Trinity Wealth Management, LLC

Form ADV Part 2A – Firm Brochure Item 1: Cover Page March 2026 Trinity Wealth Management, LLC 899 Cassatt Road, Suite 120 Berwyn, PA 19312 www.trinity-wealth.com Firm Contact: J. Charles Mann Chief Compliance Officer This brochure provides information about the qualifications and business practices of Trinity Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at (610) 296-2020 or email info@trinity-wealth.com. 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 Trinity Wealth Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Please note that the use of the term “registered investment adviser” and description of Trinity Wealth Management, LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Trinity Wealth Management, LLC is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. Since our last amendment filing on 08/13/2025, we have no material changes to disclose. ADV Part 2A – Firm Brochure Page 2 Trinity Wealth Management, LLC  Item 3: Table of Contents Section: Page(s): Item 1: Cover Page ....................................................................................................................................... 1 Item 2: Material Changes ............................................................................................................................ 2 Item 3: Table of Contents ............................................................................................................................ 3 Item 4: Advisory Business .......................................................................................................................... 4 Item 5: Fees & Compensation ..................................................................................................................... 6 Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 8 Item 7: Types of Clients & Account Requirements ................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 9 Item 9: Disciplinary Information .............................................................................................................. 11 Item 10: Other Financial Industry Activities & Affiliations .................................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ........... 11 Item 12: Brokerage Practices ................................................................................................................... 13 Item 13: Review of Accounts or Financial Plans ..................................................................................... 18 Item 14: Client Referrals & Other Compensation ................................................................................... 18 Item 15: Custody ....................................................................................................................................... 19 Item 16: Investment Discretion ............................................................................................................... 19 Item 17: Voting Client Securities .............................................................................................................. 20 Item 18: Financial Information ................................................................................................................ 20 ADV Part 2A – Firm Brochure Page 3 Trinity Wealth Management, LLC  Item 4: Advisory Business We specialize in the following types of services: Comprehensive Portfolio Management, Financial Planning & Consulting, and Pension Consulting. We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of Pennsylvania. Our firm has been in business as an independent investment adviser since 2014 and is solely owned by J. Charles Mann. Description of the Types of Advisory Services We Offer (i) Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. For clients with Assets Under Management of at least $1,000,000 we may offer personal tax preparation services through a third party CPA firm. Clients who take advantage of this service will enter into a separate agreement with the CPA firm of our choice, and we will pay the cost of Federal and Resident State Tax preparation services provided by the CPA firm. At our discretion, this service may be provided to clients with Assets Under Management below $1,000,000. We will not pay for the cost of any additional tax services, including, but not limited to, tax planning and consulting, business tax preparation, business advisory services, accounting and audit services. (ii) Financial Planning & Consulting: We provide a variety of financial planning and consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. ADV Part 2A – Firm Brochure Page 4 Trinity Wealth Management, LLC  Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. (iii) Pension Consulting: We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of either Section 3(21) or Section 3(38) of ERISA (but only with respect to the provision of services described in section 1 of the Pension Consulting Agreement). (iv)Asset Management: As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Tailoring of Advisory Services We offer individualized investment advice to clients utilizing our Comprehensive Portfolio Management service. Additionally, we offer general investment advice to clients utilizing our Financial Planning & Consulting and Pension Consulting services. ADV Part 2A – Firm Brochure Page 5 Trinity Wealth Management, LLC  Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Comprehensive Portfolio Management service. We do not manage assets through our other services. Participation in Wrap Fee Programs We do not offer wrap fee programs. Use of Pontera Platform Our firm uses the Pontera platform made available by Pontera Solutions, Inc. (“Pontera”), a third party online platform, to assist with management of clients’ “held away” accounts, including 401(k)s, 403(b)s, other defined contribution plan accounts, and as an order management system for such accounts where our firm implements tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. The specific fee schedule charged by Trinity Wealth for account management of held away assets is established in the client’s written agreement with Trinity Wealth. To facilitate use of the Pontera platform, the client securely logs into the Pontera site and entitles Trinity Wealth to manage the assets. Pontera charges Trinity Wealth 25 bps for each managed account. Clients do not pay any additional fee to Pontera or to Trinity Wealth in connection with platform participation. Trinity Wealth is not affiliated with the Pontera platform in any way and receives no compensation from them for using their platform. Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly- managed held-away accounts, such as 401(k)s. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Regulatory Assets Under Management As of December 31, 2025, we manage1 $379,801,148 on a discretionary basis and $19,369,594 on a non-discretionary basis for a total of $399,170,742 in assets under management. Item 5: Fees & Compensation How We Are Compensated for Our Advisory Services (i) Comprehensive Portfolio Management: Assets Under Management $0 to $1,499,999 $1,500,000 to $2,999,999 $3,000,000 to $4,999,999 Over $5,000,000 Annual Percentage of Assets Charge 1.50% 1.25% 0.75% 0.50% 1 Please note that our method for computing the amount of “client assets we manage” can be different from the method for computing “assets under management” required for Item 5.F in Part 1A of Form ADV. However, we have chosen to follow the method outlined for Item 5.F in Part 1A of Form ADV. If we decide to use a different method at a later date to compute “client assets we manage,” we must keep documentation describing the method we use and inform you of the change. The amount of assets we manage may be disclosed by rounding to the nearest $100,000. Our “as of” date must not be more than three months before the date we last updated our Brochure in response to Item 4.E of Form ADV Part 2A. ADV Part 2A – Firm Brochure Page 6 Trinity Wealth Management, LLC  Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. Our firm bills on cash unless otherwise agreed in writing. Fee adjustments will be made for deposits and withdrawals in client accounts made during the quarter for amounts in excess of $25,000. Our fees may be negotiable. Fees will generally be automatically deducted from your managed account*. As part of this process, you understand and acknowledge the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. *In rare cases, we will agree to directly bill clients. (ii) Financial Planning & Consulting: We charge on an hourly or flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our hourly fee is $500 and our flat fees generally range from $5000 to $50,000. We may require a 50% retainer of the total financial planning and consulting fee or we may require that the financial planning and consulting fee be due upon completion of the project. The fee paying arrangement is determined on a case-by-case basis at the discretion of the advisor and will be detailed in the Financial Planning and Consulting Agreement. In all cases, we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months. (iii) Pension Consulting: Our maximum fee for our Pension Consulting service is 1.00% of the assets under management. For plans with assets under $750,000, our firm will charge a minimum annual fee of $5,000. Once the plan reaches the $750,000 threshold, our firm will then move the plan over to our asset based pricing fee schedule with the maximum fee at 1.00%. Our firm’s fees are either billed on a pro-rata annualized basis quarterly in advance or in arrears based on the value of your account on the last day of the previous quarter. The billing schedule will be determined based on the plan’s qualified custodian. We also charge on an hourly or flat fee basis for pension consulting services. Our hourly fee is $500 and our flat fees generally range from $5,000 to $50,000. Flat fees will be charged annually for ongoing pension consulting services. Ultimately, total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. The fee-paying arrangements for pension consulting service will be determined on a case-by- case basis and will be detailed in the signed Pension Consulting Agreement. (iv)Asset Management: ADV Part 2A – Firm Brochure Page 7 Trinity Wealth Management, LLC  The maximum annual fee charged for this service will not exceed 1.00%. Fees to be assessed will be outlined in Schedule A of this Agreement. Our firm bills on cash unless otherwise agreed in writing. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from Client account(s) Adjustments will be made for deposits and withdrawals in client accounts made during the quarter for amounts in excess of $25,000. In rare cases, TWM will agree to directly invoice. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Other Types of Fees & Expenses Clients will incur transaction charges for trades executed in their accounts. These transaction fees are separate from our fees and will be disclosed by the firm that the trades are executed through. Also, clients will pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Termination & Refunds We charge our advisory fees quarterly in advance. In the event that you wish to terminate our services, we will refund the unearned portion of our advisory fee to you. You need to contact us in writing and state that you wish to terminate our services. Upon receipt of your letter of termination, we will proceed to close out your account and process a pro-rata refund of unearned advisory fees. If the Client does not receive our brochure and brochure supplements at least forty-eight (48) hours prior to entering into an agreement, the Client has the right to terminate our services without penalty within five (5) business days of entering into the agreement. Commissionable Securities Sales We do not sell securities for a commission in our advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management We do not accept performance-based fees. Item 7: Types of Clients & Account Requirements We have the following types of clients:  Individuals and High Net Worth Individuals; ADV Part 2A – Firm Brochure Page 8 Trinity Wealth Management, LLC   Trusts or Estates;  Pension and Profit-Sharing Plans; Our requirements for opening and maintaining accounts or otherwise engaging us:  We generally require a minimum household account balance of $500,000 for our Comprehensive Portfolio Management service. This minimum account balance requirement may be negotiable.  We generally require a minimum household account balance of $100,000 for our Asset Management service. This minimum account balance requirement may be negotiable. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis: We believe the best way to manage investment risk is to analyze changes in price of a security or market index through Technical Analysis. The primary types of Technical Analysis we use are Point & Figure charting and Relative Strength. Point & Figure charting has been used for over 100 years to measure the supply and demand characteristics of a security or market index by plotting day-to-day price movements without taking into consideration the passage of time. Relative Strength is a momentum investing technique that compares the price trend of one security or market index against the price trend of another security or market index. In addition to Technical Analysis, we may use Modern Portfolio Theory Statistics to help measure risk and return for a security or portfolio. Investment Strategies We Use: Using Technical Analysis, our investment strategies follow a rules-based process to manage investment risk by adapting to changing market conditions. We primarily use Exchange Traded Funds, but we will consider using Exchange Traded Notes, Mutual Funds, Individual Stocks or Bonds. We offer Conservative, Moderate and Aggressive strategies and we match each client’s investment strategy to their tolerance for investment risk using sophisticated Risk Profiling. Asset Categories. We primarily invest in four broad asset categories including Domestic Equities, International Equities, Fixed Income and Cash. Our risk based strategies have minimum and maximum allocation percentages for each of these asset categories that correspond to the investment objective and risk profile of the strategy. Margin Loans: Our firm may allow or recommend that you to pledge securities from your portfolio as collateral for a loan by using margin in brokerage account. This allows you to own more stock than you would be able to with your available cash. Margin accounts and transactions are risky and not necessarily appropriate for every client. Smart Beta. The core of our investment strategy utilizes Smart Beta investing. Smart Beta combines the benefits of passive investing with the advantages of active investment strategies. The goal of Smart Beta is to enhance portfolio returns, reduce risk or increase diversification at a lower cost than traditional active management. The primary Smart Beta strategy we use is called Factor investing. Factor investing is a strategy that selects securities based on attributes which have historically and persistently been drivers of returns. We use up to five factors in our investment strategies which are described below. ADV Part 2A – Firm Brochure Page 9 Trinity Wealth Management, LLC   Momentum – Investing in securities with upward trending prices  Quality – Selecting companies with solid balance sheets and less volatile earnings  Size – Investing in smaller companies  Minimum Volatility – Favoring stocks with historically lower risk  Value – Choosing stocks with prices that are below their fundamental value Index Investing. We also utilize index investing in our investment strategies. Index investing is a passive investment strategy that attempts to generate similar returns to a broad market index. We may use index investing for stocks, bonds or other asset categories. Risk of Loss. Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio ADV Part 2A – Firm Brochure Page 10 Trinity Wealth Management, LLC  could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under all market conditions and each investor should evaluate his/her ability to maintain any investment he/she is considering his/her own investment time horizon. Investments are subject to risk, including possible loss of principal. Item 9: Disciplinary Information We have determined that our firm and management have no legal or disciplinary events to disclose that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Our firm or our management persons have a material relationship with the following related person(s) as follows: 1. Insurance company or agency Representatives of our firm are insurance agents/brokers. They may offer insurance products and receive customary fees as a result of insurance sales. A conflict of interest may arise as these insurance sales may create an incentive to recommend products based on the compensation adviser and/or our supervised persons may earn and may not necessarily be in the best interests of the client. 2. Educational Seminars J. Charles Mann owns and operates Trinity Financial Education, which conducts informational seminars to educate the public on key retirement issues. This service does not provide investment advice and is strictly for informational purposes. A separate engagement with Trinity Wealth Management, LLC is required for advisory services. Clients of our firm are not obligated to attend these seminars. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Brief description of our Code of Ethics adopted pursuant to SEC rule 204A-1 and offer to provide a copy of our Code of Ethics to any client or prospective client upon request. We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out ADV Part 2A – Firm Brochure Page 11 Trinity Wealth Management, LLC  in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts2. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm provides investment advice to assets affected by the Department of Labor (“DOL”) Fiduciary Rule for a level fee. As such, we abide by the Impartial Conduct Standards as defined by the DOL. To comply with these standards, our firm and our advisors give advice that is in our clients’ best interest, charge no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2), and make no misleading statements about investment transactions, compensation, conflicts of interest, and any other matters related to investment decisions. B. If our firm or a related person recommends to clients, or buys or sells for client accounts, securities in which our firm or a related person has a material financial interest (excluding an interest as a shareholder of an SEC-registered, open-end investment company), we must describe our practice and discuss the conflicts of interest it presents. Neither our firm nor a related person recommends to clients, or buys or sells for client accounts, securities in which our firm or a related person has a material financial interest. C. If our firm or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that our firm or a related person recommends to clients, we are required to describe our practice and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connection with personal trading. See Item 11A of this Brochure. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, 2 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 12 Trinity Wealth Management, LLC  our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. D. If our firm or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for our firm’s (or the related person's own) account, we are required to describe our practice and discuss the conflicts of interest it presents. We are also required to describe generally how we address conflicts that arise. See Item 11A of this brochure. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling the same securities within 24 hours prior to buying or selling for our clients. If related persons’ accounts are included in a block trade, our related persons will always trade personal accounts last. Item 12: Brokerage Practices The custodian and brokers we use We do not maintain custody of your assets on which we advise, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when [we/you] instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. How we select Brokers/Custodians We seek to recommend a Custodian/Broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution • Timeliness and accuracy of trade confirmations • Liquidity of the securities traded • Willingness to commit capital • Ability to place trades in difficult market environments • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided ADV Part 2A – Firm Brochure Page 13 Trinity Wealth Management, LLC  • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation Your brokerage and trading costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, to minimize your trading costs, we have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/ custodians”). By using another broker or dealer you may pay lower transaction costs. Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts, including accounts not ADV Part 2A – Firm Brochure Page 14 Trinity Wealth Management, LLC  maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements)  Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Provide pricing and other market data  Facilitate payment of our fees from our clients’ accounts  Assist with back-office functions, record keeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:  Educational conferences and events  Consulting on technology and business needs  Publications and conferences on practice management and business succession  Access to employee benefits providers, human capital consultants, and insurance providers  Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Explanation of when we use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, and how we receive a bene(cid:976)it because our (cid:976)irm does not have to produce or pay for the research, products or services. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our (cid:976)irm to manage accounts for which we have investment discretion. Without this arrangement, our (cid:976)irm might be compelled to purchase the same or similar services at our own expense. Incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving best execution. As a result of receiving the services discussed in 12A.1, we may have an incentive to continue to use or expand the use of the Custodian’s services. Our (cid:976)irm examined this potential con(cid:976)lict of interest when we chose to enter into the relationship with the Custodian and we have determined that the relationship is in the best interest of our (cid:976)irm’s clients and satis(cid:976)ies our (cid:976)iduciary obligations, including our duty to seek best execution. The Custodian charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). The Custodian enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. The Custodian’s commission rates are generally ADV Part 2A – Firm Brochure Page 15 Trinity Wealth Management, LLC  discounted from customary retail commission rates. However, the commission and transaction fees charged by the Custodian may be higher or lower than those charged by other Custodian and broker-dealers. Causing clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar bene(cid:976)its (known as paying-up). Our clients may pay a commission to the Custodian that is higher than another quali(cid:976)ied broker dealer might charge to effect the same transaction where we determine 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 range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the bene(cid:976)it of all clients, we may not necessarily obtain the lowest possible commission rates for speci(cid:976)ic client account transactions. Disclosure of whether we use soft dollar bene(cid:976)its to service all of our clients’ accounts or only those that paid for the bene(cid:976)its, as well as whether we seek to allocate soft dollar bene(cid:976)its to client accounts proportionately to the soft dollar credits the accounts generate. We do not receive soft dollar bene(cid:976)its although the non-soft dollar investment research products and services that may be obtained by our (cid:976)irm will generally be used to service all of our clients, a brokerage commission paid by a speci(cid:976)ic client may be used to pay for research that is not used in managing that speci(cid:976)ic client’s account. Description of the types of products and services our (cid:976)irm or any of our related persons acquired with client brokerage commissions (or markups or markdowns) within our last (cid:976)iscal year. The Custodian does not make client brokerage commissions generated by client transactions available for our (cid:976)irm’s use. Explanation of the procedures we used during our last (cid:976)iscal year to direct client transactions to a particular broker-dealer in return for soft dollar bene(cid:976)its we received. Our (cid:976)irm does not direct client transactions to a particular broker-dealer in return for soft dollar bene(cid:976)its. Brokerage for Client Referrals. If we use client brokerage to compensate or otherwise reward brokers for client referrals, we must disclose this practice, the con(cid:976)licts of interest it creates, and any procedures we used to direct client brokerage to referring brokers during the last (cid:976)iscal year (i.e., the system of controls used by us when allocating brokerage). Our (cid:976)irm does not receive brokerage for client referrals. Directed Brokerage A. If we routinely recommend that a client directs us to execute transactions through a speci(cid:976)ied broker-dealer, we are required to describe our practice or policy. Further, we must explain that not all advisers require their clients to direct brokerage. If our (cid:976)irm and the broker- dealer are af(cid:976)iliates or have another economic relationship that creates a material con(cid:976)lict of interest, we are further required to describe the relationship and discuss the con(cid:976)licts of interest it presents by explaining that through the direction of brokerage we may be unable ADV Part 2A – Firm Brochure Page 16 Trinity Wealth Management, LLC  to achieve best execution of client transactions, and that this practice may cost our clients more money. Neither we nor any of our (cid:976)irm’s related persons have discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. We routinely recommend that a client directs us to execute through a speci(cid:976)ied broker-dealer. Our (cid:976)irm recommends the use of Charles Schwab & Co., Inc. Each client will be required to establish their account(s) with the Custodian if not already done. Please note that not all advisers have this requirement. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. For many of the ERISA plans we manage or establish on behalf of our clients, we will recommend the use of ePlan Services, Inc. (A Paychex company) as custodian and administrator. We receive no form of compensation (direct or indirect) for these arrangements and do so solely on our belief that it is in the best interest of our clients. Clients are under no obligation to utilize these services. B. Permissibility of Client-Directed Brokerage. We allow clients to direct brokerage outside our recommendation. However, we may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Discussion of whether, and under what conditions, we aggregate the purchase or sale of securities for various client accounts in quantities sufficient to obtain reduced transaction costs (known as bunching). If we do not bunch orders when we have the opportunity to do so, we are required to explain our practice and describe the costs to clients of not bunching. We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, ADV Part 2A – Firm Brochure Page 17 Trinity Wealth Management, LLC  current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/custodians”) and not Schwab’s services that benefit only us. Item 13: Review of Accounts or Financial Plans We review accounts on at least an annual basis for our clients subscribing to our Comprehensive Portfolio Management service. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only J. Charles Mann and Marjorie Wentz will conduct reviews. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Clients who subscribe to our Comprehensive Portfolio Management service will receive performance reports on a quarterly basis, as well as verbal reports on at least an annual basis. Pension Consulting clients receive reviews of their pension plans for the duration of the pension consulting service. We also provide ongoing services to Pension Consulting clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Pension Consulting clients do not receive written or verbal updated reports regarding their pension plans unless they choose to contract us for ongoing Pension Consulting services. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post- financial plan meeting or update to their initial written financial plan. Item 14: Client Referrals & Other Compensation Schwab We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage Practices). ADV Part 2A – Firm Brochure Page 18 Trinity Wealth Management, LLC  Referral Fees We do not pay referral fees (non-commission based) to independent solicitors (non-registered representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-3 of the Investment Advisers Act of 1940. Item 15: Custody While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Standing Instructions.” All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with the account custodian:  The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed.  The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time.  The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer.  The client has the ability to terminate or change the instruction to the client’s qualified custodian.  The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction.  The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser.  The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, we are authorized to execute securities transactions, which securities are bought and sold, the total amount ADV Part 2A – Firm Brochure Page 19 Trinity Wealth Management, LLC  to be bought and sold, and the costs at which the transactions will be effected. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information Our firm is not required to provide financial information in this Brochure because:  Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months.  Our firm does not take custody of client funds or securities.  Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. ADV Part 2A – Firm Brochure Page 20 Trinity Wealth Management, LLC