REDWOOD WEALTH MANAGEMENT GROUP, LLC

Informational Brochure August 28, 2025 Redwood Wealth Management Group, LLC 400 Stokes Rd Medford, NJ 08055 Mailing Address: PO Box 1057 Medford, NJ 08055 856-500-2900 Samuel C. Bridgers III 856-500-2900 This brochure provides information about the qualifications and business practices of Redwood Wealth Management Group, LLC. If you have any questions about the contents of this brochure, please contact us at 856- 500-2900. 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. Redwood Wealth Management Group, LLC is a registered investment adviser. Registration as an investment adviser does not imply any special degree of skill or training, or any sort of approval by any regulatory authority of an adviser’s investment methods. Additional information about Redwood Wealth Management Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. 1 | P a g e  Table of Contents ITEM 2: STATEMENT OF MATERIAL CHANGES ........................................................................................................................................... 3 ITEM 4: ADVISORY BUSINESS .................................................................................................................................................................... 3 FINANCIAL PLANNING .......................................................................................................................................................................................... 3 ASSET MANAGEMENT ......................................................................................................................................................................................... 3 WILL & TRUST ................................................................................................................................................................................................... 4 WRAP PROGRAM ............................................................................................................................................................................................... 4 ITEM 5: FEES AND COMPENSATION .......................................................................................................................................................... 6 FEES CHARGED .......................................................................................................................................................................................... 6 A. B. FEE PAYMENT ........................................................................................................................................................................................... 6 C. OTHER FEES ................................................................................................................................................................................................... 6 D. PRO-RATA FEES .............................................................................................................................................................................................. 7 E. COMPENSATION FOR THE SALE OF SECURITIES ....................................................................................................................................................... 7 F. NO-TRANSACTION-FEE FUND SHARE CLASSES ...................................................................................................................................................... 7 G. ONGOING COMPENSATION FROM ANNUITIES ...................................................................................................................................................... 7 ITEM 6: PERFORMANCE-BASED FEES ......................................................................................................................................................... 9 ITEM 7: TYPES OF CLIENTS ........................................................................................................................................................................ 9 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ......................................................................................... 9 A. METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ............................................................................................. 9 B. THIRD PARTY MANAGERS ............................................................................................................................................................................... 10 C. RISK FACTORS .............................................................................................................................................................................................. 11 ITEM 9: DISCIPLINARY INFORMATION ..................................................................................................................................................... 13 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS..................................................................................................... 13 A. B. C. D. E. BROKER-DEALER ...................................................................................................................................................................................... 13 FUTURES COMMISSION MERCHANT/COMMODITY TRADING ADVISOR ................................................................................................................ 13 RELATIONSHIP WITH RELATED PERSONS ........................................................................................................................................................ 13 RECOMMENDATIONS OF OTHER ADVISERS..................................................................................................................................................... 14 RELATIONSHIP TO PONTERA ....................................................................................................................................................................... 14 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................................ 14 ITEM 12: BROKERAGE PRACTICES............................................................................................................................................................ 15 A. B. C. RECOMMENDATION OF BROKER-DEALER ...................................................................................................................................................... 15 AGGREGATING TRADES ............................................................................................................................................................................. 16 PONTERA ............................................................................................................................................................................................... 16 ITEM 13: REVIEW OF ACCOUNTS ............................................................................................................................................................. 16 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................................................... 16 A. CLIENT REFERRALS AND SOLICITORS ............................................................................................................................................................. 16 B. OTHER PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB. .................................................................................................................. 17 D. OUR INTEREST IN SCHWAB’S SERVICES. ........................................................................................................................................................ 18 ITEM 15: CUSTODY .................................................................................................................................................................................. 18 ITEM 16: INVESTMENT DISCRETION ........................................................................................................................................................ 18 ITEM 17: VOTING CLIENT SECURITIES ...................................................................................................................................................... 19 ITEM 18: FINANCIAL INFORMATION........................................................................................................................................................ 19 2 | P a g e  Item 2: Statement of Material Changes The following is a summary of material changes since the Adviser’s last amendment: • Expanded Services for Held-Away Retirement Accounts: We have added a new service offering that includes the management and oversight of held-away retirement plan accounts (e.g., 401(k), 403(b) plans) using Pontera, a secure third-party technology platform. This service allows us to access, analyze, and rebalance client retirement plan accounts without taking custody of client assets or credentials. • Disclosure Updates in Items 4, 5, 10, 12, and 14: We have updated multiple sections of this brochure to describe our use of Pontera, including: o o o o o Item 4: The nature of our advisory services for held-away accounts Item 5:How we charge for these services and Pontera’s platform fees Item 10:Our non-compensated relationship with Pontera Item 12:Brokerage practices as they relate to retirement plan platforms Item 14: Disclosure that we do not receive compensation or incentives from Pontera Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’s fiscal year. We may further provide other ongoing disclosure information about material changes as necessary Item 4: Advisory Business Redwood Wealth Management Group, LLC (“RWMG”) was formed in 2015. Samuel C. Bridgers, is the firm’s principal. While the firm was founded in 2015, the firm’s principal and advisors have over forty (40) years of experience in the finance industry. RWMG provides personalized financial planning and/or investment management services. Clients advised include individuals, trusts, foundations, and corporations. Financial Planning In most cases, the client will supply to RWMG information including income, income sources, investments, savings, insurance, tax, assets and liabilities, age and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs and goals with you and compare your current financial situation with your stated goals. Once these are compared, we will create a financial and/or investment plan to help you meet your goals. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is very important that you accurately and completely communicate to us the information we need. Also, your circumstances and needs can change as your engagement with us progresses. It is very important that you continually update us with any changes so that if the updates require changes to your plan, we can make those changes to ensure your plan is accurate. Asset Management 3 | P a g e  RWMG requires each client to place at least $250,000 with the firm. This minimum can be waived at the discretion of RWMG. Asset management services are provided on a “discretionary” or on a “non-discretionary” basis. When RWMG is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You will receive written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive monthly or quarterly statements from your account custodian. When a client engages us to provide investment management services on a non-discretionary basis, we monitor the accounts in the same way as for discretionary services. The difference is that changes to your account will not be made until we have confirmed with you (either verbally or in writing) that our proposed change is acceptable to you. As of December 31, 2024 RWMG had approximately 928 discretionary accounts, totaling approximately $224,535,592 of regulatory assets under management and 240 non-discretionary accounts, totaling approximately $37,565,221 of regulatory assets under management. Will & Trust Our firm offers Estate Planning services included as part of our ongoing financial planning services to our clients. This service consists of education on estate planning topics and benefits of will creation. Trust & Will is an online third-party software tool service that helps clients in need of simple estate planning legal forms and related information. (See related disclosures below) The site can also be used to create (or establish) a customized will and other estate planning documents. This product is offered as either an integrated part of our investment advisory management services to our clients or separately to help clients achieve their financial goals and objectives. Clients interested in using the service are directed to go to the Trust & Will website (Estate Planning - Create an Online Will and Trust | Trust & Will (trustandwill.com)) to create their document. For clients engaging in financial planning services with our firm, there is no separate fee for estate planning services (see fees below). Trust & Will, a third-party digital estate planning service for clients who have the need for estate planning review, creation or updates. Trust & Will is not appropriate for complex estates. Trust & Will is not a law firm and is not a substitute for legal advice about estates planning. Trust & Will is not a law firm. Any advice that we give is purely investment advice as we are not a law firm nor do we hold ourselves out as a provider of legal advice. Wrap Program For some legacy clients, RWMG includes certain transactional costs in the client’s management fee. This arrangement is referred to as “Wrap Program”. RWMG manages a wrap fee program through Schwab Advisor Services ("Schwab"). A wrap fee program is a type of investment program that provides clients with portfolio management services and/or custodial and/or brokerage services for a single fee that includes administrative fees, management fees, and transaction costs. If clients participate in our wrap fee program, clients will pay a single fee, which includes our portfolio management fees, certain transaction costs, and custodial and administrative costs. We will receive a portion of the wrap fee for our services. The overall cost clients will incur if they participate in the wrap fee program may be higher or lower than they might incur by separately purchasing the types of securities 4 | P a g e  and services available in the program. Under the wrap fee program, transactions for your account are executed by Schwab, a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. For accounts in the Wrap Program, RWMG will pay a fee to Schwab Advisor Services based on Schwab’s Transaction Based Pricing IM billing model. Expenses for the management fees of third-party managers are not included in the Wrap Program, and to the extent utilized, you will be responsible for such fees. Because RWMG will be managing the assets of wrap fee program clients the same way as other non-wrap fee program clients, the use of external portfolio managers within the wrap program is expected to be limited. To the extent a third-party manager is utilized, the fees payable to such managers will not be included in the wrap program. Therefore, there is no difference between how RWMG manages wrap free accounts and how RWMG manages other accounts. RWMG does not engage other portfolio managers to manage assets within the wrap fee program. To the extent a third- party manager is utilized, the fees payable to such managers will not be included in the wrap program. RWMG is the sole portfolio manager in the wrap program, which means that RWMG receives a portion of the wrap fee for our services. Effective October 7, 2019, Schwab eliminated commissions for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. However, the ongoing operating expenses of some of the no- transaction-fee funds can be higher. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available atschwab.com/aspricingguide. Please see the separate Wrap Fee Brochure for a more complete description of the Wrap Program. Held-Away Retirement Accounts Our firm offers investment advisory services for held-away retirement accounts, including 401(k), 403(b), and similar employer-sponsored plans. To facilitate this service, we utilize Pontera, a third-party technology platform that enables us to access, analyze, and manage these accounts at the client's direction. Pontera allows us to securely view and rebalance retirement plan assets without taking custody of client credentials or funds. Clients provide access to their accounts directly through Pontera’s secure interface. This allows us to deliver advice and discretionary management in alignment with their financial goals, risk tolerance, and overall portfolio strategy. While we may manage held-away accounts on a discretionary or non-discretionary basis, we do not have the ability to withdraw funds, change beneficiaries, or perform any functions that would result in custody under SEC Rule 206(4)-2. 5 | P a g e  Item 5: Fees and Compensation A. Fees Charged All clients will be required to execute a written agreement that will describe the type of services to be provided and the fees, among other items. Financial Planning Financial planning fees can be on a fixed fee basis or included with asset management services. Fixed fees will be between $2,000 and $10,000. The fee range stated is a guide. Fees are higher or lower than this range, based on the nature of the engagement. Fees are negotiable and will depend on the anticipated complexity of your plan. Asset Management Generally, we use a flat fee schedule up to a maximum of 1.5% per annum of the net value of a client’s accounts managed by RWMG. However, fees are negotiable, and can be higher or lower, based on the nature of the account. Factors affecting fee percentages include the size of the account, whether it participates in the Wrap program, complexity of asset structures, and other factors. Will & Trust Will-Based Estate Plan and Estate Distribution Fees for assistance with a will-based estate plan will be fixed and vary depending on whether the plan is for an individual or a couple. Additionally, fixed or hourly fees may be applied for estate or account distribution services, with costs varying based on the time required and other relevant factors. B. Fee Payment Fees for financial planning and/or consulting will be billed to each client. If the client terminates the agreement prior to completion of the services, any unearned fees will be returned to the client. Investment advisory fees will be debited directly from each client’s account. The advisory fee is paid quarterly, generally in advance, and the value used for the fee calculation is the net value as of the last market day of the previous quarter. This means that if your annual fee is 1.00%, then each quarter we will multiply the value of your account by 1.00% then divide by 4 to calculate our fee. Once the calculation is made, we will instruct your account custodian to deduct the fee from your account and remit it to RWMG. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. C. Other Fees There are a number of other fees that can be associated with holding and investing in securities. RWMG will be responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded Fund, or commissions for the purchase or sale of a stock. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the mutual fund manager. For a complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued. From time to time, clients can direct RWMG to purchase certain securities. To the extent that RWMG can accommodate such requests, clients may be subject to additional fees and expenses associated with such transactions. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial 6 | P a g e  issues. D. Pro-rata Fees If you become a client during a quarter, you will pay a management fee for the number of days left in that quarter. If you terminate our relationship during a quarter, you will be refunded the portion of the prepaid management fee for the remainder of the quarter. Once your notice of termination is received, we will refund the unearned fees to you in whatever way you direct (check, wire back to your account). E. Compensation for the Sale of Securities To permit RWMG clients to have access to as many investment solutions as possible, certain professionals of RWMG are registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”) a FINRA member broker-dealer. RWMG offers certain qualified clients trading services, which gives RWMG the ability to execute trades through PKS of client assets not custodied at Schwab. The relationship with PKS allows these professionals to provide additional products to clients’ portfolios that would not otherwise be available. Because PKS supervises the activities of these professionals as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated with RWMG or considered a related party. PKS does not make investment decisions for client accounts. Registered representative status enables these professionals to receive customary commissions for the sales of various securities, including those he or she recommends to clients. Commissions charged for these products will not offset management fees owed to RWMG. Receipt of commissions for investment products that are recommended to clients gives rise to a conflict of interest for the representative, in that the individual who will receive the commissions is also the individual that is recommending that the client purchase a given product. This conflict is disclosed to clients verbally and in this brochure. Clients are advised that they may choose to implement any investment recommendation through another broker-dealer that is not affiliated with RWMG. RWMG attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. F. No-Transaction-Fee Fund Share Classes At our firm, we acknowledge a potential conflict of interest when selecting investments in no-transaction-fee fund share classes, as the firm has a financial incentive to do so due to the absence of transaction fees. These share classes often carry higher ongoing operating expenses for clients. By opting for these options, we aim to avoid transaction fees associated with share classes that may have lower ongoing costs. This strategy is intended to balance cost considerations while prioritizing the long-term financial outcomes of our clients. We are committed to transparency and ensuring that all investment decisions are made in the best interests of our clients, so clients are encouraged to review share classes and fees with the Adviser. G. Ongoing Compensation from Annuities This policy outlines the compensation structure related to annuities offered by RWMG, ensuring transparency and compliance with regulatory requirements. 1. Overview of Compensation Structure At RWMG, we may receive compensation from insurance companies when we recommend or sell annuity products to our clients. This compensation may include upfront commissions, trailing commissions, and other forms of revenue. 7 | P a g e  2. Types of Compensation a. Upfront Commissions: We may receive a one-time commission based on a percentage of the investment amount at the time of the annuity sale. This commission is typically paid by the insurance company and may vary depending on the specific annuity product. b. Trailing Commissions: In addition to upfront commissions, we may receive ongoing, trailing commissions based on the assets maintained within the annuity. These payments are usually made annually and are contingent on the client maintaining the annuity with the insurance provider. c. Fee-Based Compensation: For certain annuities, we may charge a management fee based on the assets under management. This fee structure provides a clear and transparent pricing model for services. our advisory 3. Disclosure and Transparency We are committed to disclosing all forms of compensation related to annuities. Clients will be informed of the specific compensation we may incur as a result of purchasing annuity products, including any potential conflicts of interest that may arise from our recommendations. a. Client Interests Our primary obligation is to act in the best interest of our clients. While we may receive compensation from the sale of annuities, we strive to provide recommendations that align with the client's financial goals and needs. b. Ongoing Monitoring We will periodically review the annuity products within our clients' portfolios to ensure they remain suitable and aligned with the client's financial objectives. Any changes in compensation structures will also be disclosed to clients in a timely manner. 4. Pontera Our advisory services for held-away accounts managed through Pontera are billed as part of our standard asset-based fee schedule, unless otherwise disclosed in the client’s advisory agreement. There is no separate or additional fee charged by us for access to Pontera. 8 | P a g e  Item 6: Performance-Based Fees We do not charge performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of the capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. From time to time, clients can direct RWMG to purchase certain securities. To the extent that RWMG can accommodate such requests, clients may be subject to additional fees and expenses associated with such transactions. Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial issues. _____________________________________________________________________________________________ Item 7: Types of Clients Clients advised include individuals, trusts, foundations, pension and profit-sharing plans and corporations. For asset management services, RWMG requires each client to place at least $250,000 with the firm. This minimum can be waived at the discretion of RWMG. There is no set minimum that clients are required to place with RWMG for financial planning services. _____________________________________________________________________________________________ Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis, Investment Strategies, and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Methods of Analysis and Investment Strategies Each client’s portfolio will be invested according to that client’s investment objectives. We determine these objectives by interviewing the client and/or asking the client to put these objectives in writing. Once we ascertain your objectives for each account, we will develop a set of asset allocation guidelines. An asset allocation strategy is a percentage-based allocation to different investment types. For example, a client may have an asset allocation strategy that calls for approximately 60% of the portfolio to be invested in equity securities, with 20% of that allocated to international equities and the remaining balance in fixed income. Another client may have an asset allocation of 50-60% in fixed income securities and the remainder equities. The percentages in each type that we recommend are based on the typical behavior of that security type, individual securities we follow, current market conditions, your current financial situation, your financial goals, and your time frame to attain your goals. In addition, the allocation percentages we recommend represent the maximum percentage we would target at any given time period. There may be market conditions that require more conservative allocation percentages through the use of incorporating a cash allocation into the portfolio. Thus, a client with an allocation strategy that calls for 60% of the portfolio to be invested in equities, could have an equity percentage that ranges anywhere from 0% to 60% depending upon market conditions. Because we develop an investment strategy based on your personal situation and financial goals, your asset allocation guidelines may be similar to or different from another client’s. Once we agree on allocation guidelines, risk tolerance, time horizon, and how to achieve these results, we will develop a 9 | P a g e  written investment and monitoring plan to guide all parties involved in the execution of these goals, including but not limited to, RWMG, the client, the custodian, and the investment managers. We will periodically recommend securities transactions in your portfolio to meet the guidelines of the asset allocation strategy. It is important to remember that because market conditions can vary greatly, your asset allocation guidelines are not necessarily strict rules. Rather, we review accounts individually and will deviate from the guidelines as we believe necessary. The specific securities we recommend for your account will depend on market conditions and our research at the time. Generally, we recommend some combination of stocks, index funds, exchange traded funds, mutual funds, and bonds. Specific funds are chosen based on where its investment objective fits into the asset allocation recommended by RWMG, its risk parameters, past performance, peer rankings, fees, expenses, and any other aspects of the fund RWMG deems relevant to that particular fund. We base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. We will also utilize technical analysis, which means that we will review the past behaviors of the security and the markets in which it trades for signals as to what might happen in the future. B. Third Party Managers We may recommend that certain portions of a client's portfolio be managed by independent third-party managers or recommend direct investment with independent third-party managers, typically when those managers demonstrate knowledge and expertise in a particular investment strategy. We examine the experience, expertise, investment philosophies and past performance of independent third- party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentration and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. Based on a client’s individual circumstances and needs, we will determine which selected money manager's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance and the investment philosophy of the selected money manager. We encourage clients to review each third-party manager’s disclosure document regarding the particular characteristics of any program and managers selected by us. We will regularly and continuously monitor the performance of the selected money managers. If we determine that a particular selected money manager is not providing sufficient management services to the client, or are not managing the client's portfolio in a manner consistent with the client's investment objectives, we will remove the client's assets from that selected money manager and place the client's assets with another money manager at our discretion and without prior consent from the client. RWMG will obtain appropriate due diligence on all independent third-party managers, making reasonable inquiries into their performance calculations, policies and procedures, code of ethics policies and other operational and compliance matters to account for performance and risk management. We examine the experience, expertise, investment philosophies and past performance of third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. 10 | P a g e  C. Risk Factors There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world can have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason, and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Potential Public Health Crisis; Covid-19. A public health crisis, pandemic, epidemic or outbreak of a contagious disease, such as the recent outbreak of Coronavirus (or Covid-19) in China, the United States and other countries, could have an adverse impact on global, national and local economies, which in turn could negatively impact fund clients. Disruptions to commercial activity relating to the imposition of quarantines or travel restrictions (or more generally, a failure of containment efforts) may adversely impact a fund client’s investments, including by delaying or causing supply chain disruptions or by causing staffing shortages. In addition, the imposition of travel restrictions may impact the ability of the Advisors’ personnel to travel in connection with potential or existing investments of a fund client or to the Advisors’ offices, which could negatively impact the ability of the Advisors to effectively identify, monitor, operate and dispose of investments. Finally, the outbreak of Coronavirus has contributed to, and may continue to contribute to, volatility in financial markets, including changes in interest rates. A continued outbreak may reduce the availability of debt financing to a fund client and potential purchasers of a fund client’s investments, which could have material and adverse impact on a fund client’s returns. The impact of a public health crisis such as the Coronavirus (or any future pandemic, epidemic or outbreak of a contagious disease) is difficult to predict, which presents material uncertainty and risk with respect to a client’s performance. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that RWMG may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. RWMG endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Risks Related to Investment Term. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain itsvalue. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several 11 | P a g e  rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Risks specific to sub-advisors and other managers. If we invest some of your assets with another advisor, including a private placement, there are additional risks. These include risks that the other manager is not as qualified as we believe them to be, that the investments they use are not as liquid as we would normally use in your portfolio, or that their risk management guidelines are more liberal than we would normally employ. • Short Sales. “Short sales” are a way to implement a trade in a security RWMG feels is overvalued. In a “long” trade, the investor is hoping the security increases in price. Thus in a long trade, the amount of the investor’s loss (without margin) is the amount paid for the security. In a short sale, the investor is hoping the security decreases in price. However, unlike a long trade where the price of the security can only go from the purchase price to zero, in a short sale, the price of the security can go infinitely upwards. Thus in a short sale, the potential for loss is unlimited and unknown, where the potential for loss in a long trade is limited and knowable. RWMG may utilize short sales only when the client’s risk tolerances permit. • Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan are then used to buy more securities. In a positive result, the additional securities provide additional return on the same initial investment. In a negative result, the additional securities provide additional losses. Margin therefore carries a higher degree of risk than investing without margin. Any client account that will use margin will do so in accordance with Regulation T. RWMG does not typically recommend the use of margin trading, but may utilize margin on a limited basis for clients with higher risk tolerances. • Transition risk. As assets are transitioned from a client’s prior advisers to RWMG there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by RWMG. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of RWMG may adversely affect the client's account values, as RWMG’s recommendations may not be able to be fully implemented. • • REITs. RWMG may recommend that portions of client portfolios be allocated to real estate investment trusts, otherwise known as “REITs”. A REIT is an entity, typically a trust or corporation, that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful, but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. International Investing. Investing outside of the United States, especially in emerging markets, can have special or enhanced risks. The most obvious are political risk (changes in local politics can have a vast impact on the markets in that country as well as regulations affecting given issuers) and currency risk (changes in exchange rates between the dollar and the local denominations can materially affect the value of the security even if the underlying fundamentals and market price are stagnant). There are other risks, including enhanced liquidity risk, meaning that while domestic equities and mutual funds are generally easily liquidated (though there may be a risk of loss due to the timing of the sale), equities in other jurisdictions may be subject to the circumstances of lower overall market volume and fewer companies on an emerging 12 | P a g e  exchange. In addition, there may be less information and less transparency in a foreign market or from a foreign company. Foreign markets impose different rules than domestic markets, which may not be to an investor's advantage. Also, companies in foreign jurisdictions are generally able to avail themselves of local laws and venues, meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S. Item 9: Disciplinary Information Neither the firm nor any of its employees or principals has any disciplinary information to report. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer To permit RWMG clients to have access to as many investment solutions as possible, certain professionals of RWMG are registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”) a FINRA member broker-dealer. RWMG may offer certain qualified clients trading services which gives RWMG the ability to execute trades through PKS of client assets custodied at Schwab. The relationship with PKS allows these professionals to provide additional products to clients’ portfolios that may otherwise not be available. Because PKS supervises the activities of these professionals as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated with RWMG or considered a related party. PKS does not make investment decisions for client accounts. Registered representative status enables these professionals to receive customary commissions for the sales of various securities, including those he or she recommends to clients. Commissions charged for these products will not offset management fees owed to RWMG. Receipt of commissions for investment products that are recommended to clients gives rise to a conflict of interest for the representative, in that the individual who will receive the commissions is also the individual that is recommending that the client purchase a given product. This conflict is disclosed to clients verbally and in this brochure. Clients are advised that they may choose to implement any investment recommendation through another broker-dealer that is not affiliated with RWMG. RWMG attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring employees to acknowledge their fiduciary responsibility toward each client. B. Futures Commission Merchant/Commodity Trading Advisor Neither members of management, nor any related 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. C. Relationship with Related Persons Certain professionals of RWMG are separately licensed as independent insurance agents. As such, these professionals can conduct insurance product transactions for RWMG clients, in their capacity as licensed insurance agents, and will receive customary commissions for these transactions in addition to any compensation received in his or her capacity as employees of RWMG. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. These professionals therefore may have an incentive to recommend insurance products based on the compensation to be received, rather than on a client’s needs, though RWMG’s policy is to provide the client with insurance products that are most suitable given the client’s specific needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering whether to engage RWMG or utilize these professionals to implement any insurance 13 | P a g e  recommendations. RWMG attempts to mitigate this conflict of interest by disclosing the conflict to clients, and informing the clients that they are always free to purchase insurance products through other agents that are not affiliated with RWMG, or to determine not to purchase the insurance product at all. RWMG also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients of RWMG, which requires that employees put the interests of clients ahead of their own. D. Recommendations of other Advisers See response to Item 8 regarding third-party managers. E. Relationship to Pontera Our firm has no material affiliations or ownership relationships with Pontera. Although we have entered into a service agreement with Pontera to use their technology platform, we do not receive any compensation, incentive, or benefit from them in exchange for recommending or utilizing their services. We may use Pontera’s platform to enhance our ability to manage held-away retirement plan accounts on behalf of clients. This arrangement is solely for operational support. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. B. RWMG does not recommend to clients that they invest in securities in which RWMG or any principal thereof has any financial interest. C. On occasion, an employee of RWMG may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. 14 | P a g e  Item 12: Brokerage Practices A. Recommendation of Broker-Dealer RWMG recommends that investment accounts be held in custody by Schwab Advisor Services (“Schwab”). Schwab offers enhanced services to independent investment advisors. These services include custody of securities, trade execution platforms, and access to research not available to the general public. Schwab is wholly independent from RWMG. It is expected that most, if not all, transactions in a given client account will be cleared through the custodian of that account in its capacity as a broker-dealer. RWMG recommends Schwab to its clients based on a variety of factors. These include, but are not limited to, commission costs. Schwab has what can be considered discounted commission rates. However, in choosing a broker- dealer or custodian to recommend, we are most concerned with the value the client receives for the cost paid, not just the cost. Schwab adds value beyond commission cost. Other factors that may be considered in determining overall value include speed and accuracy of execution, financial strength, knowledge and experience of staff, research and service. Schwab also has arrangements with many mutual funds that enable us to purchase these mutual funds for client accounts at reduced transaction charges (as opposed to other broker-dealers). Schwab has the highest market share of investment adviser business which makes them the most experienced in matters likely to arise for our clients. RWMG re-evaluates the use of Schwab periodically to determine if they are still the best value for our clients. Schwab provides RWMG with some non-cash benefits (not available to retail customers) in return for placing client assets with them or executing trades through them. Currently, these benefits come in the form of investment research and sponsored attendance at various investment seminars. We may also receive such items as investment software, books and research reports. These products, services, or educational seminars are items that will play a role in determining how to invest client accounts. If there is any item that has a multi-use aspect, mixed between investment and non-investment purposes, RWMG will determine a reasonable allocation of investment to non- investment use and non-cash benefits will be allocated only to the investment portion of the product (and we will pay the remaining cost). RWMG receives a benefit from these services, as otherwise we would be compiling the same research ourselves. This may cause a conflict of interest as we may to want to place more client accounts with a broker-dealer/custodian such as Schwab, solely because of these added benefits. As such, RWMG may have an incentive to select or recommend a broker-dealer based on interests in receiving the research or other products or services, rather than on clients’ interest in receiving most favorable execution. RWMG attempts to mitigate this potential conflict by performing regular reviews of execution services and value clients receive to ensure clients are receiving the best possible value for costs paid. However, the value to all of our clients of these benefits is included in our evaluation of custodians. Products and services received will generally be used for the benefit of all clients. However, it is possible that a given client’s trades will generate non-cash benefits that acquire products and/or services that are not ultimately utilized for that same client’s account. Non-cash benefits provide additional value, and are accordingly considered in determining which broker-dealer or custodian to utilize as part of our best execution analysis. Some of the products, services and other benefits provided by Schwab, benefit RWMG and may not benefit RWMG's client accounts. RWMG's recommendation or requirement that a client place assets in Schwab's custody may be based in part on benefits Schwab provides to RWMG and not solely on the nature, cost or quality of custody and execution services provided by Schwab. However, RWMG places trades for its clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Advisor may use broker-dealers other than Schwab to execute trades for client accounts maintained at Schwab, but this practice may result in additional costs to clients so that Advisor is more likely to place trades through Schwab rather than other broker-dealers. Schwab's execution quality may be different than other broker-dealers evaluation of these broker-dealers. 15 | P a g e  B. Aggregating Trades Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to be made are executed at the same time. This is called aggregating trades. RWMG may place trades for the same security needed in multiple accounts by executing one trade, and then allocate the trades to each account after execution. If an aggregate trade is not fully executed, the securities will be allocated to client accounts on a pro rata basis, except where doing so would create an unintended adverse consequence (For example, ¼ of a share, or a position in the account of less than 1%.) In many instances, commission rates are not discounted for an aggregated trade. C. Pontera Held-away retirement plan assets accessed and managed through Pontera remain at their respective plan custodians. Our use of Pontera does not involve directing brokerage transactions, executing trades through third- party brokers, or incurring traditional trade execution costs. All trading occurs within the plan’s existing platform and recordkeeping system. Pontera provides a secure, supervised interface that allows us to adjust investment allocations without requiring clients to share login credentials or initiate changes manually. Held-away retirement plan assets accessed and managed through Pontera remain at their respective plan custodians. Our use of Pontera does not involve directing brokerage transactions, executing trades through third- party brokers, or incurring traditional trade execution costs. All trading occurs within the plan’s existing platform and recordkeeping system. Pontera provides a secure, supervised interface that allows us to adjust investment allocations without requiring clients to share login credentials or initiate changes manually. Item 13: Review of Accounts All accounts will be reviewed by one of RWMG’s investment adviser representatives on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. All clients will receive statements from their account custodian showing transactions and holdings in their accounts. We encourage you to compare the information on any report prepared by RWMG against the information in the statements provided directly from Schwab and alert us of any discrepancies. Item 14: Client Referrals and Other Compensation A. Client Referrals and Solicitors Our Firm and our financial advisors may enter into types of solicitation arrangements. These solicitation arrangements are operated in accordance with Rule 206(4)-3 of the Advisers Act. The investment advisor firm can pay a solicitor a portion of the ongoing investment advisory fee charged to the client each billing period as long as such payments are consistent with the Form ADV and a separate written solicitor disclosure is given to the client in accordance with the requirements of SEC Rule 206(4)-3. A solicitor is subject to conflicts of interest arising from these referral or solicitor arrangements because the solicitor is being paid to recommend our Firm, as investment adviser, to a client, and the solicitor will only receive payment if the client ultimately decides to become our advisory 16 | P a g e  client. We address this conflict of interest by disclosing the terms of the referral relationship and related referral compensation to the referred client in accordance with Rule 206(4)-3. Our participation in these referral arrangements does not diminish our fiduciary obligations to our clients. B. Other Products and Services Available to Us from Schwab. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage - trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10 million of the assets of our firm’s advisory clients in accounts at Schwab. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Here is a more detailed description of Schwab’s support services: Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment C. Pontera We do not receive any direct or indirect compensation from Pontera in connection with our use of their platform. Our decision to use Pontera is based solely on the value it provides in helping us manage client retirement plan accounts more effectively and compliantly. There are no referral arrangements, financial incentives, or marketing payments between our firm and Pontera. Clients are never required to use Pontera, and the choice to include held-away account management is entirely optional. products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and • provide access to client account data (such as duplicate trade confirmations and account statements); • • provide pricing and other market data; • • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further 17 | P a g e  develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. D. Our Interest in Schwab’s Services. The availability of the services described above (under the caption “Other Products and Services Available to Us from Schwab”) from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $10 million of client assets in accounts at Schwab. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The minimums described above may give us an incentive to require that you maintain your account with Schwab based on our interest in receiving Schwab’s services and Schwab’s payment for third party services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services and not Schwab’s services and Schwab’s payment for third party services that benefit only us. We have adopted policies and procedures designed to ensure, at account opening and thereafter, that our use of Schwab’s services is appropriate for each of our clients. Item 15: Custody RWMG deducts fees from Schwab client accounts but does not have custody of client funds or said accounts. Clients will receive statements directly from Schwab, and copies of all trade confirmations directly from Schwab. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their account custodian showing all transactions in their account, including the fee. We encourage clients to carefully review the statements and confirmations sent to them by their custodian. Please alert us of any discrepancies. Item 16: Investment Discretion Asset management services will be provided on a “discretionary” basis. When RWMG is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes can involve selling a security or group of investments and buying others or keeping the proceeds in cash. You will receive written or electronic confirmations from your account custodian after any changes are made to your 18 | P a g e  account. You will also receive monthly or quarterly statements from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client and RWMG. We generally recommend that clients utilize Schwab Advisor Services to act as the broker-dealer/custodian for their accounts. However, the client may use another broker-dealer if the client wishes to do so. Item 17: Voting Client Securities Copies of our Proxy Voting Policies and procedures are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. RWMG will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. RWMG will not give clients advice on how to vote proxies. Item 18: Financial Information RWMG does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. 19 | P a g e