WEST INVEST

Northwest Wealth Advisors LLC DBA West Invest Firm Brochure – Form ADV Part 2A 1801 F Street Bellingham, WA 98225 360-738-6019 www.west-invest.com This brochure provides information about the qualifications and business practices of Northwest Wealth Advisors, LLC d/b/a West Invest. If you have any questions about the contents of this brochure, please contact us at (360) 738-6019 or by email at: info@west-invest.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. Additional information about Northwest Wealth Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Northwest Wealth Advisors, LLC’s CRD number is: 327641. Registration as an investment adviser does not imply a certain level of skill or training. Version Date: March 2026  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Northwest Wealth Advisors, LLC, dba West Invest (hereinafter “NWWA”) on March 22, 2025, are described below. Material changes relate to Northwest Wealth Advisors, LLC, dba West Invest (hereinafter “West Invest)’s policies, practices or conflicts of interests. • No longer using LPL Programs; this affects Item 4 and Item 5 • Updated Item 8 to reflect current investment strategies • Updated Item 15 to reflect Standing Letters of Authorization on file • Updated the Outside Business Activity in Item 10.C. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................ ii Item 3: Table of Contents ........................................................................................................... iii Item 4: Advisory Business ........................................................................................................... 2 Item 5: Fees and Compensation .................................................................................................. 5 Item 6: Performance-Based Fees and Side-By-Side Management .............................................. 7 Item 7: Types of Clients ............................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................ 9 Item 9: Disciplinary Information.................................................................................................. 12 Item 10: Other Financial Industry Activities and Affiliations ........................................................ 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 14 Item 12: Brokerage Practices .................................................................................................... 15 Item 13: Review of Accounts ..................................................................................................... 17 Item 14: Client Referrals and Other Compensation .................................................................... 18 Item 15: Custody ....................................................................................................................... 20 Item 16: Investment Discretion .................................................................................................. 21 Item 17: Voting Client Securities (Proxy Voting)......................................................................... 22 Item 18: Financial Information ................................................................................................... 23 iii  Item 4: Advisory Business A. Description of the Advisory Firm Northwest Wealth Advisors, LLC, d/b/a West Invest (hereinafter “NWWA”) is a Limited Liability Company organized in the State of Washington. The firm was formed in July 2023, and the principal owners are LaVelle Blair West and LaMar A West. B. Types of Advisory Services Portfolio Management Services NWWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. NWWA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring NWWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. NWWA will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. NWWA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of NWWA’s economic, investment or other financial interests. To meet its fiduciary obligations, NWWA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, NWWA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is NWWA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments NWWA generally limits its investment advice to mutual funds, fixed income securities, real estate funds, equities and ETFs (including ETFs in the gold and precious metal 2  sectors). NWWA may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Financial Planning Services NWWA will often provide a variety of financial planning and consulting services to clients. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, financial planning, estate planning, tax planning, cash flow planning / debt management, personal savings, education savings, insurance and risk management, and/or other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to, the client will usually include general recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations may be made that the client start or revise their investment programs, commence or alter retirement savings, or establish education savings and/or charitable giving programs. For certain financial planning engagements, NWWA will provide a written summary of the client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, NWWA may not provide a written summary. Clients are under no obligation to act on our financial planning recommendations. NWWA may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, NWWA will always ensure 3  those other advisers are properly licensed or registered as an investment adviser. NWWA then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of NWWA's client. NWWA may also allocate among one or more private equity funds or private equity fund advisers. NWWA will not review the ongoing performance of the third-party adviser as a portion of the client's portfolio. C. Client Tailored Services and Client Imposed Restrictions NWWA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by NWWA on behalf of the client. NWWA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. NWWA does not participate in wrap fee programs. E. Assets Under Management NWWA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 304,491,157 $0 December 2025 4  Item 5: Fees and Compensation Maximum Portfolio Management Fees A. Fee Schedule The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of NWWA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. We typically charge a fixed fee for financial planning services, which generally ranges between $500 and $12,000. The fee is negotiable depending upon the complexity and scope of the plan, the Client’s financial situation, and the Client’s objectives. Fees are due upon the completion of the plan. At our discretion, we may offset our financial planning fees to the extent the Client implements the financial plan through our Portfolio Management Services. The Client may terminate the financial planning engagement by providing written notice to our firm. If so, the Client will incur a pro rata charge for services rendered prior to the termination of the engagement, which means the Client will incur fees only for the services rendered. B. Payment of Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. 5  C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by NWWA. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees NWWA collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients LaVelle Blair West and LaMar A West are registered representatives of a broker dealer. LaVelle Blair West and LaMar A West are also insurance agents. In these roles, they accept compensation for the sale of investment products to NWWA clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds to NWWA's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receive compensation, NWWA will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase NWWA recommended products through other brokers or agents that are not affiliated with NWWA. 3. Commissions are not NWWA's primary source of compensation for advisory services Commissions are not NWWA’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. 6  Item 6: Performance-Based Fees and Side-By-Side Management NWWA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7  Item 7: Types of Clients NWWA generally provides advisory services to the following types of clients: Individuals • • High-Net-Worth Individuals • Pension and profit-sharing plans • Corporations or Business Entities There is no account minimum for any of NWWA’s services. 8  Item 8:Methods of Analysis, Investment Strategies, & Risk of Loss Methods of Analysis NWWA’s methods of analysis include Fundamental analysis, Modern portfolio theory and Quantitative analysis. A. Methods of Analysis and Investment Strategies Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies NWWA uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Investment Strategies 9  Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity 10  is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another, and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 11  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. 12  Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative As registered representatives of LPL Financial, LaVelle Blair West and LaMar A West accept compensation for the sale of securities. B. Registration as a Futures Commission Merchant, Commodity Pool Operation, or a Commodity Trading Advisor Neither NWWA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests LaMar A West and LaVelle Blair West are registered representatives of LPL Financial and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. NWWA always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of NWWA in such individual’s capacity as a registered representative. NWWA supervised persons, including LaMar A West and LaVelle Blair West, are also licensed independent insurance agents and may recommend insurance products for which they receive commissions. Additionally, LaVelle Blair West is a common owner of Mountain View Insurance, an insurance agency that shares office space with NWWA and through which certain insurance transactions may be facilitated. This creates a financial incentive to recommend those products. These activities are not conducted in a fiduciary capacity. NWWA mitigates these conflicts by requiring all recommendations to be made in the best interest of the client, periodically reviewing product recommendations to ensure suitability, disclosing all compensation and affiliations in advance and prohibiting any tying of advisory services to insurance or broker-dealer product purchases. Clients are not required to purchase any recommended product or service from any affiliate of NWWA and may obtain similar products from unaffiliated providers. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections NWWA does not utilize nor select third-party investment advisers. 13  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics NWWA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. NWWA's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests NWWA does not recommend that clients buy or sell any security in which a related person to NWWA or NWWA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of NWWA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of NWWA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. NWWA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of NWWA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of NWWA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, NWWA will never engage in trading that operates to the client’s disadvantage if representatives of NWWA buy or sell securities at or around the same time as clients. 14  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on NWWA’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and NWWA may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in NWWA's research efforts. NWWA will never charge a premium or commission on transactions beyond the actual cost imposed by the broker-dealer/custodian. NWWA will require clients to use LPL Financial. 1. Research and Other Soft-Dollar Benefits While NWWA has no formal soft dollar program in which soft dollars are used to pay for third party services, NWWA may receive research, products, or other services from custodians and broker- dealers in connection with client securities transactions (“soft dollar benefits”). NWWA may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and NWWA does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. NWWA benefits by not having to produce or pay for the research, products or services, and NWWA will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that NWWA’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals NWWA receives no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use NWWA will require clients to use a specific broker dealer to execute transactions. Not all advisers require clients to use a particular broker dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If NWWA buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, NWWA would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. NWWA would determine the 15  appropriate number of shares to place with brokers and will select the appropriate brokers consistent with NWWA’s duty to seek best execution. 16  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for NWWA's advisory services provided on an ongoing basis are reviewed at least annually by LaMar A. West, Managing Partner and Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at NWWA are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequence of Regular Reports Provided to Clients Each client of NWWA's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 17  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) As referenced in Item 12 above, the custodian that NWWA recommends for its clients, LPL Financial, makes available various products and services designed to assist NWWA in managing and administering client accounts. Many of these products and services may be used to service all or a substantial number of accounts. These include software and other technology that provide access to client account data (such as trade confirmation and account statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of fees from its clients’ accounts; and assist with back-office functions; recordkeeping and client reporting. LPL also makes available to NWWA other services intended to help manage and further develop its business. Some of these services assist NWWA to better monitor and service program accounts maintained at LPL, however, many of these services benefit only NWWA, for example, services that assist NWWA in growing its business. These support services and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include practice management-related publications; consulting services; attendance at conferences and seminars, meetings, and other educational and/or social events; marketing support; and other products and services used by NWWA in furtherance of the operation and development of its investment advisory business. The products and services described above are provided to NWWA as part of its overall relationship with LPL. While as a fiduciary, NWWA endeavors to act in its clients’ best interests, the receipt of these benefits creates a conflict of interest because NWWA’s recommendation that clients custody their assets at LPL is based in part on the benefit to NWWA of the availability of the foregoing products and services and not solely on the nature, cost or quality of custody or brokerage services provided by LPL. NWWA’s receipt of some of these benefits may be based on the amount of assets custodied on the LPL Financial platform. NWWA attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to our clients. NWWA considers LPL’s timeliness of execution, timeliness and accuracy of trade confirmations, and execution facilitation services provided when recommending that clients maintain accounts with LPL. However, clients should be aware of this conflict and take it into consideration in deciding whether to custody their assets in a brokerage account at LPL. Other than soft dollar benefits as described in Item 12 above, NWWA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to NWWA's clients. 18  B. Compensation to Non-Advisory Personnel for Client Referrals NWWA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 19  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, NWWA will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. For some investment products clients own or use, NWWA may recommend a direct custodian in lieu of its primary recommended qualified custodian. Custody is also disclosed in Form ADV because NWWA has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, NWWA will follow the safeguards specified by the SEC rather than undergo an annual audit. 20  Item 16: Investment Discretion NWWA provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, NWWA generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, NWWA’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to NWWA. 21  Item 17: Voting Client Securities (Proxy Voting) NWWA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 22  Item 18: Financial Information A. Balance Sheet NWWA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither NWWA nor its management has any financial condition that is likely to reasonably impair NWWA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years NWWA has not been the subject of a bankruptcy petition in the last ten years. 23