CW ADVISORS, LLC

March 28, 2025 (Part 2A of Form ADV) CW ADVISORS, LLC 155 Seaport Blvd, 3rd Floor BOSTON, MA 02210 (617) 428-7600 Fax (617) 428-7699 www.cwadvisorsgroup.com compliance@cwadvisorsgroup.com This Form ADV2A (“Disclosure Brochure”) provides information about the qualifications and business practices of CW Advisors, LLC. If you have any questions about the contents of this Disclosure Brochure, please contact us at: (617) 428-7600, or by email at: compliance@cwadvisorsgroup.com. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”), or by any state securities authority, and registration with the SEC does not imply a certain level of skill or training. Additional information about CW Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 310873.  Item 2. Material Changes Annual Update The Material Changes section of this Form ADV 2A (“Disclosure Brochure”) will be updated annually or when material changes occur since the previous released version. Material Changes since the Last Update. This Brochure, dated March 28, 2025, provides information about the qualifications and business practices of CW Advisors, LLC (the “Advisor” or “CWA”). The following material change has been made to this Disclosure Brochure since the last filing and distribution to Clients: Effective December 13, 2024, Scott Dell’Orfano was appointed as the Advisor’s Chief Executive Officer. Effective December 13, 2024, Paul Lonergan transitioned to Chairman of the Board. The Advisor recommends clients invest in CW Multi-Strategy Private Markets Fund 2024, L.P. Please see Item 10 for additional details. 2  Table of Contents Material Changes .................................................................................................. 2 Advisory Business .................................................................................................. 4 Fees and Compensation ....................................................................................... 10 Performance-Based Fees ..................................................................................... 13 Types of Clients .................................................................................................... 14 Methods of Analysis, Investment Strategies and Risk of Loss ............................. 14 Disciplinary Information ......................................................................................... 22 Other Financial Industry Activities and Affiliations ................................................ 22 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................... 25 Brokerage Practices ............................................................................................. 27 Review of Accounts .............................................................................................. 28 Client Referrals and Other Compensation ............................................................ 29 Custody ................................................................................................................. 32 Investment Discretion ........................................................................................... 33 Voting Client Securities ......................................................................................... 33 Financial Information ............................................................................................. 34 Privacy .................................................................................................................. 34 3  Item 4. Advisory Business Firm Description CW Advisors, LLC (herein the “Advisor”, “CWA”, “we” or “us”) operates as a Delaware Limited Liability Company, is located in the Commonwealth of Massachusetts and was established in March 2009. The Advisor offers personalized investment management services to individuals, high net worth individuals and families, trusts, estates, and charitable organizations, other investment advisors, private funds, corporations, and/or other business entities (each, a “Client”). The Advisor also provides these services to pension and profit-sharing plans, including plans subject to the Employee Retirement and Income Security Act (“ERISA”). The Advisor also offers personalized, independent wealth management and financial planning services, which are intended to provide a comprehensive view of the Client’s entire financial situation. As noted below, the Advisor also offers family office services to certain Qualified Clients, who are Clients with either $1,100,000 in assets under management or have a net worth of $2,200,000, as defined in Rule 205-3 of the Investment Advisers Act of 1940, as amended (“Advisers Act”). The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client, and as such is required to disclose all material conflicts of interest, and to mitigate potential conflicts of interest. The Advisor’s fiduciary commitment is further described in the Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. CWA offers a variety of risk-managed strategies, where the investment management approach for each covers a range of risk profiles from conservative to aggressive, in combination with a comprehensive suite of financial planning tools and strategies. Advisor makes available active, passive, strategic, quantitative, and environmentally conscious investment strategy options to fit different Client preferences and risk profiles. We may also recommend that asset management service be provided by a third-party money manager for all or a portion of a Client’s portfolio through a sub-advisory relationship. Generally, we retain discretion over assets designated to the third-party money manager, making decisions based on our periodic assessments to reallocate assets or hire or fire the third-party manager. For assets placed within a private fund or alternative investment, the Advisor will retain non-discretionary authority. Details on each investment management strategy are in Item 8 of this Disclosure Brochure. The Advisor employs investment strategies that use, but are not limited to, exchange-traded funds (“ETFs”), no-load mutual funds, money markets and other similar public securities. The securities in our portfolios represent a variety of asset classes, including U.S. and international equities, U.S. fixed income and international bonds, and unique classes such as commodity futures, international real estate, and emerging markets. While the specific holdings in our portfolios change during the year, we may also use nontraditional asset classes that utilize various hedge fund strategies or private investments. Investments also include equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, variable life insurance, variable annuities, mutual funds shares, U. S. Government securities, options contracts, futures contracts, and 4  interests in partnerships. Clients can impose restrictions on investing in certain securities or types of securities. CWA does not accept any commissions or referral fees from financial product sales. Among other advisers, CWA, in certain instances, engages with Congress Asset Management Company, LLP (“Congress Asset”), an SEC registered investment advisor, to provide investment management services. See Item 10 - Other Financial Industry Activities and Affiliations of this Disclosure Brochure for more information regarding the Advisor’s relationship with Congress Asset. The Advisor engages Congress Asset as an investment manager for investing Client assets in U.S. equities, U.S. fixed income and, when appropriate, for investing Client assets in risk managed portfolios primarily comprised of ETFs (herein “Core” assets). Congress Asset also utilizes investments in REITs, energy master limited partnerships (“MLPs”), commodities, high yield bonds and emerging markets (herein “Satellite”). Satellite investments offer the potential of higher levels of active alpha (returns derived from skilled active management) or exotic beta (exposure to risk factors with low correlation to global markets). The Advisor also may recommend to Clients investments held in certain privately offered pooled investment vehicles for which CWA serves as investment manager (a “CWA Fund” and collectively, “CWA Funds”) or investments held in internally managed separately managed account(s). The Advisor may also recommend to its more sophisticated high net worth Clients investment in a private fund or investment vehicle advised or managed by a non-affiliated investment manager (collectively with CWA Funds, “Private Funds”). The Advisor’s primary office is located at 155 Seaport Blvd, 3rd Floor, Boston, MA 02210. CWA also maintains satellite offices at: • 8 Wright Street, Westport, CT 06880; • 15169 N. Scottsdale Road, Suite 205, Scottsdale, AZ 85254; • 6639 Bay Laurel Dr, Suite B, Avila Beach, CA 93424; • 6345 Woodside Court, Suite 100, Columbia, MD 21046; • 9155 S. Dadeland Blvd., Suite 1212, Miami, FL 33156-2739; • 308 E Lancaster Ave, Suite 300, Wynnewood, PA 19096; • 800 Boylston Street, Suite 2830, Boston, MA 02199-8090; • 3625 Quakerbridge Rd, Hamilton Township, NJ 08619; • 74 West Broad Street, Suite 320, Bethlehem, PA 18018; • 1806 Summit Avenue, Suite 100, Richmond VA 23230; • 271 Waverley Oaks Road, Suite 200, Waltham, MA 02452; • 111 West Jackson Boulevard, Suite 17069, Chicago, IL 60604; and • 37 Stonehouse Road Basking Ridge, New Jersey 07920. Principal Owners The Advisor is organized as a Delaware limited liability company. The Advisor is owned by Congress Buyer, Inc., which is owned by private equity funds managed by Audax Management Company, LLC dba Audax Private Equity (“Audax”), detailed in Item 10 below. CWA is operated by its Executive Officers Scott Dell’Orfano (Chief Executive Officer), Ken Zannoni (President and Chief Wealth Officer), Richard Villiotte (President and Chief Operating 5  Officer), Jennifer DeSisto (Chief Investment Officer), Erin Wendell (Chief Financial Officer), Candace Cavalier (Chief Compliance Officer and General Counsel), Michael Galvin (Executive Managing Director), and Paul Lonergan (Chairman of the Board). Details of ownership and control of CWA are provided on Form ADV Part 1, which is available on the SEC’s website at www.adviserinfo.sec.gov. Types of Advisory Services The Advisor provides its Clients with regular and continuous investment advice, which is particularly tailored to each Client’s investment needs. The Advisor provides various types of investment supervisory services where the Advisor retains investment discretion over the Client’s assets, which are generally invested in separately managed accounts and/or pooled investment vehicles managed by third-party investment managers. The Advisor also offers non-discretionary investment services tailored to the Client’s needs. Please refer to Item 16 for more information about investment discretion. The Advisor’s primary business is providing a wide range of wealth management services tailored to fit each Client’s risk tolerance, financial goals, liquidity needs, time horizon and personal values. The Advisor also offers family office services for certain types of larger Clients requiring such services. As of December 31, 2024, the Advisor managed $9,205,611,801 in discretionary assets and $96,373,059 in non-discretionary assets. As of December 31, 2024, total assets under management (“AUM”) were $9,301,984,860. Wealth Management The Advisor reviews a Client's time horizon, objectives, tax situation, income and liquidity needs and will recommend a portfolio asset allocation mix based on such criteria. Based on the suggested allocation, the Advisor will recommend certain stocks, mutual funds, alternative investments, exchange traded funds, options, and/or investment manager[s] to the Client. The first part of our process is to identify, in light of Client’s risk tolerance and financial goals, the most suitable investment strategy for the accounts being brought under management. Prior to the Advisor providing investment management services, each Client will have entered into separate investment management agreements with the Advisor. The investment management agreement between the Client and the Advisor generally grants the Advisor discretion over the assets held and managed. A Client may also limit such discretion by the Advisor, pursuant to written instruction. For assets the Advisor recommends that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “investment managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an investment management agreement with the 3rd party investment manager(s) (“Independent Manager[s]”) that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients’ investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an 6  Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). The investment manager[s] contracted by the Client, on recommendation of the Advisor, will invest each Client's assets in accordance with the Client's stated objectives, subject to any restrictions agreed upon between the Client and each Independent Manager. The Advisor reviews each Independent Manager prior to recommending such investment manager to its Clients and again at least annually, to ensure that such manager continues to be capable of providing suitable investment management services to its Clients. Such review includes a review of: AUM; performance history; types of portfolios offered (strategies, methods of analysis and sources of information); portfolio management tenure; fees and expenses; risk versus return profile; portfolio turnover; account minimum; and/or disciplinary history. The Advisor receives no direct financial compensation from the investment managers it recommends. Investment managers have hosted educational seminars for Clients and may host future educational seminars for Clients. If the Advisor believes an investment manager is no longer suited to provide services to a Client, the Advisor generally has the authority under the investment management agreement to terminate and replace an investment manager. The Client may also recommend or direct the Advisor to remove a particular investment manager from his or her account[s]. The Advisor will distribute to Clients a copy of the Disclosure Brochure for each Private Fund investment manager managing a portion of the Client's assets, so that the Client sees additional details regarding the investment strategy and fees payable to such Private Fund investment manager. Client accounts are reviewed at least annually. In addition, Client accounts are rebalanced or reallocated, based on the Client's portfolio's performance, changing financial circumstances and any other relevant factors. In some cases, Advisor may recommend rebalancing account assets so that the Client’s assets remain invested according to the targeted ranges established by the agreed upon asset allocation strategy. Advisor may adjust the criteria for assigning assets to categories or add or eliminate instruments from a Client’s allocation strategy. Should the Client’s individual situation change, Advisor will assist the Client in revising the current portfolio and/or reevaluate his or her financial situation to determine if a different portfolio or allocation would be appropriate. Although the investment management agreement between the Client and the Advisor is a continuing agreement, the length of service is at the parties’ discretion. The Client or the Advisor may terminate an Agreement with written notice, up to thirty (30) days in-advance, to the other party. Upon confirmation, we consider a relationship for which a client has delinked our access to account(s) to be a terminated relationship upon knowledge of this situation. As discussed more fully below in “Methods of Analysis and Investment Strategies,” the Advisor primarily utilizes Congress Asset as an investment manager. Family Office Services As an extension of the Advisor’s wealth management services, the Advisor also provides specialized administrative services to businesses, estates, and Qualified Client families in assisting them with their complex needs, such as: estate planning, tax planning, charitable 7  giving, wealth distribution and family budgeting. The Advisor’s family office service delivers these services beginning with the integration of a Client’s financial data to formulate a family office construct and strategic purpose. The Advisor then implements the family office through its wealth management capability and an engaged partnership with the Client’s other financial service providers, such as certified public accountants, law firms and trust companies. Such firms may have an existing relationship with the Client or be appointed by the Client on recommendation by the Advisor. The Advisor receives no direct financial compensation from the firms it recommends. Any legal or tax suggestions provided to Client will be for informational purposes only. Each Client should consult with the Client's third-party legal and tax professionals to determine whether any referenced legal or tax suggestions may be applicable to his or her situation. Investment Portfolio Management CWA will provide continual portfolio management services for investing each CWA Fund portfolio in accordance with its investment objectives. Retirement Accounts When CWA provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of ERISA and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Retirement Plan Advisory Services The Advisor provides advisory services on behalf of employer sponsored retirement plans (each a “Plan”) and companies (each the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services may include: • Employee Enrollment and Education Tracking • IPS Design and Monitoring • Investment Management and Investment Consulting • Performance Reporting • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Vendor Analysis 8  Certain of these services are provided by the Advisor serving in the capacity as a fiduciary under ERISA. In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. CWA Services Provided to Other Investment Advisors CW Advisor Solutions (“CWAS”) is a division of CWA that offers sub-advisory services to other independently registered investment advisors, who care for clients on a fiduciary basis and want to maintain their independence. Our comprehensive suite of business solutions offered includes investment management, back-office support, management consulting and business continuity planning solutions. CWAS provides two fundamental sets of services to independently registered investment advisors: Strategic Partnership outsourcing solutions and PRISM continuity and succession planning. Our services may best fit independently registered investment advisors that are planning-oriented and committed to offering exceptional client service. While using our services, the owners of these firms continue to own 100% of their brand and equity. Investment Outsourcing Solutions Our Strategic Partnership service is designed for independently registered investment advisors run by solo practitioners and small ensembles to leverage resources of a larger firm while enjoying the flexibility and benefits of a small firm. Importantly, strategic partners can access these resources without forfeiting their independence. CWAS serves as a sub-advisor to clients of registered investment advisors with Level 1 Strategic Partnerships. Our internal investment team is responsible for construction, research, decision-making, trading and rebalancing the assets designated to us and determined to be suitable by the strategic partner. We also provide investment and financial planning education as part of our offering. Level 2 Strategic Partners, in addition to Level 1 services, receive operational support and technology solutions to enhance execution of key business functions. Continuity & Succession Solutions CWAS offers continuity and succession planning solutions designed for independently registered investment advisors. Our continuity planning solution, PRISM, protects clients in the event of the death or disability of the advisor. When a triggering event occurs, clients of the advisor will be given the opportunity to become clients of CWA and the advisor and/or the beneficiaries of the advisor will be compensated for the value of those clients who choose to transition to CWA. The PRISM agreement is revocable at any time, for any reason. Our succession planning solution is designed to assist advisors planning for retirement and begins with our Strategic Partnership service. The advisor will transition clients to our investment platform as the advisor prepares for an eventual exit. Tailored Relationships and Client Imposed Restrictions The Advisor works with each Client’s risk tolerance, financial goals, liquidity needs, time horizon and personal values. Stated goals and objectives are documented and may also include reasonable requirements and restrictions stipulated by the Client. Such requirements and restrictions may include investing in strategies incorporating environmental, social and governance screens or, for personal and/or religious considerations. CWA will assist the Client in understanding and evaluating the potential 9  impact of these restrictions on the portfolio. Financial Planning Through its wealth management service, the Advisor also offers comprehensive financial planning services to Clients requiring such services and has processes in place to assist Clients in a deeper understanding of their financial picture. These services include comprehensive financial planning, fact-finding, goal setting, estate tax strategies, wealth distribution and plan implementation services. CWA assists Clients in pre- and post-retirement cash flow and tax management issues, asset allocation strategies designed to mitigate taxes, required minimum distribution selection, and a host of other best practices intended to help a Client manage their financial life before and in retirement. Financial planning advice is tailored to meet the individual needs of each Client and may include a statement of net worth and cash flow, review of investment accounts, including asset allocation and repositioning recommendations, strategic tax planning, review of retirement accounts, estate planning, review of insurance policies, including recommendations for changes, and education funding planning and recommendations. The Client may also engage the Advisor for financial planning services under a separate agreement. CWA does not directly sell insurance products. Financial planning services are provided through the investment management agreement. Implementation of the recommendations of the financial plan are typically executed at the discretion of the Client. The Advisor does not offer a Wrap Fee Program to new Clients, however, the Advisor has a legacy Client where securities transaction fees are combined with investment advisory fee into a single asset-based fee. Including these fees into a single asset-based fee is considered a “Wrap Fee Program.” Item 5. Fees and Compensation Description Generally, the Advisor bases its fees on a percentage of assets managed by Advisor. The Advisor and Client may agree on services outside of the investment management agreement. Generally, in a dual contract arrangement, fees payable to the Advisor for wealth management services will range between 50 basis points and 150 basis points (annualized) multiplied by the total assets managed by the Advisor. Certain legacy engagements may be charged fees that differ from the stated fee range. Generally, in a dual contract arrangement, the Client would also be responsible for fees due both to the Advisor and the investment manager[s] with whom they have contracted with. (See “Other Fees” below). The Advisor’s fees may vary, depending on the Client's circumstances (such as account size, complexity, relationship to other accounts, and investment strategies and managers employed, etc.). The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to CWA, subject to the usual and customary securities settlement procedures. 10  However, the Advisor typically designs its investment portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client’s investment objectives. CWA may consult the Client about certain implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to securities transaction fees, short- term redemption fees, and/or tax ramifications. For all assets deposited into or withdrawn from the Client’s account[s], the Advisor’s fee will be adjusted in the next billing period to reflect the fee difference. The Advisor, at its sole discretion, will negotiate a fee that differs from the schedule above for certain account[s] or holdings. Family Office Services Each agreement between the Advisor and the Client for family office services is negotiated based on the size, complexity, and breadth of each Client’s needs. Generally, such fees will be based on a percentage of assets advised upon and/or managed. If services are in excess of the standard services in the investment management agreement, the Advisor will charge a fixed annual rate of up to $250,000, payable quarterly. Private Funds CWA may receive a fee for providing investment advisory services to CWA Funds and non- investment advisory services to Private Funds. Non-advisory services may include activity relating to fund administration, distribution, and/or investor services. Such a fee will be set-forth in each Private Fund’s Operating Agreement. CWA may also receive reimbursement for certain expenses it incurs relating to the organization and distribution of Private Funds, pursuant to the provisions of each Private Fund’s offering documents. Other Services Fees Upon mutual agreement between the Advisor and the Client, the Advisor will engage in advisory and non-advisory services not discussed in this document, where such fees will be negotiated and memorialized in a written agreement among the parties. ERISA Accounts CWA is deemed to be a fiduciary to advisory Clients that are employee benefit plans or individual retirement accounts (“IRAs”) pursuant to ERISA, and regulations under the IRC. As such, CWA is subject to specific duties and obligations under ERISA and the IRC that include, among other things, restrictions concerning certain forms of compensation. Fees can range up to 130 basis points and are negotiable depending on the size and complexity of the Plan. Fees are billed either in advance or arrears of each month or quarter pursuant to the terms of the retirement plan advisory agreement. Fees can be deducted from the accounts of the plan participants or paid directly by the plan sponsor. Financial Planning Service If engaged separately, financial planning fees for project-based engagements are agreed upon between the Advisor and Client with a maximum fee of up to $25,000. Based on that agreed- upon fee, 50% of the fee is paid to the Advisor upon the execution of the financial planning agreement with the remaining 50% of the fee due upon completion of the agreed-upon deliverable[s]. 11  Fee Billing For investment management services, fees are billed quarterly, in advance or arrears. Fees charged in advance will be based on the market value of assets at the end of the previous calendar quarter. Fees charged in arrears are based on the market values of assets at the end of the calendar quarter. Certain legacy clients are charged fees based on previously agreed upon engagements, which are honored by the Advisor. For assets placed in alternative investments, the Advisor reserves the right to bill on the most recently available valuation before the end of a calendar quarter, if valuations are not readily available at the end of the respective billing period. Fees are usually deducted from a designated Client account[s] at the custodian to facilitate billing. The Client must consent in advance to direct debiting of their investment account[s]. Clients should be aware of their responsibility to verify the accuracy of the fee amount submitted to the custodian by CWA, as the custodian will not determine whether the fee has been properly calculated. All securities, cash and cash equivalents in the account(s) will be included in calculating the value of the account(s) for purposes of computing Advisor’s fees, unless otherwise agreed upon between parties. Fees assessed on a fixed basis for family office services are payable quarterly, in arrears. Clients are advised that all fees paid to the Advisor are separate and distinct from the fees and expenses charged by investment managers, investment funds and custodians recommended to Clients by the Advisor. The Client is responsible for all securities execution and custody fees charged by the Custodian, if applicable. Certain custodians do not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the custodian's brokerage requirements. However, the custodians typically charge for mutual funds and other types of investments, and typically charge wire transfer and/or electronic fund processing fees. Clients for which investments in Private Funds may be appropriate, suitable, and eligible (e.g., real estate partnerships, private equity funds and/or hedge funds) will normally be charged a management fee and other fees and expenses by the Private Fund (which may or may not be related to CWA). In addition, investment managers of these Private Funds typically also charge a performance fee once the private fund exceeds a target rate of return or returns all capital. It is particularly important to understand all fees and expenses, in addition to CWA fees, applicable to any specific investment prior to making a decision to invest. Other Fees Custodians, at their sole discretion, may charge transaction fees on purchases or sales of certain mutual funds, ETFs, stocks and bonds. These fees are in addition to the fees paid by you to CWA. Transaction fees are usually incidental to the purchase or sale of a security, and in our opinion, the selection of the security is usually more important than the transaction fee charged by the custodian, as applicable. CWA does not receive any compensation from transaction fees charged by the custodians. For further information on Brokerage Practices, please see Item 12 of this brochure. Mutual fund companies and ETF issuers charge their shareholders an investment management fee, or expense ratio, that is disclosed in the fund or ETF prospectus. These fees are in addition to the fees paid by you to CWA. CWA does not receive any compensation for management fees charged by a mutual fund or ETF provider. 12  Clients whose assets are designated to a third-party money manager will have fees, in addition to the fees paid by you to CWA. These fees are calculated by the third-party money manager and deducted directly from your account. CWA does not receive any compensation for management fees charged by a third-party money manager. Past due Accounts and Termination of Client Agreements The Advisor reserves the right to stop work on any account where fees due to the Advisor are more than ninety (90) days overdue. A Client may terminate their agreement with the Advisor within five (5) business days of signing their agreement without incurring any advisory fees. Furthermore, the Client or the Advisor may terminate their agreement upon up to thirty (30) days written notice to the other party. Writing can be by regular mail, fax, or email; instant message or other like services are not permissible. Either party can terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party (writing can be by regular mail, fax, or email; instant message or other like services are not permissible). Upon notice of termination from the Client, the Advisor will await further instructions from the Client as to when and how Client requests to liquidate and/or transfer the portfolio and remit the proceeds. Upon receiving instructions, the Advisor will instruct the Client’s investment manager, brokers, dealers, mutual fund sponsors and others to liquidate and/or transfer the portfolio and remit proceeds to the Client. The Client will be invoiced for any investment management fees earned by the Advisor up to and including the effective date of termination. The Advisor can make no representation regarding puts, holds or other investment features that may limit a Client's ability to liquidate or transfer all or a portion of the Client’s portfolio. In the event of termination, when appropriate written notification has been provided, a Client’s obligation to pay advisory fees (pro-rated through the date of termination) will remain. As applicable, a Client will receive a pro-rata refund of any prepaid and unearned fees. Item 6. Performance-Based Fees Performance-Based Fees The Advisor does not charge a performance-based fee in relation to services it provides. However, the Advisor may recommend investment managers and investment funds, including Private Funds, which assess a performance-based fee. Such a recommendation to invest with an investment manager or investment fund with a performance-based fee arrangement would be preceded by an assessment by the Advisor as to the suitability and appropriateness of such an investment, relative to other similar investments, if any, which do not have a performance-based fee arrangement. 13  Item 7. Types of Clients Description The Advisor offers personalized investment management services to individuals, high net worth individuals and families, trusts, estates, charitable organizations, pension and profit-sharing plans, private funds, corporations, and other business entities. CWAS serves as a sub-advisor to other registered investment advisors and enters into agreements with investors of those entities. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts change over time and are updated at least annually by the Advisor. Client relationships vary in scope and length of service. Account Minimums Generally, Clients wishing to hire the Advisor for wealth management services should have at least $1 million in investable assets. The Advisor retains the right to waive such minimum, considering various facts including, but not limited to, long-standing relationships, anticipated additions to AUM, related accounts, type of assets, anticipated future earning capacity and the strategy and investment managers utilized. Account minimums for family office services are determined on a facts and circumstances basis, considering the complexity of the prospective Client’s needs. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Wealth Management Clients and Family Office Clients The Advisor works closely with Clients to determine their investment goals and levels of risk tolerance. The Advisor's basic investment philosophy is rooted in the belief that long-term returns are determined primarily by asset allocation. The Advisor attempts to construct an asset allocation designed to meet each Client's time horizon, risk tolerance, cash needs and other objectives. The Advisor will then implement such asset allocation for each Client. The Advisor uses a Core and Satellite approach to investment management. This approach allows the Advisor to manage each Client’s portfolio to: • Separate and manage various sources of portfolio risk to improve portfolio structure and efficiency; • Add return generating opportunities and / or volatility-reducing asset classes to a portfolio; and Increase the likelihood of meeting their specific financial goals. • Core strategies provide efficient exposure to asset classes that are broadly representative of the market (much of this market representation comes in the form of equity and fixed income instruments). While implementation strategies vary, the Advisor believes that a combination of active, structured and passive strategies provide a solid core for most investors. Satellite strategies generally deliver higher levels of active alpha (returns derived from skilled active management) or exotic beta (exposure to risk factors with low correlation to global markets) and can enhance expected returns. Examples include REITs, energy MLPs, 14  commodities, high yield bonds, private equity, emerging markets securities, and interest rate management investments, such as interest rate and Index swaps and other derivative securities, which allow for active management of duration and yield. In addition, CWA has various internally managed risk-managed active strategies. Series and the portfolio include the Prime Series, Market Series, Quantitative Series, Strategic Market Series, Alpine Series, Clean, Green, Global Market Series, and Clean, Green, and Global Strategic Series. Third-party Investment Manager Due Diligence Each investment manager on the Advisor’s platform is monitored throughout the year and reviewed at least annually. Each investment manager review is presented to the Advisor’s Investment Oversight Committee (“IOC”). The IOC is chaired by the Advisor’s Chief Investment Officer (“CIO”) and is responsible for recommending to the Advisor’s management the hiring or removal of an investment manager. Investment manager reviews include discussions on investment performance, market events/trends, organizational changes, and/or new investment strategies. Further, prior to adding an investment manager on the Advisor’s platform, the Advisor will conduct initial due diligence that is presented to the IOC for evaluation. The IOC, in-turn, will either recommend, or not, the hiring of such investment manager. Each Client is unique, and some Clients have outside accounts with investment limitations or restrictions, have special or unique investment needs or circumstances, or may request information or opinions about investment products that are not included in the investments approved by the IOC. In these situations, the due diligence and process described above is often not fully engaged. Internally Advised Private Funds Consistent with all of our investment strategies, oversight of CWA Funds will be the responsibility of the IOC and the CWA Board of Directors. Monitoring of Client Accounts The Advisor monitors the performance of the Clients’ accounts at least annually in order to confirm the portfolio allocation remains in line with the Client’s risk tolerance and investment objectives. The Advisor reviews broad asset class allocation, investment strategies within each asset class, as well as underlying security performance within each investment strategy. Risk of Loss Securities investments are not guaranteed, and you may lose money on your investments. Each investment style or strategy will carry different levels of risk, and risk factors specific to each investment product or security are disclosed in the prospectus, offering memorandum or other similar disclosure materials specific to each investment. Clients should review all risk factors carefully before making a decision to invest and must be willing to bear these risks. All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: 15  Investment management services include the purchase and sale of securities which involve a certain level of inherent risk. The risk includes the potential loss of principal value. CWA’s investment service is based on a process that provides two separate kinds of risk management: asset class diversification and traditional value investing strategies. 1. Asset Class Diversification - CWA tactically changes the portfolio asset allocation to reflect our views of market value on an ongoing basis. Most portfolios are diversified in terms of global asset classes. In general, CWA has complete discretion in securities chosen or recommended, amounts of securities in Client accounts and choice of broker dealer to execute trades. 2. Value Investing - As a value manager, a key factor to managing risk is our selling technique, which requires constant reevaluation of the value proposition of the securities we hold as prices fluctuate and other opportunities present themselves. This constant monitoring is carried out by an experienced investment team. By utilizing a team approach to the decision-making process, we feel that we are adding another layer of risk protection in volatile markets. Third-Party Money Managers: For assets designated to a third-party money manager, the third- party manager is responsible for continuous monitoring, the selection of securities and trade execution in such accounts. CWA may retain discretion over assets designated to the third- party money manager, using both subjective and objective evaluation factors including but not limited to manager style, previous experience, investment approach, size of firm, holdings, historical performance, and turnover. CWA may select a more costly active manager if we believe that the manager can access a more favorable return stream relative to risk. Margin: CWA uses margin in Client accounts, as appropriate and authorized by the Client. All investing involves some level of risk, including but not limited to the following: • Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Securities with greater interest rate sensitivity and longer maturities are generally subject to greater fluctuations in value. In a rising interest rate environment, a Client’s fixed income portfolio may lose value. A bond with a longer maturity will typically fluctuate more in price than a shorter-term bond. Shorter term money market instruments carry less interest rate risk. • Asset Valuation: The identification of securities and other assets believed to be undervalued is a difficult task and there are no assurances that such opportunities will be successfully recognized or acquired. • Market Risk: All securities investments are subject to changes in the marketplace. The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Economies and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region may adversely impact markets or issuers in other countries or regions. At times, movements in the market can be significant, which will cause the value of an investor’s account to change. 16  o Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Inflation also generally leads to higher interest rates, which may cause the value of many types of fixed income investments to decline. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties and most private equity funds are not. A lack of liquidity will impact the marketability of a security, meaning that it may not be purchased or sold without negatively impacting its price. Liquidity risk is the risk that may occur due to the inability to convert a security or hard asset to cash without a loss of capital and/or income in the process. Liquidity risk generally arises when an individual with immediate cash needs holds a valuable asset that cannot trade or sell at market value due to a previously agreed upon holding period. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Investment Model Allocation and Planning Tool Risk: With regard to risk managed portfolios, the investment manager’s strategic allocation assumptions and market momentum signals which drive tactical allocation and decisions regarding cash balances, may be incorrect and may result in underperformance relative to other investments. Financial planning tools rely heavily on assumptions, simulations and historical information that may or may not end up being accurate generally or given a specific Client’s circumstances. 17  • Sector Risk: 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. • Foreign securities and emerging markets risk: Foreign securities are subject to interest-rate, currency-exchange-rate, economic, and political risks, all of which may be magnified in emerging markets. Foreign securities are subject to the same market risk as US securities and involve risk of loss due to political, economic, legal, regulatory and currency risk. There are also differences in accounting and financial reporting standards. Further, events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. • ETF Risks: ETFs are investments whose shares are bought and sold on security exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some ETFs are SPDRs, PowerShares and iShares. Our investment strategies could purchase ETFs to gain exposure to a portion of the US or foreign markets, sectors, industry, or commodities. Our investment strategies for investing in another investment company will bear their pro rata share of the other investment company’s advisory fee and other expenses, in addition to their own. The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. Specifically, ETFs, depending on the underlying portfolio and its size, can have a wide price (Bid and Ask) spreads, thus diluting or negating any upward price movements of the ETF or enhancing any downward price movement. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of an ETF. Certain ETFs employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, collateral, and liquidity of the supporting collateral. The use of leverage increases interest rate cost to the ETF as well as increases the level of volatility. • Mutual Fund Risks: The major risk of investing in a mutual fund includes the quality and experience of the mutual fund portfolio management team and their ability to create fund value by investing in securities that have growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. 18  • Commodities Risk: Commodities include soft assets such as crops and coffee that are generally extracted from the ground, as well as hard assets such as minerals and metals that are mined. Investing in commodities carries significant risks, including price, credit, and market risk. Many physical commodities, as well as intangible commodities (such as security or fixed income indices) serve as the underlying asset to commodity futures contracts. • Company Risk: When investing in stock positions, there is always a certain level of company or industry-specific risk that is inherent in each investment. This is also referred to as non-systemic risk and it can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Management Risk: An investment’s value varies with the success and failure of the investment strategies, research, analysis, and determination of portfolio securities. If investment strategies do not produce the expected returns, the value of the investment will decrease. Also, Client account balances maintained at banking institutions or securities firms may exceed FDIC (Federal Deposit Insurance Commission or fdic.gov) or SIPC (Securities Investor Protection Corporation or sipc.org) insurance limits, to the extent those programs are applicable. • Client Imposed Investment Restrictions Risk: Clients who place restrictions on investing in certain industries or specific companies for social, religious, statutory, or other reasons, may forgo investment opportunities that are in the best economic interest of the Client. Such restrictions may result in performance less favorable than other Client accounts managed by CWA without such restrictions. • Risks for all forms of analysis: While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Information that we gather and impart depends upon to be accurate and unbiased information we received, which includes, but is not limited to: corporate annual reports, filings with the SEC, company press releases, research material reported by others, financial newspapers and magazines, corporate ratings/analytical services, government reports, etc. • Technical Risk: Technical analysis utilizes statistics to determine trends in security prices. This type of analysis tends to focus on but is not limited to factors such as trading volume, demand, and volatility. Technical chart analysis is also used, which involves the assessment of historical charts and graphs. • Margin Risk: The use of short-term margin borrowings results in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call," pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. 19  • Options Contract Risk: Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. Leverage risk highlights how a small investment can lead to significant gains or losses, amplifying both returns and the potential for total loss. Market risk points to the vulnerability of options to overall market movements and economic conditions, which can adversely affect option values even if predictions about the underlying asset are correct. Liquidity risk arises from the potential difficulty in selling options at fair prices before expiration, which could lead to significant losses. Lastly, expiration risk underlines the importance of timing in options trading, as options can become worthless if not exercised before their expiration date, impacting investment outcomes especially for those near expiration. • Alternative Investments (Limited Partnerships) Risk: Alternative Investments are normally investments with companies or sectors that are not publicly traded. These investments are normally very illiquid and can be volatile; therefore, they are not ideal for clients with frequent or unknown cash needs. There is normally no public market for alternative investments. As a result, if investors need to sell their shares, they will most likely do so at a substantial discount. Further, depending on the terms of the investment, the investor may not be able to transfer or sell their shares. The risk of investing in alternative investments is a substantial or complete loss of invested funds. In addition, investors may not see any return on investment for some time depending on the type of investment and as a result, these investments should be seen as long-term investments subject to a high risk of loss. Investments in alternative investments are made through a subscription agreement between the investor, the alternative investment entity, its general partner, and/or its investment manager. This means that the terms of the investment are explicitly outlined in the offering documents of the alternative investment. • Cyber Security Risk: Cyber security is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. With the increased use of technologies to conduct business, such as the Internet, CWA is susceptible to operational, information security and related risks. CWA relies on communications technology, systems, and networks to engage with Clients, employees, accounts, shareholders, and service providers, and a cyber incident may inhibit CWA’s ability to use these technologies. In general, cyber incidents can result from deliberate attacks or unintentional events by insiders or third parties, including cybercriminals, competitors, nation-states and “hacktivists,” among others. Cyber- attacks include, but are not limited to, phishing, gaining unauthorized access to digital systems (e.g., through “hacking” or infection from or spread of malware, ransomware, computer viruses or other malicious software coding) for purposes of misappropriating assets or sensitive information, structured query language attacks, corrupting data, or causing operational disruption. Cyber-attacks may also be carried out in a manner that does not require gaining unauthorized access, such as causing denial-of-service attacks on websites. A denial-of-service attack is an effort to make network services unavailable to intended users, which could cause CWA and Clients to lose access to 20  their electronic accounts, potentially indefinitely. Employees and service providers of CWA may not be able to access electronic systems to perform critical duties, such as trading and account oversight, during a denial-of-service attack. Although there are security risks associated with “screen scraping,” which clients must be prepared to bear, risks are to some extent mitigated by regular oversight and availability of client investment data and reporting. "Screen scraping” is a data collection method where the perpetrator scans user’s compromised system to obtain data from open applications that are being displayed on the monitor. There is also the possibility for systems failures due to malfunctions, user error and misconduct by employees and agents, natural disasters, or other foreseeable and unforeseeable events. Because technology is consistently changing, new ways to carry out cyber-attacks are always developing. Therefore, there is a chance that some risks have not been identified or prepared for, or that an attack may not be detected, which puts limitations on CWA’s ability to plan for or respond to a cyber-attack. Like other business enterprises, CWA and its service providers have experienced, and will continue to experience, cyber incidents consistently. In addition to deliberate cyber-attacks, unintentional cyber incidents can occur, such as the inadvertent release of confidential information by CWA or its service providers. To date, cyber incidents have not had a material adverse effect on CWA’s business operations or performance. CWA uses third party service providers who are also heavily dependent on computers and technology for their operations. Cybersecurity failures or breaches by CWA, our partners, other service providers and the issuers of securities in which a Client invests, may disrupt and otherwise adversely affect their business operations. This may result in financial losses and costs to CWA or Clients or cause violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, litigation costs, or additional compliance costs. In addition, substantial costs may be incurred in order to prevent any cyber incidents in the future. In addition, compliance with current and future privacy, data protection and information security laws could significantly impact current and planned privacy and information security related practices, the collection, use, sharing, retention, destruction and safeguarding of personal data and some of a Client’s current and planned business activities. Failure to comply with such laws and regulations could result in fines, sanctions or other penalties, which could materially and adversely affect the results of operations of a Client and/or its investing securities and overall business, as well as have an impact on reputation. While CWA and many of its service providers have established business continuity plans and risk management systems intended to identify and mitigate cyber-attacks, there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. CWA cannot control the cybersecurity plans and systems put in place by service providers and issuers in which CWA invests on behalf of Clients. CWA and Clients could be negatively impacted as a result. 21  Item 9. Disciplinary Information Legal and Disciplinary On December 22, 2014, the SEC brought a settled fraud action against F-Squared Investments, Inc. (“F-Squared”), an unaffiliated investment manager. In connection with the resolution, F-Squared admitted, among other things, to making false claims regarding its AlphaSector strategy. More specifically, it falsely represented that: (a) the signals that formed the basis of its AlphaSector index returns had been used to manage Client assets from April 2001 to September 2008; and (b) the strategy significantly outperformed the S&P 500 Index during that period. The Advisor, through its former registration, had utilized the Alpha Sector investment strategy to manage a portion of its Clients’ assets from May 2009 to October 2013. During this period, less than 5% of assets under CWA’s management were invested pursuant to this strategy. In October 2013, CWA became aware of information that caused it to question the accuracy of F- Squared’s representations and promptly removed from its advertising materials all references to F-Squared’s performance prior to September 2008. Then, in December 2013, the Advisor ceased using the AlphaSector signals entirely and terminated its relationship with F-Squared. The SEC conducted a sweep of investment advisers that had relied on F-Squared’s representations, and on August 25, 2016, it entered orders against 13 such advisers, including CWA. With respect to CWA, the SEC order found, in sum and substance, that despite its due diligence, CWA negligently relied on F-Squared representations in advertising F-Squared’s strategy, in violation of Section 206(4) of the Advisers Act and Rules 206(4)-1(a)(5) and 204- 2(a)(16) thereunder. Without admitting or denying the findings, CWA consented to the entry of a cease-and desist order imposing a $100,000 penalty. A copy of the order can be found at https://www.sec.gov/litigation/admin/2016/ia-4507.pdf Except for the matter discussed above, the Advisor has not been involved in legal, regulatory or disciplinary events related to past or present investment Clients that would be material to the evaluation of CWA or the integrity of its management personnel. Item 10. Other Financial Industry Activities and Affiliations Activities and Affiliations The Advisor is not affiliated with any custodian or non-advisory service provider, which performs services to the Advisor or its Clients. In addition, the Advisor does not engage in financial industry activities except for the advisory services performed and disclosed in this Brochure. As discussed throughout this Disclosure Brochure, the Advisor partners with but is independent from Congress Asset. The Advisor has, historically, leveraged investment expertise and operations support from Congress Asset. Additionally, the entities have - at times - jointly paid for expenses, such as salaries and infrastructure costs. Congress Asset has also shared in certain CWA expenses, including those resulting from the opening of CWA’s branch offices. Such arrangements are and have been at no cost to the Clients of either Congress Asset or the Advisor. 22  While considering a broad variety of investment options, the Advisor primarily selects and retains the investment management services of Congress Asset to actively manage domestic equities and domestic investment grade fixed income. The Advisor believes that its relationship with Congress Asset operates at a level of transparency and access, which exceeds the levels of transparency and access provided by unaffiliated investment managers and is to the benefit of its Clients. The compensation of the Advisor’s employees does not vary depending on the investment vehicles selected for Client(s) portfolios. Congress Asset Management Company, LLP Paul A. Lonergan, Chairman of the Board of CWA, is currently a non-voting member on the Management Committee of Congress Asset, and he receives compensation for his services. Congress Asset is an investment advisor registered with the SEC (CRD No. 105161; SEC No. 801-23386). The Advisor may recommend or engage Congress Asset to manage all or a portion of a Client's investment portfolio. CWA Clients enter into a separate investment management agreement with Congress Asset, including via a dual contract arrangement for which CWA may retain discretion to increase or decrease assets managed by Congress Asset. For certain Clients who wish to solely contract with CWA, rather than contracting directly with Congress Asset, a ‘single contract’ agreement exists where Congress Asset manages CWA Clients’ assets pursuant to a sub-advisory agreement between CWA and Congress Asset. The sub-advisory agreement provides for investment management and related trading and operational support. CWA pays Congress Asset a percentage of the advisory fee it collects. The Advisor is sensitive to perceived and potential conflicts, which may arise regarding Mr. Lonergan’s relationship with Congress Asset. CWA Funds CWA is the investment advisor to CWA Funds, where compensation is generated through an advisory fee. When a Client invests in a CWA Fund, CWA will waive its advisory fee on the Client’s assets invested in the CWA Funds. Additional details on the CWA Funds and their fees are disclosed in the respective private offering documents. Clients of CWA are not obligated to invest in a CWA Fund, but should understand that in some cases the fees paid to CWA as an advisor to CWA Funds may be higher than a fee that would otherwise be charged on the Client’s assets, depending on their specific fee schedule and breakpoints. Audax Private Equity Business LP As disclosed in Item 4.A, the Advisor’s principal owners are two private equity funds, Audax Private Equity Fund VII-A, L.P. and Audax Private Equity Fund VII-B, L.P. (the “Audax PE VII Funds”), that are managed by Audax, a registered investment advisor. Audax Private Equity Business VII LP, an affiliate of Audax, is the General Partner of the Audax PE VII Funds. Audax and its affiliates (collectively, “Audax Group”) provide investment advice to other private funds, separately managed accounts, and other investment accounts (collectively, the “Audax Funds”). The Audax Funds generally seek to invest in or make loans to middle-market companies but, from time to time, invest in investment advisers. 23  The affiliation between the Advisor and Audax Group poses a potential conflict of interest, when the Advisor recommends an investment into an Audax Fund or related Audax Investment, where Audax is entitled to revenue generated by such investments. Further, for certain investments recommended by the Advisor, Audax may also have beneficial ownership in such investments, potentially at different levels of the company’s capital structure. In such cases, Audax Group may take actions that conflict with the interests of the Advisor's Clients. To mitigate this conflict, the Advisor ensures that only suitable Audax investments are recommended to Clients. In addition, the Advisor does not have any direct incentive tied to revenues generated from Audax related activities, where there is no incentive for the Advisor for revenues generated by Audax Fund investments. If any additional conflicts become apparent, the Advisor will provide separate disclosures of the conflict to the Client and how such conflicts are mitigated, demonstrating that investments recommended by the Advisor are in the Client’s best interest. Aspera Limited Partnership The Advisor serves as the investment manager to Aspera Limited Partnership (“Aspera”), where an affiliated person of the Advisor serves as its General Partner. Aspera is not offered to any Clients of the Advisor, nor is it offered to any new investors. MJA Special Opportunities Fund, LP The Advisor serves as the investment manager to MJA Special Opportunities Fund, LP (“MJA Fund”), where an affiliated person of the Advisor is the owner of the MJA Fund’s General Partner. MJA Fund is not offered to any Clients of the Advisor, nor is it offered to any new investors. CW Multi-Strategy Private Markets Fund 2024, L.P. The Advisor recommends that certain clients invest in CW Multi-Strategy Private Markets Fund 2024, L.P. (“CW MSPM Fund”), a fund managed by Allocate Management Company, LLC. The Advisor had a financial incentive to recommend the CW MSPM Fund, which is detailed in the Private Placement Memorandum of CW MSPM Fund. Please note, the Advisor does not have any additional incentive to recommend the CW MSPM Fund. Alumni Venture Group Mr. Zannoni is an Investment Advisory Council member of Alumni Venture Group. Clients of the Advisor may be recommended to invest into an investment vehicle affiliated with Alumni Venture Group. Mr. Zannoni does not receive any compensation nor receive any renumerations related to the affiliated with Alumni Venture Group. Additional Information Some employees, affiliated persons of the Advisor, engage in outside business activities, including investments advisory activities, such as Aspera and MJA Fun 24  Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Advisor has adopted a “Code of Ethics”, pursuant to Rule 204A-1 of the Advisers Act. The Code of Ethics (“Code”) sets forth high ethical standards of business conduct, including compliance with applicable federal securities laws. CWA’s personnel owe duties of loyalty, fairness and good faith towards its Clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. All Supervised Persons must avoid activities, interests and relationships that run contrary or appear to run contrary to the best interests of our Clients. All associates of the Advisor (herein our “Supervised Persons”) are required to comply with CWA’s Code, which provides a standard of business conduct and also imposes reporting requirements and restrictions on the purchase or sale of securities with regard to their own accounts and the accounts of certain affiliated persons. The Code is based on the overriding principle that CWA is a fiduciary to Clients and must act in their best interests at all times. At all times, the Advisor places Client interests ahead of our own. Supervised Persons also must not: • Employ any device, scheme or artifice to defraud a Client; • Make any untrue statements of a material fact to a Client or omit to state to a Client any material facts that are necessary to make the statements made (in light of the circumstances under which they are made) not misleading; • Engage in any act, practice, or course of business, which operates or would operate as a fraud or deceit upon a Client; • Engage in any manipulative practice with respect to a Client; • Use their positions, or any investment opportunities presented by virtue of their positions, to their personal advantage or to the detriment of a Client; or • Conduct personal trading activities in contravention of the Code or applicable legal principles or in such a manner as may be inconsistent with the duties owed to Clients as a fiduciary. As noted above, these general standards are meant as overriding guidelines to be adhered to in all current and emerging situations and are not limited to the detailed behavior specifically discussed in the Code. The Code also addresses other areas of business conduct, including: duty of confidentiality, reporting suspected wrongdoing, gifts and entertainment, outside employment, insider trading and personal securities transactions. In the event of a violation of the Code, the Advisor will impose such sanctions as deemed necessary and appropriate. Sanctions range from a letter of censure, suspension of employment without pay, referral to the appropriate regulatory agency or permanent termination of employment. 25  The Code is subject to periodic review by the CCO with regard to CWA’s business activities, associates and emerging risks. A copy of our Code is available to our advisory Clients and prospective Clients. You may request a copy by email sent to compliance@cwadvisorsgroup.com, or by calling us at (617) 428-7600. Personal Trading CWA seeks to ensure that personal trading activities of its associates who have access to nonpublic client or portfolio holdings information (Access Persons), do not conflict with the interests of CWA Clients. To guard against any potential conflicts of interest with our Clients, CWA Access Persons are required to disclose annually each securities account to CWA and to either provide or arrange for their brokerage firm to provide duplicate account statements and confirms necessary to allow CWA to monitor trade activities and keep the records required by the Advisers Act and rules thereunder. The Code of Ethics also imposes restrictions on Access Persons personal securities transactions and accounts. Such restrictions include: (a) prohibitions on trading in securities while in possession of related material, nonpublic information (MNPI); (b) blackout periods; and (c) reporting of personal securities accounts, transactions and/or holdings to the CCO. The CCO will maintain Access Persons quarterly transaction reports and annual holdings disclosures in keeping with the firm’s fiduciary and recordkeeping responsibilities. As noted above, the full text of the Advisor's Code is available to Clients upon request. Participation or Interest in Client Transactions The Advisor or individuals associated with the Advisor may buy or sell - for their personal account[s] - investment products identical to those recommended to and held by Clients. However, no person employed by the Advisor may intentionally purchase or sell any security prior to transactions implemented for an advisory account, where such employees may benefit from transactions subsequently placed on behalf of advisory accounts. Individuals associated with the Advisor may personally invest in unaffiliated Private Funds that are recommended to Clients. In certain circumstances, in meeting certain minimum thresholds of total assets placed in the unaffiliated Private Fund, both CWA employees’ and Clients’ fees charged on those assets may be reduced equally. The Advisor will ensure adequate due diligence and that the investment into the unaffiliated Private Fund is in the Client’s best interest. The Advisor or the investment managers may recommend or use their discretion to affect a purchase or sale in securities of companies for which the Advisor, the investment managers or their affiliates act as a sponsor, advisor, investor and/or investment manager, including mutual funds advised or sub advised by Congress Asset. In addition, the Advisor or the investment managers may also recommend or use their discretion to affect a transaction in their Client accounts, in securities of companies (or securities of affiliates of such companies) in which the Advisor, the investment managers or their affiliates or their personnel may have an ownership or management interest. In connection with its investment activities, the Advisor may receive information that is not generally available to the public. The Advisor is not obligated to make such information available to its Clients or to use such information to effect transactions for its Clients. These procedures may limit CWA from being able to purchase or sell securities of the issuer to whom the material, non-public information pertains. 26  Supervised Persons are not permitted to trade their own securities ahead of known Client trades. Supervised Persons must comply with all provisions of our Compliance Program. Item 12. Brokerage Practices General Excluding CWA Funds, only the Client has authority to select the custodian/broker dealer for custody and execution services. The Advisor may make recommendations to the Client as to which custodians would be appropriate for the Client. The Client will engage the broker-dealer or custodian (herein the "Custodian") to safeguard Client assets and authorize CWA to direct trades to this Custodian as agreed in the Investment Management Agreement. CWA does maintain institutional relationships with various Custodians. The Client may also instruct their investment manager[s] to direct trades to their custodian or to a particular broker dealer. Clients will not incur any extra fee or cost by the Advisor when using a custodian recommended or not recommended. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not utilized. CWA Funds will be custodied as provided in their offering documents. Further, CWA does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. CWA will generally recommend that Clients establish their account[s] at Fidelity Clearing & Custody Solutions, a related entity of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”), FINRA-registered broker-dealers and members of SIPC. In general, Fidelity and Schwab will serve as the Client’s “qualified custodians.” CWA is independently owned and operated and is not affiliated with a Custodian. CWA maintains an institutional relationship with Fidelity and Schwab, whereby the Advisor receives economic benefits from Fidelity and Schwab. CWA participates in the institutional platforms at Schwab and Fidelity and receives Client and investor referrals. Please see Item 14 below. CWA considers the Custodian’s respective financial strength, reputation, execution, pricing, research and service when providing a recommendation to a Client. CWA and Clients receive some benefits from Schwab or Fidelity through participation in the institutional platforms and referral programs, such as attainment of many mutual funds without transaction charges and other securities at nominal transaction charges. Research and Other Soft Dollar Benefits Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. We do not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian except as permitted under the safe harbor rules. We may receive certain economic benefits from our recommended custodians. Directed Trading The Client and its custodian may require the investment manager to direct security trades to a particular broker or custodian. In such cases, neither the Advisor nor the investment manager are able to negotiate commission rates or spreads and may not be able to obtain the same 27  execution it receives for other Clients. Directed trades may not be able to be “bundled” with other Clients’ orders and sometimes receive a less favorable price. This means that directed- trade Clients may receive worse prices than non-directed Clients receive. Additionally, Clients who direct trades to a particular broker or dealer may experience higher commissions, greater spreads, or less favorable net prices than they would if the Advisor or investment manager[s] were able to select brokers or dealers. Order Aggregation Transactions for each Client will generally be executed independently, unless the Advisor decides to purchase or sell the same securities for several Clients at approximately the same time. CWA can, but is not obligated to, combine or “batch” such orders to obtain best execution and negotiate more favorable transaction rates. The Advisor may, but is not obligated to, allocate equitably among its Clients, any differences in prices or other transaction costs that might have been charged had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated pro rata to the purchase and sale orders placed for each Client on any given day. To the extent that the Advisor aggregates Client orders, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance from the staff of the SEC. The Advisor shall not receive any additional compensation or remuneration as result of Client order aggregation. In the event that a pro-rated allocation is not appropriate under a particular circumstance, an allocation to Client accounts will be made based upon other relevant factors, which may include: (i) when small percentage of the order is executed, shares may be allocated to the account with the smallest position or to an account that is out of line with respect to security to sector weightings relative to other portfolios, with small mandates, (ii) allocations may be given to one account when one account has limitations in its investment guidelines, which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts, (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed), (iv) with respect to sale allocations, allocations may be given to accounts low in cash, (v) in cases when a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Advisor may exclude the accounts(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts, or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13. Review of Accounts Periodic Reviews Client accounts are monitored on an ongoing basis by each Client’s financial advisor. A formal review of each Client account is performed at least annually. Arrangements for additional reviews are made on a case-by-case basis at the Client's request or as circumstances demand. The Advisor will perform out of cycle reviews of Client accounts when conditions arise that trigger a review. Examples of such conditions are changes in the tax laws, market events and/or changes in a Client's financial situation. 28  All Clients are advised that it remains their responsibility to notify the Advisor of any changes to their investment objectives, liquidity needs, time horizons, risk tolerance or financial situation. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment and economic information, or changes in a Client's situation. Regular Reports Clients receive statements (from either the Advisor and/or the account custodian), including monthly activity statements, quarterly performance reporting and year-end tax reporting. CWA offers Clients secure online access to reports as well as summarized updated values of their portfolio. If utilized, the online report portal will show activity up to the previous days’ market values. If a Client discovers any discrepancy in their information or positions reflected on any report, they are encouraged to contact us immediately. Item 14. Client Referrals and Other Compensation Referrals CWA has been fortunate to receive many Client referrals over the years. These referrals originate from current Clients, estate planning attorneys, employees, personal friends or relatives of employees and other similar sources. CWA has also created a referral program with various professionals, including independent certified public accounting firms, insurance professional and attorneys in exchange for revenue sharing. We also participate in programs with Fidelity and Schwab. Institutional Advisor Platforms Participation in Fidelity Wealth Advisor Solutions® The Advisor participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which the Advisor receives referrals from Fidelity Personal and Workplace Advisors LLC (“FPWA”), a registered investment advisor and Fidelity Investments company. The Advisor is independent and not affiliated with FPWA or any Fidelity Investments company. FPWA does not supervise or control the Advisor, and FPWA has no responsibility or oversight for the Advisor’s provision of investment management or other advisory services. Under the WAS Program, FPWA acts as a solicitor for the Advisor, and the Advisor pays referral fees to FPWA for each referral received based on the Advisor’s AUM attributable to each Client referred by FPWA or members of each Client’s household. The WAS Program is designed to help investors find an independent investment advisor, and any referral from FPWA to the Advisor does not constitute a recommendation or endorsement by FPWA of the Advisor’s particular investment management services or strategies. More specifically, the Advisor pays the following amounts to FPWA for referrals: the sum of: (i) an annual percentage of 0.10% of any and all assets in Client accounts where such assets are identified as “fixed income” assets by FPWA; and (ii) an annual percentage of 0.25% of all other assets held in Client accounts. In addition, the Advisor has agreed to pay FPWA a minimum annual fee amount in connection with its participation in the WAS Program. These referral fees are paid by the Advisor and not the Client. 29  To receive referrals from the WAS Program, the Advisor must meet certain minimum participation criteria, but the Advisor may have been selected for participation in the WAS Program as a result of its other business relationships with FPWA and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, the Advisor may have a potential conflict of interest with respect to its decision to use certain affiliates of FPWA, including FBS, for execution, custody and clearing for certain Client accounts, and the Advisor may have a potential incentive to suggest the use of FBS and its affiliates to its advisory Clients, whether or not those Clients were referred to the Advisor as part of the WAS Program. Under an agreement with FPWA, the Advisor has agreed that the Advisor will not charge Clients more than the standard range of advisory fees disclosed in its Form ADV Part 2A Brochure to cover solicitation fees paid to FPWA, as part of the WAS Program. Pursuant to these arrangements, the Advisor has agreed not to solicit Clients to transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other custodians for referred Clients other than when the Advisor’s fiduciary duties would so require, and the Advisor has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a Client account that is transferred from FPWA’s affiliates to another custodian; therefore, the Advisor may have an incentive to suggest that referred Clients and their household members maintain custody of their accounts with affiliates of FPWA. However, participation in the WAS Program does not limit the Advisor’s duty to select brokers on the basis of best execution. Schwab CWA receives Client referrals from Schwab through CWA’s participation in Schwab Advisor Network® (“the Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with CWA. Schwab does not supervise CWA and has no responsibility for CWA’s management of Clients’ portfolios or CWA’s other advice or services. CWA pays Schwab fees to receive referrals through the Service. As a registered investment advisor participating in the Service, CWA receives access to software and related support without cost because CWA renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab benefit CWA and many, but not all, services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. CWA’s participation in the Service raises potential conflicts of interest described below. CWA pays Schwab a Participation Fee on all referred Client’s accounts that are maintained in custody at Schwab and a separate one-time Transfer Fee on all accounts that are transferred to another custodian. The Transfer Fee creates a conflict of interest that encourages CWA to recommend that Client accounts be held in custody at Schwab. The Participation Fee paid by CWA is a percentage of the value of the assets in the Client’s account. CWA pays Schwab the Participation Fee for so long as the referred Client’s account remains in custody at Schwab. The Participation Fee is paid by CWA and not by the Client. CWA has agreed not to charge Clients referred through the Service fees or costs greater than the fees or costs CWA charges Clients with similar portfolios who were not referred through the Service. 30  The Participation and Transfer Fees are based on assets in accounts of CWA’s Clients who were referred by Schwab and those referred Clients’ family members living in the same household. Thus, CWA will have incentives to recommend that accounts and household members of Clients referred through the Service maintain custody of their accounts at Schwab. For accounts of CWA’s Clients maintained in custody at Schwab, Schwab generally does not charge the Client separately for custody but receives compensation from CWA Clients in the form of commissions or other transaction-related compensation on securities trades Schwab executes for a Client’s accounts. Clients also pay Schwab a fee for clearance and settlement of trades executed through broker dealers other than Schwab. Schwab’s fees for trades executed at other Custodians are in addition to the other Custodian fees. Thus, CWA may have an incentive to cause trades to be executed through Schwab rather than another broker. CWA, nevertheless, acknowledges its duty to seek best execution of trades for Client accounts. Trades for Clients’ accounts held in custody at Schwab may be executed through a different Custodian than trades for CWA’s other Clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other custodians. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to CWA that may not benefit the Client. The services offered by Schwab include educational conferences and events, financial start-up support, consulting services, and discounts for various service providers. Were CWA to utilize any of these services, it may create a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. CWA believes, however, that any recommendation of Schwab as Custodian is in the best interests of its Clients. Other Incoming Referrals The Advisor may pay referral fees to unaffiliated consultants, independent contractors, registered investment advisors, certified public accounting firms and other independent persons or firms (“Promoters”) for introducing Clients to the Advisor, for either a fixed amount or a percentage of advisory fees. Whenever the Advisor pays a referral fee, the Advisor requires the Promoter to provide, at the time of referral, the prospective Client with a copy of this document (our Disclosure Brochure) 31  and a separate disclosure statement that includes the following: • the Promoter’s name and relationship with the Advisor; • the fact that the Promoter is being paid a referral fee by the Advisor; • the amount of the fee paid or to be paid by the Advisor; and • Whether the fees paid to the Advisor by the Client will be increased above the Advisor’s normal fee in order to compensate the Promoter. CWA makes a bona fide effort to determine whether the Promoter has complied with our agreement, so that we have a reasonable basis for believing the Promoter provided the required disclosures. CWA will not charge a higher fee for services for Clients referred to the Advisor. Referrals Out The Advisor does not accept referral fees or any form of remuneration from other professionals when a prospect or Client is referred to the professional. Item 15. Custody All Clients must place their assets with a “qualified custodian”. Clients are required to engage the custodian to retain their funds and securities and direct CWA to utilize the custodian for the Client’s security transactions. Clients should review statements provided by the custodian and compare them to any reports provided by CWA to ensure accuracy, as the Custodian does not perform this review. If the Client gives CWA authority to move money from one account to another account, we have custody of those assets. In order to avoid additional regulatory requirements in these cases, the custodian and CWA have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. For certain engagements, the Advisor is deemed to have custody pursuant to Rule 206(4)-2 of the Advisers Act. For all such Client accounts: (i) the Advisor will obtain an annual surprise examination from an independent accounting firm; (ii) Client assets are held at qualified custodian[s] of a Client’s choosing, who shall provide account statements directly to Clients, at least quarterly; and (iii) the Advisor will provide to each Client an account statement[s] at least quarterly, enabling Clients to compare such information to their custody statements. The Advisor has an independent public accountant perform an audit of each pooled investment vehicle managed by the Advisor and will distribute the audited financial statements to each investor in the pooled investment vehicle. Any related opinions issued by an independent accounting firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov). 32  Item 16. Investment Discretion Discretionary Authority for Trading Discretionary authority allows us to determine which securities and the quantity of securities to be bought or sold, and the broker-dealer to be used. Generally, a Client grants the Advisor discretion over the assets held and managed by those third-party investment managers, funds or securities recommended by the Advisor. The Client may, however, withhold discretion or place reasonable limitations on the Advisor’s and/or investment manager’s discretion. For example, a Client may specify that the percentage of their overall portfolio to be allocated to any one particular investment manager, or investment strategy, or a specific type of security, sector or industry may not exceed a certain limit. For assets designated to third-party managers, CWA may be granted discretionary authority to replace the third-party manager, and the third-party manager is granted authority to purchase and sell securities they select and deem appropriate. Non-Discretionary Authority for Trading Under limited circumstances, the Advisor may manage accounts on a non-discretionary basis. In these instances, the Advisor provides recommendations to Clients and, if recommendations are approved, the Advisor will implement them in accordance with the Client’s instructions. Directing the brokerage activities solely to the custodian and at the sole instruction of the Client may result in the loss of best execution of orders at the most favorable prices reasonably obtainable. Item 17. Voting Client Securities Proxy Voting Generally, Clients are expected to vote their own proxies. Clients may also delegate such authority to the investment managers they hire on the recommendation of the Advisor. In cases, where Client assets are held in pooled investment vehicles (e.g., mutual funds, private funds), the investment manager to each such pooled investment vehicles, shall retain proxy voting authority. Clients will receive their proxy notices and solicitations directly from the Custodian or transfer agent. On rare occasions, CWA may share its thoughts to all Clients regarding a proxy vote, if it deems such communication beneficial to assisting its Clients. In cases where the Advisor is the investment manager for a CWA Fund, the Advisor shall vote proxies in the best economic interests of the CWA Fund and in accordance with our established policies and procedures. The Advisor will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, and a copy of any document created by us that was material to making a decision how to vote proxies. From time to time, conflicts may arise with regard to how the Advisor should vote or abstain a particular proxy vote. Generally, in such cases the Chair of the IOC and the CCO will be notified. If a true conflict is identified, a meeting of the IOC will be called to order to review the conflict and determine how the proxy will be voted in a Client’s best interests. If requested, the CCO will advise with senior management and if necessary, outside legal counsel, and provide guidance to the IOC. The CIO and IOC will weigh all factors affecting these constituents and 33  exercise their fiduciary obligation in accordance with the economic best interest of all concerned to the best of its ability. We will neither advise nor act in legal proceedings involving companies whose securities are held in the Client’s account[s], including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, when the Advisor acts as investment manager, Clients may direct us to transmit copies of class action notices to them or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Clients can obtain a copy of our complete proxy voting policies and procedures by contacting the Advisor by telephone at (617) 428-7600, or by email at: compliance@cwadvisorsgroup.com or in writing to CW Advisors, LLC, 155 Seaport Blvd, 3rd Floor, Boston, MA 02210. If applicable, Clients may request, in writing, information on how proxies for his/her shares were voted. Class Actions The Advisor does not advise or act for Clients in any legal proceedings, including bankruptcies or class actions, involving securities held or previously held in a Client’s Account. Item 18. Financial Information Financial Condition The Advisor does not have any financial impairment that will preclude the Advisor from meeting contractual commitments to Clients. Neither the Advisor, nor any of its Advisory Persons, has been subject to bankruptcy or financial compromise. A balance sheet is not required to be provided because the Advisor does not serve as a custodian for Client funds or securities and does not require prepayment of fees of more than $1,200 per Client, and six months or more in advance. Therefore, financial information is not required to be disclosed in this section. CWA maintains discretionary authority for Client accounts and is required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to Clients. CWA has no such conditions to report. We have never been subject to a bankruptcy petition at any time during our history. Privacy The trust and confidence of our customers is important to the Advisor. For this reason, we are careful in the way we collect and handle non-public, personal information about our Clients (“Client Information”). Information We Collect We may collect Client Information from the following sources: • Information we receive on contracts or other forms, such as name, address, date of birth, and social security number 34  • • Information relating to transactions with us, our affiliates and others, such as the purchase and sale of securities and account balances Information we receive from third parties, such as custodians, brokers and financial services firms, as required or permitted by law Information We Disclose We disclose Client Information about our present or former Clients to third parties only to the extent required or permitted by law. Such sharing of Client Information is applied to: • Everyday business purposes such as processing transactions, maintaining and or servicing your account • Cooperating with regulatory authorities, responding to court orders and legal investigations • Taking reasonable and necessary steps to prevent fraud, unauthorized transactions, etc. Opting-Out The information we disclose is limited, and essential to servicing your account, protecting your privacy and meeting obligations under state and federal law. We do not disclose Client Information requiring a notice to you for limiting such disclosure, otherwise known as “opting- out”. However, should we wish to disclose additional Client Information of yours, we will only do so with your written permission as discussed below. Opt-In Process for Sharing Additional Client Information In response to a Massachusetts law, Clients must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Our current business practices require us to obtain your affirmative written permission before we disclose any Client Information outside of what is discussed above in the “Information We Disclose” section of this notice. In the event we wish to share such additional Client Information, we will provide you with an Opt-In form describing the additional Client Information we seek to share, with whom we wish to share it with and for what purpose. Until such form is received by us from you, indicating your permission, such additional Client Information about you will not be shared. 35 

Item 1: Cover Sheet INFORMATIONAL BROCHURE WRAP FEE PROGRAM BROCHURE CW ADVISORS, LLC 155 Seaport Blvd, 3rd Floor BOSTON, MA 02210 (617) 428-7600 Fax (617) 428-7699 www.cwadvisorsgroup.com compliance@cwadvisorsgroup.com March 28, 2025 This Form ADV Appendix 1 - Wrap Fee Program Brochure (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices of CW Advisors, LLC. If you have any questions about the contents of this Wrap Fee Program Brochure, please contact Compliance at the email or above. The information in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about the firm and its representatives is also available on the SEC’s website at www.adviserinfo.sec.gov 1  Item 2: Statement of Material Change The Advisor provides wrap fee services to certain legacy clients. The Wrap Fee Program Brochure is newly drafted to disclose services provided to clients under a wrap fee arrangement (“Clients”). 2  Item 3: Table of Contents TABLE OF CONTENTS Item Description Page 1 Cover Sheet 2 Statement of Material Changes 3 Table of Contents 4 Services, Fees, and Compensation 5 Account Requirements and Types of Clients 6 Portfolio Manager Selection and Evaluation 7 Client Information Provided to Portfolio Managers 8 Client Contact with Portfolio Managers 9 Additional Information 1 2 3 4 6 6 6 6 6 3  WRAP FEE PROGRAM BROCHURE CW ADVISORS. LLC. Item 4 Services, Fees, and Compensation A. Services When CW Advisors, LLC (“CWA”, “we”, “us” or the “Adviser”) is engaged to provide investment management services we will monitor your accounts to help achieve your investment needs and objectives. This Wrap Fee Program Brochure is provided as a supplement to the CWA Form ADV Part 2A (“Disclosure Brochure”). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting us as your investment adviser. Under this Wrap Fee Program, CWA offers a single, “bundled” fee for its investment management services, where it includes applicable securities transaction fees, custodial costs, certain mutual fund redemption fees, SEC exchange process fees, administrative fees, trade away transaction, and other fees and expenses (herein “Covered Costs”) related to the management of Client accounts as part of the overall investment advisory fee. This is commonly referred to as a “Wrap Fee Program.” The Adviser sponsors the CWA Wrap Fee Program. CWA does not engage other portfolio managers to manage assets within the Wrap Fee Program. Rather, CWA is the sole portfolio manager, which means that CWA receives the entire amount of the wrap fee above. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into the single “bundled” investment advisory fee. The Wrap Fee Program is not offered to new and is only provided to certain Legacy Clients. B. Program Costs Advisory services provided by CWA are offered in a wrap fee structure whereby Covered Costs are included in the overall investment advisory fee paid to CWA. As the level of trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transactions costs are borne separately by the Client. Additionally, the Adviser's recommended Custodian does not charge securities transaction fees for exchange traded fund (“ETF”) and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. The Custodian also offers certain share classes of mutual funds that do not have transaction fees but do carry higher internal expense ratios. As such, the Adviser is incentivized to select ETFs, equity securities and higher expense paying mutual fund shares to limit the overall cost to the Adviser. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or if there is selection of more investments that bear transaction fees in the Client’s account[s]. Please see Item 5 – Fees and Compensation of the firm’s Form ADV 2A disclosure brochure for complete details on fees. C. Fees Investment advisory fees are typically based on the market value of assets under management at the end of each calendar quarter, pursuant to the investment management agreement. Generally, ranges from 50 basis points to 100 basis points per annum based on the following schedule: 4  Total Assets Under Management Up to $500,000 $500,001 to $1,000,000 Over $1,000,000 Annual Fee 100 bps 75 bps 50 bps The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees are negotiable at the sole discretion of the Adviser. Factors affecting fee percentages include the size of the account[s], complexity of asset structures, and other factors. Certain Clients may be offered an investment advisory fee at a fixed annual rate or a fixed annual dollar amount. All securities held in accounts managed by CWA will be independently valued by the Custodian. CWA will not have the authority or responsibility to value portfolio securities. Clients may make additions to and withdrawals from their account[s] at any time, subject to CWA’s right to terminate an account. Additions may be in cash or securities provided that CWA reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw account assets on notice to CWA, subject to the usual and customary securities settlement procedures. However, CWA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client’s investment objectives. CWA may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated you may be assessed a fee at the mutual fund level (i.e. contingent deferred sales charge) and/or subject to tax ramifications. If assets are deposited into or withdrawn from the Client’s account[s], the Adviser’s fee will be adjusted in the current billing period to reflect the fee difference. The Adviser may negotiate a fee that differs from the schedule above for certain account[s] or holdings. Investment advisory fees will be calculated by the Adviser and debited directly from each Client’s account[s] at the Custodian. The advisory fee is paid quarterly, at the end of each calendar quarter, and the value used for the fee calculation is the net value as of the last market day of the quarter. This means that if your annual fee is 100 bps, then each quarter we will multiply the value of your account by 100 bps then divide by 4 to calculate our fee. Once the calculation is made, we will instruct the Custodian to deduct the fee from your account and remit it to CWA. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by the Custodian directed by the Client. At least quarterly, Clients will receive a statement from the Custodian reflecting the fees to be debited. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s statement as the Custodian does not assume this responsibility. Clients will incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s], which are not included as part of this Wrap Fee Program. All fees paid to CWA for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. For example, CWA seeks the lowest-cost share class for mutual funds for its Clients. However, there may be circumstances where the mutual fund in the lowest-cost share class charges 12b-1 fees. CWA does not receive any revenue from 12b-1 fees, but this may result in Clients paying higher internal expenses on type of mutual funds. Additionally, fees related to Client-directed trades and account activity, such as electronic funds and wire transfers fees, certificate delivery fees, markups and markdowns, 5  bid-ask spreads, selling concessions, and other miscellaneous fees and expenses as outlined in the account opening paperwork executed with the Custodian, are generally charged back to the Client. Finally, securities transaction fees for Client-directed trades may be charged back to the Client. The Adviser does not control nor share in these fees. Clients are encouraged to review all fees charged by the fund[s], third parties and CWA to fully understand the total fees to be paid. Please see Item 5.C – Other Fees and Expenses in the Disclosure Brochure. Additionally, or a complete discussion of expenses related to each mutual fund, please read a copy of the prospectus issued by that fund. CWA can provide or direct you to a copy of the prospectus for any fund that we recommend to you. D. Compensation CWA is the sponsor and portfolio manager of this Wrap Fee Program. CWA receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with the normal trading activity in the Client’s account[s]. Neither CWA or CWA advisory personnel receive compensation for recommending the Wrap Fee Program to a Client who participates in the Wrap Fee Program. Item 5 Account Requirements and Types of Clients Clients participating in the Wrap Fee Program may include individuals, trusts, foundations, and corporations. CWA does not offer wrap fee services to new clients, however, maintains that Clients engaged in wrap fee services maintain a minimum assets of $250,000 to be managed, waivable at the sole discretion of the Advisor. Item 6 Portfolio Manager Selection and Evaluation The Wrap Fee Program offered by CWA is sponsored by the firm, and CWA is the sole portfolio manager. The only fees covered under the Wrap Fee Program are transaction fees associated with the purchase and sale of securities in an account managed by CWA. All Client accounts managed by CWA, including Wrap Fee Program Clients, are managed with similar processes, although account recommendations may differ. Item 7 Client Information provided to Portfolio Managers CWA is the sponsor and sole portfolio manager for the Wrap Fee Program. The Adviser does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Item 8 Client Contact with Portfolio Managers Clients may contact CWA, the only portfolio manager, at any time. Item 9 Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations On December 22, 2014, the SEC brought a settled fraud action against F-Squared Investments, Inc. (“F- Squared”), an unaffiliated investment manager. In connection with the resolution, F-Squared admitted, among other things, to making false claims regarding its AlphaSector strategy. More specifically, it falsely represented that: (a) the signals that formed the basis of its AlphaSector index returns had been used to manage Client assets from April 2001 to September 2008; and (b) the strategy significantly outperformed the S&P 500 Index during that period. The Adviser, through its former registration, had utilized the Alpha Sector investment strategy to manage a 6  portion of its Clients’ assets from May 2009 to October 2013. During this period, less than 5% of assets under CWA’s management were invested pursuant to this strategy. In October 2013, CWA became aware of information that caused it to question the accuracy of F-Squared’s representations and promptly removed from its advertising materials all references to F-Squared’s performance prior to September 2008. Then, in December 2013, the Adviser ceased using the AlphaSector signals entirely and terminated its relationship with F-Squared. The SEC conducted a sweep of investment advisers that had relied on F-Squared’s representations, and on August 25, 2016, it entered orders against 13 such advisers, including CWA. With respect to CWA, the SEC order found, in sum and substance, that despite its due diligence, CWA negligently relied on F-Squared representations in advertising F-Squared’s strategy, in violation of Section 206(4) of the Advisers Act and Rules 206(4)-1(a)(5) and 204-2(a)(16) thereunder. Without admitting or denying the findings, CWA consented to the entry of a cease-and desist order imposing a $100,000 penalty. A copy of the order can be found at https://www.sec.gov/litigation/admin/2016/ia-4507.pdf Except for the matter discussed above, the Adviser has not been involved in legal, regulatory or disciplinary events related to past or present investment Clients that would be material to the evaluation of CWA or the integrity of its management personnel. B. Other Financial Activities and Affiliations a) Futures Commission Merchant/Commodity Trading Adviser Neither the Adviser nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. b) Relationship with Related Persons Certain Advisory Persons that service clients are under the wrap fee program of CWA are separately licensed as independent insurance professionals. As such, these Advisory Persons may offer insurance products and receive normal and customary commissions as a result of insurance transactions for CWA Clients, in their capacity as licensed insurance agents, and will receive customary commissions for these transactions in addition to any compensation received in their capacity as Advisory Persons of CWA. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. Advisory Persons have an incentive to recommend insurance products based on the compensation to be received, rather than on a Client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and Clients should be aware of this conflict when considering whether to engage CWA or utilize these professionals to implement any insurance recommendations. CWA seeks to mitigate this conflict of interest by disclosing the conflict to Clients and informing the Clients that they are under no obligation to act upon any recommendations from the Advisory Persons or effect any transactions through them if they do follow the recommendations. CWA also seeks to mitigate the conflict of interest by requiring Advisory Persons to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the Clients of CWA, which requires that Advisory Persons put the interests of Clients ahead of their own. 7  c) Recommendations of other Advisers CWA does not recommend or select other investment advisers for our Clients. C. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics As required by Rule 204A-1 of the Investment Advisers Act of 1940, CWA has adopted a Code of Ethics (the “Code”). As a registered investment adviser, CWA has a duty of utmost good faith to act solely in the best interest of each Client. CWA and its representatives have a fiduciary duty to all Clients. CWA has established a Code of Ethics that all persons associated with the firm must read. They must then execute an acknowledgment agreeing that they understand and agree to comply with the Code of Ethics. The fiduciary duty of CWA and its representatives to Clients is considered the core underlying principle for CWA’s Code of Ethics and represents the expected basis for all dealings with Clients. CWA has the responsibility to make sure that the interests of Clients are placed ahead of it or its associated persons’ own investment interests. All representatives will conduct business in an honest, ethical and fair manner. All representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to Clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect their duty of complete loyalty to Clients. Participation or Interest in Client Transactions The Code requires CWA personnel to report their personal securities holdings and transactions and requires the Chief Compliance Officer (“CCO”) to pre-approve certain investments. CWA personnel are required to submit an annual report of brokerage accounts and holdings along with an acknowledgement and certification stating that the individual will comply with the Code of Ethics. All supervised persons at CWA are required to submit quarterly transaction reports that detail the individual’s securities transactions for the quarter. On occasion, CWA employees may purchase for his or her own account securities which are also recommended for Clients at the same time the Clients purchase the securities. To prevent conflicts of interest, Adviser’s Code of Ethics includes personal investment and trading policies for all Access Persons. The Code of Ethics is distributed to all Access Persons, upon employment, annually and upon amendment and all Access Persons acknowledged they have read, understand, and agree to abide by Adviser’s policies and procedures. To address this potential conflict of interest, we impose several restrictions on personal trading. Access Persons may not trade in a manner that would be adverse or detrimental to Client trades. Access Persons statements are reviewed to confirm compliance with the trading procedures. Any Access Persons not observing Adviser’s policies or violating any applicable state and federal Advisory practice regulations, is subject to sanctions up to, and including, termination. telephone at 617-428-7635 A copy of the Firm’s Code of Ethics will be provided to any Client or prospective Client upon request by or by email at contacting Candace Cavalier, CCO by ccavalier@cwadvisorsgroup.com. D. Review of Accounts Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of CWA. Formal reviews are generally conducted at least annually or more or less frequently depending on the needs of the Client or upon Client request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is 8  encouraged to notify CWA if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Adviser may also provide Clients with periodic reports regarding their holdings, allocations, and performance during Client meetings or as requested. E. Client Referrals and Other Compensation Participation in Institutional Adviser Platform CWA has established an institutional relationship with Schwab through its “Schwab Adviser Services” unit, a division of Schwab dedicated to serving independent advisory firms like CWA. As a registered investment adviser participating on the Schwab Adviser Services platform, CWA receives access to software and related support without cost because the Adviser renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Adviser Services benefit the Adviser and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Adviser endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Adviser's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Adviser may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Adviser may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisers with access to technology, research, discounts and other services. In addition, the Adviser receives duplicate statements for Client accounts, the ability to deduct advisory fees, and trading tools as part of its relationship with Schwab. These services are intended to assist the Adviser in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Adviser – Schwab also offers other services to CWA that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Adviser to recommend Schwab, which results in a potential conflict of interest. CWA believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Client Referrals from Promoters CWA may pay referral fees to unaffiliated consultants, independent contractors, registered investment advisors, certified public accounting firms and other independent persons or firms (“Promoters”) for introducing Clients to CWA, for either a fixed amount or a percentage of advisory fees. Whenever CWA pays a referral fee, CWA requires the Promoter to provide, at the time of referral, the prospective Client with a copy of this document (our Disclosure Brochure) and a separate disclosure statement that includes the following: • the Promoter’s name and relationship with CWA; • the fact that the Promoter is being paid a referral fee by CWA; • the amount of the fee paid or to be paid by CWA; and 9  • Whether the fees paid to CWA by the Client will be increased above CWA’s normal fee in order to compensate the Promoter. F. Financial Information CWA has no financial commitment that impairs its ability to meet its contractual and fiduciary commitments to its Clients and has not been the subject of a bankruptcy. CWA does not require prepayment of fees of more than $1,200 per client, six months or more in advance. 10