MOSS, LUSE & WOMBLE, LLC

MOSS, LUSE & WOMBLE, LLC 5160 Tennyson Parkway, Suite 2000W Plano, Texas 75024 (P) 972.674.2584 (F) 469.461.5751 www.mlwfinancial.com October 27, 2025 This brochure provides information about the qualifications and business practices of Moss, Luse & Womble, LLC. If you have any questions about the contents of this brochure, please contact us at (972) 674-2584 or jeff@mlwfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as a registered investment advisor does not imply a certain level of skill or training. Additional information about Moss, Luse & Womble, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. The firm’s CRD# 152841 may be used as a search term on the SEC website to look up the additional information.  ITEM 2: MATERIAL CHANGES July 30, 2025 – Item 10 was updated to disclose Third-Party Administrator services and fees. The material changes discussed above are only those changes that have been made to this brochure since the firm’s last annual update of the brochure. The date of the last annual update of the brochure was February 27, 2025. 2 | P a g e Moss, Luse & Womble, LLC  ITEM 3: TABLE OF CONTENTS Table of Contents ............................................................................................................................ 3 Item 3 Advisory Business ............................................................................................................................. 4 Item 4 Fees and Compensation ................................................................................................................... 5 Item 5 Performance-Based Fees and Side-by-Side Management ............................................................... 8 Item 6 Item 7 Types of Clients ................................................................................................................................ 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 8 Disciplinary Information ................................................................................................................. 11 Item 9 Item 10 Other Financial Industry Activities and Affiliations ........................................................................ 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 12 Item 11 Brokerage Practices ........................................................................................................................ 12 Item 12 Review of Accounts ........................................................................................................................ 14 Item 13 Client Referrals and Other Compensation ..................................................................................... 14 Item 14 Custody .......................................................................................................................................... 14 Item 15 Investment Discretion .................................................................................................................... 14 Item 16 Item 17 Voting Client Securities .................................................................................................................. 15 Financial Information ..................................................................................................................... 15 Item 18 3 | P a g e Moss, Luse & Womble, LLC  ITEM 4: ADVISORY BUSINESS Moss, Luse & Womble, LLC is a registered investment advisor firm registered (initially with a predecessor firm, Moss, Luse & Womble, LLP) with the U.S. Securities and Exchange Commission since April 10, 2019. Prior to that date, the firm was registered with the states of Texas, Louisiana, and Colorado securities regulators from March 5, 2010, November 12, 2010, and January 13, 2017, respectively. The Principal Owners of Moss, Luse & Womble, LLC are: Moss MLW, LLC (principal owner is Jeffrey M. Moss) Luse MLW, LLC (principal owner is Jason S. Luse) Womble MLW, LLC (principal owner is Michael A. Womble) Portfolio Management Services Moss, Luse & Womble, LLC’s (“Moss, Luse & Womble” or “Advisor”) principal service is providing fee- based portfolio management services and financial planning services. The Advisor practices custom management of portfolios, on a discretionary basis, according to the client’s objectives. The Advisor’s primary approach is to use a tactical allocation strategy aimed at reducing risk and increasing performance. While Moss, Luse & Womble can advise on any investment asset, our recommendations are primarily related to investments in exchange traded funds and mutual funds. The Advisor measures and selects mutual funds by using various criteria, such as the fund manager’s tenure, and/or overall career performance. The Advisor may recommend, on occasion, redistributing investment allocations to diversify the portfolio in an effort to reduce risk and increase performance. The Advisor may recommend specific stocks to increase sector weighting and/or dividend potential. The Advisor may recommend employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. The Advisor may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance. Moss, Luse & Womble will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. Pension Consulting Services Moss, Luse & Womble may offer pension consulting services and participant fiduciary advice to plan participants for assets held at Qualified Plans, pursuant to the Pension Protection Act of 2006. The Advisor’s pension consulting services and participant fiduciary advice will be based on information obtained from the plan participant about goals and investment objectives, time horizon, risk tolerance and the plan participant's financial situation. Moss, Luse & Womble will utilize Investment Policy Statements when providing standardized asset allocation recommendations for the investment assets of plan participants within Qualified Plans. The plan participant is responsible for implementation of recommendations and Moss, Luse & Womble will not act on the plan participants behalf to implement these recommendations. Moss, Luse & Womble may offer other pension consulting services that include but are not limited to plan design and installation, plan administration, educational seminars, plan surveys, evaluations of vendor's services or special projects on behalf of the plan sponsor. 4 | P a g e Moss, Luse & Womble, LLC  Financial Planning Moss, Luse & Womble will provide financial planning services to its clients. The Advisor will provide a full day initial consultation with the client to discuss client’s financial goals and objectives and develop a financial plan. The Advisor will discuss recommendations, which may include topics such as retirement needs, investments, taxes, insurance, estate planning, business planning and other relevant topics with client. Under the initial financial planning agreement, the Advisor will also provide the client with ongoing monitoring of the financial plan for up to 90 days. Clients may then engage the Advisor to perform ongoing monitoring under a separate agreement. During the monitoring of client’s financial plan, the Advisor will continually develop and adjust client’s financial plan, monitor the progress of the plan in relation to meeting the client’s financial goals and objectives, continue to offer recommendations and advice pertinent to the client’s financial plan and individual situation with respect to their relevant topics. The monitoring of client’s financial plan will include scheduled and unscheduled phone calls and meetings to discuss relevant topics. All of the Investment Advisor Representatives of Moss, Luse & Womble provide general non-securities advice on topics such as: tax planning, estate planning, business planning, payroll services, budgeting and cash flow. Moss, Luse & Womble will tailor its advisory services to its client’s individual needs based on meetings and completion of a client profile. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions with the client to have a clear understanding of the client’s requirements. Moss, Luse & Womble does not provide portfolio management services to wrap fee programs. Moss, Luse & Womble manages client assets and as of December 31, 2024, manages $595,179,000 in discretionary client assets under management. ITEM 5: FEES AND COMPENSATION Asset Management Fees Client will pay the Advisor for compensation for its services under this Agreement, an advisory fee at an annual rate of up to 0.45% of assets being managed by the Advisor. The advisory fee is payable quarterly either in advance or arrears depending on the capabilities of the custodian, and is based on the balance of the portfolio assets at the end of each quarter. Fees may be reduced or waived at the sole discretion of the Advisor. These fees may be negotiated at the sole discretion of the Advisor. In most situations, the qualified custodian will directly deduct asset management fees from the client account on a quarterly basis pursuant to instructions from the Advisor. The client will give written authorization permitting the Advisor to be paid directly from their account held by the custodian and the custodian will send a quarterly statement to the client. For those cases where direct fee deduction is not appropriate in the circumstances or not authorized by the client, client will be invoiced each quarter for the advisory fee and is due upon receipt. 5 | P a g e Moss, Luse & Womble, LLC  Expenses related to the ordinary servicing of the Account by the custodian, including, custody fees, security transaction fees, and/or platform fees shall be paid by the Client. Other non-ordinary fees or fees incurred by the Advisor at the direction of the Client shall be paid by the Client. Operating fees of selected mutual funds and other investment products are deducted from the net asset value of those investments as defined in the prospectus for each product. The Advisor shall not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds in which the Client is invested. Except as described in Item 15, the Advisor will generally not accept or maintain custody of a client’s funds or securities except for authorized fee deduction. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The Advisor’s fee is separate and distinct from the custodian and execution fees. Clients may request to terminate their advisory contract with the Advisor, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any unearned fees will be refunded to client. Client’s advisory agreement with the Advisor is non-assignable without client’s prior written approval. Fixed Fees/Hourly Fees for Financial Planning and Pension Consulting Services Fees For Ongoing Financial Planning Monitoring Services: The Advisor will charge a fixed fee for ongoing financial planning monitoring services as follows: • A fee ranging up to $855 per month for business owners of one business, plus an additional $100 per month for each additional business owned, for a minimum of five months, will be charged in advance on an ongoing basis until the Agreement is terminated. • The actual monthly fee will depend on the complexity and scope of services to be provided. The highest fee is applicable to clients that have small business financial planning monitoring needs in addition to their personal needs. • Fixed fees may be negotiated at the discretion of the Advisor. It is assumed the standard time involved in the monitoring of Client’s financial plan will not exceed 28 hours in a calendar year. Excess time over standard can be due to various reasons including above average complexity of Client’s financial situation, difficulties arising from implementation with other professional advisor(s), and/or above average phone calls and meetings initiated by Client during the course of the engagement. In order to dedicate additional resources in these circumstances, Advisor may need to bill excess hours at $260.00 per hour. Fees for Pension Consulting Services: The Advisor provides the Pension Consulting Services described in Item 4 above for Financial Planning clients only, and the fee for those services are included in the Ongoing Financial Planning Monitoring Services fees described above. Where the Client engages Moss, Luse & Womble to provide plan design, installation and administration services, separate fees will be charged for these services as follows: Standard 401(k) Plan (15 or less employees in prior tax year) - $235 per month 6 | P a g e Moss, Luse & Womble, LLC  Large 401(k) Plan (16 or more employees in prior tax year) Standard Cash Balance Plan (15 or less employees in prior tax year) Large Cash Balance Plan (16 or more employees in prior tax year) - $270 per month - $470 per month - $505 per month The plan design, installation and administration services fee is charged monthly in advance. Other Pension Transaction Fees: Moss, Luse & Womble will charge the following transaction fees for services as requested by a 401(k) Plan: Transaction Termination Distribution In-Service Distribution Hardship Distribution Loan Origination QDRO Takeover Fee for Existing Plans Interim Valuation for Standard Interim Valuation for Large Plan Termination Fee $100.00/1099 $100.00/1099 $100.00/1099 $500.00 $500.00 $750.00 $1,000.00 $1,500.00 $750.00 Responsible Party Participant Account Participant Account Participant Account Participant Account Participant Account Plan Sponsor Plan Sponsor Plan Sponsor Plan Sponsor Moss, Luse & Womble will charge the following transaction fees for services as requested by a cash balance Plan: Transaction Plan Document for New Plan Takeover Fee for Existing Plans Distribution Plan Amendment Plan Termination Fee $2,350.00 $1,600.00 $225.00 $300.00 $1,000.00 Responsible Party Plan Sponsor Plan Sponsor Participant Account Plan Sponsor Plan Sponsor The Transaction Fees are billed in arrears as the work is completed. For each of the Advisor's services described above, the Client may terminate these services within five business days of the effective date of an Agreement signed with the Advisor without any payment of the Advisor's fee. Where Moss, Luse & Womble’s management fee is payable in advance, upon termination, any fees paid in advance will be prorated to the date of termination and any unearned fees will be refunded to client. Neither Moss, Luse & Womble nor its supervised persons accept compensation for the sale of securities or other investment products or asset-based sales charges or service fees from the sale of mutual funds. 7 | P a g e Moss, Luse & Womble, LLC  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Moss, Luse & Womble does not charge performance-based fees. ITEM 7: TYPES OF CLIENTS Moss, Luse & Womble will offer its services to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations or other business entities. Moss, Luse & Womble does not have any minimum requirements for opening or maintaining an account. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Moss, Luse & Womble will utilize a fundamental method of analysis in formulating investment advice or managing assets for clients. Fundamental analysis of businesses involves analyzing its financial statements and health, its management and competitive advantages and its competitors and markets. Fundamental analysis is performed on historical and present data but with the goal of making financial forecasts. There are several possible objectives; to conduct a company stock valuation and predict its probable price evolution; to make a projection on its business performance; to evaluate its management and make internal business decisions and to calculate its credit risk. In order to facilitate investing clients in suitable securities portfolios, Moss, Luse & Womble has developed eight proprietary investment models across which allocations to multiple securities types and asset classes vary depending on the risk profiles of the clients. Generally, the higher the appetite for risk, the greater the portfolio weighting towards growth- oriented asset classes and away from stable-oriented asset classes. The securities types, asset classes and allocation percentages in these models are periodically updated by Moss, Luse & Womble for various reasons, including overall market conditions, and how a security type or asset class responds to outside conditions. Clients have the ability to place restrictions on the securities used, securities types or asset classes in which they are invested, or may choose to have Moss, Luse & Womble portfolio managers develop a customized portfolio. Following are descriptions of the eight models developed by the Advisor and recommended to clients: CAPITAL PRESERVATION The Capital Preservation Risk Profile is designed for the investor with an extremely low threshold for risk tolerance. This could be due to a personal aversion to market volatility or a very short time horizon. The main objective of a portfolio designed for this Risk Profile is to preserve capital without concern over maximizing income or growth. CONSERVATIVE The Conservative Risk Profile is designed for the conservative investor, one with a low risk tolerance. This profile is appropriate when the time horizon is short and there is a current need for some spendable income from the portfolio. The objective of a conservative investor is to primarily preserve capital while allowing for slight price fluctuation in order to create a low level of income. 8 | P a g e BALANCED The Balanced Risk Profile is designed to equally balance the need for income and capital appreciation. This balance should offer moderate, but steady growth of the portfolio over time. The portfolio designed Moss, Luse & Womble, LLC  for this Risk Profile will allow for some market volatility and price fluctuation. A short to moderate time horizon is necessary to allow for this risk. The objective of a balanced investor is to give up some capital appreciation of the portfolio in order to smooth investment returns over time. MODERATE GROWTH The Moderate Growth Risk Profile is designed for the investor that does not require a high exposure to fixed income investments, such as bonds and cash. A portfolio for a moderate growth investor will be more heavily weighted toward diversified equities, which increases the volatility risk and need for a longer time horizon. The main objective is to provide steady, long-term capital appreciation with moderate market volatility. GROWTH The Growth Risk Profile is designed only for the investor with a long time horizon. The growth investor must have a higher tolerance for risk associated with market volatility and price fluctuation when compared to a moderate growth investor. The main objective of a portfolio appropriate for a growth investor is high, long-term capital appreciation with little to no need for spendable income. MODERATE AGGRESSIVE The Moderate Aggressive Risk Profile is designed only for the investor with a long time horizon. The moderate aggressive investor must have a higher tolerance for risk associated with market volatility and price fluctuation when compared to a growth investor. The main objective of a portfolio appropriate for a moderate aggressive investor is high, long-term capital appreciation to last for an extended period of years, with little to no need for spendable income. AGGRESSIVE The Aggressive Risk Profile is appropriate only when the investor has a high tolerance for risk and long time horizon. An aggressive portfolio will allow for substantial fluctuations in value from year to year. The main objective for this Risk Profile is to achieve higher returns by taking on added risk not suitable for other Risk Profiles. There should be no expectation of producing spendable income from the portfolio. An aggressive investor has little to no aversion to risk and can withstand considerable market volatility as a tradeoff for attempting to achieve higher returns. ULTRA AGGRESSIVE The Ultra Aggressive Risk Profile is appropriate only when the investor has a very high tolerance for risk and long time horizon. An ultra aggressive portfolio will allow for extreme fluctuations in value from year to year. The main objective for this Risk Profile is to achieve higher returns by taking on even higher risk when compared to an aggressive investor, which is not suitable for other Risk Profiles. There should be no expectation of producing spendable income from the portfolio. An ultra aggressive investor has little to no aversion to risk and can withstand substantial market volatility as a tradeoff for attempting to achieve higher returns. The investment strategies the Advisor will implement may include long term purchases of securities held at least for one year; short term purchases for securities sold within a year and mutual funds that implement alternative/flexible strategies. Clients need to be aware that investing in securities involves risk of loss that clients need to be prepared to bear. The methods of analysis and investment strategies followed by the Advisor are utilized across all of the Advisor’s clients, as applicable. One method of analysis or investment strategy is not more significant 9 | P a g e Moss, Luse & Womble, LLC  than the other as the Advisor is considering the client’s portfolio, risk tolerance, time horizon and individual goals. However, the client should be aware that with any trading that occurs in the client account, the client will incur transaction and administrative costs. Investing includes the risk that the value of an investment can be negatively affected by factors specifically related to the investment (e.g., capability of management, competition, new inventions by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or terrorism around the world, concern about oil prices or unemployment, etc.). Clients need to be aware that investing in securities involves the risk of loss of some or all of their investment that clients need to be prepared to bear. Risks of fundamental analysis may include risks that market actions, natural disasters, government actions, world political events or other circumstances not directly related to the price or valuation of a specific company’s fundamental analysis can adversely impact the stock price of a company causing a portfolio containing that security to lose value. Risks may also include that the historical data and projections on which the fundamental analysis is performed may not continue to be relevant to the operations of a company going forward, or that management changes or the business direction of management of the company may not permit the company to continue to produce metrics that are consistent with the prior company data utilized in the fundamental analysis, which may negatively affect the Advisor’s estimate of the valuation of the company. While Moss, Luse & Womble can provide investment advice and recommendations on any type of investment security, Moss, Luse & Womble primarily recommends exchange traded funds and mutual funds to meet clients’ investment objectives. Clients are advised that many unexpected broad environmental factors can negatively impact the value of portfolio securities causing the loss of some or all of the investment, including changes in interest rates, political events, natural disasters, and acts of war or terrorism. Further, factors relevant to specific securities may have negative effects on their value, such as competition or government regulation. Also, the factors for which the company was selected for inclusion in a client portfolio may change, for example, due to changes in management, new product introductions, or lawsuits. Following is a list of some of the risks to consider specifically when investing in exchange traded funds and mutual funds. • Call Risk. The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date. • Country Risk. The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Credit Risk. The possibility that a bond issuer will fail to repay interest and principal in a timely manner. Also called default risk. • • • • Currency Risk. The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. Income Risk. The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. Industry Risk. The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. Inflation Risk. The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. 10 | P a g e Moss, Luse & Womble, LLC  • Interest Rate Risk. The possibility that a bond fund will decline in value because of an increase in interest rates. • Manager Risk. The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk. The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk. The possibility that an investment will go down in value, or "lose money," from the original or invested amount. ITEM 9: DISCIPLINARY INFORMATION Neither Moss, Luse & Womble nor its management persons have had any legal or disciplinary events, currently or in the past. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither Moss, Luse & Womble nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither Moss, Luse & Womble nor any of its management persons are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Moss, Luse & Womble does not currently have any relationships or arrangements that are material to its advisory business or clients with either a broker-dealer, municipal securities dealer, or government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund” and offshore fund), other investment advisor or financial planner, futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift institution, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or sponsor of syndicator of limited partnerships. In addition to the investment advisory, pension consulting and financial planning services provided by the Advisor as described in Item 4, Moss, Luse & Womble provides accounting, tax preparation and payroll services to business clients who may also be advisory clients of the firm. Such services are provided for separate compensation. Moss, Luse & Womble also provides Third-Party Administrator (“TPA”) services to defined contributions plans, and receives separate compensation from the defined contribution plans, as described in Item 5 above. In certain limited cases where another plan provider platform is involved with the plans, Moss, Luse & Womble’s TPA business will receive payments from the provider of the other plan services to compensate the firm for its support for the installation of the plan at the other plan services provider of a one-time payment of up to 0.20% on the assets transferred or rolled over, and 1.00% payment on the first year contributions to the plan. Subsequently, Moss, Luse & Womble receives 0.05% per month on the plan assets using the other plan services provider for the ongoing coordination and support of the plan. The receipt of separate compensation is a conflict of interest in that the firm is incented to encourage clients to use these services to increase fees. Clients always have the choice to decide whether or not to use the accounting, tax and payroll services or TPA services offered by Moss, Luse & Womble, but if they do, all fees will be disclosed to the client prior to engaging for the services. Further, Moss, Luse & Womble and its personnel are fiduciaries under securities laws and are required to 11 | P a g e Moss, Luse & Womble, LLC  put the interests of clients before their own interests. Moss, Luse & Womble requires that all supervised personnel follow its Code of Ethics (see Item 11) that emphasizes this fiduciary duty to clients. Moss, Luse & Womble monitors compliance with securities laws and regulations through a compliance program, including the Code of Ethics, and other policies and procedures designed to prevent, detect and correct violations. Moss, Luse & Womble does not recommend or select other investment advisers for clients. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Moss, Luse & Womble is registered with the SEC and maintains a Code of Ethics pursuant to SEC rule 204A- 1. Moss, Luse & Womble has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the adviser. In addition, the Code of Ethics governs personal trading by each employee of Moss, Luse & Womble deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of Moss, Luse & Womble are conducted in a manner that avoids any conflict of interest between such persons and clients of the adviser or its affiliates. Moss, Luse & Womble collects and maintains records of securities holdings and securities transactions effected by Access Persons. These records are reviewed to identify and resolve conflicts of interest. Moss, Luse & Womble will provide a copy of the Code of Ethics to any client or prospective client upon request. Moss, Luse & Womble does not recommend, buy or sell securities in which the firm or a related person has a material financial interest. Moss, Luse & Womble and/or its investment advisory representatives may from time to time purchase or sell products that they may recommend to clients. Moss, Luse & Womble and/or its investment advisory representatives have a fiduciary duty to put the interests of their clients ahead of their own. Moss, Luse & Womble requires that its investment advisory representatives follow its basic policies and ethical standards as set forth in its Code of Ethics. ITEM 12: BROKERAGE PRACTICES Moss, Luse & Womble prefers that clients select Charles Schwab & Co., Inc. for execution and custody services, but does not require that clients use a particular custodian. Moss, Luse & Womble may receive proprietary research services or other products as a result of recommending a particular custodian which may result in the client paying higher commissions than those obtainable through other brokers. If Moss, Luse & Womble does receive such products or services, it will follow procedures which ensure compliance with Section 28(e) of the Securities Exchange Act of 1934 or applicable state securities rules. The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services and commissions. Although the firm seeks competitive commission rates, it may pay commissions on behalf of clients which may be higher than those available from other custodians in order to receive other services. The firm may enter into such transactions so long as it determines in good faith that the amount of commission paid was reasonable in relation to the value of the brokerage and research services 12 | P a g e Moss, Luse & Womble, LLC  provided by the custodian. The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and the performance of accounts; or (3) effecting securities transactions and performing functions incidental thereto. Such research furnished by custodians may be used to service any or all of Moss, Luse & Womble’s clients and may be used in connection with accounts other than those that pay commissions to the custodians providing the research. In particular, third-party research provided by custodians may be used to benefit all of the firm’s clients. This creates a conflict of interest in that the firm has an incentive to select or recommend a custodian based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution. Benefits received may be used as soft dollars provided that: • The service is primarily for the benefit of Moss, Luse & Womble’s clients • The commission rates are competitive with rates charged by comparable custodians; and • Moss, Luse & Womble does not guarantee a minimum amount of commissions to any custodian. Moss, Luse & Womble does not receive client referrals from any custodian or third party as a result of the firm selecting or recommending that custodian to clients. The client will provide authority to Moss, Luse & Womble to direct all transactions through the selected custodian in the investment advisory agreement. As an investment advisory firm, Moss, Luse & Womble has a fiduciary duty to seek best execution for client transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the client. Moss, Luse & Womble’s primary objectives when placing orders for the purchase and sale of securities for client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. Moss, Luse & Womble may not necessarily pay the lowest commission or commission equivalent as specific transactions may involve specialized services on the part of the broker. Moss, Luse & Womble may combine orders into block trades when more than one account is participating in the trade. This blocking or bunching technique must be equitable and potentially advantageous for each such account (e.g. For the purposes of reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek best execution and is consistent with the terms of Moss, Luse & Womble’s investment advisory agreements. Equity trades are blocked based upon fairness to client, both in the participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All managed accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order that remains unfilled at the end of a given day will be rewritten on the following day as a new order with a new daily average price to be determined at the end of the following day. Due to the low liquidity of certain securities, broker availability may be limited. Open orders are worked until they are completely filled, which may span the course of several days. If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the allocation statement. Moss, Luse & Womble may allocate trades in a different 13 | P a g e Moss, Luse & Womble, LLC  manner than indicated on the allocation statement (non-pro rata) only if all managed accounts receive fair and equitable treatment. ITEM 13: REVIEW OF ACCOUNTS Jeffrey Moss, Jason Luse, and Michael Womble, Partners, Miles Kellum, Executive Planner, and Travis Ferguson, Jackson McDaniel, Dustin Nunley, Christopher Carroll, Jason Kobza, Grayson Hatfield, and Ian Evans, Senior Planners, and Matthew Bryan, Associate Planner of Moss, Luse & Womble, monitor their client accounts on at least an annual basis. These individuals will also review a client account if they become aware of a change in client’s investment objective, a change in market conditions, change of employment, re-balancing of assets to maintain proper asset allocation and any other activity that is discovered as the account is reviewed. The client will receive written statements no less than quarterly from the trustee or custodian. In addition, the client will receive other supporting reports from Mutual Funds, Asset Managers, Trust Companies or Custodians, Insurance Companies, Broker-Dealers and others who are involved with client accounts. Moss, Luse & Womble prepares and delivers separate written quarterly performance reports to clients. Clients are urged to compare the account statements they receive from the qualified custodian with the reports they receive from Moss, Luse & Womble. Any discrepancies should be immediately brought to the firm’s attention. The client is encouraged to notify the Advisor and Investment Advisor Representative if changes occur in his/her personal financial situation that might adversely affect his/her investment plan. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Moss, Luse & Womble is not compensated by anyone for providing investment advice or other advisory services. Moss, Luse & Womble does not directly or indirectly compensate any person who is not a supervised person for client referrals. ITEM 15: CUSTODY Moss, Luse & Womble does not have custody of client funds or securities, except for the withdrawal of advisory fees directly from client accounts (please see Item 5 which describes the safeguards around direct fee deduction). However, as noted in Item 13 above, clients will receive statements not less than quarterly from the qualified custodian, and we encourage you to review those statements carefully. Any discrepancies should be immediately brought to the firm’s attention. ITEM 16: INVESTMENT DISCRETION Moss, Luse & Womble generally has discretion over the selection and amount of securities to be bought or sold in client accounts without obtaining prior consent or approval from the client. However, these purchases or sales are subject to specified investment objectives, guidelines, or limitations previously set forth by the client and agreed to by Moss, Luse & Womble. Discretionary authority will only be authorized upon full disclosure to the client. The granting of such authority will be evidenced by the client’s execution of an Investment Advisory Agreement containing all Moss, Luse & Womble, LLC 14 | P a g e  applicable limitations to such authority. All discretionary trades made by Moss, Luse & Womble will be in accordance with each client’s investment objectives and goals. ITEM 17: VOTING CLIENT SECURITIES Moss, Luse & Womble will not vote, nor advise clients how to vote, proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. Also, Moss, Luse & Womble cannot give any advice or take any action with respect to the voting of these proxies. The client and Moss, Luse & Womble agree to this by contract. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. Also, Moss, Luse & Womble cannot give any advice or take action with respect to the voting of these proxies. ITEM 18: FINANCIAL INFORMATION Moss, Luse & Womble does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and is not required to file a balance sheet. Moss, Luse & Womble has discretionary authority over client accounts and is not aware of any financial condition that will likely impair its ability to meet contractual commitments to clients. If Moss, Luse & Womble does become aware of any such financial condition, this brochure will be updated and clients will be notified. Moss, Luse & Womble has never been the subject of a bankruptcy petition. 15 | P a g e Moss, Luse & Womble, LLC