Cardinal Wealth Advisors LLC

7205 Ohms Lane Suite 200 Edina MN 55439

FORM ADV PART 2A BROCHURE

This brochure provides information about the qualifications and business practices of Cardinal Wealth Advisors LLC If you have any questions about the contents of this brochure please contact John R Bergstrom at (952) 746-4700 or at johncardinalwealthnet The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority Additional information about Cardinal Wealth Advisors LLC is also available on the SECrsquos website at wwwadviserinfosecgov The searchable IARDCRD number for Cardinal Wealth Advisors LLC is 134758 Cardinal Wealth Advisors LLC is a Registered Investment Adviser Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training

April 21 2014

Cardinal Wealth Advisors LLC IARDCRD No 134759 Form ADV Part 2A Brochure April 21 2014

Material Changes

Form ADV Part 2A Item 2

This Item will be used to provide our clients with a summary of new andor updated information We will inform you of the revision(s) based on the nature of the updated information Consistent with the new rules we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our businessrsquo fiscal year Furthermore we will provide you with other interim disclosures about material changes as necessary This brochure dated April 21 2014 contains no material changes from the brochure dated February 25 2013 which was filed with our last annual updating amendment

Cardinal Wealth Advisors LLC IARDCRD No 134759 Form ADV Part 2A Brochure April 21 2014

Table of Contents Item 3

Advisory Business 1 Fees and Compensation 3 Performance-Based Fees and Side-By-Side Management 5 Types of Clients 6 Methods of Analysis Investment Strategies and Risk of Loss 7 Disciplinary Information 8 Other Financial Industry Activities and Affiliations 9 Code of Ethics Participation or Interest in Client Transactions and Personal Trading 10 Brokerage Practices 11 Review of Accounts 13 Client Referrals and Other Compensation 14 Custody 15 Investment Discretion 16 Voting Client Securities 17 Financial Information 18 Requirements for State-Registered Advisers 19 Additional Information 21

1

Advisory Business

Form ADV Part 2A Item 4 Cardinal Wealth Advisors LLC (ldquoCWArdquo) is a registered investment adviser located in Edina Minnesota It is registered with the state of Minnesota It is wholly owned by John R Bergstrom and has been in existence since 2005 CWA has two main services financial planning and investment management which it provides to individuals pension and profit sharing plans trusts estates and charitable organizations A Financial Planning

CWA gives advice to clients on a periodic best-efforts basis relative to the change in the applicable market conditions and the individual clientrsquos holdings CWA conducts a thorough review of clientrsquos financial records in order to establish the suitability of investments for clients The financial planning that CWA offers includes divorce planning investment planning asset allocation estate planning college planning insurance planning business succession planning and tax planning The specifics of the financial planning engagement would be described in a written Financial Planning Agreement and signed by both parties This procedure would follow the recommendations and requirements of the Code of Ethics of the CFP Board CWA may purchase andor subscribe to various vendor software programs that produce material relative to the financial planning and investment advisory services CWA may also furnish the client with industry-standard calculations used in determining investment asset-class comparisons Through the course of reviewing a clientrsquos financial status other non-financial issues may surface (human resource issues business succession planning etc) and become part of the review that CWA does for the client These types of issues are generally not dealt with as part of most traditional financial planning software programs Any applicable qualified advice given will be considered separate and distinct from any investment advisory service and securities-related advice B Investment Management

CWA undertakes to provide investment advisory clients with objective setting and asset allocation services and assistance CWA prepares individually designed reports concerning the investment programs and portfolios of each client CWA may manage investment management accounts for clients without complete knowledge of all the relevant factors as to individual participants for accounts with more than one beneficiary such as employee

2

benefit plans In the former case CWA would endeavor to pursue an investment strategy that it considered consistent with the plan trustees or with the clients objectives and prudent investment management CWA may manage no-load mutual fund portfolios for its clients

CWA uses a number of tools to evaluate client suitability for a particular investment These include a client profile risk questionnaire andor investment policy statement

C Referrals to Third Party Money Managers

CWA may place clients with third party investment advisors (ie fund managers) based on factors including but not limited to their track record investment strategy public reports and comparisons with other advisors and their related disclosure documents ^

3

Fees and Compensation

Form ADV Part 2A Item 5 CWA manages investment portfolios for clients for a percentage of assets under management CWArsquos annual fee is exclusive of and in addition to brokerage commissions transaction fees and other related costs and expenses which shall be incurred by the client However CWA shall not receive any portion of these commissions fees and costs CWArsquos annual fee shall be prorated and charged quarterly in arrears based upon the market value of the assets on the last day of the previous quarter The fee schedule is as follows $0 - $1000000 100 $1000001 to $2000000 90 $2000001 to $3000000 80 $3000001 and above 70 A client can opt to hire CWA for this service on an hourly basis A charge will be billed at $225 an hour Fees can be negotiable depending on the circumstances CWA shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investment Co for investment management accounts CWArsquos Agreement andor the separate agreement with Fidelity or with other financial institutions may authorize CWA through the financial institution(s) to debit the clientrsquos account for the amount of CWArsquos fee and to directly remit that management fee to CWA in accordance with applicable custody rules The financial institution(s) recommended by CWA have agreed to send a statement to the client at least quarterly indicating all amounts disbursed from the account including the amount of management fees paid directly to CWA The client may make additions to and withdrawals from the account at any time subject to CWArsquos right to terminate an account 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 asset withdrawals may impair the achievement of a clientrsquos investment objectives For the initial quarter of investment management services the first quarterrsquos fees shall be calculated on a pro rata basis The Agreement between CWA and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement CWArsquos annual fee shall be prorated through the date of termination and any remaining balances shall be charged or refunded to the client as appropriate in a timely manner

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

Cardinal Wealth Advisors LLC IARDCRD No 134759 Form ADV Part 2A Brochure April 21 2014

Table of Contents Item 3

Advisory Business 1 Fees and Compensation 3 Performance-Based Fees and Side-By-Side Management 5 Types of Clients 6 Methods of Analysis Investment Strategies and Risk of Loss 7 Disciplinary Information 8 Other Financial Industry Activities and Affiliations 9 Code of Ethics Participation or Interest in Client Transactions and Personal Trading 10 Brokerage Practices 11 Review of Accounts 13 Client Referrals and Other Compensation 14 Custody 15 Investment Discretion 16 Voting Client Securities 17 Financial Information 18 Requirements for State-Registered Advisers 19 Additional Information 21

1

Advisory Business

Form ADV Part 2A Item 4 Cardinal Wealth Advisors LLC (ldquoCWArdquo) is a registered investment adviser located in Edina Minnesota It is registered with the state of Minnesota It is wholly owned by John R Bergstrom and has been in existence since 2005 CWA has two main services financial planning and investment management which it provides to individuals pension and profit sharing plans trusts estates and charitable organizations A Financial Planning

CWA gives advice to clients on a periodic best-efforts basis relative to the change in the applicable market conditions and the individual clientrsquos holdings CWA conducts a thorough review of clientrsquos financial records in order to establish the suitability of investments for clients The financial planning that CWA offers includes divorce planning investment planning asset allocation estate planning college planning insurance planning business succession planning and tax planning The specifics of the financial planning engagement would be described in a written Financial Planning Agreement and signed by both parties This procedure would follow the recommendations and requirements of the Code of Ethics of the CFP Board CWA may purchase andor subscribe to various vendor software programs that produce material relative to the financial planning and investment advisory services CWA may also furnish the client with industry-standard calculations used in determining investment asset-class comparisons Through the course of reviewing a clientrsquos financial status other non-financial issues may surface (human resource issues business succession planning etc) and become part of the review that CWA does for the client These types of issues are generally not dealt with as part of most traditional financial planning software programs Any applicable qualified advice given will be considered separate and distinct from any investment advisory service and securities-related advice B Investment Management

CWA undertakes to provide investment advisory clients with objective setting and asset allocation services and assistance CWA prepares individually designed reports concerning the investment programs and portfolios of each client CWA may manage investment management accounts for clients without complete knowledge of all the relevant factors as to individual participants for accounts with more than one beneficiary such as employee

2

benefit plans In the former case CWA would endeavor to pursue an investment strategy that it considered consistent with the plan trustees or with the clients objectives and prudent investment management CWA may manage no-load mutual fund portfolios for its clients

CWA uses a number of tools to evaluate client suitability for a particular investment These include a client profile risk questionnaire andor investment policy statement

C Referrals to Third Party Money Managers

CWA may place clients with third party investment advisors (ie fund managers) based on factors including but not limited to their track record investment strategy public reports and comparisons with other advisors and their related disclosure documents ^

3

Fees and Compensation

Form ADV Part 2A Item 5 CWA manages investment portfolios for clients for a percentage of assets under management CWArsquos annual fee is exclusive of and in addition to brokerage commissions transaction fees and other related costs and expenses which shall be incurred by the client However CWA shall not receive any portion of these commissions fees and costs CWArsquos annual fee shall be prorated and charged quarterly in arrears based upon the market value of the assets on the last day of the previous quarter The fee schedule is as follows $0 - $1000000 100 $1000001 to $2000000 90 $2000001 to $3000000 80 $3000001 and above 70 A client can opt to hire CWA for this service on an hourly basis A charge will be billed at $225 an hour Fees can be negotiable depending on the circumstances CWA shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investment Co for investment management accounts CWArsquos Agreement andor the separate agreement with Fidelity or with other financial institutions may authorize CWA through the financial institution(s) to debit the clientrsquos account for the amount of CWArsquos fee and to directly remit that management fee to CWA in accordance with applicable custody rules The financial institution(s) recommended by CWA have agreed to send a statement to the client at least quarterly indicating all amounts disbursed from the account including the amount of management fees paid directly to CWA The client may make additions to and withdrawals from the account at any time subject to CWArsquos right to terminate an account 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 asset withdrawals may impair the achievement of a clientrsquos investment objectives For the initial quarter of investment management services the first quarterrsquos fees shall be calculated on a pro rata basis The Agreement between CWA and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement CWArsquos annual fee shall be prorated through the date of termination and any remaining balances shall be charged or refunded to the client as appropriate in a timely manner

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

1

Advisory Business

Form ADV Part 2A Item 4 Cardinal Wealth Advisors LLC (ldquoCWArdquo) is a registered investment adviser located in Edina Minnesota It is registered with the state of Minnesota It is wholly owned by John R Bergstrom and has been in existence since 2005 CWA has two main services financial planning and investment management which it provides to individuals pension and profit sharing plans trusts estates and charitable organizations A Financial Planning

CWA gives advice to clients on a periodic best-efforts basis relative to the change in the applicable market conditions and the individual clientrsquos holdings CWA conducts a thorough review of clientrsquos financial records in order to establish the suitability of investments for clients The financial planning that CWA offers includes divorce planning investment planning asset allocation estate planning college planning insurance planning business succession planning and tax planning The specifics of the financial planning engagement would be described in a written Financial Planning Agreement and signed by both parties This procedure would follow the recommendations and requirements of the Code of Ethics of the CFP Board CWA may purchase andor subscribe to various vendor software programs that produce material relative to the financial planning and investment advisory services CWA may also furnish the client with industry-standard calculations used in determining investment asset-class comparisons Through the course of reviewing a clientrsquos financial status other non-financial issues may surface (human resource issues business succession planning etc) and become part of the review that CWA does for the client These types of issues are generally not dealt with as part of most traditional financial planning software programs Any applicable qualified advice given will be considered separate and distinct from any investment advisory service and securities-related advice B Investment Management

CWA undertakes to provide investment advisory clients with objective setting and asset allocation services and assistance CWA prepares individually designed reports concerning the investment programs and portfolios of each client CWA may manage investment management accounts for clients without complete knowledge of all the relevant factors as to individual participants for accounts with more than one beneficiary such as employee

2

benefit plans In the former case CWA would endeavor to pursue an investment strategy that it considered consistent with the plan trustees or with the clients objectives and prudent investment management CWA may manage no-load mutual fund portfolios for its clients

CWA uses a number of tools to evaluate client suitability for a particular investment These include a client profile risk questionnaire andor investment policy statement

C Referrals to Third Party Money Managers

CWA may place clients with third party investment advisors (ie fund managers) based on factors including but not limited to their track record investment strategy public reports and comparisons with other advisors and their related disclosure documents ^

3

Fees and Compensation

Form ADV Part 2A Item 5 CWA manages investment portfolios for clients for a percentage of assets under management CWArsquos annual fee is exclusive of and in addition to brokerage commissions transaction fees and other related costs and expenses which shall be incurred by the client However CWA shall not receive any portion of these commissions fees and costs CWArsquos annual fee shall be prorated and charged quarterly in arrears based upon the market value of the assets on the last day of the previous quarter The fee schedule is as follows $0 - $1000000 100 $1000001 to $2000000 90 $2000001 to $3000000 80 $3000001 and above 70 A client can opt to hire CWA for this service on an hourly basis A charge will be billed at $225 an hour Fees can be negotiable depending on the circumstances CWA shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investment Co for investment management accounts CWArsquos Agreement andor the separate agreement with Fidelity or with other financial institutions may authorize CWA through the financial institution(s) to debit the clientrsquos account for the amount of CWArsquos fee and to directly remit that management fee to CWA in accordance with applicable custody rules The financial institution(s) recommended by CWA have agreed to send a statement to the client at least quarterly indicating all amounts disbursed from the account including the amount of management fees paid directly to CWA The client may make additions to and withdrawals from the account at any time subject to CWArsquos right to terminate an account 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 asset withdrawals may impair the achievement of a clientrsquos investment objectives For the initial quarter of investment management services the first quarterrsquos fees shall be calculated on a pro rata basis The Agreement between CWA and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement CWArsquos annual fee shall be prorated through the date of termination and any remaining balances shall be charged or refunded to the client as appropriate in a timely manner

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

2

benefit plans In the former case CWA would endeavor to pursue an investment strategy that it considered consistent with the plan trustees or with the clients objectives and prudent investment management CWA may manage no-load mutual fund portfolios for its clients

CWA uses a number of tools to evaluate client suitability for a particular investment These include a client profile risk questionnaire andor investment policy statement

C Referrals to Third Party Money Managers

CWA may place clients with third party investment advisors (ie fund managers) based on factors including but not limited to their track record investment strategy public reports and comparisons with other advisors and their related disclosure documents ^

3

Fees and Compensation

Form ADV Part 2A Item 5 CWA manages investment portfolios for clients for a percentage of assets under management CWArsquos annual fee is exclusive of and in addition to brokerage commissions transaction fees and other related costs and expenses which shall be incurred by the client However CWA shall not receive any portion of these commissions fees and costs CWArsquos annual fee shall be prorated and charged quarterly in arrears based upon the market value of the assets on the last day of the previous quarter The fee schedule is as follows $0 - $1000000 100 $1000001 to $2000000 90 $2000001 to $3000000 80 $3000001 and above 70 A client can opt to hire CWA for this service on an hourly basis A charge will be billed at $225 an hour Fees can be negotiable depending on the circumstances CWA shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investment Co for investment management accounts CWArsquos Agreement andor the separate agreement with Fidelity or with other financial institutions may authorize CWA through the financial institution(s) to debit the clientrsquos account for the amount of CWArsquos fee and to directly remit that management fee to CWA in accordance with applicable custody rules The financial institution(s) recommended by CWA have agreed to send a statement to the client at least quarterly indicating all amounts disbursed from the account including the amount of management fees paid directly to CWA The client may make additions to and withdrawals from the account at any time subject to CWArsquos right to terminate an account 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 asset withdrawals may impair the achievement of a clientrsquos investment objectives For the initial quarter of investment management services the first quarterrsquos fees shall be calculated on a pro rata basis The Agreement between CWA and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement CWArsquos annual fee shall be prorated through the date of termination and any remaining balances shall be charged or refunded to the client as appropriate in a timely manner

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

3

Fees and Compensation

Form ADV Part 2A Item 5 CWA manages investment portfolios for clients for a percentage of assets under management CWArsquos annual fee is exclusive of and in addition to brokerage commissions transaction fees and other related costs and expenses which shall be incurred by the client However CWA shall not receive any portion of these commissions fees and costs CWArsquos annual fee shall be prorated and charged quarterly in arrears based upon the market value of the assets on the last day of the previous quarter The fee schedule is as follows $0 - $1000000 100 $1000001 to $2000000 90 $2000001 to $3000000 80 $3000001 and above 70 A client can opt to hire CWA for this service on an hourly basis A charge will be billed at $225 an hour Fees can be negotiable depending on the circumstances CWA shall generally recommend that clients utilize the brokerage and clearing services of Fidelity Investment Co for investment management accounts CWArsquos Agreement andor the separate agreement with Fidelity or with other financial institutions may authorize CWA through the financial institution(s) to debit the clientrsquos account for the amount of CWArsquos fee and to directly remit that management fee to CWA in accordance with applicable custody rules The financial institution(s) recommended by CWA have agreed to send a statement to the client at least quarterly indicating all amounts disbursed from the account including the amount of management fees paid directly to CWA The client may make additions to and withdrawals from the account at any time subject to CWArsquos right to terminate an account 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 asset withdrawals may impair the achievement of a clientrsquos investment objectives For the initial quarter of investment management services the first quarterrsquos fees shall be calculated on a pro rata basis The Agreement between CWA and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement CWArsquos annual fee shall be prorated through the date of termination and any remaining balances shall be charged or refunded to the client as appropriate in a timely manner

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

4

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 clientrsquos account CWA may consult with its clients about the options and ramifications of transferring securities However clients are advised that when transferred securities are liquidated they are subject to transaction fees fees assessed at the mutual fund level (ie contingent deferred sales charge) andor tax ramifications Financial Planning Fees Clients may pay an hourly fee of $22500 per hour In the alternative clients may choose to pay for financial planning services on a fixed fee basis of $300000 per year Should the client opt for a combination of services of both fixed-fee financial planning services along with asset planning services CWA retains the right to waive the financial planning fee Transaction Costs Clients may incur certain charges imposed by the financial institution(s) and other third parties such as custodial fees charges imposed directly by a mutual fund or exchange traded fund in the account which shall be disclosed in the fundrsquos prospectus (eg fund management fees and other fund expenses) deferred sales charges odd-lot differentials transfer taxes wire transfer and electronic fund fees and other fees and taxes on brokerage accounts and securities transactions Additionally for assets outside of any wrap fee programs clients may incur brokerage commissions and transaction fees Such charges fees and commissions are exclusive of and in addition to CWArsquos fee

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

5

Performance-Based Fees and Side-By-Side Management

Form ADV Part 2A Item 6 CWA does not accept performance-based fees which are fees based on a share of capital gains or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle)

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

6

Types of Clients

Form ADV Part 2A Item 7 CWA clients are mostly trusts estates charitable organizations pension and profit sharing plans individuals and corporations or business entities

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

7

Methods of Analysis Investment Strategies and Risk of Loss

Form ADV Part 2A Item 8

CWA primarily uses fundamental analysis in its investment analysis The company also uses quantitative analysis to determine and portray statistical concepts investment properties and the affects on investment portfolios and investment asset classes With that said 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

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

Market Risk 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 securityrsquos particular underlying circumstances For example political economic and social conditions may trigger market events

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

Currency Risk Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investmentrsquos 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 (ie interest rate) This primarily relates to fixed income securities

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

8

Disciplinary Information

Form ADV Part 2A Item 9 Neither CWA nor its president John Bergstrom has any disciplinary actions to report

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

9

Other Financial Industry Activities and Affiliations

Form ADV Part 2A Item 10 In addition John Bergstrom is licensed with the State of Minnesota to sell insurance products These may or may not be securities per se and are not classified as ldquoinvestmentsrdquo Insurance products can include lifeaccidentdisability and long-term carehealth insurance

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

10

Code of Ethics Participation or Interest in Client Transactions and Personal Trading

Form ADV Part 2A Item 11 CWA has adopted a Code of Ethics related to such matters as insider trading personal securities trading gifts and confidentiality of client information A copy of CWArsquos Code of Ethics is available upon request CWA and its advisory representatives may buy or sell securities identical to those securities recommended to clients Therefore CWA and its advisory representatives may have an interest or position in certain securities that are also recommended and bought or sold to clients CWA and its advisory representatives will not put their interests before a clientrsquos interest Advisory representatives may not trade ahead of their clients or trade in such a way to obtain a better price for themselves than for their clients CWA is required to maintain a list of all securities holdings for its associated persons Further associated persons are prohibited from trading on non-public information or sharing such information Clients have the right to decline any investment recommendation CWA and its associated persons are required to conduct their securities and investment advisory business in accordance with all applicable Federal and State securities regulations CWA complies with the Insider Trading and Securities Fraud Enforcement Act of 1988 and has adopted a firm policy that outlines insider-trading compliance The statement has been distributed to all advisory representatives associated persons and employees CWA has a written policy to help protect nonpublic information including 1) restricting access to files 2) providing continuing education 3) restricting and or monitoring trading on securities for which CWA has knowledge of nonpublic information 4) requiring employees of CWA to conduct their personal trading through specified brokers and reporting transactions promptly to CWA and 5) monitoring the securities trading of the firm and its employees

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

11

Brokerage Practices

Form ADV Part 2A Item 12 Brokerage- Generally In general CWA recommends that clients custody their assets and effect their trades

through Fidelity Investments Co (ldquoFidelityrdquo) Factors CWA considers in recommending

Fidelity or any other broker-dealer to clients include their respective financial strength

reputation execution pricing research and service Fidelity enables CWA to obtain many

mutual funds without transaction charges and other securities at nominal transaction

charges In addition the commissions andor transaction fees charged by CWA may be

higher or lower than those charged by other broker-dealers

Soft Dollars

The commissions paid by CWArsquos clients shall comply with CWArsquos duty to obtain ldquobest executionrdquo However a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where CWA determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution taking into consideration the full capability commission rates and responsiveness Consistent with the foregoing while CWA will seek competitive rates it may not necessarily obtain the lowest possible commission rates for client transactions CWA may receive from various broker-dealers without cost to CWA computer software and related systems support which allow CWA to better monitor client accounts maintained at that custodian CWA may receive the software and related support without cost because CWA renders investment management services to clients that in the aggregate maintain a certain level of assets at the various broker-dealers Specifically CWA may receive the following benefits referral networks receipt of duplicate client confirmations and bundled duplicate statements access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts access to an electronic communication network for client order entry and account information and discounts for the purchase of software Block Trading

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

12

Transactions for each client generally will be effected independently unless CWA decides

to purchase or sell the same securities for several clients at approximately the same time

CWA may (but is not obligated to) combine or batch such orders to obtain best

execution to negotiate more favorable commission rates or to allocate equitably among

CWArsquos clients differences in prices and commissions or other transaction costs that might

have been obtained had such orders been placed independently Under this procedure

transactions will generally be averaged as to price and allocated among CWArsquos clients pro

rata to the purchase and sale orders placed for each client on any given day Commission

cost may vary due to volume of assets or method of receipt of confirmations In the event

that CWA determines that a prorated allocation is not appropriate under the particular

circumstances the allocation will be made based upon other relevant factors which may

include cash balances investment objectives or limitations in investment guidelines

A more thorough recital of CWArsquos trading allocation procedures is contained within its

Compliance Manual In addition CWA corrects all trade errors through an Error Account

at the various custodians If there is a loss due to a trade error by CWA CWA will make

the client whole If there is a gain in correcting the trade error the gain will be retained by

the respective custodian or retained in the respective trade error account

Brokerage for Client Referrals CWA does not direct brokerage for client referrals Nor does CWA direct brokerage outside of Fidelity if a client requests it

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

13

Review of Accounts

Form ADV Part 2A Item 13 Review John Bergstrom generally reviews all accounts on a monthly basis for investment activity In addition net worth projections and income expense reviews are conducted semi-annually along with a review of the financial goals and tax projections for CWArsquos clients Reports Clients receive investment portfolio statements on a monthly basis These statements include current positions ending month values and trading activity in the account Each calendar quarter clients will receive an Investment Policy Summary reflecting the portfolio positions and client-appropriate investment allocations Clients will also receive from the investment vendor an annual statement revealing tax-related material such as a statement of interest dividends capital gains distributions etc Clients will also receive information from their investment account vendor as it pertains to account distributions from retirement plans Finally clients will also receive statements of net worth incomeexpense reports income tax projections and financial goal-oriented projections on a semi-annual basis Clients are urged to compare the reports provided by CWA with those provided by the custodian

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

14

Client Referrals and Other Compensation

Form ADV Part 2A Item 14 As described in Item 4 CWA may place clients with a third party money manager In these instances CWA receives a fee paid to it by the third party money manager

CWA through its President John Bergstrom may receive compensation that derives from the sale of insurance products John Bergstrom is licensed with the State of Minnesota to sell insurance products and as such may receive usual and ordinary compensation from insurance companies for those transactions

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

15

Custody

Form ADV Part 2A Item 15 CWA does not have custody of client funds Each clientrsquos custodian sends at least quarterly a statement detailing the clientsrsquo holdings transactions and values for a particular period Clients should carefully review those statements From time to time or for a client meeting CWA may prepare reports or statements for clients CWA urges its clients to compare the account statements they receive from the qualified custodian with those they receive from CWA

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

16

Investment Discretion

Form ADV Part 2A Item 16 CWA manages accounts on a discretionary basis only and will place trades without first obtaining the consent of the client for each transaction However CWA generally will contact clients prior to a trade to discuss the recommendation and obtain client approval Clients may specify investment objectives guidelines and impose conditions on their accounts

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

17

Voting Client Securities

Form ADV Part 2A Item 17 CWA does vote client proxies and most often will vote with Board recommendations

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

18

Financial Information

Form ADV Part 2A Item 18 All fees are billed quarterly and in arrears CWA does not solicit prepayment of more than $1200 in fees per client six months or more in advance Neither CWA nor its principals has any financial information to report

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

19

Requirements for State-Registered Advisers

Form ADV Part 2A Item 19 John Bergstrom is the Managing Member and sole owner of CWA Mr Bergstrom founded CWA in 2005 Mr Bergstromrsquos education and business background includes the following Mr Bergstrom received a Bachelor of Arts degree in EconomicsInternational Business from Augsburg College in Minneapolis in 1994 Mr Bergstrom has passed the Series 3 7 63 and 65 examinations and is a Certified Financial Planner (CFPreg) Chartered Life Underwriter Chartered Financial Consultant (ChFC) and a Certified Divorce Financial Analyst (CDFA) A description of the qualifications for these designations is found below Neither Mr Bergstrom nor CWA is compensated with performance-based fees Mr Bergstrom has not been found liable in any arbitration or civil claim awards that require disclosure Furthermore Mr Bergstrom has not been the subject of a bankruptcy petition Mr Bergstrom does not have any relationship or arrangement with any issuer of securities Designation Qualifications In order to receive a Series 3 designation applicants must pass The National Commodity Futures Examination consisting of 120 multiple choice questions administered over 2 hours and 30 minutes In order to receive a Series 7 designation applicants must pass The General Securities Representative Examination consisting of 250 multiple choice questions administered over 6 hours The Series 7 qualifies a candidate for the solicitation purchase andor sale of all securities products In order to receive the Series 63 designation applicants must pass The Uniform Securities Agent State Law Examination consisting of 60 multiple choice questions administered over 75 minutes The Series 63 is designed to qualify candidates as securities agents The examination covers the principles of state securities regulation reflected in the Uniform Securities Act In order to receive a Series 65 designation applicants must pass The Uniform Investment Adviser Law Examination which is designed to qualify candidates as investment adviser

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

20

representatives in a three hour long test spanning 130 questions Candidates much pass with at least a 72 in order to receive a Series 65 designation In order to receive the CFPreg designation candidates must pass CFP Boards Fitness Standards for Candidates and Registrants agree to abide by CFP Boards Code of Ethics and Professional Responsibility which puts clients interests first and comply with the Financial Planning Practice Standards which spell out what clients should be able to reasonably expect from the financial planning engagement The Chartered Life Underwriter designation is for individuals who wish to specialize in life insurance and estate planning Individuals must complete five core courses and three elective courses and successfully pass all eight two-hour 100-question examinations in order to receive the designation The ChFC designation signifies that the recipient has completed the most extensive educational program required of any financial services credential To receive the ChFC designation individuals must complete eight or more college-level courses on all aspects of financial planning from The American College a non-profit educator with the highest level of academic accreditation The average study time is over 400 hours and advisors frequently spend years earning this coveted distinction Each ChFC must also complete 30 hours of continuing education every two years must meet extensive experience requirements and must adhere to strict ethical guidelines To become a CDFA a person must have two years of financial planning or legal experience After attaining the proper work experience candidates are required to complete a four-step modular program and exam designed by the IDFA The program is a self-study system covering financial and tax issues with case studies of divorce settlements

21

Additional InformationPrivacy Policy

Form ADV Part 2A Item 20

PRIVACY NOTICE (Regulation S-P)

Pursuant to Regulation S-P adopted by the Securities and Exchange Commission it is the policy of Cardinal Wealth Advisors to keep confidential nonpublic personal information (ldquoinformationrdquo) pertaining to each current and former client (ie information and records pertaining to personal background investment objectives financial situation investment holdings account numbers account balances etc) unless Cardinal Wealth Advisors is (1) previously authorized by the client to disclose information to individuals andor entities not affiliated with Cardinal Wealth Advisors including but not limited to the clientrsquos other professional Advisors andor service providers (ie attorney accountant insurance agent broker-dealer investment Advisor account custodian etc) (2) required to do so by judicial or regulatory process or (3) permitted to do so in accordance with the parameters of regulation S-P The disclosure of information contained in any document completed by the client for processing andor transmittal by Cardinal Wealth Advisors in order to facilitate the commencement continuation termination of a business relationship between the client and nonaffiliated third party service provider (ie broker-dealer investment adviser account custodian insurance company etc) including information contained in any document completed andor executed by the client for Cardinal Wealth Advisors (ie Advisory agreement client information form etc) shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider Each individual andor entity affiliated with Cardinal Wealth Advisors is aware of Cardinal Wealth Advisorsrsquo privacy policy and has acknowledged hisherits requirement to comply with same In accordance with the Cardinal Wealth Advisorsrsquo privacy policy each such affiliated individual andor entity shall have access to information to the extent reasonably necessary for Cardinal Wealth Advisors to perform its services for the client and to comply with applicable regulatory procedures and requirements If you have any questions please contact John Bergstrom at (952) 746-4700 or at johncardinalwealthnet