Description of Firm SWBC Investment Company ("SWBC" or “Firm”) is a Texas corporation, headquartered in San Antonio, TX. We are part of the SWBC Corporation group of financial services companies, and controlled by Charles Amato and Gary Dudley. Since 2007, we have been registered with the Securities and Exchange Commission as an investment adviser (“RIA”). SWBC delivers financial advice, manages portfolios and constructs financial plans for individuals through “Investment Adviser Representatives” or “IARs.” SWBC also provides investment management services on a discretionary basis to registered mutual funds and to private pooled investment vehicles (such private pooled investment vehicles, the “Private Investment Funds”) as discussed in more detail below. This Brochure discusses the Services provided by SWBC, except for the SWBC Wrap Fee Program, which is described in detail within separate disclosure brochures: SWBC Wrap Fee Program Brochure, Form ADV Part 2A, Appendix 1. Persons interested in additional information about these programs, should contact their SWBC IAR, or contact SWBC at the contact information on the front of this Brochure. You may also click the link to the SEC’s website on the front of this Brochure and use our firm CRD number to locate the disclosure brochure you desire. As an organization, SWBC is committed to consumer sovereignty and transparency. We want to deliver services to clients under the arrangement preferred by the client. We also want the client to be aware of the capacity in which each SWBC financial professional is acting at the time of any transaction or of any professional engagement. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we," "our," and "us" refer to SWBC and the words "you," "your," and "client" refer to you as either a client or prospective client of the Firm. Portfolio Management Services As part of our portfolio management services, we can manage your portfolio internally or use one or more sub-advisers to manage a portion of your financial assets. The sub-adviser(s) may use one or more of their model portfolios to manage your account. We will regularly monitor the performance of your accounts managed by sub-adviser(s). We will share a portion of the advisory fee you pay with the sub-adviser(s); however, you will not pay the Firm a higher advisory fee as a result of our use of any sub-advisers. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by an unaffiliated investment manager. These models are designed for investors with varying degrees of risk tolerance, ranging from more aggressive investment strategies to more conservative investment strategies. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. In providing account management services, we can accept client restrictions on the specific securities or the types of securities that may be purchased for your account. However, at our direction, we can select sub-advisers specializing in portfolios that may avoid “sin stocks” and/or invest according to environmental, social and governance (“ESG”) principles approved by the client. As an institution, SWBC prides itself on its customer centric focus. That is, SWBC is determined to deliver goods and services to its clients / customers in the manner preferred by the client / customer. The financial services industry is among the most rapidly evolving and innovative industries in the world. Advances in technology, communications and the science of asset management have created new delivery channels for financial advice. Among these investment options is so called “robo advice”. Robo advice is characterized by less personal service but generally reflects lower costs, lower account minimums and algorithmic implementation. The highly automated, electronic delivery option previously available (being phased out) through SWBC was offered only online through an interactive website. As part of this Program, you must agree to accept electronic delivery of contracts, disclosure documents, prospectuses, statements, and other materials. The Program is only available to residents of the U.S., and is not available to foreign investors (individuals or entities) or U.S. citizens residing outside of the U.S. Regular and continuous Internet access is required to enroll in the Program and access all Program-related documents. You should not utilize this Program if you do not have regular and continuous Internet access. The Program is a discretionary investment management service designed for individual investors with accounts of $5,000 or more. When you enroll in this Program, you will provide financial profiling information through an online website, including but not limited to, investment objective, risk tolerance, and investment time horizon. We will rely on your responses to recommend asset allocation models. Our recommendation of an asset allocation model is conducted via an algorithmic process that assesses values to some of the answers you provide during the account establishment process. The Program will generally implement investment allocations using funds that have a lower-than-average net expense ratio compared with funds in the same fund asset class (“Low-Cost Funds”). Low-Cost Funds will generally contain equities, open ended mutual funds and/or exchange-traded funds. This Program may be implemented “in house” by SWBC employees, or we may choose to use sub- advisers and third-party money managers. In any case, our use of sub-advisers and third-party money managers will not raise the cost borne by the client. Reference the SWBC Program Brochure for more information. Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to us and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify us if your financial situation, goals, objectives

or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. Pension Consulting Services Our affiliate, SWBC Investment Advisory Services, LLC (common ownership and control) offers pension consulting services to employee benefit plans, their fiduciaries and their sponsors. The Firm, certain of its IARs and certain of the registered representatives of our affiliated broker- dealer may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:  Diversification;  Asset allocation;  Risk tolerance; and  Time horizon Please see Item 10 below for a more detailed discussion. Wrap Fee Program(s) We are a portfolio manager to and sponsor of a wrap fee program, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee. That fee includes administrative fees, management fees and commissions. If you participate in our wrap fee program, you will pay the Firm a single fee which includes our investment management fees, certain transaction costs, custodial and administrative costs. The Firm will receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing investment advisory services in a non-wrap fee format. In order to participate in the wrap fee program sponsored by the Firm, you will be required to transact through one of our approved Custodians such as, but not limited to, our affiliated broker-dealer, SWBC Investment Services, LLC, member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation, Fidelity Institutional, Pershing, Charles Schwab (“Schwab”) or TD Ameritrade Institutional, a division of TD Ameritrade, Inc. member FINRA/SIPC. Pershing, Schwab, and TD Ameritrade are independent SEC registered broker-dealer(s). Pershing, Schwab and TD Ameritrade and the Firm are separate and unaffiliated entities. To compare the cost of the wrap fee program with non-wrap fee alternatives, you should consider the frequency of trading activity associated with your planned investment strategies and the brokerage commissions charged by other broker-dealers and the advisory fees charged by investment advisers. For more information concerning the Firm’s wrap fee programs, see Appendix 1 to this Form ADV 2A. Types of Investments We currently offer advice on ETF's, equities (including, advice in respect of privately issued equity securities to SWBC CPG Fund I, LP (“CPG Fund”) and real estate-related partnerships to SWBC RE Fund, LP (“RE Fund” and together with the CPG Fund, the “Private Investment Funds”), mutual funds, options and fixed income and, in respect of RE Fund, real estate. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. Finally, for those of our clients who are “Accredited Investors,” the Firm may provide investment advice with respect to securities exempt from registration under Regulation D, generally speaking, “private placements.” Some of these private placement investments may be sponsored by affiliates of the Firm. Others may be sponsored by unaffiliated third-parties. Please be advised that an inherent conflict of interest exists when the Firm advises a client to invest in a private placements sponsored by an affiliated entity (such as another SWBC enterprise under common control and ownership with the Firm). Private Investment Funds Interests in the Private Investment Funds are offered exclusively to investors satisfying applicable eligibility and suitability requirements. Further information can be found in each Private Investment Fund’s private placement memorandum, limited partnership agreement, subscription agreements, investment management agreements and/or other governing documents, as applicable (collectively, the “Offering Documents”). All discussions of the Private Investment Funds in this Brochure, including but not limited to their investments, the strategies used in managing the Private Investment Funds, the fees and other costs associated with an investment in the Private Investment Funds, investor suitability standards and conflicts of interest faced by SWBC in connection with management of the Private Investment Funds, are qualified in their entirety by reference to each Private Investment Fund’s respective Offering Documents.1 Subadviser to Institution(s) SWBC serves as a subadviser to institutional investors and AlphaCentric Municipal Opportunities Fund (the “Fund”), for which SWBC provides advice with respect to a portfolio of municipal bonds and municipal securities that are exempt from regular federal individual income taxes, but without regard to the alternative minimum tax (AMT). On behalf of the Fund, SWBC may buy bonds of any rating, including unrated bonds, and may invest in bonds that are in default. For more information on the investment objective, principal risks, and fees associated with the Fund, please see the Fund’s prospectus and SAI, which are available from the AlphaCentric website at www.AlphaCentricFunds.com . Subadvised services are bound by separate agreements stipulating its services and costs please refer to the separate agreements for more information. Please be advised that an inherent conflict of interest exists when the Firm advises a client to invest in a Fund by an affiliated or unaffiliated entity (such as another SWBC enterprise under common control and ownership with the Firm or a Fund in which SWBC may receive additional compensation). Assets Under Management As of March 15, 2024, we provide asset management services for $345,800,000 in client assets on a discretionary basis.