Firm Overview BWM was founded in November 2006 and registered with the SEC in May 2008. BWM is a wholly- owned subsidiary of Bulltick Capital Markets Holdings LLC, a holding company that also owns Bulltick, LLC (“BLLC”), an SEC registered, FINRA member broker-dealer, Bulltick Insurance Agency, LLC, a registered insurance agency, Bulltick4UAdvisor, LLC an SEC registered investment advisor and Bulltick Administrative Services, LLC (f/k/a Bulltick Financial Advisory Services, LLC). Firm Products & Services BWM provides investment advisory services to (1) high net worth individuals, trusts, family offices, and corporations (“Managed Accounts”); and (2) private pooled investment vehicles (each a “Client” and collectively the “Clients”). BWM Managed Accounts BWM provides investment advisory services through various types of discretionary and non- discretionary Managed Accounts in accordance with each Client’s investment objectives, financial goals and risk tolerance. BWM provides investment advisory services on a discretionary basis that are customized to each Client. Subject to a grant of discretionary authorization, BWM has the authority and responsibility to formulate and implement investment strategies on the Client’s behalf. This authorization includes deciding which securities to buy and sell, when to buy and sell, and in what amounts, in accordance with each Client’s investment profile, without obtaining the Client’s prior consent or approval for each transaction. Discretionary authority is granted to BWM in the investment advisory agreement the Client signs with BWM (“Client Agreement”), a power of attorney, and/or the appropriate trading authorization forms. The Client may limit BWM’s discretionary authority (for example, limiting or restricting the types of securities that can be purchased for the Managed Account) by providing BWM with the Client’s restrictions and guidelines (if any) in the executed Client Agreement. Clients should be aware that the performance of restricted accounts may differ from the performance of accounts without such impediments, possibly producing lower overall results. BWM utilizes information regarding the Client’s investment objectives, overall financial holdings, risk tolerance, and investment horizon, to work with each Client in constructing investment portfolios across asset classes in equities, corporate and government debt securities, ETFs, mutual funds, options, and alternative investments (e.g., REITs, hedge funds, structured products, digital asset funds). Managed Accounts may focus on investments in specified asset classes and securities, or they may be broad-based across various sectors of the market. The strategies utilized for these Managed Accounts may be similar to or may vary widely from the core strategies typically utilized by BWM as further described in Item 7. As part of the discretionary investment management services offered by BWM, a Client can elect to work with our asset management team according to one or more proprietary model portfolios (the “Models”) across various asset classes and investment strategies by investing in a portfolio of investments, in accordance with the investment strategy of the Model. Client’s Advisory Representative will recommend the Models developed and provided by one or more internal portfolio managers (hereinafter “Internal Managers”). The Internal Managers will maintain discretionary authority to effect the purchase of the investments into the Client’s Account in accordance with the selected Model, including to rebalance or adjust account holdings (in accordance with the Client’s investment objective and risk tolerance) by redeeming, exchanging, selling, or purchasing additional securities consistent with the selected Model. The Models presented to the Client will be based on a Client Objectives and Risk Profile as as determined by the Advisory Representative based on, among other things, investment goals, risk tolerance, investment time horizon, and overall financial situation of the Client. Notwithstanding, it is Client’s responsibility to inform Client’s Advisory Representative in writing if Client’s financial circumstances or investment objectives materially change. BWM may allow Client to impose reasonable restrictions on the management of Client’ account, in its sole discretion. Based upon the stated investment objectives, guidelines and risk profile of the client, as well as any restrictions considered for the management of the Account, BWM may recommend and utilize for certain clients the active discretionary management of all or a portion of their assets by certain investment managers that are not affiliated with BWM (“External Managers”). Prior to selecting an External Manager for a client, BWM conducts due diligence concerning the manager through assessing overall strategy, credentials, and performance. BWM will provide ongoing monitoring of the investment performance of the External Managers and is authorized to add, terminate, or change External Managers at any time when, in BWM’s sole discretion, it is determined that such action is in the best interests of a client. External Managers have discretion over certain Account assets and the responsibility to implement personalized investment advice to the client. Clients should review any selected External Manager’s Form ADV filing for a complete description of the External Manager. BWM also provides investment advisory services to Managed Accounts on a non-discretionary basis, meaning Client consent must be granted prior to each transaction and the Client has an unrestricted right to decline to implement any advice provided by BWM. In accordance with the Client Agreement, upon the Client’s approval of any recommendation, Clients can choose whether BWM will arrange for effecting the securities transactions recommended. BWM also offers a comprehensive portfolio wrap program sponsored and managed by BWM for certain fixed income strategies. BWM’s wrap fee program provides discretionary management on an individualized basis according to the Client’s investment objectives, financial goals, risk tolerance. The Client pays a specified bundled fee for investment management services and the execution of transactions as a percentage of assets held in the account. A detailed description of the wrap program can be found in BWM’s Form ADV Part 2A, Appendix 1. BWM Private Funds BWM provides investment management services on a discretionary basis to its domestic and foreign private funds, not registered under the Investment Company Act of 1940, as amended, (1) Domum Real Estate Fund LP, a Delaware limited partnership; (2) Domum Real Estate Offshore Fund, LP, an Ontario, Canada limited partnership (each and collectively “Domum I”); (3) Domum Real Estate Fund II LP, a Delaware limited partnership and (4) Domum Real Estate Offshore Fund II, LP (each and collectively “Domum II”) (each a “Fund” or “Internal Fund” and collectively the “Funds” or “Internal Funds”). As investment manager to the Funds, BWM is involved in (a) formulating and implementing the Funds’ investment strategy; (b) evaluating and monitoring investments made by the Funds; and (c) making investment decisions for the Funds. Domum Real Estate Ventures LLC (the “Domum I GP”), an affiliate of BWM is the General Partner of Domum I. Domum I is co-managed by an unaffiliated investment manager, LaFirma Asset Services, SC, a Mexican Sociedad Civil (“LFC”), an

exempt reporting adviser with the SEC, and co- owner of Domum I GP. Domum Real Estate Ventures II LLC (the “Domum II GP”), an affiliate of BWM is the General Partner of Domum II (each a “General Partner” and collectively the “General Partners”). The General Partners and BWM are under common control. BWM will pursue its investment objective by allocating Fund capital primarily among a diversified group of real estate related private funds or special purpose vehicles managed by third party portfolio real estate operators with differing strategies. The Funds’ investments are ultimately approved by an Investment Committee. The General Partners utilize an advisory committee which also includes independent members. BWM provides investment management services consistent with each Fund’s investment strategies objectives and/or parameters set forth in the Fund’s governing documents and confidential private placement memoranda (collectively the “Offering Documents”). This Brochure is not an offer to sell or a solicitation of an offer to buy Interests in the Funds. Such an investment may be made only after receipt and review of the Fund’s Offering Documents and execution of certain agreements. The Offering Documents contain important information concerning risk factors and other material aspects of the Fund and it must be read carefully before making an investment decision. The information in this Brochure is qualified in its entirety by, and should be read in conjunction with, the information contained in the Offering Documents. A copy of the Offering Documents is available upon request to BWM to persons meeting the definitions of both accredited investor (as defined in Regulation D promulgated under the Securities Act) and qualified Client (as defined in Rule 205-3 under the Advisers Act). BWM may also provide investment advice to Managed Account Clients regarding unaffiliated private investment fund(s) (each an “External Fund” and collectively the “External Funds”) which may not be held at the Client’s custodian. This arrangement creates certain material conflicts of interest of which a Client should be aware of. Please refer to Item 10 and Item 11 of this Brochure for important disclosures regarding conflicts of interest that arise in these circumstances. For External Funds recommended by BWM, BWM will include the amount of assets invested in the External Funds as part of “assets under management” for purposes of BWM calculating its investment advisory fee per Item 5 below. BLLC may receive a placement fee from the External Funds’ managers in connection with the placement of certain External Funds recommended by BWM. BLLC may also be compensated by an External Fund, or its managing member/general partner based on assets placed in the External Fund, such as performance fees paid to or a share in revenue of the External Fund’s managing member/general partner. This compensation received by BLLC presents a conflict of interest, however it is mitigated since the compensation is not paid by the Client and the Client’s adviser representative does not receive any additional direct or indirect compensation for recommending an External Fund (other than a portion of the investment advisory fee paid to BWM). Further, BWM Clients are under no obligation to consider or make an investment in any Internal or External Fund. If a Client chooses to invest in a private investment fund, the Client shall be required to complete the applicable private placement subscription and/or other opening documents to establish the investment. Other Services Additional services for Clients may be provided from time to time as agreed between the Client and BWM. Such services may include family office investment advisory services as well as furnishing advice to Clients on matters not involving securities, such as financial planning matters, retirement planning, real estate planning and property management services, and trust services that often include estate planning and educational services. These additional services may be provided by a third party. BWM may charge a Client for recommending and coordinating services provided by third parties. BWM provides Clients with consolidated portfolio reports. BWM uses third party software to prepare portfolio consolidated statements and related reports. These reports may be incorporated as part of the periodic account review by BWM advisory personnel. BWM also makes its investment advisory services available to unaffiliated investment advisors through a consulting relationship. The specific manner in which BWM provides investment consulting services is governed by BWM’s investment consulting agreement with that advisor. Generally, BWM will assist the other advisor to provide general research, advice, and guidance that the other adviser may or may not implement. As a consultant, BWM shall not have the responsibility or authority for the active management and monitoring of the other advisor’s client account(s). In addition, BWM engages unaffiliated investment advisers (“Consultants”) to provide investment consulting services with expertise in certain matters relating to foreign and US financial markets, including but not limited to, economic analysis, asset allocation, securities analysis, investment research, general investment advice, and to the extent requested by BWM, specific investment recommendations. The investment consulting services shall be provided to BWM in order to assist BWM in rendering investment advisory services to certain Clients. However, BWM is free to utilize any consulting advice and/or information provided by Consultants in managing any of BWM’s Client accounts. Consultants shall not render any personalized investment advice directly to Clients, shall not have any discretion over the account assets, and shall have no responsibility to implement any advice and/or recommendations provided to BWM. Consultants may also solicit and refer certain Clients to BWM; however, Consultants shall not make any investment recommendations or give any investment advice directly to any Clients or prospective Clients in connection with investment consulting services provided to BWM. As a result of the solicitation services, BWM may have an incentive to utilize the Consultants’ services over other investment advisers. Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to Clients or engaged directly by the Client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the Client in the event they should exist. Client Assets Total Assets Under Management1 As of December 31, 2023, BWM maintained total regulatory assets under management of $2,591,098,865, of which discretionary and non-discretionary assets under management were $2,069,163,950 and $521,934,915 respectively. Total Assets Under Advisement In addition to the assets under management, BWM maintains assets under advisement including non-discretionary advisory services that BWM is not responsible for arranging or effecting the transaction and consolidated reporting-only services in the amount of $910,770,395 of assets. Therefore, total assets for which BWM either advises, manages, or reports on were $3,501,869,260 as of December 31, 2023.