Westrock offers only brokerage services to its retail investors. Westrock’s principal brokerage services include buying and selling securities on a solicited and unsolicited basis. Westrock does not provide any investment advisory services including, for example, financial planning or wrap fee programs to its retail investors.

Monitoring: Westrock voluntarily review the holdings of its retail customers’ accounts for the purposes of determining whether to provide a recommendation to the customer. This voluntary review is not considered to be “account monitoring,” and not meant to create an implied agreement with the customer to monitor the account.

Investment Authority: All accounts are not discretionary.

Account Minimums and Other Requirements: Westrock does not require any minimum amount to open or maintain brokerage accounts with the exception of margin accounts. Margin account rules are based on clearing firm’s requirement.

Limited Investment Offerings: Westrock neither participates in Investment offerings nor it offers any proprietary manufactured products except mutual funds. Mutual fund charges are disclosed in the individual companies’ prospectus. Westrock does not have revenue sharing arrangements, and does not participate in principal trading.

Brokerage Account Fees

Westrock does not charge brokerage account fees other than transaction-based fees (also known as commissions) maximum to an extent of 5% whether you make or lose money. Additionally, the following fees may be charged:

- Inactivity fees (charged by AXOS Clearing)

- Yearly IRA fees (charged by AXOS Clearing)

- Reorg fees (charged by AXOS Clearing)

What are your legal obligations to me when providing recommendations?

How else does your firm make money and what conflicts of interest do you have?

-----------------------------------------------------------------------------------------------------Westrock does provide recommendations on a limited basis based on the available market information. When we act as your representative as a broker, we have to act in your best interest and not put our interest ahead of yours.

Conversation Starters - Ask your financial professional these questions to learn more:

 - Given my financial situation, should I choose a brokerage service? Why or why not?

 - How will you choose investments to recommend to me?

 - What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?

Conversation Starter –

 - Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

How are we paid?

Commissions: Fee you pay is based on specific transaction and not the value of your account. We get commissions when you buy or sell securities. Sometimes we also get payments from third parties. Example: mutual fund commissions and trailers which do not have any effect on the value of your mutual fund balance.

What about conflict of interest?

Conversation Starter –

• How might your conflicts of interest affect me, and how will you address them?

Yes. For additional information, please visit FINRA website https://brokercheck.finra.org/. to research of our financial professionals. Westrock Capital Management, Inc. does not have legal or disciplinary events. For additional information, you can visit Investor.gov/CRS for a free and simple search tool to research our firm and financial professionals.

 Conversation Starter –

 - Who is my primary contact person?

 - Is he or she a representative of an investment adviser or broker-dealer? 

 - Who can I talk to if I have concerns about how this person is treating me?

Conversation Starter –

 - As a financial professional, do you  have any Disciplinary history? For what type of conduct?