securities through JWCF and receive commissions, sell insurance products through an insurance carrier and receive additional compensation, and also provide investment advisory services and charge a separate JWCA Advisor Fee, all to the same Client. As such, these IARs have a conflict of interest when they recommend advisory Clients to purchase products for which the IAR also receives compensation, in addition to his/her Advisory Fee. Our IARs manage assets on either a discretionary or non‐discretionary basis. As of December 31, 2025, JWCA manages $6,740,299,532 in Client assets on a discretionary basis, and $1,507,617,359 on a non‐discretionary basis. The Types of Advisory Services We Offer JWCA and its IARs may solicit, offer, sell and charge for fee‐based investment management services, fee‐ based financial planning, the use of Third‐Party Advisers, or other third‐party advisory services, and/or for managing Clients' accounts as further detailed below. For each of these services, JWCA receives a fee (“Advisor Fee”). IARs, when also acting as RRs of JWCF, may also solicit, offer, and sell securities, including but not limited to individual stocks and bonds, mutual funds, closed end funds, Exchange Traded Funds ("ETFs"), as well as non‐traded alternative products, including but not limited to Real Estate Investment Trusts ("REITs") and private placements, Hedge Funds and Private Equities. IARs that are licensed as insurance agents may also solicit, offer, and sell fixed and/or property and casualty insurance products, 4  and receive compensation for doing so. Usually, the Client will be charged a commission when purchasing securities or variable insurance products through JWCF. IARs of JWCA may also offer fixed insurance through insurance companies unaffiliated with JWCA, therefore neither JWCA nor JWCF supervises the solicitation or sale of these products. In sum, an IAR may receive an Advisor Fee and a commission from the same Client. investment trusts, mutual funds or other pooled Our advisory services consist of advice regarding various types of public and private securities. These include, but are not limited to equities, corporate debt, government obligations, municipal securities, exchange‐traded funds, unit investments, options/derivatives, alternative investments, interests in real estate or oil and gas partnerships, annuities/insurance products, and other investment instruments. In certain arrangements, you have the ability to impose restrictions on a particular security or asset category. Please understand that JWCA does not guarantee or promise that your financial goals and objectives will be met. It is your obligation to review any analysis and advice, and provide updates whenever your financial situation, goals, objectives, or needs change, so your IAR can adjust his/her advice and/or your plan accordingly. A.) JWCA Managed Programs Transaction‐Based v. WRAP advisory accounts In a transaction‐based advisor account, you will pay an ongoing, asset‐based Advisor Fee based on a percentage of the market value of billable assets being managed, and transaction costs for each transaction. Most accounts also incur a program fee imposed by the custodian and/or JWCA (“Program Fee”). Your JWCA IAR may or may not pay for transaction costs. If the IAR does not pay for such costs, you will incur costs each time you purchase or sale a security. This will increase the costs associated with such Account, as compared to a Wrap Account (see below). However, if your IAR elects to pay transaction charges, while you will not pay such costs, your IAR is incented to either not recommend transactions, in order to avoid having to pay such transaction costs, or may recommend investments which have lower transaction costs, but which may be more expensive to you. In a Wrap account, while you will pay a Program Fee, similar to a transaction‐based Advisory Account, the asset‐based Program Fee includes certain transaction costs not covered under a transaction‐based Advisory Account described above. However, the Program Fee for JWCA’s Asset‐Based offerings is higher than the Program Fee for the Transaction‐Based Advisory Programs. Thus, if you are a Client that intends to engage in, and receive advice on multiple securities transactions, a Wrap Account may be more beneficial. However, if you intend to engage in fewer transactions, but still desire ongoing investment advice, a Transaction‐Based Advisory Account may be more appropriate for you given the lower Program Fee. Understand that in a Wrap Account, JWCA and the JWCA IAR have a conflict of interest in that they are incented to not recommend transactions since JWCA pays for the costs of such transactions which thereby reduces the profitability of the Wrap Account to them. We offer three types of managed programs: Transaction-Based Advisory Account Programs – These are fee‐based investment 1. Advisory Accounts, in which your IAR will directly manage your investment account based on your financial profile and investment objectives. You will pay an ongoing, advisor fee based on the market value of billable assets being managed at an account‐level (“Advisor Fee”), and nominal transaction costs for each transaction. In addition to the Advisor Fee charged by JWCA, most accounts also incur the Program Fee imposed by the custodian and/or JWCA1. A custodian is the 5  entity that actually holds your securities and other investments on behalf of JWCA. The Advisor Fee and Program Fee are payable quarterly, in advance/arrears as identified in your Assets Under Management (AUM) Agreement. The initial Advisor Fee is due upon execution of the AUM Agreement. For accounts with advance billing, the initial Advisor Fee is based upon the value of the assets deposited into the account (including cash and cash equivalents) and is pro‐rated for the number of days remaining in the calendar quarter. For accounts with arrears billing, the initial Advisor Fee is based upon the billable value while the Program fee is based on the total account value on the last business day of the preceding calendar quarter and is prorated for the number of days invested in the prior quarter. Subsequently, whether the Advisor Fee and Program Fee are payable in advance/arrears, the Advisor Fees will be billed based upon the billable value of the Account on the last business day of the preceding calendar quarter while the Program Fee is based on the total account value. You will pay an Advisor Fee and a Program Fee regardless of whether there are any transactions in your Account. Total account and billable value of the Account is determined by Black Diamond Wealth Platform, a product of SS&C Advent, after reconciliation of data provided by the custodian. Certain assets may be excluded from the Advisor Fee by the Client. These are called “excluded assets” which are not considered part of the advisory relationship with JWCA and are not considered billable assets for determining an Advisor Fee. As such, neither JWCA nor your IAR will provide any investment advice on excluded assets. Please note that unlike the Advisor Fee, the Program Fee is billed based on the total account value, inclusive of both billable and excluded assets, and thus may differ from the billable value when the Program Fee is billed simultaneously with the Advisor Fee. Your IAR will deliver regular investment advice and monitoring of your security holdings. You have the option to allow your IAR to manage your assets on a non‐discretionary basis, wherein you must contemporaneously approve each transaction recommended by your IAR before it is executed, or you may authorize, in writing, that your Account be managed on a discretionary basis, if certain qualifications are met (certain minimum fees apply). In a discretionary account, your IAR makes investment decisions on your behalf, without your contemporaneous approval. In no case, however, can your IAR withdraw funds or securities without your approval (Please see Item 16 for further details). Please note that in addition to the Advisor Fee, you will pay other certain fees, such as service charges. Asset-Based Advisory Account Program – This is a legacy program, and new accounts are 2. not being opened. The program was designed as a “wrap” fee investment Advisory Account, in which an IAR managed your investment account based on your financial profile and investment objectives. In exchange, you paid an ongoing Advisor Fee. The Advisor Fee and Program Fee are payable quarterly, in advance. The initial Advisor Fee and Program Fee were due upon execution of the AUM Agreement and are pro‐rated for the number of days remaining in the calendar quarter. Subsequently, the Advisor Fee was billed based upon the billable value of the Account on the last business day of the preceding calendar quarter. The billable value of the Account is determined by Black Diamond after reconciliation of data provided by the custodian. Excluded assets are not included in the Advisor Fee. The Program Fee is billed based on the total account value, inclusive of both billable and excluded assets, and thus may differ from the billable value. See below for additional details relating to Advisor Fees and Program Fees. 6  Your IAR will deliver ongoing investment advice and monitoring of your security holdings. You have the option to allow your IAR to manage your assets on a non‐discretionary basis, or they may be managed on a discretionary basis, if certain qualifications are met and upon your written authorization. Note, there is no cost for the initial 50 trades placed in your Account during a rolling 12 month period, however in the event trading activity exceeds that number during the 12‐month period (each 12‐month period begins at your Anniversary date), you will be charged a transaction cost for each trade after the 50 trades. For further information please refer to the JWCA Form ADV Part 2A Appendix Wrap Fee Program Brochure. FMAX – The Fidelity Managed Account Xchange – is an advisory platform that allows your 3. IAR the option to manage your Account or provide advisory solutions by using a third‐party service. Depending on the particular FMAX solution selected, the day‐to‐day management of the Advisory Account may be performed by the IAR, a third‐party manager, or a combination of the two. This is a tri‐party investment advisory platform sponsored by Fidelity Institutional Wealth Advisers, LLC (“FIWA” or “program sponsor”) and a clearing custodial firm, National Financial, LLC (NFS) or Institutional Wealth Services (a Fidelity entity). As stated previously, a custodian is the entity that actually holds your securities and other investments on behalf of JWCA. The FMAX program is a wrap program and consists of an extensive range of investment advisory services, including Separately Managed Accounts, Wrap Strategist Solution of Mutual Funds and ETFs, Unified Managed Accounts, Multi‐Manager Accounts and an IAR‐Managed Model Program. Clients who select the FMAX program will also receive from FIWA a Form ADV Part 2A, which provides greater detail regarding the program sponsor. Each of these programs has a distinct minimum Account Fee and other fees and charges such as platform, custody and clearing and are outlined in the Statement of Investment Selection (SIS) that will be provided to you by your IAR prior to investing. In certain instances, additional costs may be incurred such as an asset‐based surcharge for mutual funds that are deemed by the Custodian to be nonrevenue paying to the Custodian, commonly referred to as non‐Sub‐Transfer Agency Fees (Sub‐TA) paying funds. Please note that the cut‐off time for entering transactions to be executed on a particular trading day is 1:00 p.m. Eastern time. Transactions entered after 1:00 p.m. Eastern will likely be executed the next trading day. Your IAR can discuss the features of each program with you so that you may determine your preferred cost option that best suits your investment style. Unlike the legacy JWCA wrap programs mentioned above, there is no limit to the amount of transactions. As such, there are no transaction costs in an FMAX Account. Remember, if you are a Client that intends to receive advice on multiple securities transactions, a Wrap Strategist Solution may be beneficial. However, if you intend to engage in fewer transactions, but still desire ongoing investment advice, a Transaction‐Based Solution may be more appropriate for you. Understand that in a Wrap Account, JWCA and the JWCA IAR have a conflict of interest in that they are incented to not recommend transactions since the costs of such transactions reduce the profitability of the Wrap Account to them. B.) Third-Party Investment Advisers In addition, we offer advisory services through Third‐Party Investment Advisers (TPIAs) (also known as, “third‐party asset managers,” or “unaffiliated investment advisers”) who are responsible for managing your assets on a day‐to‐day basis. These TPIA programs offer Clients access to a variety of portfolio managers who create model portfolios with varying levels of risk from which you may choose. A TPIA generally provides a range of services to IARs and Clients to help them meet portfolio management needs; including building various investment strategies, providing access to various asset managers and 7  custodians, providing due diligence and research, portfolio construction, proposal generation, account rebalancing, account monitoring, performance reporting, account support, and other tools designed to manage and invest your assets. When working with a TPIA, JWCA acts as either a “Promoter” (formerly known as “Solicitor”) or as a “Co‐ Advisor” when making these programs available to Clients. When JWCA acts as a compensated Promoter for the TPIA Program sponsor, JWCA and your IAR will help you determine your risk tolerance, investment goals and other relevant guidelines to assist you in choosing an appropriate TPIA Program. When JWCA and your IAR act as a Co‐Advisor we will again help you determine your risk tolerance, investment goals and other relevant guidelines to help you choose a suitable TPIA Program, strategy and manager, and also help you determine whether such remain appropriate. Regardless of whether JWCA acts in a Promoter or Co‐Advisor capacity, neither JWCA nor your IAR provides direct, day‐to‐day, investment management or advice about the securities in your TPIA Account. While your IAR helps you select the appropriate TPIA program and particular investment strategy offered by the TPIA, the TPIA is responsible for the day‐to‐day advice and execution of transactions in your Account. We maintain an approved list of TPIAs which are available for your IAR to recommend. Your IAR periodically monitors changes to your financial profile and the TPIA you selected, and depending in which capacity your IAR is acting (Promoter or Co‐Advisor) may provide advice for you to adjust the strategy or the TPIA, if necessary. Either the TPIA or JWCA will debit your Advisor Fee as outlined in the TPIA’s document(s). A portion of this Advisor Fee will be retained by the TPIA; a portion will cover the transaction costs, and a portion will go to your IAR and JWCA. Depending on your particular TPIA relationship, the JWCA IAR, when acting as Co‐Advisor may have discretion to switch Strategies and/or managers within the particular TPIA, without your contemporaneous approval. However, any such discretion must be consistent with your financial profile and investment objectives. Please note, such co‐advisory relationships do not give JWCA or the JWCA IAR discretion over the management of your assets on a day‐to‐day basis; such authority remains with the TPIA. Further, the discretionary authority does not give JWCA or your IAR the authority to withdraw funds from your account or move the assets in your Account to another TPIA. However, by granting discretion to JWCA and your IAR you are specifically consenting and agreeing that all your account information with the TPIA may be shared with investment managers who will likely be different than the account managers initially utilized when you opened the TPIA. Remember, the TPIA manages your Advisory account on a day‐to‐day basis. Certain TPIAs and investment strategies offered by our firm may be available directly through multiple platforms. Although the underlying strategy may be similar, the fees, costs, service models, trading practices, and operational features associated with each TPIA can differ. As a result, the total cost you pay for a particular strategy—including platform fees, manager fees, and account‐level expenses—may vary depending on which platform and TPIA strategy selected. Different TPIAs may also provide different tools, technology, reporting, custodial relationships, or service features that could impact your overall experience. Therefore, you should not assume that the fees or services associated with a given strategy are identical across all TPIA platforms. Before selecting a TPIA, you should speak with your IAR to review the available options and understand the differences in costs, features, and potential benefits. Your IAR will assist you in determining which TPIA platform is most appropriate for your investment objectives, financial situation, and service preferences. 8  C.) Digital Advice JWCA has entered into various selling agreements with digital advice providers to provide Clients the opportunity to receive advice regarding financial goal setting and investment planning tools through a web‐based portal that covers particular financial topics, including a combination of interaction with an IAR and access to written materials. Neither JWCA nor your IAR will have discretion of the assets managed by a digital advice provider. Through the use of algorithms, providers advise Clients and manage their accounts on a discretionary basis, even though JWCA and its IARs do not have discretion. These algorithms are developed, overseen, and monitored by personnel of the provider. When a retail Client or Retirement Plan Participant creates an account, and identifies their investment objective, time horizon, and investment risk tolerance data, an algorithm, developed by the providers personnel, then determines which investment allocation is appropriate based on these inputs from the Client or their financial professional (“Client Survey Process”). Please note, the Client Survey Process does not always accurately capture a Client’s actual financial situation or goals; accordingly, this could result in advice to invest in securities that are not aligned with the Client’s objectives. To help reduce this risk, the financial professional may attempt to determine whether the suggested investment allocation determined by the digital advice provider’s algorithm is appropriate. Algorithms from some digital advice providers also generate advice regarding other investment decisions, including but not limited to allocation, savings and withdrawal rates, automatic rebalancing, and account type selection. When Clients make deposits or withdrawals, elect to change portfolio strategies, or add shares, the digital advice provider will utilize its algorithm to determine how to allocate or liquidate positions within the portfolio. These allocations may result in tax consequences including, but not limited to, short‐term capital gains, long‐term capital gains, wash rules, etc. Rebalancing to achieve the stated target asset allocation may not include consideration of such tax consequences. Certain conflicts of interest may exist with the digital advice provider of such service, and Clients should carefully review all materials provided by the provider. While Clients directly own all the securities in the portfolio, Clients should be aware that they cannot generally create restrictions by designating particular securities or types of securities that should not be purchased or that should be sold if held in the Account. Certain providers may make an accommodation for such requests. The process for making such requests varies based on the platform provider and is not determined, nor controlled by JWCA or your IAR. Each digital advice provider has their own disclosure forms that provide additional information regarding their various costs for services and outline specifics relating to their investment management process, e.g., algorithms. Investors should review these disclosures closely in addition to what is provided here. In addition to the cost assessed by the digital advice provider, Clients typically pay a separate fee to their JWCA IAR in the form of an Advisor Fee. The amount of the Advisor Fee is negotiated between the IAR and the Client. D.) Financial Planning and Consulting JWCA also offers financial planning and consulting services regarding securities and non‐securities topics, for which we charge either an hourly rate or a flat fee. In addition, you may elect to engage in an ongoing financial planning arrangement for which you will pay a recurring fee. Financial planning topics may include, but are not limited to: tax planning, asset allocation, estate planning, investment planning, risk management, retirement planning, and college planning. Financial Planning may be comprehensive and cover multiple financial matters and goals, or it may include only one or a few particular goals. Your IAR will consult with you to discuss your goals, objectives, risk tolerance, and any special circumstance unique 9  to you. After performing this analysis, your IAR will present suggestions to you, either verbally or in a written financial analysis. Your IAR may prepare other special reports on these matters for you at your request. Please note, JWCA does not provide legal advice or perform tax preparation services. To implement the planning advice that you receive from your IAR, your IAR may recommend that you work with other professionals, such as other broker‐dealers (including JWCF), investment advisers, attorneys, property and casualty professionals or accountants. Your IAR may also recommend that you utilize various financial products to assist with helping to meet your financial goals. You are under no obligation to act on any of the financial planning recommendations provided to you by your IAR, and you may choose to implement the recommendations through a service provider suggested by your IAR or through any other service providers. Please note that your IAR is incented to recommend products and services in your financial plan for which he/she receives additional compensation; for instance, as a registered representative of JWCF. Specifically, your IAR may recommend that you use advisory products from which he/she receives a portion of the Advisor Fee and/or brokerage or insurance products from which your IAR receives a portion of the commission. These fees and commissions are in addition to the financial planning fee that you pay to JWCA and your IAR. Your IAR will base the financial planning recommendations on your initial profile provided at the time of engagement. E.) Variable Annuity Sub-Account Management and Registered Indexed-Linked Annuities: We offer advisory services to help manage variable annuity (“VA”) insurance products that you may currently own. Variable annuity insurance products contain sub‐accounts, which are portfolios of investment assets. Based upon your financial profile, your IAR will recommend an advisory service designed to assist you with selecting which sub‐accounts help you meet your financial goals. Like Variable Annuities, Registered Indexed‐Linked Annuities (RILA’s) are insurance products that contain certain features such as cap rates, buffers and allow for participation in the performance of various index(es). In some instances, your IAR may manage the investments in those sub‐accounts within a VA or the underlying Index(es) of a RILA. This management service may include annuity contracts you purchase through your IAR in his/her capacity as a registered representative of JWCF for which your IAR, as a registered representative, may have also received a commission. Alternatively, your IAR may recommend that you select a TPIA who will manage the sub‐accounts of a VA according to your financial profile. The advisory services offered by the TPIA are separate from our other JWCA services and are pursuant to a written Annuity Advisory Agreement with the TPIA. In this case, JWCA and your IAR will receive a promoter’s fee for the referral to the TPIA. Both your IAR and JWCA will receive a portion of the fee charged to manage your sub‐accounts. In addition, your IAR may recommend fee‐only annuities. For further information on Variable Annuity Sub- Account Management, please refer to Item 5 and Item 12. F.) Asset Management for Participants in Held-Away Employer-Sponsored Plans JWCA utilizes an unaffiliated third‐party platform which enables a JWCA IAR to manage a Client’s retirement plan assets that are held at the custodian for the Client’s employer‐sponsored retirement plan. Such management occurs on a discretionary basis. Through this platform, JWCA does not take custody of your funds and does not have direct access to your Accounts. You are not required to, and should never, provide log in credentials to your Accounts to JWCA or your IAR. 10  The third‐party platform provides a link to you, allowing you to connect your Account at your employer‐ sponsored retirement plan to the platform. Once your Account(s) is connected to the third‐party platform, your IAR will then be able to review the current Account(s) allocations and when necessary, will make any changes in the allocations based on your financial profile and investment objectives. To participate you must acknowledge that JWCA’s investment advice is limited based on the investment options made available by the employer‐sponsored plan and that such limitations may impact the IARs ability to effectively manage the assets. You will be charged an Advisor Fee and a Program Fee. A portion of the Program Fee is paid to the third‐ party in exchange for access to their system. Fees are assessed quarterly, in advance and determined based on the total account value. Fees cannot be debited directly from the employer‐sponsored plan. You are required to provide an alternative billing method. In the event of an account closure or termination of the agreement, Advisor fees will be rebated based on the remaining days in the period. However, Program Fees are not rebated. Advisor Fees and Program Fees are not pro‐rated for additions and withdrawals that occur during a billing cycle. Neither JWCA nor your IAR has the ability to withdraw funds or securities from your retirement plan account. G.) Additional Advisory Services JWCA and your IAR may also offer a wide range of additional advisory services such as management of a 529 Plan, Mutual Funds held directly with the Plan or fund company, fee based Fixed Indexed Annuities, management of qualified plans, etc. These solutions are designed specifically for advisory services, and do not generate a commission. Each fund company or 529 issuer may offer different share classes, and the share classes used with these programs are determined by the Mutual Fund Company, not JWCA or your IAR. Certain 529 and Mutual Fund companies will calculate and debit the JWCA advisory fee from your account and a portion of this fee is paid to your IAR. In other instances, JWCA will calculate the fee for these accounts, will debit such fees from another account, and a portion of the fee will be paid to your IAR. Fee‐based 529 plans are designed to pay your IAR based on assets, rather than commissions or sales charges. Fee based Fixed Indexed Annuities are offered by insurance companies allowing investors to earn interest based on positive market performance tied to a specific index, such as the S&P 500, while minimizing downside risk through guarantees offered by the issuer. Certain custodians and Third‐Party Investment Advisers may offer wrap‐based solutions to JWCA and your IAR. The structure and platform cost(s) associated with these solutions vary and are determined by that specific provider. Your IAR will determine your Advisor Fee based on the parameters discussed herein. Clients should review the materials provided by the provider for complete details to ensure an understanding of all costs associated with the solution. 11  Item 5: Fees and Compensation JWCA Managed Account Fees The default Advisor Fee tiered schedule is applicable for the following three Managed Programs: Transaction‐Based Advisory Account Programs, Asset‐Based Advisory Account Program, and FMAX. Under certain circumstances, Advisor Fees may be negotiated. Fees may also be charged at a flat rate, instead of on a tiered schedule. Your fees may be higher or lower than the default schedule outlined below and in the Firm’s AUM agreement. Generally, the maximum Advisor Fee is 3.00% and the minimum fee is 0.25%. Exceptions to the minimum fee may be granted by the firm based on varying circumstances including, but not limited to, asset size and registration type. Certain other minimum fees may apply. Tiered Advisor Fee Schedule Advisor Fees outlined above are exclusive of Program Fees and other potential transaction fees. Advisor Fees (also referred to as “Management Fees”), are fees typically charged by JWCA to manage the assets in your selected Advisory Account. In general, Advisor Fees are based on a percentage of the Client’s billable assets under management that are held in the Advisory Account, but the Advisor Fee varies by Platform Offering (described in the previous pages), custodian and type of Advisory Account (see the AUM Agreement and particular Addendum for the Advisory Account you select). Billable assets represent those assets on which JWCA and your IAR are providing active investment advice. The Advisor Fee is payable quarterly in advance or in arrears, depending on the particular Platform Offering, custodian and Advisory Account. Please review the Fee Schedule in the applicable addendum to your AUM Agreement to determine the exact Advisor Fee and methodology of payment. Understand that you will pay the quarterly Advisor Fee regardless of whether there are any transactions in your Account during the quarter. In the event you close your Account prior to the end of a quarter, and you are paying in arrears, you will owe a prorated Advisory and Program Fee. If paying in advance, you will receive a prorated refund of the Advisory Fee. In some instances, the Advisor Fee includes not only investment 12  management services but also includes the costs of transactions in your Advisory Account (i.e., a “wrap account”; see Asset‐Based program and FMAX described previously). Please note, if an Advisory Account has no or few transactions over a period of time, JWCA may, for the benefit of the Client, either cease charging an Advisor Fee on the Account (although a Program Fee would still be charged) or move the Advisory Account to a brokerage account at JWCF, a broker‐dealer affiliated with JWCA. In either case, the Account would no longer be considered part of an advisory relationship with JWCA. JWCA can make a unilateral decision to cease charging an Advisor Fee on a Client’s Advisory Account and/or move an Advisory Account to a brokerage account. In addition to the Advisor Fee, a separate Program Fee is also charged in most cases depending on the particular platform offering, the custodian utilized, and the nature of the IAR’s business (such that a Program Fee may vary depending on the IAR offering the Advisory Account). The Program Fee is billed in exchange for services provided by JWCA and custodian to your investment Account. The Program Fee is also generally based on a percentage of total asset account value, which is inclusive of both billable and excluded assets in your Advisory Account, often with a minimum annual fee amount required. The quarterly Program Fee is determined based on the number of days in the period and prorated based on the total minimum Program Fee. In the case of leap year, Clients should be aware that the Program Fee may be slightly higher than non‐leap years. Collectively, the Advisor Fee and Program Fee are also sometimes together referred to as Total Portfolio Fee in the Fee Schedules of Addendums to the AUM Agreement. Understand that you will pay the Program Fee regardless of whether there are any transactions in your Account during the quarter. The Program Fee is charged quarterly in advance/arrears in accordance with the AUM Agreement. Transaction costs are imposed by a Custodian to execute securities transactions in an Advisory Account (the costs are also sometimes referred to as “ticket charges”). For “Transaction‐Based” Advisory Accounts, the costs of such transactions are charged to the Client’s Advisory Account. In such Advisory Accounts, the Client is charged for the cost of each purchase or sale of an investment. Please note that transaction costs are in addition to the Advisor Fee and Program Fee and will vary by custodian, Managed Program and IAR. The JWCA IAR may or may not elect to pay such transaction costs. If the IAR does not pay for such costs, you will incur additional costs each time you purchase or sale a security. This will increase the costs associated with such Account, as compared to an Asset‐Based Advisory Account. If your IAR elects to pay transaction charges, while you will not pay such costs, your IAR is incented to either not recommend transactions, in order to avoid having to pay such transaction costs, or may recommend investments which have lower transaction costs, but which may be more expensive to you. Further, JWCF, an affiliated broker‐dealer, marks‐up transaction costs and therefore receives compensation from the transaction costs charged to you. In an “Asset‐Based” Account (also known as a “Wrap Account”), transaction costs are included in the Advisory/Program Fee. However, the Program Fee in an Asset‐Based Advisory Account is higher than the Program Fee in a Transaction‐Based Advisory Account and certain trading limits may apply in such Accounts. Transactions above such limits in certain Wrap Accounts will incur transaction costs. Other Fees and Expenses: In addition to the above and depending on the Program Offering and Advisory Account selected, Client’s Advisory Account may also incur other fees, including, among others, service fees, statement fees, wire fees, account termination fees and minimum account fees, which in most cases benefit JWCF, an affiliated broker‐dealer through mark‐ups on those fees. Additionally, a Miscellaneous Fee is assessed and includes, but is not limited to, dividend checks, brokerage credit inquiries, excess SIPC protection, confirmations – Customer and interest party, year‐end tax forms (including 1099’s and 5498), basic and detailed TLA 13  statements and prospectuses. For Clients who utilize eDelivery, the Miscellaneous fee applies and is used to cover certain costs described above along with updates to email addresses, electronic prospectus delivery, and invalid email notifications. JWCA and the JWCA IAR may also offer no‐load and load‐waived mutual funds. While there are no commissions charged for these mutual funds, the Client will incur certain expenses imposed by those mutual funds. These charges include but are not limited to: mutual fund 12(b)‐1 distribution fees, shareholder service fees, short term redemption fees on certain mutual funds that are being redeemed, and certain IRA and qualified retirement plan fees. Other investments, such as insurance companies, may also charge fees associated with insurance riders and mortality and expense (M&E) charges, and/or certain IRA and qualified retirement plan fees. As stated above, the Advisor Fee is based on a percentage of the current market value of the billable assets in your Advisory Account. In most cases, the Advisor Fee is charged quarterly and is calculated based on the number of days in the specific quarter, generally equating to a 365‐day basis. The quarterly Advisor Fee is charged in advance or in arrears dependent on the terms of your specific AUM Agreement. We use a third‐party fee‐billing service that receives asset valuations from the custodian of your Account, and we do not independently verify, value, or aggregate your assets. Advisor and Program Fees are calculated on the last business day of each quarter. The Advisor Fee is calculated by using the ending market value of the billable assets in your Account, while the Program Fee is calculated by using the ending market value of the total assets in your Account. We pro‐rate the initial and closing Advisor Fee, based on the number of days in which advisory services were rendered to you in the calendar quarter. Upon notification to us, Advisor Fees will be adjusted for additions or withdrawals to your Account during the quarter but only if such activity exceeds a net $15,000 in a day. Program Fees are assessed on additions but are not rebated in the event of withdrawals or account closures. Unless otherwise approved, an Advisor Fee is separately charged for each Advisory Account that you maintain with JWCA. In the event of Tiered Billing, we do not automatically combine overall advisory assets that you may hold across multiple JWCA Advisory Accounts, commonly referred to as “householding,” that could otherwise provide an Advisor Fee discount. As applicable, custodial fees, e.g., charges assessed to hold and safeguard your assets, still apply and, in certain cases, are shared with JWCF, an affiliated entity. Any applicable Program Fees attributable to those assets in the Account would also still apply. Please request a complete list of the fees for the advisory program in which you are investing. Upon notification that a pre‐paid advisory service has been terminated, we will automatically pro‐rate the period in question and refund you back any Advisor Fees due. It is not necessary for you to separately request the refund. Your JWCA Advisory Account may also contain certain assets for which no active investment advice is being given, either at the discretion of the Client or by JWCA. These assets are considered “excluded assets” and will not be billed an Advisor Fee while the assets remain excluded. Excluded assets are not considered part of the advisory relationship with JWCA or your IAR, and you will not receive investment advice on such excluded assets. Although an Advisor Fee will not be charged on excluded assets, other charges may be incurred on such excluded assets including, but not limited to, a Program Fee, transactions costs, and other custodial related fees. In addition, miscellaneous fees will still apply, and the Program Fee will continue to be based on a percentage of the overall market value of the total assets in your Account (including excluded assets). Examples of excluded assets may include securities with disadvantaged tax consequences; restricted, control, affiliate, or employer securities, other investments you may have an attachment to, and securities for which your IAR is prohibited from giving advice. The 14  time period that the Advisor Fee is excluded will be determined on a case‐by‐case basis as agreed to between you, the IAR and JWCA. Billing on Cash For purposes of this section, cash and/or cash equivalents are collectively referred to as “cash”. If an Advisory Account maintains “excess cash” (i.e., cash that is 50% or more of the total Advisory Account value, for six (6) consecutive months or longer), the Account’s entire cash position will be excluded from the Advisor Fee. The Advisor Fee will continue to be charged on non‐cash assets in the Advisory Account, and the Program Fee will continue to be billed on the entire Account, including cash. Once the Account no longer maintains excess cash, the assessment of an Advisor Fee will be reinstated on all cash positions. Securities Previously Purchased in a JWCF brokerage account If your IAR, in his/her capacity as a registered representative with JWCF, received a commission on certain investment purchases and those investments are subsequently moved into your Advisory Account, this creates a conflict of interest. There is an incentive for your IAR to recommend investment products, not necessarily based on your needs, but based on the compensation received by the IAR in his/her capacity as a registered representative of JWCF and then move the investments to an Advisory Account and to receive Advisor Fees on the same investments. To help mitigate this conflict, JWCA maintains a policy to temporarily waive the advisory fees attributable to securities that were recently purchased in a JWCF brokerage account and then transferred into an Advisory Account. Third-Party Investment Adviser (“TPIA”) Fees When you choose to utilize a TPIA, each TPIA will charge TPIA management fees in accordance with the terms of the agreement that the Client signs with the TPIA. TPIA relationships may include separately managed accounts, unified managed accounts, and direct fund fee‐based platforms. TPIA management fees, or any minimum investment requirements imposed by the TPIA, may or may not be negotiable. TPIA Management fees will generally be determined by the TPIA and a) may only allow for fee billing in arrears or advance, b) may be based on daily average asset values compared to an end of quarter value, c) may calculate fees monthly or quarterly, and d) may have different rules regarding credits or debits relating to additions or withdrawals. You should review closely the criteria used by the TPIA for determining and debiting Advisor Fees. The TPIA will custody your assets with their corresponding custodian. Additionally, TPIAs have different policies regarding liquidation requests which could result in changes in market value from the time of request to the time of liquidation. You are encouraged to review the specific criteria established by the TPIA prior to investing. TPIAs may or may not be wrap programs. Any fees or charges for transaction and custodial services incurred in connection with the TPIA’s management of your Advisory Account are in addition to the TPIA’s management fee. Also, please note that you will be paying both a JWCA Advisor Fee and the TPIA Management fee. Certain TPIAs may assess one consolidated fee from which a portion is paid to JWCA as an Advisor Fee, while other TPIAs will process separate and distinct fee debits for both their management fee and the JWCA Advisor fee. Our Advisor Fee for the advisory services that we provide to you in connection with selecting and monitoring the TPIA (as described above) is paid to JWCA by either the TPIA or by the custodian of your assets, who will debit the fee from your Account. 15  Financial Planning and Consulting Fees Clients electing to engage us for financial planning and consulting services may choose between an hourly rate, or a flat fee for either a one‐time engagement, or for ongoing financial planning and consulting services. These fees may be negotiated prior to executing the agreement and can be paid with a check, credit card, bank EFT or withdrawal from an Account held with JWCA or JWCF. Clients electing a flat fee for financial planning services may be requested to pay the Financial Planning and Consulting fee in advance or upon delivery of agreed upon services. For the hourly rate option, we may request payment either upon execution of your agreement, upon delivery of the advisory services, or some combination of these. We may charge up to $350.00 per hour for these advisory services. Either party may terminate the financial planning agreement at any time by providing the other party with written notice. Upon termination, we will refund any unearned Financial Planning and Consulting fees paid by you, based upon the amount of documented time and/or services already rendered by your IAR on the financial plan prior to the termination of the agreement. You may terminate your agreement within five business days of initially signing the agreement and receive a full refund of all Financial and Consulting fees paid. Variable Annuity Sub-Account Management Clients engaged in Variable Annuity Sub‐Account Management will pay an Advisor Fee for such management services. Under certain circumstances, Advisor Fees may be negotiated. Advisor Fees may also be charged at a flat percentage or on a tiered schedule. Your fees may be higher or lower than the default schedule. The maximum allowable Advisor Fee is 2.00% and the minimum allowable fee is 0.25%. Certain minimum fees may apply. The Advisor Fee is based on a percentage of the current market value of the annuity assets under management. The market value of such assets is determined by your applicable annuity company. We review, but do not independently verify or value your annuity assets. The Advisor Fee is charged quarterly, in advance or in arrears based on the terms of your JWCA AUM Agreement and Addendum(s) thereto, and, in some cases, by the annuity company. The Advisor Fee schedule dictating what you pay is set forth in the applicable Addendum to your AUM Agreement, which will include details on how payment is made to JWCA; in advance or arrears. JWCA calculates the Advisor Fee at the end of each calendar quarter; determined from the reported ending market value of your assets in your Advisory Account on the last business day of the quarter. In certain instances, Advisor Fees will be determined by the annuity company and a) may only allow for fee billing in arrears or advance, b) may be based on daily average asset values compared to an end of quarter value, c) may calculate fees monthly or quarterly, and d) have different rules regarding credits or debits relating to additions or withdrawals. Certain insurance companies allow for the debiting of the Advisor Fee directly from the annuity. Clients must review their applicable annuity company’s provisions closely to ensure that the debiting of fees from the annuity does not impact any benefit riders that may exist and understand that the withdrawal of the fee may be considered a taxable event. For annuities that do not allow for the debiting of the fee from the annuity, Clients must identify an alternative solution for the fee to be debited. Your IAR, acting in his/her capacity as a registered representative of JWCF, may also receive or previously have received commissions on the sale of annuity(ies) to you. In addition to commissions, variable annuities also carry internal fees. These commissions and fees create a conflict of interest when your representative recommends that you purchase an annuity, and as a result of the purchase receives a 16  commission in his/her capacity as a registered representative of JWCF, and then also subsequently receives Advisor Fees for management of the sub‐account or index(es) of the same annuity(ies). Your IAR should disclose this conflict of interest to you by giving you a copy of his/her Form ADV 2B, which contains appropriate disclosure language. Upon notification that a pre‐paid advisory service has been terminated, we will automatically pro‐rate the period in question and rebate back to you any fees due. It is not necessary for you to separately request the rebate. You also have the option to select TPIAs to manage the sub‐accounts in your variable annuity. Under this relationship, you pay the TPIA’s management fee (and any other fees as identified in the TPIA’s Form ADV Part 2A) per your agreement with the TPIA. You will also pay JWCA a promoter’s fee for the referral made by your IAR to the TPIA. This promoter’s fee is negotiable. The default promoter fee is one percent (1%). Your TPIA will charge all of the fees to your Account and forward to us a portion of the fee for JWCA’s and your IAR’s role as Promoter. A “no‐load” annuity generally charges lower fees and expenses and is not sold on a commission basis. Typically, a load annuity, sold on a commission basis, is not transferable into a similar no‐load product offered by the same annuity company. In other words, if you have a load annuity, you will not likely be able to convert this annuity to a no‐load annuity, even if it is held with the same annuity company. While no‐load annuities do not charge a commission and have lower annual fees, they may also lack certain features and benefits of load annuities, such certain income riders. Please speak with your IAR regarding the features and benefits of the various annuities available to you. Important Considerations Regarding Direct Billing to Your Custodian Generally, your signed AUM Agreement, including applicable Addendum(s), authorizes JWCA to bill Advisor Fees to the custodian of your Account and directs your custodian to debit Advisor Fees from your Account to us. Your statements produced by the custodian will reflect each Advisor Fee deduction from your Advisory Account. You may withdraw the authorization for direct billing of these Fees at any time by notifying us, or your custodian, in writing. Conflict of Interest Considerations Regarding Mutual Funds and Variable Annuities All fees paid to JWCA for advisory services are separate and distinct from the internal fees and expenses charged by mutual funds and/or variable annuity sub‐accounts, which are described in each mutual fund’s or variable annuity’s prospectus. Generally, these internal mutual fund and variable annuity fees and expenses include a separate management fee assessed by the fund company and/or variable annuity for the investment management of the individual mutual fund or annuity, as well as other expenses. Variable annuities and mutual funds also generally pay distribution fees to JWCF, often referred to as 12b‐1‐fees. This creates a conflict for JWCA as it incents JWCA to recommend such mutual funds and variable annuities to increase revenue paid to JWCF, an affiliated broker‐dealer with which JWCA maintains an expense sharing arrangement. The Firm mitigates this conflict by requiring its IARs to act in the Client’s best interest when recommending mutual funds and annuities, and their respective share classes; supervising IARs’ recommendations and advice; and, with respect to mutual funds, regularly converting mutual fund share classes that charge 12b‐1 fees to lower‐cost share classes when appropriate (see next paragraph). 12b‐1 fees associated with mutual funds are automatically credited back to your Advisory Account by NFS, or maintained by other custodians (but not paid to JWCA). Specifically, for Advisory Accounts that are not categorized as ERISA qualified Client plan accounts, every 60 days, consistent with your best interest, JWCA reviews whether you are invested in the mutual fund share class with the lowest overall fees available on the specific platform in which your mutual fund assets 17  are custodied. The review may determine you are invested in a share class that pays 12b‐1 fees, even though a lower cost share class is available. The Firm remedies this conflict by initiating on a regular basis a share class conversion, on applicable Client assets, from a higher cost share class to a lower cost share class, if we determine that conversion is in your best interest. However, certain limitations may apply that would cause the Firm to not to convert the funds to a lower share class including, but not limited to, minimum investment requirements by the mutual fund, surcharges imposed by the custodian, short‐term redemption fees, etc. Because custodians may assess different surcharges, some mutual fund share classes deemed to be most appropriate at one custodian may not be so at another custodian. Additionally, as stated above, to the extent a non‐12b‐1 fee paying fund share class is unavailable on the NFS platform, any 12b‐1 fees generated are automatically credited back your Account by NFS. Certain funds also charge transaction costs to purchase or sell the fund. Advisory Accounts that incur such transaction costs for mutual funds or other securities, commonly referred to as “ticket charges,” are referred to as “Transaction‐Based Advisory Accounts.” As stated earlier, at your IAR’s discretion, he/she may choose to pay for your associated transaction costs. Please note, if your IAR elects to pay for such transaction costs, there is a conflict of interest in that your IAR is incented to not recommend that you purchase and sell securities, as the IAR will have to pay the transaction costs. Whether or not there are transactions in your Advisory Account, you will still be charged the Advisor Fee and other fees, including Program Fees and miscellaneous fees charged by the custodian.1 In an “Asset‐Based Advisory Account” (i.e. A Wrap Account), transaction costs are included in the Advisor Fees you pay. However, the Program Fee in an Asset‐Based Advisor Account is higher than the Program Fee in a Transaction‐Based Advisory Account and other miscellaneous fees also apply. You should review and discuss with your IAR, all JWCA fees and those fees charged by mutual funds, variable annuities, and other entities to fully understand the total amount of fees you are paying. The assets subject to an Advisor Fee waiver (i.e., “excluded assets”) do not include a waiver of 12b‐1 payments, which are mitigated by the steps discussed above. It is important to note that a commission paid to your IAR, in his/her capacity as a registered representative of JWCF on an excluded asset, may be higher than the amount of the Advisor Fee that would have otherwise been charged on the asset if it was purchased in an Advisory Account. Conflicts of Interest and Compensation Related to Loans to IARs JWCA, or JWCA through JWCF, provides various benefits and/or payments to newly associated JWCA IARs to assist the IARs with the costs of transitioning the IAR’s Clients’ business to JWCA (including the IARs’ foregone revenues caused by their transition to JWCA) by offering forgivable loans to such IARs. These IARs, in turn, each execute a “Promissory Note” to JWCA. The Promissory Note reflects the IAR’s obligation to pay back the loan, including interest, unless the IAR meets certain agreed‐upon terms, which then results in the loan being forgiven by JWCA. The agreed‐upon terms generally require the IAR to remain associated with JWCA as an IAR for a period of time. There is no production requirement for IARs to meet in JWCA Promissory Note Agreements. While an IAR who meets the agreed‐upon terms of a forgivable loan causes JWCA to forego the financial benefit of the loan repayment, the forgivable loans are structured by JWCA in such a manner that when the IAR remains associated with JWCA for a certain period of time, JWCA generally receives an economic benefit from that IAR’s continued association with JWCA, 1 However, as stated in Item 5 “Fees and Compensation,” Managed Program Fee,” JWCA may cease charging the Advisor Fee in accounts with no to little transaction activity. 18  so that the loan can be forgiven. The forgivable loans are generally in the form of payments by JWCA/JWCF to the IAR with favorable interest rate terms as compared to those of a traditional lender. The proceeds of the forgivable loan may be used for a variety of purposes by the IAR, including but not limited to, providing working capital to assist in funding the IAR’s business, satisfying any outstanding debt owed by the IAR to the IAR’s prior firm, offsetting account transfer fees (ACATs) as a result of the IAR’s Clients transitioning to a JWCA‐approved custodial platform, technology set‐up fees, marketing and mailing costs, stationery and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. However, JWCA does not verify that any forgivable loan proceeds given to an IAR are actually used for the above purposes or for any other transition costs. The amount of the forgivable loan to the IAR is generally based on the IAR’s production established at his or her prior firm. For example, the amount of a forgivable loan may be based on a percentage of the revenue earned, or assets serviced by the IAR at the prior firm. The amount of a forgivable loan to an IAR can be significant in relation to the overall revenue earned or compensation received by the IAR from his/her prior firm. As stated above, the loan is then forgiven by JWCA if the IAR remains associated with JWCA for a required number of years. An IAR’s transition to JWCA and receipt of a forgivable loan creates a conflict of interest in that an IAR has a financial incentive to recommend that a Client switch from securities, investment programs and services, and advisory options that the Client maintained at the IAR’s prior firm, to advisory options available through JWCA so that the IAR can continue to maintain his/her association with JWCA to meet the terms of the forgivable loan, and continue to be compensated at their initially agreed upon rate. JWCA and its IARs attempt to mitigate these conflicts of interest by supervising and oversighting IARs to reasonably ensure that the IARs recommend advisory services and investments that are appropriate for Clients and based on the benefits to Clients. The supervisor of the IAR is not generally made aware of forgivable loans provided to the IAR, nor is the supervisor incented by the production of the IAR. However, Clients should be aware of this conflict and take it into consideration when deciding whether to establish or maintain a relationship with the newly associated IAR and/or JWCA. Further, Clients always maintain the right not to use JWCA’s services. In addition to forgivable loans to IARs to assist with their transition to JWCA, occasionally JWCA may provide other loans to IAR’s. These loans are generally intended to assist an IAR with the acquisition of another IAR’s book of business or other business‐related activities. However, JWCA does not verify that any payments made by it are used for such activities. The supervisor of the IAR is not generally made aware of loans provided to the IAR, nor is the supervisor incented on the production of the IAR. Item 6: Performance-Based Fees and Side-by-Side Management JWCA does not charge any performance‐based fees (fees based on a share of capital gains or on a share of capital appreciation of your assets). However, there may be some TPIAs offered by JWCA who charge performance‐based fees. You should review the specific TPIA’s Form ADV Part 2A to identify such fees. Item 7: Types of Clients JWCA provides the advisory services described above to: individuals, partnerships, pension and profit‐ sharing plans, trusts, estates, charities, corporations, retirement plans and other entities. JWCA imposes certain conditions for opening or maintaining an Advisory Account. Generally, our Transaction‐Based Advisory Account Program requires a minimum of $10,000; our Asset‐Based Advisory Account Program requires a minimum of $100,000; and our FMAX Program requires a minimum of $10,000 in cash or 19  securities. We may terminate the agreement if the Account does not meet the minimum amount required. At our discretion, we may waive the minimum requirements if, for example, the Client has additional or related accounts that collectively exceed the minimum requirements. Certain minimum fees apply. TPIAs also impose minimum fees and may require larger minimums than JWCA. Please review all agreements and request your IAR to explain any fees and account requirements prior to executing your written agreement. JWCA does not require a minimum account size for financial planning services but does impose a minimum fee. Item 8: Methods of Analysis, Investment Strategies and Risk Loss Methods of Analysis: Your IAR may employ various methods of investment analysis to evaluate securities for potential investment advice and securities recommendations. These methods can include but are not limited to the following: A.) Fundamental Analysis: A technique that attempts to identify investment opportunities by comparing an estimated true value of a company versus its current market value. The estimated value may be conducted by assessing the company’s current financial condition and consideration of other important company factors including, but not limited to: revenue projections, profitability, competitive advantages, liability exposure, management expertise, industry outlook, etc. Based on this analysis, the estimated value of the underlying company is compared to the firm’s current market value, as reflected by its stock price, to identify potential buying and selling opportunities. Because it can take a long time for the market to reflect the company's value, one risk associated with this method of analysis is that potential investment gains may not be realized until the security’s market price rises to the company’s estimated true value if it ever does. Furthermore, the information collected by an IAR may be incomplete or incorrect resulting in an inaccurate estimate of earnings, which may cause an incorrect assessment of the investment's estimated value versus the market. Even if the information is complete and correct, given the uncertainties of the markets, the analysis may ultimately prove wrong. Market volatility driven by factors such as, but not limited to, geopolitical instability, inflation, central bank policies, natural disasters, cyber threats and/or new information regarding a specific security may result in price volatility. Due to these risks, relying upon fundamental analysis for investment opportunity may not result in favorable performance. B.) Technical Analysis: This technique involves the comparison of a security’s past price movements to identify trends and attempt to forecast future price movements for potential investment opportunities. Unlike fundamental analysis, technical analysis does not analyze the company’s value, but instead, analyzes the security’s price movement in the market. o “Charting” is a form of technical analysis in which the price and volume information for a security are analyzed using mathematical equations. The results are then graphically represented to illustrate patterns and identify potential investment opportunities. o “Cyclical analysis” is another form of technical analysis, which focuses on the regularity of movements in the market and attempts to time the trading of a security to coincide with anticipated market cycles. 20  “Technical analysis” analyzes the supply and demand in the market in an attempt to determine what direction, or trend, will continue in the future. However, there are risks involved with the technical analysis method, including the risk that trends will change unpredictably and that market timing results may not be favorable if the analysis does not accurately predict future price movements. Past performance or trends may not be a reliable indicator of future performance or trends. Daily changes in securities prices often follow random patterns and may not be predictable with any reliable degree of accuracy. Sources of Information: Your IAR obtains investment information from a number of sources, both public and by purchase, including financial newspapers and magazines, reviews of corporate documents and activities, research materials prepared by third‐parties, corporate rating services, annual reports, prospectuses and filings with the SEC, and company press releases. JWCA believes these resources for information are generally reliable, but JWCA is not responsible for the accuracy or completeness of this information. Investment Strategies: An investment strategy recommended to you is based upon the financial profile information you provided to your IAR, as well as your investment objectives. Prior to choosing an investment strategy, it is important to review with your IAR your investment objectives, risk tolerance, tax objectives, liquidity needs, and any other relevant financial considerations. Thereafter, such considerations should be reviewed at least annually. All investments carry a certain degree of risk, and no particular investment style or portfolio manager is suitable for all types of investors. Your IAR may use a variety of investment strategies depending on your circumstances, financial objectives, and needs. In general, your IAR may recommend implementing one or more of the following investment strategies: long‐term securities (generally held at least a year); short‐ term purchases (generally held less than a year); trading (typically held less than 30 days); margin transactions (purchase of a security on credit extended by a custodian based on the value of securities in your Account); option transactions (call and put positions), etc. If you are uncomfortable or object to any investment strategy proposed or used by your IAR, promptly advise JWCA or your IAR. Since you will receive confirmations from your Account custodian for every transaction in your Account, you need to contact JWCA at (866) 592‐ 6531 if any transaction or series of transactions, in your view, is objectionable in any way. If you do not contact JWCA within sixty (60) calendar days, you are hereby agreeing that each transaction, series of transactions, and investment strategy is consistent with your financial profile and investment objectives. Risk of Loss: Investing in securities involves the risk of loss. Electing to follow the investment advice of your IAR indicates you understand, are prepared for, and have accepted the risk of loss. Investors face various risks including, but not limited to, any or all of the following types of investment risks: • Market Risk: The values and prices of securities fluctuate in reaction to tangible events such as an underlying security’s operating results; and/or intangible events such as political, social, economic matters; or the forces of investor supply and demand. Securities values may decline upon negative influences from any of these circumstances. • Interest Rate Risk: Fixed income securities (e.g. bonds) typically have an inverse relationship with the movements of interest rates, meaning the prices of bonds will generally decrease during 21  periods of rising interest rates. Interest rates can change based on a number of economic factors including but not limited to inflation, U.S. Federal Reserve monetary policy, and supply/demand. Interest rates can also impact equity securities as changes to interest rates affect a company’s ability to borrow and/or ability to service variable debt. • Credit Risk: There are three primary forms of Credit Risk which can impact the price of a security. o Default Risk occurs when an issuer (e.g. a company or government entity issuing a bond) fails to satisfy the terms of the obligation with respect to the timely payment of interest and the repayment of an amount borrowed. o Credit Spread Risk represents the risk fixed income investors experience when the yields of fixed income securities fluctuate and affect the market value of the bond. The credit spread risk is generally determined by the yield of a fixed income security relative to its risk‐free alternative. o Downgrade Risk is the risk that bond prices will decline, due to a downgrade in its issuer’s credit rating as assigned by agencies such as Moody’s or S&P. • Liquidity Risk: Risk that a given security or asset cannot be readily traded, such as when there are few buyers for a security, or liquidations are restricted to certain time periods. This results in potentially having to sell the security at a loss below market value. • Business Risk: The probability of loss inherent in an organization’s operations, management and environment that impairs its ability to experience profit, negatively affecting the company’s security price. • Inflation Risk: The uncertainty over the future real value of assets, due to the prevailing economic conditions. • Political Risk: Risk that investment returns could suffer as a result of political changes or instability. You should work with your IAR to attempt to identify the balance of risks and rewards that are appropriate and comfortable for you. However, it is still incumbent on you to ask questions if you do not fully understand the risks associated with any investment or investment strategy. By opening an Advisory Account, you are explicitly acknowledging that you understand and accept that there is always a risk of loss, or below‐market rates of performance. While your IAR strives to render his/her best judgment on your behalf, many investment, economic and market variables are beyond the control of your IAR and JWCA, and these variables affect the performance of your investments. JWCA and your IAR cannot assure you that your investments will be profitable, or that no losses will occur in your investment portfolio. Past performance is one consideration with respect to any investment or investment strategy, but it is not a predictor of future performance. If you are ever uncomfortable or unhappy with your investment performance, contact your IAR immediately to discuss your concerns or contact JWCA at (866) 592‐ 6531. 22  Item 9: Disciplinary Information On August 25, 2021, JWCA, without admitting or denying the findings, consented to the entry of an Order by the Securities and Exchange Commission that its mutual fund share class selection practices resulted in another broker‐dealer, with which JWCA maintained an expense sharing arrangement, receiving three types of fees generated by certain transactions in JWCA Advisory Accounts, without being fully disclosed. Between January 2014 and November 2016, JWCA recommended that JWCA Advisory Clients purchase or hold mutual fund share classes that charged 12b‐1 fees when lower cost share classes were available for the same fund(s). Between January 2014 and March 2021, JWCA recommended that JWCA Advisory Clients purchase or hold mutual fund share classes which resulted in another broker‐dealer, with which JWCA maintained an expense sharing arrangement, receiving revenue sharing payments when lower‐cost share classes of the same mutual funds were available and would have resulted in no or lower revenue sharing. Additionally, between September 2016 and March 2020, the same broker‐dealer received revenue sharing payments when Client assets were invested in certain share classes of money market funds used as “cash sweep vehicles” when other, non‐revenue sharing money market fund options were available. JWCA failed to adequately disclose to Advisory Clients the above conflicts of interest relating to the payments of these fees and its selection of certain mutual fund or money market share classes that paid such fees. As a result of this conduct, JWCA, without admitting or denying the findings, consented to an Order that found JWCA violated Sections 206(2) and 206(4) of the Advisors Act and Rule 206(4)‐7 thereunder. Pursuant to the Order, JWCA was ordered to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)‐ 7. Further, JWCA received a censure and agreed to pay disgorgement, prejudgment interest and a civil penalty totaling $1,957,053.11. JWCA complied with the undertakings enumerated in the Order. To review the order, visit: sec.gov/litigation/admin/2021/ia‐5832.pdf. Item 10: Other Financial Industry Activities and Affiliations JWCA and JWCF are affiliated companies under the common ownership of JWC Wealth Partners. JWCA and JWCF share a physical office location and mutually seek to minimize expenses of administration by sharing certain staff, equipment, supplies, and other administrative and office expenses. When we selected JWCF as a service provider, we considered the variety of JWCF’s services, financial stability and competitive commission rates in our effort to provide brokerage services that meet your needs. Your IAR, if he/she serves in the capacity of a registered representative with JWCF, normally earns commissions on purchases and sales of securities and insurance products. This creates a conflict of interest when your IAR recommends the purchase of product, for which he/she receives a brokerage commission. To mitigate conflicts, JWCA does not require you to purchase any recommended brokerage products from our IARs in their capacity as registered representatives of JWCF, or to utilize JWCF, for any products or services. You are free to purchase such products from another broker‐dealer. JWCA and/or its IARs may also have referral arrangements with unaffiliated outside professionals. These referral arrangements may present a conflict of interest because JWCA and/or your IAR may have a direct or indirect financial incentive to recommend another professional’s service as a result of that outside professional’s referral of Clients to JWCA. While we believe that compensation charged by outside professionals is competitive, such compensation may be higher than fees charged by other professionals providing the same or similar services. Some IARs are licensed in other professional capacities such as accountants, attorneys, and insurance agents. These other professional services are separate and distinct from JWCA’s advisory services and are 23  not affiliated with JWCA. IARs of JWCA may also offer fixed insurance through insurance companies unaffiliated with JWCA, therefore JWCA does not supervise the solicitation or sale of these outside products. When you use these other businesses to purchase or sell insurance, or obtain accounting, tax, legal or other professional services, you will incur commissions, fees, and/or other charges. These charges are separate and distinct from JWCA and are not part of JWCA’s Advisor Fees. When an IAR recommends that you utilize such separate service, your use of such services generates additional sources of compensation for the IAR and therefore creates a conflict of interest. To mitigate such conflicts, JWCA will never require you to utilize a separate service offered by your IAR, nor are you required to implement any tax, legal, investment, or other recommendations through such businesses. You are always free to use any accountant, attorney, insurance agent, or any other professional of your choice. In some instances, we may allow your IAR to independently own their own investment adviser firm (“IA”). In such cases, your IAR is then dually registered as an IAR of both JWCA, and their own IA. As a result, your IAR may provide advisory services to you under both their own IA, and under JWCA as described in your written AUM Agreement (including applicable Addendum(s)), or Financial Planning and Consulting Agreement. In every situation, you should carefully consider any conflicts of interest when your IAR offers other advisory professional services through third‐party IAs, for which he/she receives additional compensation. JWCA also has a dedicated team of IARs in its corporate office who operate a “doing business as” (“dba”) unit of both JWCA and JWCF. The dba is known as “JWC Wealth Management” (“JWC Wealth”). In addition, a small subset of those within JWC Wealth, who are IARs of JWCA, operate their own offices around the United States. JWC Wealth is not a registered investment adviser. JWC Wealth IARs may service certain Accounts of JWCA Clients that are not currently serviced by other JWCA IARs, and, in some cases, are also compensated as employees of JWCF, which can include such compensation as a salary, bonus and other things of value as set out above. Item 11: Code of Ethics JWCA has adopted a Code of Ethics describing the standards of business conduct that it expects its’ officers, directors, employees, and IARs to follow. Our Code of Ethics also describes certain reporting requirements that individuals associated with JWCA, or employed by us, must comply with. JWCF, in its capacity as a broker‐dealer, may buy and sell securities in their proprietary Accounts. In addition, IARs buy and sell securities in their own Accounts. These Accounts are known as “proprietary accounts.” Also, your IAR may recommend to you and other Clients, securities in which he/she is personally investing or is recommending to other Clients. Both scenarios create a conflict of interest. To mitigate any potential conflicts, JWCA may aggregate orders for securities transactions for more than one Client to obtain a better overall price. In appropriate circumstances, the aggregation may include proprietary accounts. However, we strive to treat each Client fairly and will not favor any given Client or proprietary account. JWCA does not maintain proprietary accounts. JWCA does not act as principal in securities transactions. Further, we maintain internal policies which generally prohibit IARs from knowingly buying or selling securities from a Client, as principal and/or affecting agency cross‐transactions involving a Client. You may request a copy of our Code of Ethics by contacting our corporate office, at (866) 592‐ 6531 or email us at: compliance@jw‐cole.com. 24  Item 12: Brokerage Services JWCA does not require you to use a specific broker‐dealer to execute securities transactions for your Advisory Account. However, we have established a relationship with JWCF, and utilize their clearing firm, National Financial, LLC (“NFS”), a subsidiary of Fidelity Investments, which acts as custodian for certain JWCA related accounts. We also use Institutional Wealth Services (“IWS”), a business unit and a division of Fidelity Institutional and a subsidiary of Fidelity Investments, and Schwab Institutional, as custodians. These broker-dealers, as well as other brokerage service providers, such as mutual fund and annuity companies provided through JWCF, an affiliated broker-dealer, with various direct and indirect benefits, which raises conflicts of interest as discussed below In the absence of a written pre‐approval from JWCA allowing the use of another broker‐dealer, your IAR will utilize JWCF to execute securities transactions for your Advisory Account through its relationship with NFS. As described in “Item 10 – "Other Financial Industry Activities and Affiliations” when selecting JWCF as the broker‐dealer, it creates a conflict of interest, if your IAR is dually registered as a registered representative of JWCF. While JWCA permits for this conflict in consideration of the additional services provided by JWCF, JWCA must determine, in good faith, that the amount of any commission or transaction cost paid to JWCF is reasonable in relation to the value of the brokerage services provided to JWCA. This is viewed in terms of 1) best execution of a particular transaction, 2) overall services provided to JWCA and its IARs and/or 3) JWCF’s overall responsibilities with respect to the transaction, including but not limited to, execution of the transaction, review of the trade, and fulfilling regulatory reporting requirements. Conflicts of Interest with respect to JWCA’s affiliated broker-dealer JWCF: Any transaction costs you pay as a result of a JWCF securities transaction effected at NFS for your Advisory Account will be determined according to standard rates in effect at JWCF, or as negotiated by you and your IAR. Transactions fees are charged by the applicable custodian (e.g., NFS), paid by you in your JWCA Account, and partially shared with JWCF. These transaction costs are competitive in the industry but are not the lowest transaction costs available and in certain cases may be marked up by JWCF for which it receives a monetary benefit. However, any monetary benefit relating to transaction costs are not shared with your IAR or JWCA. NFS’ sharing of revenue generated from transaction costs with JWCF and/or JWCF’s markup of such transaction costs is a conflict of interest because JWCA is affiliated with JWCF, and JWCF receives a benefit. They are also a conflict of interest when your IAR is affiliated with both JWCF and JWCA. This conflict is mitigated, since these charges are not shared with JWCA or your IAR, and JWCA does not require you to use JWCF to effect transactions. You always have a choice as to the type of advisory services that you select. Asset‐Based advisory programs do not separately charge transaction costs as the transaction costs are included in the overall Advisor Fee. However, the overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the same types of securities in our Transaction‐Based Advisory Program, as the Program Fee in our wrap accounts is higher than a Program Fee in a transaction‐based Advisory Account. Since you have the ability to choose the type of account you want, including the fee structure and the custodian, we believe this mitigates this conflict. JWCA also has an expense sharing agreement with JWCF in connection with JWCF providing JWCA with staff, technology, office space, office equipment, and administrative services. This agreement provides a financial benefit to JWCA, which does directly benefit you. However, to mitigate this conflict of interest, you may utilize a different broker‐dealer to purchase your securities, as described in more detail below under the “Directed Brokerage” section. 25  Annuities sold through JWCF: Variable annuities and RILA’s are complex investments offered by insurance companies. An investment in a variable annuity contract is subject to general market risk and the insurance company’s credit risk. RILA’s are subject to market risk in the event that the specific index(es) linked to the product decline below the buffer or the amount of decline to the floor. RILAs also generally have limits on their upside potential gains due to caps. Both types of annuities are regulated under securities and insurance laws and the related rules and regulations. Annuities may offer benefits and features that may or may not have value to you depending on your circumstances, which your IAR will discuss with you. Similar to other investments, commissions are paid for the purchase of annuities (excluding fee‐based annuities), a portion of which is paid to a registered representative, and there are often surrender charges for the early liquidation of an annuity. These charges are listed in the annuity’s prospectus. You will find additional information about the risks, commissions, surrender charges, and other expenses in the prospectus. Similar to mutual funds, insurance companies may charge a variety of fees against the assets invested in the sub‐accounts or indexes of the insurance contract. As noted previously, when JWCA and your IAR provide sub‐account variable annuity advisory services, this typically means there are two layers of fees incurred: one layer by the insurance company and one layer to JWCA for the advisory services provided by your IAR. In addition, JWCA or the custodian may impose a Program Fee to maintain your advisory assets and execute transactions. As described in more detail in “Item 10 ‐ Other Financial Industry Activities and Affiliations,” many of our IARs are also registered representatives with JWCF and licensed to sell general securities products, such as commission‐based annuities. Thus, in addition to the above fees and costs, if you also purchase a variable annuity through your IAR, in their capacity as a representative of JWCF, your IAR receives compensation in connection with the sale of those products. This creates a conflict of interest as your IAR has an incentive to sell you a variable annuity thereby receiving a commission, and then offer to advise you with respect to the variable annuity sub‐accounts, thereby also receiving an Advisory Fee. To mitigate this conflict of interest, among other things, you are not required to purchase any brokerage products through JWCF. Benefits Received from Brokerage Service Providers: Brokerage service providers frequently offer us other products and services that assist us in managing and administering Clients’ Advisory Accounts, but these may not directly benefit your Account. JWCA often uses many of these products and services to service all, or a substantial number of, our Client accounts, including providing these services for accounts that are not utilizing alternate broker/dealer services. These products and services include software and other technology that: 1. provide us access to Client account data, such as trade confirmations and account statements; 2. facilitate trade execution and allocate aggregated trade orders for multiple Client accounts; 3. provide market reports, pricing and other economic data; 4. facilitate payment of our fees from our Clients’ accounts; and 5. assist with back‐office functions, recordkeeping, and Client reporting (See section below “Soft Dollars” for research benefits received. Brokerage service providers also offer a wide variety of other services intended to help us manage and further develop our business enterprise. These services include support and assistance in such areas as: business consulting; publications; conferences on practice management and business succession, and access to employee benefits providers; human capital consultants; and insurance providers. Brokerage 26  service providers, at times, provide other benefits to us, such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend a custodian for your assets, JWCA and/or your IAR may take into account the availability of some of these services and other arrangements as part of the total mix of factors considered, in addition to the nature, cost or quality of custody and brokerage services. The availability of these services from brokerage service providers creates a conflict of interest. To mitigate this conflict, JWCA does not encourage or limit the above benefits of these products and services to only those Clients utilizing a specific brokerage service provider’s service. Instead, JWCA allows the use of the market data and other services provided by the brokerage service providers or other institutions for the benefit of all Clients. Unless directed otherwise by you, we seek to negotiate commissions, mark‐ups, and other brokerage fees to ensure a reasonable rate based on multiple factors, including execution prices which we review annually to determine their reasonableness. Soft Dollars: The Firm may enter into an agreement with our brokerage service providers to allow JWCA to receive certain brokerage and research products and services that qualify under Section 28(e) of the Securities Exchange Act of 1934. These benefits associated with this agreement may not directly benefit you. Client Referrals: JWCA receives no Client referral fees from our brokerage service providers in exchange for using those providers. Cash Balances: Cash balances in your Advisory Account are placed in a cash sweep account or, in some instances, “cash alternatives,” such as a money market fund which typically pays you interest on the cash in your Advisory Account. As disclosed above, JWCA does not custody Client accounts and you, the Client, have the ability to decide where your Account will be custodied. Cash sweep accounts and money market funds offered through JWCA are typically custodied at NFS through our affiliated broker‐dealer, JWCF. Cash Sweep Accounts Custodied at NFS through JWCF: In an effort to minimize potential conflicts of interest, there is a primary default for cash sweep on the NFS platform. It is referred to as the Bank Deposit Sweep Program (“BDSP” typically a program identified as “QPRMQ”). This option provides you with FDIC protection that other options do not afford. However, the BDSP pays you a lower interest rate than other cash investment options. In some cases, specifically Clients who have certain entity accounts where QPRMQ is not available, the Fidelity Government Money Market Fund (“SPAXX”) will be used. QPRMQ and SPAXX (both BDSPs) are used to hold your cash balances while awaiting reinvestment for eligible accounts. The cash balance in your eligible JWCA Advisory Account will be automatically deposited into the cash sweep account. Note that when your cash balance is placed in a FDIC‐Insured option or a money market fund, the cash balance is not invested in securities. QPRMQ and SPAXX are generally intended to be short‐term investments but, in certain instances, may be held longer‐time periods for those who have current or anticipated distribution needs, or seek FDIC protection of their assets. In the event that cash balances cannot be swept into the QPRMQ or SPAXX, due to a lack of capacity at the banks, the cash will instead sweep into a Fidelity Money Market Fund, MMKT Overflow. The decision to use this alternative option is at the discretion of the Custodian. Cash in your Account will continue to 27  sweep to the MMKT Overflow until bank capacity becomes available. These changes will not affect your Account if you do not use the Bank Deposit Sweep Program BDSP as your core sweep position. As previously mentioned, your cash will be held in a BDSP (QPRMQ or SPAXX) for accounts custodied at NFS, through JWCF. Both BDSPs are considered cash sweep accounts, and both pay you interest on the cash balance of your Advisory Account. That cash balance, however, may also incur several fees depending on the program you are invested: (1) the Advisory Fee, charged by JWCA; (2) an asset‐based fee charged by NFS; and (3) certain internal fees paid to each Program Bank participating. (Additional details about QPRMQ and SPAXX, including information about fees charged by the account manager, can be found in the “Fidelity® Cash Management Account FDIC‐Insured Deposit Sweep Program Disclosure”). In addition to providing a lower interest rate, the BDSPs generate financial benefits for JWCF and NFS. Specifically, NFS receives a fee from participating Program Banks on all assets held by JWCA Clients in the BDSPs. NFS shares a portion of the fee from the participating Program Banks with JWCF pursuant to a revenue sharing agreement equal to a percentage of all participants’ average daily deposits at the Program Bank. The combined amount of interest and revenue share available is determined solely by the Custodian. These financial benefits and fees are not shared with JWCA or your IAR. While the FDIC BDSP offers FDIC protection, participating program banks in the FDIC BDSP pay rates of interest that are typically lower than prevailing market interest rates but may exceed rates available in traditional checking or savings accounts. This will negatively impact your potential returns. Fees paid to JWCF for FDIC BDSP will vary but in no event will they be more than 4.00% on an annualized basis as applied across all Deposit Accounts in QPRMQ. The revenue generated by JWCF may be greater than revenues that could obtain from the sweep options at other firms and may be greater than other core account investment vehicles. Therefore, the recommendation to open a FDIC‐Insured Deposit Cash Sweep account, which will pay you lower interest rates than money market investment options, and the potential for JWCF to generate fees based on your use of that account, creates certain conflicts of interest between you and JWCA and/or between you and your IAR. To mitigate this, the IAR does not receive any additional benefit if the account is in an FDIC‐insured account as opposed to any other cash equivalent. As required by federal banking regulations, the participating Program Banks has the right to require seven (7) calendar days prior notice before permitting a withdrawal of any Program deposits. The interest rate payable to Clients is based on the eligible amounts paid by the Program Bank to JWCF, less a fee retained by JWCF. The fee that JWCF receives can be higher than the interest rate payable to Clients and any increase in the fee that JWCF chooses to receive, based on available tiers, will decrease the amount of interest payable to Clients. JWCA Advisory Fee Includes Cash Balances The Advisor Fee charged by JWCA to you is determined based on the total value of the billable assets in your Advisory Account. As previously stated, unless an Advisory Account maintains an excess cash balance (that is 50% or more of the total Advisory Account value, for six (6) consecutive months or longer), the Advisor Fee includes any cash balance in an FDIC‐Insured Deposit Cash Sweep, money market and other cash equivalents. Therefore, JWCA is incentivized to recommend that you maintain your cash positions in your JWCA Advisory Account, as opposed to outside your Advisory Account because this increases the amount of assets in your Advisory Account subject to the Advisory Fee. 28  Mutual Funds, Index Funds, and ETFs: Mutual Funds, Index Funds, and ETFs typically charge their shareholders various fees and expenses associated with their investment management and ongoing operation. These fees generally include a management fee, a shareholder servicing fee, other fund expenses, and sometimes a 12b‐1 fee. As discussed above, in Item 5 “Fees and Compensation”, “Conflicts of Interest Considerations Regarding Mutual Funds and Variable Annuities,” both mutual funds and variable annuities that pay 12b‐1 fees to JWCF create a conflict for JWCA as it incents JWCA to recommend the purchase of such mutual funds and variable annuities in order to increase the revenue to JWCF, an affiliated broker‐dealer. In addition, certain mutual funds pay revenue to JWCF, based on the amount of Client assets, including JWCA Client assets, invested at the mutual fund. This creates a conflict of interest for JWCA to use those mutual funds since they benefit JWCF. For all Advisory Accounts, the Firm seeks to minimize this conflict as described above (See “Conflicts of Interest Considerations Regarding Mutual Funds and Variable Annuities”). Also, the firm does not share such revenue directly with IARs. However, IARs do receive economic benefits or indirect benefits as these revenues support product reviews, marketing and training, annual firm conference costs, other firm events, promotional items, meals or entertainment and/or other non‐cash compensation, as permitted by regulatory rules. Certain Mutual Funds, index funds or ETFs may also impose short term redemption fees for sales of funds that occur prior to the specified period as outlined in the prospectus. Prospectuses are available from your IAR, the fund, or JWCA upon request. Consequently, for any type of mutual fund or variable annuity investment it is important to understand that you may be paying various levels of fees and expenses: you are charged a sales load when you purchase a mutual fund or variable annuity, there is a layer of fees and expenses that is paid at the fund or annuity level, as discussed above, and another layer of fees is paid by you directly to JWCA and your IAR to manage your Advisory Account (e.g., Advisor Fee). In addition, JWCA or the custodian may impose a Program Fee to maintain your advisory assets and execute transactions. NFS also offers JWCF access to its No Transaction Fee Program (“NTF Program”). As part of the NTF Program, NFS waives transactions fees that it, and JWCF, would have otherwise charged the Client for purchases and sales of certain mutual funds available on NFS’ platform. Instead of charging a transaction fee (i.e., transaction cost), these funds generally have higher internal fees and expenses than a similar, non‐NTF Program fund. Such fees and expenses negatively impact the performance of the fund over time. Depending on how long you remain invested in NTF Program mutual funds, you may pay more in fees than you would if you had invested in a non‐NTF Program fund and paid the transaction charge at purchase. These NTF mutual funds are sold under a prospectus wherein the various share classes and internal fees are outlined. The Firm strongly encourages you to review the fund prospectus. The specific funds that are part of NFS’ NTF Program are determined by the mutual fund companies and the custodian, and not by JWCA or its affiliated broker‐dealer, JWCF. Certain NTF funds are designated by the custodian as an iNTF, also referred to as a Managed NTF. These funds do not incur a transaction charge, and their specified share classes have lower internal fees and expenses compared to the specified share class of the same fund that is designated as an NTF. When available, and if determined that this share class option is in your best interest, we will convert it to this share class. The Firm does not maintain proprietary models and does not promote or encourage the use of specific mutual funds. 29  Directed Brokerage: Retail brokerage services are made available through NFS, which has an agreement with JWCF, an affiliated broker‐dealer. Depending on the advisory program you select, JWCA generally requires Clients to agree in their advisory agreement that their Account(s) are introduced by JWCA on a fully disclosed basis, and that securities purchase and sale transactions in their Account(s) shall be directed through JWCF. You should consider that not all investment advisory firms allow Clients to direct execution of transactions through a specific broker‐dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, NFS on behalf of JWCF, subject to JWCF policies, policies which help to assure that the resultant price to the Client is as favorable as possible under the prevailing market conditions. Trade Allocation Policy Review: JWCA has adopted a trade allocation policy to govern how we handle the aggregation of orders for multiple Client Accounts. We may aggregate orders for securities transactions for more than one Client. In appropriate circumstances, the aggregation may include proprietary accounts (e.g., personal accounts of IARs). We strive to treat each Client fairly and will not favor any given Client or proprietary account. When executed, we will allocate the aggregated order with the intent to achieve fair treatment. The purpose of aggregating orders is for our administrative convenience and, in some transactions, to obtain better execution for the aggregated order than what might have otherwise been achieved if each of the transactions was processed separately. A consequence of not aggregating a Client’s order with other orders for the same securities is that the Client may not obtain as favorable of a price, or as low of a cost in a separate transaction, as Clients whose orders have been aggregated. Each account that participates in an aggregated order will participate at the average share price for all transactions in the security attributable to that aggregated order. If permitted by the broker‐dealer affecting the transaction, transaction costs will be shared on a pro rata basis. If an aggregated order is not filled in its entirety, it will be allocated among participating accounts on a fair and equitable basis. This is typically done on a pro rata basis. Item 13: Review of Accounts IARs provide regular investment advice and periodically monitor their Clients’ Accounts. As part of the investment process, IARs may schedule annual Client meetings, or meet at the Client’s request. Meetings are generally conducted in person but can be conducted by telephone or other forms of communication. During a Client meeting, the IAR will generally review the Client’s financial situation and investment objectives, the performance of the Client’s Account, and verify that that the portfolio is still consistent with the Client’s stated investment objectives, asset allocation, and risk tolerance. JWCA may also review the Client’s Account based on, among other things: material market, economic or political events, transaction activity, or changes in your financial situation, (such as retirement, termination of employment, physical move, or inheritance), large deposits or withdrawals from your Account, or in response to your request for an additional review. If we provide you with portfolio management services, we may prepare portfolio reports, depending on the size of your Account, and whether the money manager, broker‐dealer, or custodian involved in the relationship regularly produces reports. However, for the most part, we rely on the custodians and third‐ party investment advisers to send written reports directly to you, or to your IAR, who in turn distributes them to you. Reports provided directly to you by JWCA will include security and cash transactions, along with end of period holdings. 30  Each Client of JCWA will receive a quarterly report detailing his/her Advisory Account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Item 14: Client Referrals and Other Compensation JWCA must disclose any economic benefits the firm, its’ IARs, or its’ affiliates receive for providing investment advice and other services to you, as described in “Item 10 ‐ Other Financial Industry Activities and Affiliations.” Additionally, when serving as licensed insurance agents, accountants, attorneys or in other professional capacities distinct from JWCA, our IARs may receive other forms of compensation. As described above, while this creates a conflict of interest, we mitigate this conflict by not requiring you to purchase such other products or professional services. We also describe in “Item 12 Brokerage Practices” that we receive ancillary benefits, services and products from custodians and broker‐dealers. A conflict of interest exists for JWCA as certain TPIAs or TPIA platforms in which you may invest will pay JWCA marketing fees and provide revenue sharing or other indirect compensation (collectively “indirect compensation”). As of March 31, 2025, AssetMark, among others, pay indirect compensation to JWCA based on the JWCA Client assets invested in their TPIA platforms. These third‐parties can change at any time. Please see the J.W. Cole website, “Indirect Compensation Disclosures” for the most up‐to‐date disclosures. While the amounts paid to us differ with each TPIA, AssetMark represents the greatest source of indirect compensation to JWCA. However, no indirect compensation from any TPIA exceeds an average of 10bps (.10%) of customer assets and indirect compensation does not impact the overall payout percentage to your IAR. For example, if you invest $10,000, JWCA could be paid up to $10.00 in indirect compensation. This does not impact the Advisory Fee you pay to JWCA. We help mitigate this conflict because IARs do not receive any portion of the indirect compensation directly, nor are they specifically aware of JWCA’s specific arrangements related to Indirect compensation. Also, you may choose among various management platforms, regardless of the amount of indirect compensation paid to JWCA. Although IARs do not receive the above stated indirect compensation, certain IARs may receive economic benefits or indirect benefits such as fees to support product reviews, marketing and training, technology, annual firm conference costs, other firm events, promotional items, meals or entertainment and/or other non‐cash compensation. Further, such benefits and other non‐cash compensation are also received by IARs from representatives of mutual fund companies, insurance companies, and direct participation sponsors, as well as TPIAs, as permitted by regulatory rules. In addition, the sale of mutual funds, variable insurance products, and other products, and the use of TPIAs by an IAR, at times, qualifies our IARs for additional business support and for attendance at seminars, conferences, and entertainment events. However, you are always free to choose which mutual fund, insurance company, TPIA, or direct participation sponsor in which you want to invest. Finally, some JWCA IARs are compensated at different levels, depending on the product or program in which you are invested. In these cases, those IARs will receive a higher overall percentage of the Advisor Fee split between JWCA and the IAR based on the TPIA platform they recommend, excluding ERISA accounts. This creates a conflict of interest because your IAR may be incented to direct your assets into programs that compensate the IAR at a higher level. However, we mitigate this conflict by charging you the same range of Fees regardless of your IAR’s compensation level. We encourage you to ask your IAR about their compensation level in different programs. Client Referrals - Paid Promotor Arrangements: JWCA permits the compensated endorsement of third‐party “Paid Promoters” such as attorneys, tax professionals, accountants, insurance agents, banks or other broker/dealers and investment advisers, for 31  referring your advisory business to our Firm. However, while JWCA also allows client testimonials, the Firm does not permit client to be compensated for such testimonials. If you are referred to us by a third‐party Paid Promoter, you will receive a separate Paid Promoter Disclosure Document describing our solicitation arrangements with that entity or individual, how the Promoter is compensated, and the terms of that relationship. You will also receive a copy of this brochure. Item 15: Custody Except as stated below, we do not maintain physical custody of Client funds or securities. Custody for investment management accounts is maintained by either Fidelity (NFS and IWS), Schwab, or other approved custodians. You will receive account statements directly from your custodian at least quarterly. We encourage you to carefully review these statements upon receipt. We do not have access to Client funds or securities except as stated below and for having Advisor Fees deducted from Client accounts and paid to us by the custodian. Any Fee deductions will be done pursuant to Client’s written authorization provided to the custodian. However, we do have custody as a result of Standing Letters of Instruction (“SLOI”). The SEC issued a no‐ action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an investment adviser which has the power to disburse Client funds to a third‐party pursuant to an SLOI” is deemed to have custody. JWCA has custody for this limited purpose. As a result, our firm has adopted the following safeguards with our custodians: The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third‐party’s name, and either the third‐party’s address or the third‐party’s account number at a custodian to which the transfer should be directed pursuant to the SLOI. • The Client authorizes JWCA as the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third‐party either on a specified schedule or from time to time. • The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization and provides a transfer of funds notice to the Client promptly after each transfer. • The Client has the ability to terminate or change the instruction to the Client’s qualified • • custodian. JWCA has no authority or ability to designate or change the identity of the third‐party, the address, or any other information about the third‐party contained in the Client’s instruction. JWCA maintains records showing that the third‐party is not a related party of the investment adviser or located at the same address as the investment adviser. • The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Your IAR will manage your assets on either a discretionary or nondiscretionary basis. Discretionary authority grants your IAR the authority, to buy or sell securities for your portfolio, as well as the amount of securities to buy or sell, without obtaining your specific contemporaneous consent. However, your IAR is required to exercise discretion that is consistent with your financial profile, investment objectives, any written investment guidelines, and any restrictions you established with us in writing to limit our 32  discretionary authority in relation to your Account. You must expressly authorize your IAR, in writing, either at the beginning of your advisory relationship for your specific advisory service, or at the time discretion is requested, in order for your IAR to trade on a discretionary basis for your Account. You may also be required to sign an agreement with your custodian, which generally includes a limited power of attorney. This limited power of attorney grants your IAR the authority to direct and implement the investment and reinvestment of your assets within the Account. In no case does discretion, or a limited power of attorney, grant either JWCA or your IAR the authority to transfer or withdraw securities, funds, or assets from your Account, except for JWCA’s deduction of Advisor Fees. Item 17: Voting Client Securities As a matter of firm policy and practice, JWCA is not responsible for forwarding or responding to any proxy solicitations resulting from securities held in your Account, including proxies for annual meetings or special meetings of shareholders. The custodians will forward proxy solicitation materials to you directly for your response or inquiry. Third‐party managers (e.g. TPIAs) may vote proxies if authorized to do so in your agreement. Neither JWCA nor its IARs will vote proxies for you. Item 18: Financial Information As an investment adviser, we must provide you with certain financial information or disclosures about our financial condition if we have financial commitments that impair our ability to meet contractual and fiduciary commitments to you. We have not been the subject of a bankruptcy proceeding and do not have any financial commitments that would impair our ability to meet any contractual or fiduciary commitments to you. © 2026 J.W. Cole Advisors 33 

ASSET-BASED ADVISORY ACCOUNT Cover Page Sponsored by J.W. COLE ADVISORS, INC. SEC File No: 801-60722 CRD No: 112294 4301 Anchor Plaza Parkway, Suite # 450 Tampa, FL 33634 www.jw-cole.com (866) 592-6531 March 31, 2026 This wrap fee program brochure provides information about the qualifications and business practices of J.W. Cole Advisors, Inc. (“JWCA”), a U.S. Securities and Exchange (“SEC”) registered Investment Adviser (“IA”). If you have any questions about the contents of this Brochure, please contact the JWCA Compliance Department Toll Free at (866) 592-6531. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about JWCA also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 Material Changes There have been no material changes since the last update. DISCLAIMER We recommend that you read our entire Brochure. You may request a copy of the Brochure by contacting our corporate office (866) 592-6531 or by email to: compliance@jw-cole.com. Additional information about JWCA is available at www.jw-cole.com and via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered, or are required to be registered, as Investment Advisor Representatives (“IARs”) of JWCA. As required by the SEC rules, we will annually mail clients a summary of any material changes to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary, including a new Brochure based on changes or new information, at any time, without charge. 2  Item 3 Table of Contents Cover Page .................................................................................................................................................... 1 Item 2 Material Changes ............................................................................................................................... 2 Item 3 Table of Contents............................................................................................................................... 3 Item 4 Services, Fees, and Compensation .................................................................................................... 4 Item 5 Account Requirements and Types of Clients ..................................................................................... 6 Item 6 Portfolio Manager Selection and Evaluation ..................................................................................... 6 Item 7 Client Information Provided to Portfolio Managers .......................................................................... 9 Item 8 Client Contact with Portfolio Managers .......................................................................................... 10 Item 9 Additional Information .................................................................................................................... 10 3  Item 4 Services, Fees, and Compensation Our Services JWCA sponsors the Asset Based Advisory Account Wrap Fee Program (“Program”), which is a fee only investment advisory program offered on a discretionary or nondiscretionary basis. This is a legacy program, and new accounts are not being opened. If you require your IAR to manage your assets on a non-discretionary basis, you must contemporaneously approve each transaction recommended by your IAR. However, you may authorize, in writing, that your assets be managed on a discretionary basis, if certain qualifications are met. In the discretionary account, your IAR makes investment decisions on your behalf, without your contemporaneous approval. In no case can your IAR withdraw funds or securities without your approval. The Program features investment products and advisory services that we have approved for investment options. If you participate in the Program, we charge you a specified fee which covers our advisory services and many of the costs associated with the fees for executing transactions within your account. Our IARs directly manage your account in the Program on a discretionary or nondiscretionary basis, as specified in your written Asset-Based Advisory Account Agreement (“Agreement”). Our IARs will gather information from you regarding your investment objectives, risk tolerance level, tax status, investment experience, financial status, and other relevant information to develop your investment profile. Your IAR will use the information in your investment profile to design a portfolio of assets consistent with your investment profile. Often, our IARs manage your account in the Program with the intent to diversify your investments and therefore may include various types of securities such as equities, exchange traded funds (“ETFs”), mutual funds, and various fixed income securities. Our IARs may also recommend other types of investments when the IAR deems such investments appropriate based on your investment profile and any restrictions that you may impose. As part of the services within the Program, your IAR will, on an ongoing basis, track the performance of your account(s), review your financial circumstances and investment objectives, meet with you periodically and make appropriate adjustments to your portfolio to facilitate the desired results. Other services within the Program typically include, but are not limited to the following: Investment policy planning; Identification and evaluation of appropriate investment vehicles; • Assessment of your investment needs and objectives; • • Development of a suitable asset allocation strategy designed to help meet your objectives; • • Deployment of selected investment vehicles on your behalf; • Ongoing review of your accounts to monitor adherence to your investment policy guidelines and investment profile; • Recommendations for account rebalancing, if applicable; • Reporting of your account performance and progress; • Fully integrated back-office support systems, including trade execution; • Quarterly transaction confirmation(s) notices and account statements generated and • Provided by Institutional Wealth Services (“IWS”), with custodial services through Fidelity Brokerage Services, LLC., or National Financial Services (“NFS”) 4  Our Fees and Compensation Fees are charged at an account level and not aggregated across accounts. These fees may be charged at a flat rate or tiered schedule and although we may negotiate our fees under certain circumstances, our standard fee schedule is as follows: (please note that there is a minimum Program Fee of $280.00 per year per account). Assets Initial $250,000 $250,000 - $500,000 $500,000 - $1,000,000 $1,000,000 - $2,000,000 Above $2,000,000 Default Advisor Fee 2.65% 2.45% 1.75% 1.50% Negotiable Program Fee 0.30% 0.26% 0.25% 0.24% 0.23% Total Management Fee 2.95% 2.71% 2.00% 1.74% Negotiable The fee for the Program includes both an advisor fee and a program fee. We charge an annual advisor fee based upon a percentage of the market value of your total assets placed under our management. Our advisor fee is negotiable and ranges from 0.25% to a maximum permitted fee of 3.00% of your assets under our management. Our advisor fee does not include brokerage commissions, transaction fees and other clearing and execution costs and expenses. In addition to the advisor fee, the Program charges a program fee which does cover most brokerage commissions, transaction fees and other costs related to executing transactions in your account. The program fee ranges from 0.23% to 0.30% and is also based upon a percentage of the market value of your total assets in the account. The program fee is not negotiable. There is a minimum annual program fee of $280.00 per account. In the event your account activity exceeds 50 trades before your annual account anniversary, additional transaction fees will apply. The total management fee (which includes the sum of the advisor fee and program fee) is payable quarterly, in advance, and upon deposit of any additional funds or securities in the account. We prorate your initial management fee based on the number of calendar days remaining in the calendar quarter, which is due upon execution of your Agreement. We bill your management fee for subsequent quarters based upon the market value of your assets in the account on the last business day of the preceding calendar quarter based on actual days managed over 365 days in the year. We may adjust your quarterly management fee for significant contributions or withdrawals that you notify us about. Generally, you authorize us in the Agreement to invoice NFS or IWS directly and grant NFS or IWS permission to deduct our fees directly from your account. NFS’s or IWS’s periodic statements will show all amounts disbursed from your account, including the amount of our fee. You may terminate this authorization at any time by notifying us in writing. You should also be aware that participation in the Program may cost you more or less than purchasing such services separately. In determining the cost benefit of the Program, you should consider the size of your account, the level of trading and other services that are required to accomplish and maintain your goals and objectives. You should also consider the commissions charged on a per transaction basis and paying a separate fee for advisory services. Our fee may be higher or lower than fees charged by other sponsors of comparable investment advisory programs. 5  Other Fees and Charges In addition to the Program fee that you pay covering most commissions and transaction fees incurred on products in the Program, you may incur certain charges imposed by Institutional Wealth Services, with custodial services through Fidelity Brokerage Services, LLC or NFS. These charges can include, but are not limited to, mutual fund 12(b)-1 distribution fees, certain contingent deferred sales charges, also referred to as short-term redemption fees, and surcharge fee for certain asset classes, on certain mutual funds that are being redeemed, certain IRA and qualified retirement plan fees, transfer taxes, wire transfer and electronic fund fees, check writing fees, SEC expenses on securities transactions, custodial termination fees, postage & handling fees and other fees and taxes on brokerage accounts and securities transactions. Item 5 Account Requirements and Types of Clients Account Requirements We impose certain conditions for starting or maintaining an account. Generally, we require that you have a minimum of $100,000.00 in cash and/or securities to open and maintain an account under the Program. We may require you to add to the amount in order to maintain the minimum or request that the Agreement be terminated. We may waive this requirement on a case-by-case exception basis. Types of Clients We provide the Program to individuals, pension and profit-sharing plans, trusts, estates, corporations, and other business entities. Item 6 Portfolio Manager Selection and Evaluation Advisory Business Your IAR is the portfolio manager for all accounts in the Program. We also offer financial planning and consulting services. We offer clients a diverse menu of financial planning services including, but not limited to, education planning; estate planning; tax planning; risk management; retirement planning; cash flow planning and other investment and non-investment related matters. If you would like us to provide you with financial planning or consulting services, we enter into a separate written agreement with you setting forth the terms and conditions of our engagement, describing the scope of our services to be provided and our fee. Please note, JWCA does not provide legal advice or perform tax preparation services. For additional information regarding these services, and our fees, contact our corporate office, at (866) 592- 6531 or compliance@jw-cole.com to receive a copy of Part 2A of our Form ADV. Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees in this Program (fees based on a share of capital gains on or capital appreciation of your assets). Methods of Analysis, Investment Strategies, Types of Investments and Risk of Loss Methods of analysis include but are not limited to the following: We may utilize fundamental analysis to evaluate securities for potential investments. Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the economic well- 6  being of a financial entity as opposed to only its price movements. When conducting fundamental analysis, we will review a company’s financial statements and consider factors including, but not limited to, whether the company’s revenue is growing, if the company is profitable, if the company is in a strong enough position to beat its competitors in the future, and if the company is able to repay its debts. We also may utilize technical analysis to evaluate potential investments. Unlike fundamental analysis, technical analysis does not analyze the company’s value, but instead analyzes the stock’s price movement in the market. Charting is a form of technical analysis in which the various technical factors are diagrammed in order to illustrate patterns. Technical analysis studies the supply and demand in the market in an attempt to determine what direction, or trend, will continue in the future. Cyclical analysis is another form of technical analysis which focuses on the regularity of movements in the stock market and times trading to coincide with anticipated market cycles. However, there are risks involved with this method, including the risk that the trends will change unpredictably, which is why we use a combination of methods and obtain information from a variety of sources. We obtain information from a number of sources, both public and by purchase, including financial newspapers and magazines, inspections of corporate activities, research materials prepared by third- parties, corporate rating services, annual reports, prospectuses and filings with the SEC and company press releases. We believe these resources for information are reliable and regularly depend on these resources for making our investment decisions; however, we are not responsible for the accuracy or completeness of this information. Investment Strategies We use a variety of investment strategies depending on your circumstances, financial objectives and needs. We may recommend implementing one or more of the following investment strategies: long-term purchases (held at least a year); short-term purchases (held less than a year); trading (held less than 30 days); margin transactions (purchase of a security on credit extended by a securities company); and option strategies. We may recommend implementing these strategies using stocks, bonds, mutual funds, municipal securities, options contracts, interests in partnerships, investing in real estate or oil and gas interests, and other types of investments. Mutual funds of different kinds may be used to promote portfolio diversification within various asset classes, such as industry sectors, domestic/international, or equities/bonds. We may recommend periodic purchases, sales, and exchanges of those mutual fund shares within mutual fund families and between different mutual fund families when there are changes in your needs, market conditions, or economic developments. Types of Investments and Risk of Loss We offer advice about a wide variety of investment types, including but not limited to mutual funds, index funds, ETFs, stocks, bonds, and a variety of fixed income securities, each having different types and levels of risk. We will discuss these risks with you in determining the investment objectives that will guide our investment advice for your account. We will explain and answer any questions you have about these kinds of investments. Investing in securities involves risk of loss that you should be prepared to bear. Obtaining higher rates of return on investments vs. bank guaranteed rates typically entails accepting higher levels of risk. We do 7  not represent, warrant, or imply that our services or methods of analysis can, or will, predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. We will work with you to attempt to identify the balance of risks and rewards that is appropriate and comfortable for you. However, it is still your responsibility to ask questions if you do not understand fully the risks associated with any investment or investment strategy. It is incumbent upon you to monitor the fees and activity in your account. If you do not notify us of transactions or fees you believe are not suitable for you within sixty (60) days of the occurrence(s), we will assume you have reviewed and accept as suitable the transactions and/or fees. Also, while we strive to render our best judgment on your behalf, many economic and market variables beyond our control can affect the performance of your investments and we cannot assure you that your investments will be profitable or that no losses will occur in your investment portfolio. Past performance is one consideration with respect to any investment or investment advisor, but it is not a predictor of future performance. Mutual Funds, Index Funds and ETFs and/or other non-cash compensation, as permitted by regulatory Mutual Funds, Index Funds, and ETFs typically charge their shareholders various fees and expenses associated with their investment management and ongoing operation. These fees generally include a management fee, a shareholder servicing fee, other fund expenses, and sometimes a 12b-1 fee. Both mutual funds and variable annuities that pay 12b-1 fees to JWCF create a conflict for JWCA as it incents JWCA to recommend the purchase of such mutual funds and variable annuities in order to increase the revenue to JWCF, an affiliated broker-dealer. In addition, certain mutual funds pay revenue to JWCF, based on the amount of Client assets, including JWCA Client assets, invested at the mutual fund. This creates a conflict of interest for JWCA to use those mutual funds since they benefit JWCF. For all Advisory Accounts, the Firm mitigates this conflict by requiring its IARs to act in the Client’s best interest when recommending mutual funds and annuities, and their respective share classes; supervising IARs’ recommendations and advice; and, with respect to mutual funds, regularly converting mutual fund share classes that charge 12b-1 fees to lower-cost share classes when appropriate. 12b-1 fees associated with mutual funds are automatically credited back to your Advisory Account by NFS, or maintained by other custodians (but not paid to JWCA). Also, the firm does not share such revenue directly with IARs. However, IARs do receive economic benefits or indirect benefits as these revenues support product reviews, marketing and training, annual firm conference costs, other firm events, promotional items, meals or entertainment rules. Certain Mutual Funds, index funds or ETFs may also impose short term redemption fees for sales of funds that occur prior to the specified period as outlined in the prospectus. Prospectuses are available from your IAR, the fund, or JWCA upon request. JWCA reviews whether you are invested in the mutual fund share class with the lowest overall fees available on the specific platform in which your mutual fund assets are custodied. The review may determine you are invested in a share class that pays 12b-1 fees, even though a lower cost share class is available. The Firm remedies this conflict by initiating on a regular basis a share class conversion, on applicable Client assets, from a higher cost share class to a lower cost share class, if we determine that conversion is in your best interest. However, certain limitations may apply that would cause the Firm to not to convert the funds to a lower share class including, but not limited to, minimum investment requirements by the mutual fund, surcharges imposed by the custodian, short-term redemption fees, etc. Because custodians may assess different surcharges, some mutual fund share classes deemed to be most appropriate at one custodian may not be so at another custodian. 8  Additionally, as stated above, to the extent a non-12b-1 fee paying fund share class is unavailable on the NFS platform, any 12b-1 fees generated are automatically credited back your Account by NFS. If your IAR, in their capacity as a registered representative with JWCF, elects to receive a commission on certain investments made with assets held in your account, this creates a conflict of interest. There is an incentive to recommend investment products based on the compensation received, rather than on your needs. Your IAR is therefore required to waive the advisor fee on these assets for a period of time. Other fee-excluded assets may be marked as such by your IAR when there is no true active management or investment advice being given. Examples include: fixed income securities being held to maturity; securities with disadvantaged tax consequences; restricted, control, affiliate, employee securities or other investments you may have an attachment to; and existing investments not recommended to you by your current IAR. The time period of these advisor fee exclusions will be determined on a case-by-case basis. The payments requiring advisor fee waiver do not include any 12b-1 payments, which are not considered commissions for purposes of fee waiver consideration. It is important to note that the resulting commission paid to your IAR may be higher than the amount of your advisor fee as agreed upon in your signed agreement. Also, we may recommend “no-load” mutual funds, which do not have a commission or sales charge because the shares are distributed directly by the investment company, instead of going through a secondary party. Some mutual funds may be purchased directly, without using our services and without incurring our advisor fees. As described in more detail in the section of our ADV Part 2A Brochure titled “Other Financial Industry Activities and Affiliations”, many of our IARs are also Registered Representatives (“RRs) with JWCF and licensed to sell securities products. If you choose to purchase brokerage products from one of our IARs in their capacity as a RR of JWCF, you should be aware that they may receive compensation in connection with the sale of those products. To mitigate any conflict of interest, we do not require you to purchase any brokerage products we recommend through JWCF, and you may choose to use an unaffiliated broker- dealer. Voting Client Securities As a matter of firm policy and practice, we will not be responsible for responding to proxies solicited with respect to annual or special meetings of shareholders of securities held in your account. Proxy solicitation materials will be forwarded to you for response and voting. The custodians will forward proxy solicitation materials to you directly for your response or inquiry. Third-party managers (e.g. TPIAs) may vote proxies if authorized to do so in your agreement. Neither JWCA nor its IARs will vote proxies for you. Item 7 Client Information Provided to Portfolio Managers As the portfolio managers, your IARs have access to all of the information you provide to them, including your financial information, investment objectives, risk tolerance level, tax status, investment experience, financial status, and other information relating to your investment profile. JWCA has adopted a Privacy Policy, in accordance with Regulation S-P under section 504 of the Gramm-Leach-Bliley Act, which restricts our firm’s use and your IARs’ use of, and access to, your nonpublic personal information. In order for our IARs to effectively manage your account and assist you in helping to meet your financial objectives, you 9  must update your IAR as soon as possible when any changes to your personal or financial information occur. You may obtain a complete copy of our Privacy Policy by contacting our corporate office at (866) 592- 6531 or compliance@jw-cole.com. Item 8 Client Contact with Portfolio Managers Our IARs manage your account in the Program directly. As a client of the Program and as a client of our IAR, you will have unfettered access to contact and consult with the IAR who is managing your assets under the Program. Item 9 Additional Information Disciplinary Information On August 25, 2021, JWCA, without admitting or denying the findings, consented to the entry of an Order by the Securities and Exchange Commission that its mutual fund share class selection practices resulted in another broker-dealer, with which JWCA maintained an expense sharing arrangement, receiving three types of fees generated by certain transactions in JWCA advisory accounts, without being fully disclosed. Between January 2014 and November 2016, JWCA recommended that JWCA advisory clients purchase or hold mutual fund share classes that charged 12b-1 fees when lower cost share classes were available for the same fund(s). Between January 2014 and March 2021, JWCA recommended that JWCA advisory clients purchase or hold mutual fund share classes which resulted in another broker-dealer, with which JWCA maintained an expense sharing arrangement, receiving revenue sharing payments when lower-cost share classes of the same mutual funds were available and would have resulted in no or lower revenue sharing. Additionally, between September 2016 and March 2020, the same broker-dealer received revenue sharing payments when client assets were invested in certain share classes of money market funds used as “cash sweep vehicles” when other, non-revenue sharing money market fund options were available. JWCA failed to adequately disclose to advisory clients the above conflicts of interest relating to the payments of these fees and its selection of certain mutual fund or money market share classes that paid such fees. As a result of this conduct, JWCA, without admitting or denying the findings, consented to an Order that found JWCA violated Sections 206(2) and 206(4) of the Advisors Act and Rule 206(4)-7 thereunder. Pursuant to the Order, JWCA was ordered to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)- 7. Further, JWCA received a censure and agreed to pay disgorgement, prejudgment interest and a civil penalty totaling $1,957,053.11. JWCA complied with the undertakings enumerated in the Order. To review the order, visit: sec.gov/litigation/admin/2021/ia-5832.pdf. Other Financial Industry Activities and Affiliations JWCA and JWCF are affiliated companies under the common ownership of JWC Wealth Partners. JWCA and JWCF share a physical office location and mutually seek to minimize expenses of administration by sharing certain staff, equipment, supplies, and other administrative and office expenses. When we selected JWCF as a service provider, we considered the variety of JWCF’s services, financial stability and competitive commission rates in our effort to provide brokerage services that meet your 10  needs. Your IAR, if he/she serves in the capacity of a registered representative with JWCF, normally earns commissions on purchases and sales of securities and insurance products. This creates a conflict of interest when your IAR recommends the purchase of product, for which he/she receives a brokerage commission. To mitigate conflicts, JWCA does not require you to purchase any recommended brokerage products from our IARs in their capacity as registered representatives of JWCF, or to utilize JWCF, for any products or services. You are free to purchase such products from another broker-dealer. JWCA and/or its IARs may also have referral arrangements with unaffiliated outside professionals. These referral arrangements may present a conflict of interest because JWCA and/or your IAR may have a direct or indirect financial incentive to recommend another professional’s service as a result of that outside professional’s referral of Clients to JWCA. While we believe that compensation charged by outside professionals is competitive, such compensation may be higher than fees charged by other professionals providing the same or similar services. Some IARs are licensed in other professional capacities such as accountants, attorneys, and insurance agents. These other professional services are separate and distinct from JWCA’s advisory services and are not affiliated with JWCA. IARs of JWCA may also offer fixed insurance through insurance companies unaffiliated with JWCA, therefore JWCA does not supervise the solicitation or sale of these outside products. When you use these other businesses to purchase or sell insurance, or obtain accounting, tax, legal or other professional services, you will incur commissions, fees, and/or other charges. These charges are separate and distinct from JWCA and are not part of JWCA’s Advisor Fees. When an IAR recommends that you utilize such separate service, your use of such services generates additional sources of compensation for the IAR and therefore creates a conflict of interest. To mitigate such conflicts, JWCA will never require you to utilize a separate service offered by your IAR, nor are you required to implement any tax, legal, investment, or other recommendations through such businesses. You are always free to use any accountant, attorney, insurance agent, or any other professional of your choice. In some instances, we may allow your IAR to independently own their own investment adviser firm (“IA”). In such cases, your IAR is then dually registered as an IAR of both JWCA, and their own IA. As a result, your IAR may provide advisory services to you under both their own IA, and under JWCA as described in your written AUM Agreement (including applicable Addendum(s)), or Financial Planning and Consulting Agreement. In every situation, you should carefully consider any conflicts of interest when your IAR offers other advisory professional services through third-party IAs, for which he/she receives additional compensation. JWCA also has a dedicated team of IARs in its corporate office who operate a “doing business as” (“dba”) unit of both JWCA and JWCF. The dba is known as “JWC Wealth Management” (“JWC Wealth”). In addition, a small subset of those within JWC Wealth, who are IARs of JWCA, operate their own offices around the United States. JWC Wealth is not a registered investment adviser. JWC Wealth IARs may service certain Accounts of JWCA Clients that are not currently serviced by other JWCA IARs, and, in some cases, are also compensated as employees of JWCF, which can include such compensation as a salary, bonus and other things of value as set out above. You may request a copy of our Code of Ethics by contacting our corporate office, at (866) 592-6531 or compliance@jw-cole.com. 11  Code of Ethics and Participation or Interest in Client Transactions and Personal Trading JWCA has adopted a Code of Ethics describing the standards of business conduct that it expects its’ officers, directors, employees, and IARs to follow. Our Code of Ethics also describes certain reporting requirements that individuals associated with JWCA, or employed by us, must comply with. JWCF, in its capacity as a broker-dealer, may buy and sell securities in their proprietary Accounts. In addition, IARs buy and sell securities in their own Accounts. These Accounts are known as “proprietary accounts.” Also, your IAR may recommend to you and other Clients, securities in which he/she is personally investing or is recommending to other Clients. Both scenarios create a conflict of interest. To mitigate any potential conflicts, JWCA may aggregate orders for securities transactions for more than one Client to obtain a better overall price. In appropriate circumstances, the aggregation may include proprietary accounts. However, we strive to treat each Client fairly and will not favor any given Client or proprietary account. JWCA does not maintain proprietary accounts. JWCA does not act as principal in securities transactions. Further, we maintain internal policies which generally prohibit IARs from knowingly buying or selling securities from a Client, as principal and/or affecting agency cross-transactions involving a Client. You may request a copy of our Code of Ethics by contacting our corporate office, at (866) 592- 6531 or email us at: compliance@jw-cole.com. Review of Accounts IARs provide regular investment advice and periodically monitor their Clients’ Accounts. As part of the investment process, IARs may schedule annual Client meetings, or meet at the Client’s request. Meetings are generally conducted in person but can be conducted by telephone or other forms of communication. During a Client meeting, the IAR will generally review the Client’s financial situation and investment objectives, the performance of the Client’s Account, and verify that that the portfolio is still consistent with the Client’s stated investment objectives, asset allocation, and risk tolerance. JWCA may also review the Client’s Account based on, among other things: material market, economic or political events, transaction activity, or changes in your financial situation, (such as retirement, termination of employment, physical move, or inheritance), large deposits or withdrawals from your Account, or in response to your request for an additional review. If we provide you with portfolio management services, we may prepare portfolio reports, depending on the size of your Account, and whether the money manager, broker-dealer, or custodian involved in the relationship regularly produces reports. However, for the most part, we rely on the custodians and third- party investment advisers to send written reports directly to you, or to your IAR, who in turn distributes them to you. Reports provided directly to you by JWCA will include security and cash transactions, along with end of period holdings. Each Client of JCWA will receive a quarterly report detailing his/her Advisory Account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Client Referrals and Other Compensation JWCA must disclose any economic benefits the firm, its’ IARs, or its’ affiliates receive for providing investment advice and other services to you, as described in “Item 10 - Other Financial Industry Activities 12  and Affiliations.” Additionally, when serving as licensed insurance agents, accountants, attorneys or in other professional capacities distinct from JWCA, our IARs may receive other forms of compensation. As described above, while this creates a conflict of interest, we mitigate this conflict by not requiring you to purchase such other products or professional services. We also describe in “Item 12 Brokerage Practices” that we receive ancillary benefits, services and products from custodians and broker-dealers. A conflict of interest exists for JWCA as certain TPIAs or TPIA platforms in which you may invest will pay JWCA marketing fees and provide revenue sharing or other indirect compensation (collectively “indirect compensation”). As of March 31, 2025, AssetMark, among others, pay indirect compensation to JWCA based on the JWCA Client assets invested in their TPIA platforms. These third-parties can change at any time. Please see the J.W. Cole website, “Indirect Compensation Disclosures” for the most up-to-date disclosures. While the amounts paid to us differ with each TPIA, AssetMark represents the greatest source of indirect compensation to JWCA. However, no indirect compensation from any TPIA exceeds an average of 10bps (.10%) of customer assets and indirect compensation does not impact the overall payout percentage to your IAR. For example, if you invest $10,000, JWCA could be paid up to $10.00 in indirect compensation. This does not impact the Advisory Fee you pay to JWCA. We help mitigate this conflict because IARs do not receive any portion of the indirect compensation directly, nor are they specifically aware of JWCA’s specific arrangements related to Indirect compensation. Also, you may choose among various management platforms, regardless of the amount of indirect compensation paid to JWCA. Although IARs do not receive the above stated indirect compensation, certain IARs may receive economic benefits or indirect benefits such as fees to support product reviews, marketing and training, technology, annual firm conference costs, other firm events, promotional items, meals or entertainment and/or other non-cash compensation. Further, such benefits and other non-cash compensation are also received by IARs from representatives of mutual fund companies, insurance companies, and direct participation sponsors, as well as TPIAs, as permitted by regulatory rules. In addition, the sale of mutual funds, variable insurance products, and other products, and the use of TPIAs by an IAR, at times, qualifies our IARs for additional business support and for attendance at seminars, conferences, and entertainment events. However, you are always free to choose which mutual fund, insurance company, TPIA, or direct participation sponsor in which you want to invest. Finally, some JWCA IARs are compensated at different levels, depending on the product or program in which you are invested. In these cases, those IARs will receive a higher overall percentage of the Advisor Fee split between JWCA and the IAR based on the TPIA platform they recommend, excluding ERISA accounts. This creates a conflict of interest because your IAR may be incented to direct your assets into programs that compensate the IAR at a higher level. However, we mitigate this conflict by charging you the same range of Fees regardless of your IAR’s compensation level. We encourage you to ask your IAR about their compensation level in different programs. JWCA permits the compensated endorsement of third-party “Paid Promoters” such as attorneys, tax professionals, accountants, insurance agents, banks or other broker/dealers and investment advisers, for referring your advisory business to our Firm. However, while JWCA also allows client testimonials, the Firm does not permit client to be compensated for such testimonials. If you are referred to us by a third-party Paid Promoter, you will receive a separate Paid Promoter Disclosure Document describing our solicitation arrangements with that entity or individual, how the Promoter is compensated, and the terms of that relationship. You will also receive a copy of this brochure. 13  Financial Information As an investment adviser, we must provide you with certain financial information or disclosures about our financial condition if we have financial commitments that impair our ability to meet contractual and fiduciary commitments to you. We have not been the subject of a bankruptcy proceeding and do not have any financial commitments that would impair our ability to meet any contractual or fiduciary commitments to you. 14