21 WEST WEALTH MANAGEMENT LLC

Form ADV Part 2A Disclosure Brochure January 27, 2026 2 1 W E S T W E A L T H M A N A G E M E N T L L C 2522 Chambers Road, Suite 100 Tustin, CA 92780 www.21westwm.com Firm Contact: Sara Lovell, CFP Managing Partner & Chief Compliance Officer saralovell@21westwm.com Item 1: Cover Page This brochure provides information about the qualifications and business practices of 21 West Wealth Management LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 949-774-2121. 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 21 West Wealth Management LLC (CRD #304532) is available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing of this brochure on January 21, 2025, there have been no material changes to this ADV. Full Brochure Available ii  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................... 1 Item 2: Material Changes ................................................................................................................. 2 Annual Update .................................................................................................................................................................... 2 Material Changes since the Last Update ........................................................................................................ 2 Full Brochure Available ................................................................................................................................................. 2 Item 4: Advisory Business ............................................................................................................... 6 Firm Description ................................................................................................................................................................ 6 Types of Advisory Services .......................................................................................................................................... 6 Client Tailored Services and Client Imposed Restrictions .................................................................. 7 Wrap Fee Programs ........................................................................................................................................................ 7 Client Assets under Management ........................................................................................................................ 7 Item 5: Fees and Compensation .................................................................................................. 7 Method of Compensation and Fee Schedule .............................................................................................. 7 Client Payment of Fees .............................................................................................................................................. 10 Additional Client Fees Charged ........................................................................................................................... 10 Prepayment of Client Fees ...................................................................................................................................... 10 External Compensation for the Sale of Securities to Clients ......................................................... 10 Item 6: Performance-Based Fees and Side-by-Side Management ...................... 10 Item 7: Types of Clients ................................................................................................................... 10 Description .......................................................................................................................................................................... 10 Account Minimums ...................................................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............... 10 Methods of Analysis ...................................................................................................................................................... 10 Investment Strategy .................................................................................................................................................... 11 Security Specific Material Risks ........................................................................................................................... 11 Item 9: Disciplinary Information ............................................................................................... 13 Criminal or Civil Actions ............................................................................................................................................. 13 Administrative Enforcement Proceedings ................................................................................................. 13 Self- Regulatory Organization Enforcement Proceedings ............................................................. 13 Item 10: Other Financial Industry Activities and Affiliations .................................... 13 iii  Broker-Dealer or Representative Registration ........................................................................................ 13 Futures or Commodity Registration ................................................................................................................ 13 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ....................................................................................................................................................................................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................. 14 Code of Ethics Description ...................................................................................................................................... 14 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest .............................................................................................................................................................................. 14 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest .............................................................................................................................................................................. 14 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ................................................................................... 15 Item 12: Brokerage Practices ....................................................................................................... 15 Factors Used to Select Custodians .................................................................................................................... 15 Research and Other Soft-Dollar Benefits ..................................................................................................... 15 Brokerage for Client Referrals .............................................................................................................................. 16 Clients Directing Which Broker/Dealer/Custodian to Use ............................................................. 17 Allocation of Block Trade Security Transactions for Client Accounts ..................................... 17 Item 13: Review of Accounts ........................................................................................................ 17 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................. 17 Review of Client Accounts on Non-Periodic Basis ................................................................................ 17 Content of Client Provided Reports and Frequency ........................................................................... 17 Item 14: Client Referrals and Other Compensation ....................................................... 18 Compensation Received by 21 West Wealth Management .......................................................... 18 Advisory Firm Payments for Client Referrals ............................................................................................ 18 Item 15: Custody .................................................................................................................................. 18 Account Statements .................................................................................................................................................... 18 Item 16: Investment Discretion .................................................................................................. 19 Discretionary Authority for Trading .................................................................................................................. 19 Item 17: Voting Client Securities ............................................................................................... 19 Proxy Votes .......................................................................................................................................................................... 19 Item 18: Financial Information .................................................................................................... 19 Balance Sheet ................................................................................................................................................................... 19 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet iv  Commitments to Clients .......................................................................................................................................... 20 Bankruptcy Petitions during the Past Ten Years ................................................................................... 20 Item 19: Requirements for State Registered Advisors ................................................. 20 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure 23 v  Item 4: Advisory Business Firm Description 21 West Wealth Management LLC (“21 West”) is a registered investment advisor based in Tustin, California. The firm was founded in 2019, and it is owned and operated by Michael Silane and Sara Lovell. 21 West provides discretionary wealth management and financial planning services primarily to affluent individuals and families, as well as discretionary investment management services to select institutional and retirement plan clients. Types of Advisory Services WEALTH MANAGEMENT 21 West offers discretionary wealth management services to advisory clients. 21 West offers clients ongoing wealth management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The client will authorize 21 West discretionary authority to execute selected investment program transactions as stated within the Wealth Management Agreement. Financial Planning & Consulting Financial planning is integrated into the ongoing wealth management relationship and is not offered as a standalone service. When provided as part of a discretionary wealth management relationship, financial planning services are included at no additional cost. Financial planning services may include, as applicable, retirement planning, cash flow analysis, investment planning, education planning, insurance planning, tax planning strategies, business planning, and estate planning considerations. Financial planning services are advisory in nature and do not include the provision of legal, tax, or accounting advice. EMPLOYEE BENEFIT PLAN SERVICES In addition to its primary wealth management services, 21 West provides discretionary investment management services to employer sponsored retirement plans when engaged as an investment manager within the meaning of ERISA Section 3(38). In this capacity, 21 West acts as a fiduciary solely with respect to the discretionary selection, monitoring, and replacement of plan investment options, subject to the terms of the applicable advisory agreement, plan documents, and the plan’s Investment Policy Statement. 21 West’s services do not include plan establishment, plan administration, recordkeeping, compliance testing, benefit calculations, loan administration, or the provision of legal, tax, or actuarial advice. The plan sponsor retains responsibility for plan administration, compliance with ERISA, and participant level outcomes. At the request of the plan sponsor, 21 West may provide non fiduciary, ministerial services such as general investment education meetings or assistance with vendor searches and fiduciary documentation. These services do not constitute individualized investment advice to plan participants and do not create fiduciary responsibility beyond the scope of the advisory agreement. - 6 -  Defined Benefit and Cash Balance Plan Services 21 West may provide discretionary investment management services to defined benefit and cash balance plans when engaged as an ERISA Section 3(38) investment manager. In these engagements, 21 West’s services are limited to investment management of plan assets in accordance with the plan’s Investment Policy Statement and applicable plan documents. 21 West does not provide actuarial services and does not prepare or certify funding interest calculations, contribution requirements, minimum funding standards, or crediting rate determinations. 21 West relies on actuarial assumptions, liability measurements, and funding information provided by the plan’s enrolled actuary or third- party administrator and is not responsible for the accuracy of such information. Investment performance is not guaranteed and may not equal or exceed the plan’s stated interest crediting rate or assumed rate of return. SEMINARS AND WORKSHOPS 21 West may hold seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature, and no specific investment or tax advice is given. These educational activities are incidental to the Firm’s advisory business and are not a primary service offering. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each client are documented within an Investment Policy Statement (IPS). Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Wrap Fee Programs 21 West does not sponsor any wrap fee programs. Client Assets under Management 21 West managed $128,894,175.28 of client assets as of December 31, 2025. Item 5: Fees and Compensation Method of Compensation and Fee Schedule WEALTH MANAGEMENT 21 West offers discretionary direct wealth management services to advisory clients. Pursuant to CCR Section 260.238(j), lower fees for comparable services may be available from other sources. Total fees to client will never exceed the safe harbor threshold of 3% of assets under management per year. 21 West charges an annual wealth management fee based on the total assets under management as follows: - 7 -  Assets Under Management First - $2,000,000 The next $2,000,001 - $7,000,000 The next $7,000,001 - $12,000,000 Amounts over $12,000,001 Annual Fee 1.00% 0.75% 0.50% 0.25% Monthly Fee .0833% .0625% .0417% .0208% 21 West requires a minimum of $1,000,000 to open an account. In certain instances, the minimum account size may be lowered or waived. The annual fee may be negotiable. Accounts within the same household may be combined for a reduced fee. Fees are billed monthly in arrears based on an average daily balance of the account for the previous month. Additionally, this is a blended fee schedule, the wealth management fee is calculated by applying different rates to different portions of the portfolio. 21 West may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. The calculation for the average daily balance is based on the formula (A/D) x F. A = the sum of the daily balances in the billing period D = number of days in the billing period F = monthly management fee For example (based on monthly billing period): the first step taken using the average- daily-balance calculation method would be to take the average of the values of the client’s account over the course of the entire month. For instance, 25 days at $7,500,000 plus six days at $8,000,000 averages out to approximately $7,596,774.19. This account would be charged $5,039.26 for the month. Calculation example: AUM Monthly Fee Total First $2,000,000 X .0833% = $1,666 Next $5,000,000 X .0625% = $3,125 Next $596,774.19 X .0417% = $248.26 Grand total for the month $5,039.26 Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Wealth Management Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. For accounts opened or closed mid-billing period, unearned fees will be refunded to the client. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. If 21 West is authorized or permitted to deduct fees directly from the account by the custodian: • 21 West will provide the client with an invoice concurrent to instructing the custodian to deduct the fee stating the amount of the fee, the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. • 21 West will obtain written authorization signed by the client allowing the fees to be deducted, and - 8 -  • The client will receive quarterly statements directly from the custodian which disclose the fees deducted. CASH BALANCE PLAN: ERISA-COVERED PLAN 3(38) SERVICES Pursuant to ERISA Section 408(b)(2), the Advisor hereby provides a detailed description of the fees that are paid to the Advisor. The Plan or Plan Sponsor will pay the Advisor an annualized advisory fee based on the market value of the Plan assets according to the following fee schedule (“Advisory Fee”): Assets Under Management First - $2,000,000 The next $2,000,001 - $7,000,000 The next $7,000,001 - $12,000,000 Amounts over $12,000,001 Annual Fee 1.00% 0.75% 0.50% 0.25% Monthly Fee .0833% .0625% .0417% .0208% The Advisory Fee is billed quarterly or monthly, in arrears, based on the fair market value of portfolio assets supervised by the Advisor on the last business day of the immediately preceding billing period. If the Advisor provides services for less than the whole of any calendar quarter or month, its compensation shall be determined on the basis of the value of Plan assets on the date of inception or date of termination, as applicable, and shall be payable on a pro rata basis for the period of the calendar quarter or month for which it has served as Advisor hereunder. 401(k) PLAN: ERISA-COVERED PLAN 3(38) Services Pursuant to ERISA Section 408(b)(2), the Advisor hereby provides a detailed description of the fees that are paid to the Advisor. The Plan or Plan Sponsor will pay the Advisor an annualized advisory fee based on the market value of the Plan assets according to the following fee schedule (“Advisory Fee”): Assets Under Management First - $20,000,000 Amounts over $20,000,001 Annual Fee 0.50% 0.25% Monthly Fee .0417% .0208% The Advisory Fee is billed quarterly or monthly, in arrears, based on the fair market value of portfolio assets supervised by the Advisor on the last business day of the immediately preceding billing period. If the Advisor provides services for less than the whole of any calendar quarter or month, its compensation shall be determined on the basis of the value of Plan assets on the date of inception or date of termination, as applicable, and shall be payable on a pro rata basis for the period of the calendar quarter or month for which it has served as Advisor hereunder. SEMINARS AND WORKSHOPS 21 West may hold seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature, and no specific investment or tax advice is given. 21 West does not charge a fee for attendance to these seminars. - 9 -  Client Payment of Fees Investment management fees are billed monthly in arrears, meaning that we invoice the client after the billing period. Fees are deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. 21 West, in its sole discretion, may waive its minimum fee and/or charge a lesser wealth management fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of securities such as mutual funds, equities, structured notes, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees 21 West does not require any prepayment of fees of more than $500 per client and six months or more in advance. Fees for financial plans are billed 50% in advance with the balance due upon plan delivery. If the client cancels after five (5) business days, any unearned fees will be refunded to the client, or any unpaid earned fees will be due to 21 West. External Compensation for the Sale of Securities to Clients 21 West does not receive any external compensation for the sale of securities to clients, nor do any of the investment advisor representatives of 21 West. Item 6: Performance-Based Fees and Side-by-Side Management 21 West does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for 21 West to recommend an investment that may carry a higher degree of risk to the client. Item 7: Types of Clients Description 21 West generally provides investment management services to affluent individuals and families, multi-generational family relationships, trusts and estates, and, to a lesser extent, employee benefit plans, corporations, foundations, and endowments. Account Minimums 21 West requires a minimum of $1,000,000 to open an account. In certain instances, the minimum account size may be lowered or waived. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Portfolio construction and risk management are evaluated at both the individual account and household level. - 10 -  Security analysis methods may include fundamental analysis. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. In developing a financial plan for a client, 21 West’s analysis may include cash flow analysis, investment planning, tax planning and estate planning. Based on the information gathered, a detailed strategy is tailored to the client’s specific situation. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategy The investment strategy for a specific client is based upon the objectives stated by the client during consultations, and it is formalized in an Investment Policy Statement (IPS). The purpose of an IPS is to document the goals and objectives for a client’s investment portfolio(s) as well as allowable parameters for achieving those goals, including the client’s risk tolerance and liquidity needs. Investment implementation strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies). Security Specific Material Risks 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 and should discuss these risks with 21 West: § Market Risk: The prices of securities held by mutual funds in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional, or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. § 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. § Inflation Risk: When any type of inflation is present, a dollar today will buy more than 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 investment’s 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 (i.e. interest rate). This primarily relates to fixed income securities. § Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. - 11 -  § Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. § Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. § Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. § Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. § Derivatives Risk: Funds in a client’s portfolio may use derivative instruments. The value of these derivative instruments derives from the value of an underlying asset, currency, or index. Investments by a fund in such underlying funds may involve the risk that the value of the underlying fund’s derivatives may rise or fall more rapidly than other investments, and the risk that an underlying fund may lose more than the amount that it invested in the derivative instrument in the first place. Derivative instruments also involve the risk that other parties to the derivative contract may fail to meet their obligations, which could cause losses. § Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. - 12 -  § Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. § Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. § Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. § Options Trading: The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership. Item 9: Disciplinary Information Criminal or Civil Actions 21 West and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings 21 West and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings 21 West and its management have not been involved in legal or disciplinary events that are material to a client’s or prospective client’s evaluation of 21 West or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration 21 West is not registered as a broker-dealer, and no affiliated representatives of 21 West are registered representatives of a broker-dealer. Futures or Commodity Registration Neither 21 West nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither Michael Silane nor Sara Lovell has any other business activities; therefore, no material conflicts of interest exist. - 13 -  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc. and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Additionally, 21 West requires adherence to its Insider Trading Policy, and the CFA Institute's Asset Manager Code of Professional Conduct and Code of Ethics and Standards of Professional Conduct. This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our clients. A summary of the Code of Ethics' Principles is outlined below. • Integrity - Access persons shall offer and provide professional services with integrity. • Objectivity - Access persons shall be objective in providing professional services to Clients. • Competence - Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. • Confidentiality - Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. • Professionalism - Access persons conduct in all matters shall reflect the credit of the profession. • Diligence - Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest 21 West and its affiliated persons do not make recommendations on client securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 21 West and its affiliated persons may buy or sell securities that are also held by clients. To mitigate conflicts of interest such as trading ahead of client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide 21 West with copies of their brokerage statements. The Chief Compliance Officer of 21 West is Sara Lovell. She reviews all trades of affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets - 14 -  and that clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest 21 West maintains an investment account for the purpose of investing its cash in cash equivalent investments. The firm does not maintain a proprietary trading account for any other purpose and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for clients. To mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide 21 West with copies of their brokerage statements. The Chief Compliance Officer of 21 West is Sara Lovell. She reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Custodians In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodians: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody). • Capability to execute, clear, and settle trades (buy and sell securities for your account). • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.). • Breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.). • Availability of investment research and tools that assist us in making investment decisions • Quality of services. • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices. • Reputation, financial strength, security and stability. • Prior service to us and our clients. With this in consideration, our firm recommends Charles Schwab & Co., Inc. (“Schwab”), an independent and unaffiliated SEC registered broker-dealer firm and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Schwab may provide us with certain services that may benefit us. - 15 -  Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. 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 on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. This conflict of interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Schwab’s support services: 1. 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. 2. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our Clients’ accounts, including accounts not 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 facilitate payment of our fees from our Clients’ accounts • provide pricing and other market data • • assist with back-office functions, recordkeeping, and Client reporting 3. 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, compliance, legal, and business needs • Publications and conferences on practice management and business succession 4. Your brokerage and custody 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 ETFs) may not incur Schwab commissions or transaction fees. Brokerage for Client Referrals We receive no referrals from a custodian, broker-dealer or third party in exchange for - 16 -  using that custodian, broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use Our firm recommends Clients establish account(s) at Schwab to execute transactions through. We will assist with establishing your account(s) at Schwab, however, we will not have the authority to open accounts on the Client's behalf. Not all investment advisers require their Clients to use their recommended custodian. By recommending that Clients use Schwab, we may be unable to achieve most favorable execution of Client transactions, and this practice may cost Clients more money. We base our recommendations on the factors disclosed in Item 12 herein and will only recommend custodians if we believe it's in the best interest of the Client. If Clients do not wish to utilize our recommended custodian, we permit Clients to direct brokerage. We will be added to your account through a limited trading authority. However, due to restraints from not having access to an institutional platform, we are unable to achieve most favorable execution of Client transactions. Clients directing brokerage may cost Clients more money. For example, in a directed brokerage account, the Client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the Client may receive a higher transaction price at their selected custodian versus our recommended custodian. Allocation of Block Trade Security Transactions for Client Accounts Our policy prohibits any allocation of trades in a manner that our proprietary accounts, affiliated accounts, employee accounts, or any client(s) or group of clients receive more favorable treatment than other clients. 21 West is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other clients of 21 West. All clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Reviews for wealth management clients incorporate household level coordination, tax awareness, and planning considerations where applicable. Account reviews are performed at least annually by a Managing Partner of 21 West. Account reviews are performed more frequently when market conditions dictate. Reviews of client accounts include, but are not limited to, a review of client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bands of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Financial plans generated are updated as requested by the client and pursuant to a new or amended agreement. 21 West suggests updating this at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation. Content of Client Provided Reports and Frequency Clients will receive trade confirmations from the custodian(s) for each transaction in their - 17 -  accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. Portfolio summary reports will be provided by 21 West at least monthly to clients with assets under management, exclusive of Assets Held Away. Item 14: Client Referrals and Other Compensation Compensation Received by 21 West Wealth Management 21 West is a fee-only firm that is compensated solely by its Clients. 21 West does not receive commissions or other sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Advisory Firm Payments for Client Referrals 21 West does not, directly, or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody Account Statements All assets are held by qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by 21 West. 21 West is deemed to have constructive custody solely because advisory fees are directly deducted from client’s accounts by the custodian on behalf of 21 West. Pursuant to CCR Section 260.237(b)(3) and standing letters of authorization. A. The investment adviser has custody of the funds and securities solely as a consequence of its authority to make withdrawals from client accounts to pay its advisory fee. B. The investment adviser has written authorization from the client to deduct advisory fees from the account held with the qualified custodian. C. Each time a fee is directly deducted from a client account, the investment adviser concurrently: 1. Sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client’s account; and 2. Sends the client an invoice or statement itemizing the fee. Itemization includes the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. D. The investment adviser notifies the Commissioner in writing that the investment adviser intends to use the safeguards provided in this paragraph (b)(3). Such notification is required to be given on Form ADV. 21 West and its qualified custodian will meet the following conditions when a standing letter or authorization (SLOA) has been established with a client: 1. 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. - 18 -  2. The client authorizes 21 West, 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. 3. 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. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. 21 West 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. 6. 21 West maintains records showing that the third party is not a related party of 21 West or located at the same address as 21 West. 7. 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 Discretionary Authority for Trading 21 West requires discretionary authority to manage securities accounts on behalf of clients. 21 West has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. 21 West allows clients to place certain restrictions, as outlined in the client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to 21 West in writing. The client approves the custodian to be used, and the commission rates paid to the custodian. 21 West does not receive any portion of the transaction fees or commissions paid by the client to the custodian. For employee benefit plan clients, discretionary authority is exercised solely in accordance with the scope of authority granted under the applicable ERISA Section 3(38) advisory agreement. Item 17: Voting Client Securities Proxy Votes 21 West does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, 21 West will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because 21 West does not serve as a custodian for client funds or securities and 21 West does not require prepayment of fees of more than $500 per client and six months or more in advance. - 19 -  Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients 21 West has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. Bankruptcy Petitions during the Past Ten Years 21 West has not had any bankruptcy petitions in the last ten years. Item 19: Requirements for State Registered Advisors Principal Executive Officers and Management Persons The education and business background for all management and supervised persons can be found in the Part 2B of this Brochure. Outside Business Activities The outside business activities for all management and supervised persons can be found in the Part 2B of this Brochure. Performance Based Fee Description Neither 21 West nor its management receive performance-based fees. Please see Item 6 of the ADV 2A for more information. Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving Management Persons 1. Neither 21 West nor its management have been involved in an arbitration claim alleging damages in excess of $2,500 involving any of the following: a) An investment or an investment-related business or activity. b) Fraud, false statement(s) or omissions. c) Theft, embezzlement or other wrongful taking of property. d) Bribery, forgery, counterfeiting, or extortion. e) Dishonest, unfair or unethical practices. 2. Neither 21 West nor its management have been found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: a) An investment or an investment-related business or activity. b) Fraud, false statement(s) or omissions. c) Theft, embezzlement or other wrongful taking of property. d) Bribery, forgery, counterfeiting, or extortion. e) Dishonest, unfair or unethical practices. Material Relationship Maintained by this Advisory Business or Management persons with Issuers of Securities There are no material relationships with issuers of securities to disclose. Business Continuity Plan 21 West maintains a written Business Continuity Plan that identifies procedures related to an emergency or significant business disruptions, including the death of the investment adviser or any of its representatives. - 20 -  Material Conflicts of Interest Assurance All material conflicts of interest regarding 21 West, its representatives or any of its employees which could be reasonably expected to impair the rendering of unbiased and objective advice are disclosed as required under CCR Section 260.238(k). - 21 -  Form ADV Part 2B – Cover Page Supervised Person Brochure January 27, 2026 2 1 W E S T W E A L T H M A N A G E M E N T L L C 2522 Chambers Road, Suite 100 Tustin, CA 92780 (949) 774-2121 www.21westwm.com Sara Lovell, CFP Managing Partner & Chief Compliance Officer saralovell@21westwm.com Item 1 – Cover Page This brochure supplement provides information about Sara Lovell and Michael Silane and supplements the 21 West Wealth Management LLC ADV brochure. You should have received a copy of that brochure. Please contact Sara Lovell if you did not receive the brochure or if you have any questions about the contents of this supplement. Additional information about Sara Lovell (CRD#5326656) and Michael Silane (CRD #7134524) is available on the SEC’s website at www.adviserinfo.sec.gov. - 22 -  Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Item 2 - Educational Background and Business Experience Managing Partner – Michael Silane, CFA • Year of birth: 1969 Educational Background: • Loyola Marymount University; Master’s in Business Administration – Business Administration and Finance; 1995 • Loyola Marymount University; Bachelor of Arts in Business Administration; 1991 Business Experience: • 21 West Wealth Management LLC; Managing Partner; 06/2019 – Present • BNY Mellon; Managing Director-Southwest; 12/2003 – 06/2019 • Bank of America; Senior Portfolio Manager; 4/1993 - 12/2003 Professional Certifications Employee has earned certifications and credentials that are required to be explained in further detail. Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by the CFA Institute. CFA certification requirements: • Hold a bachelor’s degree from an accredited institution or have equivalent educational or work experience. • Successful completion of all three exam levels of the CFA Program. • Have 48 months of acceptable professional work experience in the investment decision-making process. • Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. Managing Partner – Sara Lovell, CFP • Year of birth: 1986 Educational Background: • UC Irvine; Bachelor of Arts in Dance and Minor in Business Management; 2008 Business Experience: • 21 West Wealth Management LLC; Managing Partner; 07/2020-Present • BNY Mellon; Wealth Manager; 05/2016 – 07/2020 • JPMorgan Chase Bank N.A., Private Client Investment Associate 05/2014– 05/2016 • AXA Advisors, Registered Client Service Associate 11/2013 – 05/2014 • Raymond James, Registered Client Service Manager 09/2012 – 09/2013 • Merrill Lynch, Senior Registered Client Associate 06/2008 – 09/2012 Professional Certifications Employee has earned certifications and credentials that are required to be explained in further detail. The CERTIFIED FINANCIAL PLANNER™, CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold the CFP® certification. It is recognized in the United States and a number of other countries for its: (1) high standard of professional education. (2) stringent code of conduct and standards of practice; and - 23 -  (3) ethical requirements that govern professional engagements with clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in two, three-hour sessions, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances. • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year) or two-year apprenticeship option; and, • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals Item 3 – Disciplinary Information Criminal or Civil Action: None to report. Administrative Proceeding: None to report. Self-Regulatory Proceeding: None to report. Item 4 - Other Business Activities Engaged In Michael Silane and Sara Lovell have no additional business activities; therefore, no material conflicts of interest exist. Item 5 - Additional Compensation Michael Silane and Sara Lovell receive no additional compensation in any capacity, nor do they receive any performance-based fees. Item 6 - Supervision Michael Silane and Sara Lovell own and operate 21 West. They share responsibility for the formulation and monitoring of investment advice offered to clients. Sara Lovell is the firm’s Chief Compliance Officer, and she supervises all compliance and personal investment related activities as outlined in the firm’s Compliance Manual. She can be reached at saralovell@21westwm.com or 949-774-2600. Item 7 - Requirements for State-Registered Advisors Arbitration Claims: None to report. Self-Regulatory Organization or Administrative Proceeding: None to report. Bankruptcy Petition: None to report. - 24 -