Description of Advisory Firm Liberty Wealth Management, LLC is an investment advisor registered with the Securities and Exchange Commission (SEC) pursuant to the Investment Advisers Act of 1940 (the Advisers Act). The firm, located at 411 30th Street, 2nd Floor, Oakland, CA 94609, has been in business since March 1998 and SEC-registered since January 19, 2018. Liberty Wealth is wholly owned by its Principal and President, David J. Hollander. (Please refer to Mr. Hollander's Form ADV Part 2B - Brochure Supplement for additional details on formal education and business background and note that registration as an investment advisor with the SEC does not imply a certain level of skill or training.) As used in this brochure, the words "we," "our," and "us" refer to Liberty Wealth Management, LLC (LWM, or the adviser), and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or Associates) refers to LWM's supervised personnel, the officers, employees, and individuals providing investment advice or advisory services on behalf of the firm. LWM serves as a fiduciary to clients and has a duty of loyalty, fairness, and good faith towards each client and seeks to mitigate potential conflicts of interest. LWM's relationship with each client is non-exclusive; in other words, LWM provides advisory services to multiple clients. LWM seeks to avoid situations in which one client's interest may conflict with the interest of another of its clients. LWM's advisory services are made available to clients through its Investment Advisor Representatives (Advisor Representatives). Each advisory relationship at LWM is managed by one or more Advisor Representatives registered with the firm, who serve as the primary point of contact between LWM and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs to clients as deemed appropriate for their situation, financial circumstances, goals, and objectives. Advisor Representatives are required to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, a separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive an ADV 2B brochure supplement, they should contact their Advisor Representative or LWM directly.) Co-Branding Disclosures LWM offers services through its network of Advisor Representatives. Some Advisor Representatives have other business interests, as described in their Form ADV Part 2B Brochure, and may have established their legal business entities, a doing business as (DBA) firm, whose trade names and logos may appear on marketing materials or client statements. The DBA's investment advisory and financial planning products and services are provided through LWM. Other business lines such as brokerage and insurance services and products, provided through their DBA, are provided through other unaffiliated and affiliated firms. Clients should understand that these businesses are the advisor representatives' legal entities and not of LWM, the investment adviser. Advisor Representatives are under the supervision of LWM, and the advisory services of the Advisor Representatives are provided through LWM. LWM presently has co-branding arrangements with the following Advisor Representatives:
• Daniel Ross, Daniel D. Ross, CPA, A Professional Corporation
• David Hedger, Granite Bay Asset Management
• Michael Hullen, Granite Bay Asset Management
• Kelvin Kwan, Granite Bay Asset Management
• Steven Mantzouris, The Independent Advisors, LLC
• Charles N. (Nick) Moore, Moore Financial Advice, LLC DBA MFA Financial Planning
• Kenneth Henson II, Moore Financial Advice, LLC DBA MFA Financial Planning
• Jared Wegrzyn, Moore Financial Advice, LLC DBA MFA Financial Planning Types of Advisory Services LWM is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. LWM's investment professionals emphasize continuous personal client contact and interaction in providing the following types of advisory services:
• Investment management and supervisory services, including: - ERISA retirement and employee benefit plans - Third-party management program services
• Financial planning services
• Hourly and fixed fee consulting services
• 529 college planning services
• Educational seminars and workshops LWM's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the Advisory Agreement or Investment Management Agreement, Financial Planning Agreement, or Consulting Services Agreement, depending on the services selected, collectively, the Agreement) that disclose, in substance, the scope of service, contract term, advisory fee—or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to LWM. Final advisory fee structures are documented within the written Agreement. Advisor Representatives provide services and fees specified within each contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in LWM's advisory services, and clients may engage LWM for additional services at any time. (Please refer to Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, LWM may recommend the services of other professionals. The client is under no obligation to engage the services of any such recommended professional. The client retains discretion over all such implementation decisions and is free to accept or reject any recommendation from LWM. (Note: If a client engages any recommended professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities LWM's advisory services depend on and rely upon the information received from clients. The adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. LWM will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify LWM in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy and the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. LWM reserves the right to terminate any client engagement where a client has willfully concealed or has refused to provide pertinent information about information material to the advisory services to be provided or individual/financial situations when necessary and appropriate in its judgment to provide proper financial advice. Following is a summary description of advisory services covered by this Brochure. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment Management and Supervisory Services Investment management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Advisory Agreement. If appropriate for the account type established, LWM will also create an Investment Policy Statement (IPS) to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes expectations, objectives, and guidelines for investing the client’s portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client’s Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. LWM does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from client accounts. LWM primarily recommends its clients maintain all investment management accounts at a preferred custodian unless the client directs otherwise. LWM will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. Clients should consult their Agreement for complete details. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, ongoing suggestions are made and implemented as the client and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management, and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. ERISA - Retirement and Employee Benefit Plan Services LWM also offers an ERISA retirement and employee benefit plan service, wherein the adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts (i.e., IRAs) for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act (ERISA) and regulations under the Internal Revenue Code of 1986. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor (DOL) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 (PTE 2020-02) where applicable, clients should be aware of the following: When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code laws governing retirement accounts, as applicable. The way LWM is compensated creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under the rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice).
• never put our financial interests ahead of yours when making recommendations (give loyal advice).
• avoid misleading statements about conflicts of interest, fees, and investments.
• follow policies and procedures designed to ensure that we provide advice that is in your best interest.
• charge no more than is reasonable for our services.
• give you basic information about conflicts of interest. LWM benefits financially from the rollover of a client’s assets from a retirement account to an account that we manage or on which we provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. LWM’s policy as a fiduciary is only to recommend that the client roll over retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by LWM. Finally, if a client or a prospective client receives a recommendation to leave their plan assets with their old employer, LWM will receive no compensation. IRA Rollover Considerations In determining whether to make an IRA rollover to LWM, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plan. Further, current employees can sometimes move assets out of their company plan before retiring or changing jobs. There are various factors LWM will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services, and responsiveness of the plan's investment professionals versus those of LWM, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients should carefully consider the costs and benefits of:
• leaving the funds in the employer's/former employer's plan.
• moving the funds to a new employer's retirement plan.
• cashing out and taking a taxable distribution from the plan.
• rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. If you contemplate rolling over retirement funds to an IRA for us to manage, we encourage you to speak with your CPA or tax attorney before making a change. The following are additional points for consideration before making any change:
• Determine whether the investment options in your employer's retirement plan address your needs or whether you might wish to consider other investment types: o Employer retirement plans generally have a more limited investment menu than IRAs. o Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds.
• Consider plan fees - your current plan may have lower fees than LWM’s fees: o If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. o You should understand the various products and services you might take advantage of at an IRA provider and the potential costs.
• LWM’s strategy may have a higher risk than your plan's option(s).
• Your current plan may also offer financial advice.
• If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72.
• Your 401(k) may offer more liability protection than a rollover IRA; each state may vary.
• Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors.
• You may be able to take out a loan on your 401(k) but not from an IRA.
• IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses, or a home purchase.
• If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate.
• Your plan may allow you to hire LWM as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement, and Other Qualified Accounts When establishing ERISA accounts, LWM will have plan fiduciaries for discretionary accounts evidence their authority to retain LWM's advisory services and appoint LWM as an investment manager within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. They will confirm the services described in LWM's Agreement are consistent with plan documents and furnish true and complete copies of all documents establishing and governing the plan. They will provide us with a copy of all relevant documents and agree that their selected advisory program is consistent with those documents and will notify us, promptly in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan

documents about investments by the plan. If the assets in the account constitute only a part of their plan assets, they will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge LWM has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment LWM’s Advisor Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made in the account are inconsistent with such guidelines, policies, restrictions, or instructions. LWM is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, it is the client’s responsibility to obtain and maintain (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, and agents in connection with LWM’s Advisory Agreement. If ERISA or other applicable law requires bonding for the account's assets, LWM will ensure bonding is in place to satisfy the obligation to cover LWM and all Associates whose inclusion is expected by law. Plan fiduciaries will agree to provide appropriate documents evidencing such coverage promptly upon request. Third-Party Management Program Services As part of its investment management services, LWM may select, recommend, and provide access, after appropriate due diligence to independent third-party manager advisers (TPM or Program) with which LWM has entered an agreement to make their services available as a co-investment adviser, to clients' accounts. LWM's role is to determine if the potential referred client has assets to invest and confirm they have a minimum understanding of investment management advisory services. LWM will assist clients in understanding the referred manager's Program Agreement, help them complete their investor profile to aid the TPM in determining the appropriate allocation strategy for their account, and answer any questions they may have about the TPM or Program. LWM will refer only those individuals or entities suitable for its TPM Program services. Currently LWM utilizes the third-party management services of 1) Inland Securities Corporation; 2) SEI 3) SVL Investment Management, and 4) The Pacific Financial Group. Fees can be structured in one of the following ways and are disclosed in each client's Agreement: LWM receives a split of management fees with the TPM; a fixed flat percentage fee on total assets in the account; a tiered fee schedule whereby the fee is calculated by applying different rates to different levels of assets; or a linear fee schedule where a breakpoint percentage fee is assessed to total assets in the account. Clients wishing to engage in this type of service will execute two (2) advisory account management agreements. The first Advisory Agreement will be with LWM, and the second agreement will be executed with the TPM. The client will sign an acknowledgment receipt and will receive copies of all material operative documentation and disclosures related to such arrangements, detailing the nature of the relationship, compensation to LWM, and other terms of the TPM Program. Client accounts managed by TPMs are typically managed on a discretionary basis in which the referred manager has a limited trading authorization. LWM will not typically hold discretion over accounts managed by any TPM, make investment decisions, trade accounts in aggregation, or incur trade errors in such accounts. The referred TPM will provide all investment advice to the client and bear fiduciary responsibility. The referred manager with whom the client opens their account will maintain responsibility for these items. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The TPM will observe the client's arrangements in the executed Program Agreement for exact account management and implementation. According to the TPM's Program Agreement, custody of client assets will be held with the TPM's independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's referred account. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines. Clients should refer to their TPM Program Agreement for complete details. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for communicating to their TPM and LWM all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship promptly and as they occur. (Please refer to Item 15: Custody for additional details on custodial practices.) TPM Program advisers are subject to review by LWM's standards for inclusion and subject to future change from time to time. Clients should review all applicable disclosure brochures before participating in any TPM Program. LWM receives compensation from the third-party advisers who we recommend that you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated, contractually or otherwise, to use the services of any referred advisor we recommend. We do not have any other business relationships with the recommended TPMs. Financial Planning Services LWM offers personal financial planning services tailored to the client's individual needs as determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on lifestyle objectives, retirement planning, planning for major purchases, life and disability insurance needs, long-term care needs, estate planning issues, or other financial planning or consulting service’s needs. Clients will execute a Financial Planning Agreement setting forth the terms and conditions of the engagement, including termination and describing the services' scope and fixed or hourly fees due before LWM commences services. The final fee structure will be documented within the executed Agreement. Financial planning services may be the only service provided to the client. Executing a Financial Planning Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by LWM, or any insurance or other products or services offered by any advisory Associate as a result of any business activities in which they may participate outside their advisory activities with the adviser. Neither LWM nor the Advisor Representative will have discretionary investment authority when offering financial planning or consulting services. Our holistic financial planning services are designed to offer a comprehensive analysis that encompasses a wide range of financial considerations, including, but not limited to, tax implications and estate planning strategies. It's important to note that while we do furnish general guidance in the areas of taxation and estate planning as part of our consultative approach, such guidance should not be construed as formal, specialized advice in these highly complex areas. We strongly urge clients to consult with qualified professionals for tailored advice concerning your individual tax and legal matters. By engaging our financial planning services, clients acknowledge and understand that LWM’s role is to assist in general financial planning, rather than to provide specialized tax and legal advice. LWM reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning Agreement for complete details. Please note that a conflict exists between LWM and the client in offering financial planning. LWM's clients are under no obligation to act upon any recommendations received. Further, if they elect to act on any recommendations received, they are under no obligation to implement the financial plan through LWM or any suggested third party. The client retains absolute discretion over all such implementation decisions and is free to accept or reject LWM's recommendations. LWM does not represent that these products or services are offered at the lowest available cost - clients may be able to obtain the same products or services at a lower price from other providers. Clients should consult their Financial Planning Agreement for complete details Hourly and Fixed Fee Consulting Services LWM provides consulting hourly and fixed-fee consulting services on investment and non-investment-related matters, on a stand-alone separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status which may include any combination of the following: lifestyle objectives, retirement, or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, LWM may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains the sole responsibility for determining whether to implement any recommendations made by the Advisor Representative and placing any resulting transactions. After engagement completion, LWM and the Advisor Representative do not provide ongoing consulting or management services and do not have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. 529 College Savings Planning Services We offer planning services to 529 college savings plans whereby our investment advice is tailored to meet your needs and investment objectives. If you retain our 529 college savings planning services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will assist you in setting up a 529 plan account. With respect to this account, we will use the information we gather to develop a strategy that enables us to give you advice. We will review your 529 plan holdings on at least an annual basis and will rebalance the holdings as required by changes in market conditions, your financial circumstances, and the circumstances of the account's named beneficiary with regard to the proximity of requiring distributions for qualified expenses, (e.g., qualified educational expenses in the near future). If you participate in our 529 college savings planning services, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with us, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing us with your restrictions and guidelines in writing. Educational Seminars and Workshops Services LWM provides complimentary investment educational seminars and workshops on various investment topics for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content will vary depending upon the attendees' needs and are purely educational—they do not involve selling any investment products. LWM will not provide personalized investment advice to attendees during such events. Information presented will not be based on an individual's needs; LWM will not provide personalized investment advice to attendees during such events. LWM will only provide investment advice if engaged independently and only where the attendee's individualized financial information, investment goals, and objectives are known. The materials provided are for general educational purposes and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from LWM or affiliates, or become client. LWM and its affiliates may share information from seminars and workshops, observing the adviser's privacy practices. (See Item 10: Other Financial Industry Activities and Affiliations.) Conflicts of Interest LWM has an inherent conflict of interest in offering and providing advisory services. The adviser and its Associates can receive compensation for the provision of its services and the sale of insurance or other affiliated and/or non-affiliated products and services. Clients are under no obligation to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are under no obligation to place the transaction through LWM, or any third party recommended. The client may act on recommendations received by placing their business and securities transactions with any brokerage firm or third party of their choice. LWM does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how LWM mitigates conflicts of interest can be found in the adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics. LWM's Code is available for review free of charge to any client or prospective client upon request. Types of Investments LWM will generally provide investment and portfolio asset allocation advice and management on the following investment types:
• Certificates of deposit
• Commercial paper
• Equities
• Delaware statutory trusts and other real estate-focused investments
• Fixed income
• Interests in partnerships investing in real estate
• Mutual and exchange-traded funds
• Real estate investment trusts (REITS)
• Private fund investments, including hedge and private equity funds and other similar investments Although LWM provides advice predominantly on the products listed above, it reserves the right to advise on any investment product deemed suitable for a client's specific circumstances, needs, and individual goals and objectives. It will use other securities as necessary to help diversify a portfolio when applicable and appropriate. When recommending investments in mutual funds, it is LWM’s policy to consider all available share classes and select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically have a lower cost than other share classes. Generally, institutional class shares do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, it will be in the client's best interest to recommend or purchase share classes with the lowest cost (institutional share class) in most cases. Client Tailored Services LWM offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are offered at a discounted rate at LWM's discretion, as defined in each client's written services contract. Client-Imposed Restrictions Investment management and supervisory services clients who engage LWM on a discretionary basis may, at any time, impose restrictions, in writing, on LWM's discretionary authority. Clients may impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Clients may also amend/change such limitations by once again providing written instructions. Reasonable efforts are made to comply with client investment guidelines by standard industry practices. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. LWM will discuss the restriction request's feasibility to ensure expectations are met and confirm client acknowledgment and understanding of imposed restriction's possible outcomes. If client-imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, LWM reserves the right to end the client relationship. In no event, regardless of the advisory service provided, is the adviser obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. TPM services clients may impose restrictions on their TPM program accounts according to the referred manager’s Program Agreement. Wrap Fee Programs LWM does not offer a wrap fee program as part of its advisory services. Assets Under Management LWM offers its advisory services on a discretionary and non-discretionary basis. As of March 31, 2022, the adviser’s assets under management are $1,047,791,457. The following represents client assets under management by account type: Account Type Assets Under Management Discretionary $930,890,342 Non-Discretionary $116,901,115 Total $1,047,791,457