Firm Description CW Advisors, LLC (herein the “Advisor”, “CWA”, “we” or “us”), formerly known as Congress Wealth Management, LLC, 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, 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 is 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 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, Arizona 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; and
• 308 E Lancaster Ave, Ste 300, Wynnewood, PA 19096. 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 Paul Lonergan (Chief Executive Officer), Ken Zannoni (President and Chief Wealth Officer), Richard Villiotte (President and Chief Operating Officer), Richard Barrett (Chief Investment Officer), Erin Wendell (Chief Financial Officer), Candace Cavalier (Chief Compliance Officer and General Counsel), Michael Galvin (Executive Managing Director) and Scott Dell’Orfano (Chief Strategic Officer). 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, 2023, the Advisor managed $6,842,247,230 in discretionary assets and $78,165,743 in non-discretionary assets. As of December 31, 2023, total assets under management (“AUM”) were $6,920,412,973. 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 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) be a terminated 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 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 an 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 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 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. 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.