Rtw Financial Advisors Inc.

FORM ADV PART 2A BROCHURE Item 1 – Cover Page 5757 Alpha Road, Suite 700 Dallas, TX 75240 972-960-1212 This brochure provides information about the qualifications and business practices of RTW Financial Advisors, Inc. If you have any questions regarding the contents of this brochure, please do not hesitate to contact our Chief Compliance Officer, Josh Jones by telephone at 513-744-3196 or by email at josh.jones@dinsmorecomplianceservices.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. RTW Financial Advisors is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about RTW Financial Advisors is available on the SEC’s website at www.adviserinfo.sec.gov. May 2026  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure since the last annual update of the disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the last annual amendment filing on March 31, 2026, the following material changes have occurred:      In May 2026, reference to Family Office Services has been removed; In May 2026, RTW’s fee schedule was removed and specified wealth management fees range up to 1% of assets under management per annum In May 2026, removed minimum account size for investment advisory services; In May 2026, added information related to postage charges In May 2026, RTW engaged with Charles Schwab & Co., Inc. (“Schwab”) to provide custodial services; In May 2026, Josh Jones was named RTW’s Chief Compliance Officer.   Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................................ 3 Item 4 - Advisory Business ........................................................................................................................... 5 A. Description of the Advisory Firm .................................................................................................... 5 B. Types of Advisory Services ............................................................................................................. 5 C. Client-Tailored Advisory Services .................................................................................................. 6 D. Information Received From Clients ................................................................................................. 7 E. Assets Under Management .............................................................................................................. 7 Item 5 - Fees and Compensation ................................................................................................................... 7 A. Investment Management and Financial Planning Services .............................................................. 7 B. Payment of Fees ............................................................................................................................... 8 C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers ... 9 D. Prepayment of Fees .......................................................................................................................... 9 E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients .......... 10 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................. 10 Item 7 - Types of Clients ............................................................................................................................ 10 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 10 A. Methods of Analysis and Risk of Loss .......................................................................................... 10 B. Material Risks Involved ................................................................................................................. 11 Item 9 – Disciplinary Information .............................................................................................................. 14 Item 10 – Other Financial Industry Activities and Affiliations .................. Error! Bookmark not defined. Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 15 Item 12 – Brokerage Practices .................................................................................................................... 16 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................ 16 B. Trade Aggregation ......................................................................................................................... 19 Item 13 – Review of Accounts .................................................................................................................... 19 A. Periodic Reviews ........................................................................................................................... 19 B. Other Reviews and Triggering Factors .......................................................................................... 19 C. Regular Reports ............................................................................................................................. 20 Item 14 – Client Referrals and Other Compensation .................................................................................. 20 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ............................ 20  RTW Financial Advisors Disclosure Brochure B. Compensation to Non-Supervised Persons for Client Referrals .................................................... 20 Item 15 – Custody ....................................................................................................................................... 20 Item 16 – Investment Discretion ................................................................................................................. 21 Item 17 – Voting Client Securities .............................................................................................................. 21 Item 18 – Financial Information ................................................................................................................. 21 4  RTW Financial Advisors Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm RTW Financial Advisors, Inc. (“RTW” or the “Firm”) is a corporation organized in the State of Texas. RTW is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). RTW became SEC registered in 1991. RTW is wholly owned by Morris C. Williams, Treasurer and Peter H. Roe, Vice President, with S. Tyler McKimmey named President. B. Types of Advisory Services RTW provides financial planning and discretionary and non-discretionary investment management services to individuals, high net worth individuals, estates and trusts, pension and profit sharing plans, and charitable organizations. Additionally, separate from our Investment Management and Financial Planning services, RTW provides Performance Measurement services under separate agreements. Investment Management Services RTW offers investment management services on a discretionary and non-discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by RTW to determine the appropriate portfolio asset allocation and investment strategy for the client. The securities utilized by RTW for investment management services clients consist of registered mutual funds, exchange traded funds (ETFs), equity securities, corporate bonds, state and local municipality fixed income instruments (“municipal securities”), US government and agency securities, options, gold and silver bullion, and annuities, if we determine such investments fit within a client’s objectives and are in the best interest of our clients. RTW may further recommend to investment management services clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. RTW generally renders services to the client relative to the discretionary selection of External Managers. RTW also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers are exclusive of, and in addition to, the annual investment management services fee charged by RTW. If an External Manager is utilized for clients that engages in brokerage transactions and/or custody services with a broker-dealer/custodian other than Schwab, the fees charged by that broker-dealer/custodian will be exclusive of, and in addition to, the annual RTW fee. Financial Planning Services RTW offers financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the financial planning services 5  RTW Financial Advisors Disclosure Brochure will include recommendations for retirement planning, educational planning, estate planning, charitable planning, cash flow planning, tax planning and insurance needs and analysis. RTW provides the financial planning client with recommendations and performs periodic reviews of provided recommendations, as agreed upon with the client. In addition, RTW provides financial planning services that are completed upon the delivery of recommendations to the client. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided by RTW. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have RTW implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. RTW cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Investment Management Services to Retirement Plans RTW offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Performance Measurement & Presentation Services RTW provides performance measurement reporting services to individuals, families, and family offices. We work with our clients to quantify all investments, whether or not they are under our management, categorize them by asset class, and obtain necessary data to provide performance measurements based on diverse criteria as mutually agreed upon in a separate engagement. RTW provides ongoing investment recommendations for assets managed by unaffiliated third-party managers, including asset allocation, manager due diligence and monitoring, and liquidity and cash flow planning. Clients retain sole authority to select and terminate third-party managers and to determined whether to implement RTW’s recommendations. Note Regarding Tax or Legal Advice: In providing services, RTW does not offer or otherwise provide tax or legal advice. RTW will, at a client’s direction and approval, work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees charged by any tax, legal or other third-party professionals are the responsibility of the client. RTW may refer professionals; however, there is no compensation to RTW for these referrals, and clients are under no obligation to use the referred service providers. C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if RTW determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for RTW’s management efforts. 6  RTW Financial Advisors Disclosure Brochure D. Information Received From Clients RTW will not assume any responsibility for the accuracy of the information provided by clients. RTW is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client and RTW is expressly authorized by the client to rely on such information provided. Under all circumstances, clients are responsible for promptly notifying RTW in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management As of 12/31/2025, RTW was actively managing $545,274,980 of clients' assets on a discretionary basis, plus $35,748,989 of clients' assets on a non-discretionary basis. Item 5 - Fees and Compensation RTW charges fees based on a percentage of assets under management as well as fixed fees and hourly fees, depending upon the particular types of services to be provided. The specific fees charged by RTW for services provided will be set forth in each client’s agreement. A. Investment Management and Financial Planning Services Fees for Investment Management Services In providing investment management services, RTW charges an annual investment management services fee that is agreed upon with each client and set forth in an agreement executed by RTW and the client. The RTW investment management services fee is based on a percentage of the value of assets under management and is generally paid quarterly in advance. Fees for investment management services range up to 1% of assets under management per annum. RTW does charge a minimum fee of $1,000 per annum. When a client’s account is opened, the investment management services fee is billed for the remainder of the current quarterly billing period and is based on the client’s initial contribution to the client account. Subsequent quarterly investment management services fees will be based on the client’s account value as of the last business day of the previous calendar quarter. If cash or securities, or a combination thereof, are deposited to or withdrawn from a client’s account on an individual business day during a quarter, RTW will (i) assess investment management services fees to the deposited assets based on the value of the assets on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) refund prepaid investment management services fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the quarter. For purposes of the investment management services fee calculation, RTW utilizes third party sources, such as pricing services, custodians, fund administrators, and client-provided sources. For purposes of fee calculation, the asset value of client accounts include cash and cash equivalents, as well as margined securities. RTW does not reduce the investment management fees for margin borrowing, regardless of whether the assets are in cash or other securities. RTW has a financial incentive to recommend that clients borrow money for the purchase of additional securities for the client’s investment management services account or otherwise not liquidate some or all the assets RTW manages. RTW addresses this conflict of 7  RTW Financial Advisors Disclosure Brochure interest through this disclosure and working to ensure that any recommendation to a client regarding the use of margin is suitable for the client. RTW’s policy is to include all related client accounts, specifically the accounts of direct family members sharing the same residence address, for purposes of determining a client’s market value of assets. Fees for Financial Planning Services Clients that receive financial planning services are charged a fixed fee ranging up to $25,000 or an hourly fee rate up to $1,500, depending upon the complexity of a client’s plan and services provided. For clients receiving ongoing financial planning services the annual fee is charged monthly, quarterly or for such other period as agreed upon by the client and RTW. For financial planning services that are completed upon the delivery of RTW’s recommendations, the fixed fee can be charged in monthly or quarterly installments, or otherwise in full upon delivery of RTW’s recommendations. Actual fees charged are clearly outlined in the financial planning agreement. Notwithstanding the foregoing, RTW and the client may choose to negotiate an advisory fee that varies from the schedule and ranges set forth above. Factors upon which a different annual advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The investment management services fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. Although RTW believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. The investment advisory agreement between RTW and the client may be terminated at will by either RTW or the client upon written notice. RTW does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. Fees for Performance Measurement Services RTW’s fees for these services are negotiable and are typically fixed monthly or quarterly fees based on the defined scope of work, number of investments, and specific presentation output requested by the client. Fees for these services typically range from 1-40 basis points annually, but the specific fee arrangements are outlined in the applicable services agreement as mutually agreed. Investment Management Services and Performance services are offered separately or as part of a bundled arrangement. For clients receiving both services, RTW will charge a single combined fee. In certain cases, the fee is calculated based on the value of all assets included in the reporting arrangement, including assets over which RTW does not provide Investment Management Services. With respect to assets not managed by RTW, the fee compensates RTW for reporting, account aggregation, coordination with third-party professionals, and other administrative services. Fees are negotiable based on scope and complexity of services provided. B. Payment of Fees 8  RTW Financial Advisors Disclosure Brochure RTW generally deducts its investment management services fee from a client’s investment account(s) held at the custodian. Upon engaging RTW to manage such account(s), a client grants RTW this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the investment management services fee; the custodian will not determine whether the fee is accurate or properly calculated. For financial planning services clients a client may utilize the same procedure if the client has investment management services accounts held at a custodian or otherwise RTW will receive the financial planning services fee directly from the client. Although clients generally are required to have their investment management services fees deducted from their accounts, in some cases, RTW will directly bill a client for investment management services fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to RTW. Clients may make additions to, and withdrawals from, their investment management services account at any time, subject to RTW’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s investment management services account. Clients may withdraw account assets at any time on notice to RTW, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. RTW may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In connection with RTW’s management of an account, a client will incur fees and/or expenses separate from and in addition to RTW’s advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate account manager (and the manager’s platform manager, if any), limited partnership, or other advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. For External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. D. Postage Fees 9  RTW Financial Advisors Disclosure Brochure RTW generally bears the cost of ordinary postage associated with its standard advisory services and routine reporting. Clients will be charged, at cost, for postage expenses related to non-routine mailings or other special correspondence requested by the client. E. Prepayment of Fees As noted in Item 5(B) above, RTW’s advisory fees generally are paid in advance. Upon the termination of a client’s advisory relationship, RTW will issue a refund equal to any unearned management fee for the remainder of the quarter. F. Outside Compensation for the Sale of Securities or Other Investment Products to Clients RTW does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. However, as further described in Item 10, certain representatives of RTW, in their individual capacities, are associated with Momentum Independent Network as broker-dealer registered representatives (“Dually Registered Persons”). In their capacity as registered representatives of Momentum Independent Network, certain Dually Registered Persons earn commissions for the sale of securities or investment products that they recommend for brokerage clients. . Item 6 - Performance-Based Fees and Side-by-Side Management RTW does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of 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. RTW’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients RTW offers investment advisory services to individuals, high net worth individuals, estates and trusts, pensions and profit sharing plans, charitable organizations, and family offices. However, RTW reserves the right to accept or decline a potential client for any reason in its sole discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss The first step in RTW’s investment strategy is getting to know a client – to understand the client’s financial condition, risk profile, investment goals, tax situation, liquidity constraints, time horizon and other information determined relevant for that client. With this information RTW seeks to assemble a picture of the client’s financial situation and, therefore, an understanding of the client’s needs and goals. Pursuant to RTW’s understanding of a client’s needs and goals, the Firm can recommend strategies and investments that it believes are suitable for the client. 10  RTW Financial Advisors Disclosure Brochure RTW primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from RTW is based on numerous sources, including third-party research materials and publicly available materials, such as company annual reports, prospectuses, and press releases. RTW generally employs a long-term investment strategy for its clients, as consistent with their financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence RTW’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. RTW’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation of the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by RTW include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries 11  RTW Financial Advisors Disclosure Brochure or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks do not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. • US government securities risk, is the risk relating to securities backed by the credit of the government as a whole or only by the issuing agency. US Treasury bonds, notes and bills and some agency securities, such as those issued by the Federal Housing Administration and Ginnie Mae, are backed by the full faith and credit of the US government as to payment of principal and interest and are the highest quality government securities. Other securities issued by US government agencies or instrumentalities, such as securities issued by the Federal Home Loan Banks and Freddie Mac, are supported only by the credit of the agency that issued them, and not by the US government. Securities issued by the Federal Farm Credit System, the Federal Land Banks and Fannie Mae are supported by the agency’s right to borrow money from the US Treasury under certain circumstances but are not backed by the full faith and credit of the US government. No assurance can be given that the US government would provide financial support to its agencies and instrumentalities if not required to do so by law. • Municipal securities risk, is the risk related to securities issued by or on behalf of states, territories, possessions and local governments and their agencies and other instrumentalities. Municipal securities may be secured by the issuer’s general obligations or by the revenue associated with a specific capital project. Both “general obligation” municipal bonds and “revenue” bonds are subject to interest rate, credit and market risk, and uncertainties related to the tax status of a 12  RTW Financial Advisors Disclosure Brochure municipal bond or the rights of investors invested in these securities. The ability of an issuer to make payments could be affected by litigation, legislation or other political events or the bankruptcy of the issuer. In the event of bankruptcy of such an issuer, a client account investing in the issuer’s securities could experience delays in collecting principal and interest, and the client account may not, in all circumstances, be able to collect all principal and interest to which it is entitled. In addition, imbalances in supply and demand in the municipal market may result in a deterioration of liquidity and lack of price transparency in the market. At certain times, this may affect pricing, execution, and transaction costs associated with a particular trade. The value of certain municipal securities, in particular obligation debt, may also be adversely affected by rising health care costs, increasing unfunded pension liabilities, changes in accounting standards, and by the phasing out of federal programs providing financial support. Municipal securities may be less liquid than taxable bonds and there may be less publicly available information on the financial condition of municipal securities issuers than for issuers of other securities, and the investment performance of a client account investing in municipal securities may therefore be more dependent on the analytical abilities of RTW than if the client account held other types of investments such as stocks or taxable bonds. The secondary market for municipal securities also tends to be less well-developed or liquid than many other securities markets, a by-product of lower capital commitments to the asset class by the dealer community, which may adversely affect a client account’s ability to sell municipal securities it holds at attractive prices or value municipal securities. Lower rated municipal bonds are subject to greater credit and market risk than higher quality municipal bonds. • • Commodity Risk: Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy-producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the availability of local, intrastate and interstate transportations systems and thee motions of the marketplace. The risk of loss in trading commodities can be substantial. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. 13  RTW Financial Advisors Disclosure Brochure • • Management risk, which is the risk that the investment techniques and risk analyses applied by RTW may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to RTW. There is no guarantee that a client’s investment objectives will be achieved. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of RTW and its service providers. The computer systems, networks and devices used by RTW and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. RTW does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of External Managers RTW may select certain External Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. In addition, RTW generally may not have the ability to supervise the External Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. RTW has no information applicable to this Item. 14  RTW Financial Advisors Disclosure Brochure Item 10 – Other Financial Industry Activities and Affiliations Broker-dealer Activities Certain management personnel of RTW are separately licensed as registered representatives of Momentum Independent Network, an unaffiliated broker-dealer. These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. While RTW and these individuals endeavor at all times to put the interest of the client first as part of RTW’s fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest, and may affect the judgment of these individuals when making recommendations. Accounting Activities Management personnel of our firm are also partners in the accounting firm of Morris C. Williams & Associates, P.C., where they are individually licensed and practicing Certified Public Accountants providing accounting services for separate and typical compensation. The accounting services and applicable fees are separate from and in addition to RTW’s advisory fee, and are provided only under separate engagement. Clients should be aware that the receipt of additional compensation by RTW Financial Advisors, Inc. and its management persons or employees creates a conflict of interest that may impair the objectivity of our firm and these individuals when making advisory recommendations. This practice presents a conflict of interest as Mr. Morris, as an accountant, has an incentive to recommend accounting services to RTW clients for the purpose of generating additional compensation rather than solely based on client needs. RTW addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to utilize accounting services through any person affiliated with RTW. RTW clients should understand that lower fees and/or commissions for comparable services may be available from other accounting firms. Huber, Prater and Henson, P.C. sometimes recommends RTW Financial Advisors, Inc. to tax return clients in need of advisory services. Conversely, RTW Financial Advisors, Inc. sometimes recommends Huber, Prater and Henson, P.C. to advisory clients in need of tax return and planning services. Services provided by Huber, Prater and Henson, P.C. are separate and distinct from our advisory services, and are provided for separate and typical compensation. There are no referral fee arrangements between our firms for these recommendations. No RTW Financial Advisors, Inc. client is obligated to use Huber, Prater and Henson, P.C. for any services and conversely, no tax return client is obligated to use the advisory services provided by RTW. Huber, Prater and Henson, P.C.'s services do not include the authority to sign checks or otherwise disburse funds on any of our advisory clients behalf. A conflict of interest exists because RTW has an incentive to refer clients to Huber, Prater and Henson P.C. who refers clients back to RTW which could influence the Adviser’ recommendation. As a result, RTW’s recommendation may be based, in part, on the potential for reciprocal referrals rather than solely on the quality or suitability of the professional’s services. 15  RTW Financial Advisors Disclosure Brochure Clients of RTW are under no obligation to engage Huber, Prater and Henson P.C.’s services and are encouraged to independently evaluate whether the provider is appropriate for their needs. RTW seeks to mitigate this conflict by recommending professionals that it believes are qualified to provide the relevant services, but clients are fee to select any provider of their choosing. Recommendation of External Managers RTW may recommend that clients use External Managers based on clients’ needs and suitability. RTW does not receive separate compensation, directly or indirectly, from such External Managers for recommending that clients use their services. RTW does not have any other business relationships with the recommended External Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions RTW has a Code of Ethics (the “Code”) which requires RTW’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to RTW for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. RTW will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers RTW generally recommends that its investment management clients utilize the custody and brokerage services of an unaffiliated broker/dealer custodians (a “BD/Custodian”) with which RTW has an institutional relationship. Currently, this includes Charles Schwab & Co., Inc. (“Schwab”), which is a “qualified custodian” as that term is described in Rule 206(4)-2 of the Advisers Act. Each BD/Custodian provides custody of securities, trade execution, and clearance and settlement of transactions placed on behalf of clients by RTW. If your accounts are custodied at Schwab, Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. In making BD/Custodian recommendations, RTW will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) RTW’s past experience with the BD/Custodian; and 7) RTW’s past experience with similar trades. Recognizing the 16  RTW Financial Advisors Disclosure Brochure value of these factors, clients may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. In exchange for using the services of Schwab, RTW may receive, without cost, computer software and related systems support that allows RTW to monitor and service its clients’ accounts maintained with Schwab. Schwab also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist RTW in managing and administering client accounts. They include investment research, both Schwab’s own and that of third parties. RTW may use this research to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting.   provide pricing and other market data;   Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; access to employee benefits providers, human capital consultants, and insurance providers.    publications and conferences on practice management and business succession; and  Schwab may provide some of these services themselves. In other cases, such firm will arrange for third- party vendors to provide the services to the Firm. 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 the Firm with other benefits such as occasional business entertainment of Firm personnel. In addition, RTW receives financial support from Schwab up to capped dollar amount to be used toward qualifying marketing, technology, consulting and/or research expenses incurred by RTW in registering and launching the operations of RTW. This financial support is available to RTW during the first 12 months from the start of RTW clients having assets custodied at Schwab, and the ultimate amount payable by Schwab is dependent upon the amount of RTW client assets custodied at Schwab. Furthermore, Schwab has agreed to reimburse account termination fees charged to RTW clients by the former custodian of the clients’ accounts up to a capped dollar amount. This reimbursement is available during an initial 12 month period. The fact that we receive these services from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as custodian and broker is in 17  RTW Financial Advisors Disclosure Brochure the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. RTW will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including, but not limited to, the following:      a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. Brokerage for Client Referrals RTW does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage RTW to manage on a discretionary basis, RTW has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by RTW. In selecting a broker-dealer to execute a client’s securities transactions, RTW seeks prompt execution of orders at favorable prices. RTW may, in their sole discretion, accept instructions to custody a client account at a specific BD/Custodian other than Schwab. 18  RTW Financial Advisors Disclosure Brochure Trade Errors RTW’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, RTW endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab. In all cases, RTW will take the appropriate measures to return the client’s account to its intended position. B. Trade Aggregation To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts A. Periodic Reviews Investment Management Services Account Reviews Client accounts are monitored on an ongoing basis, and reviewed periodically in seeking to ensure continued alignment with client objectives, risk tolerance, and financial circumstances. Generally, RTW’s investment adviser representatives seek to have at least one annual meeting with each client to conduct a formal review of the client’s accounts. Accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. For certain clients, depending upon such factors as client account size or agreed upon service levels, RTW will provide written materials to the client including current portfolio information and the provided client financial and related information. The client is instructed to review such materials and to contact RTW if there are any required changes or additions to the materials, or if the client requests an in person meeting with an RTWfinancial professional. Financial Planning Services Account Reviews Upon completion of the initial recommendations, any ongoing reviews and the frequency of those reviews are established, if provided for in the client agreement. For clients receiving ongoing financial planning services generally we seek to meet with our clients on an annual basis; however, more frequent reviews are not uncommon. The nature of the annual review is to evaluate the client’s progress from the previous year based on their goals and objectives. While less common, there are financial planning services clients whose services are completed upon the delivery of RTW’s recommendations. In such situations, RTW does not provide any ongoing reviews of provided recommendations. B. Other Reviews and Triggering Factors In addition to the periodic reviews described above, reviews may be triggered by changes in an account holder’s personal, tax or financial status. Other events that may trigger a review of an account are material changes in market conditions as well as macroeconomic and company- specific events. Clients are 19  RTW Financial Advisors Disclosure Brochure encouraged to notify RTW of any changes in his/her personal financial situation that might affect his/her investment needs, objectives, or time horizon. C. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. RTW provides account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by RTW. RTW statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients RTW does not receive benefits from third parties for providing investment advice to clients. However, we receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our client’s assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12- Brokerage Practices). B. Compensation to Non-Supervised Persons for Client Referrals RTW does not enter into agreements with individuals or organizations for the referral of clients. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct RTW to utilize the custodian for the client’s securities transactions. RTW’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize RTW through such BD/Custodian to debit the clients’ accounts for the amount of RTW’s fee and to directly remit that fee to RTW in accordance with applicable custody rules. The BD/Custodian recommended by RTW has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly 20  RTW Financial Advisors Disclosure Brochure to RTW. RTW encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other statements received from RTW. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Item 16 – Investment Discretion Clients have the option of providing RTW with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in RTW’s client agreement. By granting RTW investment discretion, a client authorizes RTW to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of RTW if RTW determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for RTW. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities RTW does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. Item 18 – Financial Information RTW is not required to disclose any financial information pursuant to this item due to the following: a) RTW does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) RTW is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) RTW has never been the subject of a bankruptcy petition. 21