Overview

Total Firm Assets
$130 million
Average High-Net-Worth Client Portfolio Size
$6.4 million
Stated Minimum Account Size
$3,000,000

Fee Disclosure

PEARL WEALTH DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT

MinMaxDisclosed Annual Rate
$0 $2,000,000 1.00%
$2,000,001 $4,000,000 0.75%
$4,000,001 and above 0.50%

Stated Minimum Annual Fee: $10,000

Estimated Annual Advisory Fees
Portfolio ValueEstimated Annual FeeEffective Fee Rate
$1 million Below minimum client size
$5 million $40,000 0.80%
$10 million $65,000 0.65%
$50 million $265,000 0.53%
$100 million $515,000 0.52%

Actual fees may vary; other investment costs may apply.

Clients

High-Net-Worth Share of Firm Assets
84.13%
Number of High-Net-Worth Clients
17
Total Client Accounts
102
Discretionary Accounts
102

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Regulatory Filings

SEC CRD Number
296811

Additional Brochure: PEARL WEALTH DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT (2026-08-24)

View Document Text
Pearl Wealth LLC Form ADV Part 2A – Disclosure Brochure Effective: August 24, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (303) 250-0036. Pearl Wealth is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Pearl Wealth to assist you in determining whether to retain the Advisor. Additional information about Pearl Wealth and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 296811. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 http://pearlwealth.net Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Pearl Wealth. For convenience, the Advisor has combined these documents into a single disclosure document. Pearl Wealth believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Pearl Wealth encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on March 5, 2026. • Effective April 1, 2026, the Advisor has moved primary address to 2101 Pearl Street, Boulder, CO 80302. • The Advisor has updated its billing fee schedule. Please see Item 5 for additional information. • The Advisor has amended its fixed fee language. Please see item 5 for additional information • The Advisor has amended its minimum relationship size language. Please item 7 for additional information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 296811. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (303) 250-0036. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 2 Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 Item 5 – Fees and Compensation ......................................................................................................................... 6 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8 Item 7 – Types of Clients ....................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9 Item 9 – Disciplinary Information ....................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11 Item 12 – Brokerage Practices ............................................................................................................................ 11 Item 13 – Review of Accounts ............................................................................................................................ 12 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 Item 15 – Custody ................................................................................................................................................ 13 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ...................................................................................................................... 14 Item 18 – Financial Information .......................................................................................................................... 14 Form ADV Part 2B – Brochure Supplement ...................................................................................................... 15 Privacy Policy ...................................................................................................................................................... 18 Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 3 Item 4 – Advisory Services Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”) is a registered investment advisor with the SEC. Pearl Wealth is organized as a limited liability company (“LLC”) under the laws of Colorado. Pearl Wealth was formed under the business name DH2 Capital, LLC in April 2018 and changed its legal name to Pearl Wealth LLC in June 2018. Pearl Wealth became a registered investment advisor in June 2018. The Principal Officer of the Advisor is Debra Herz Huttner (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Pearl Wealth. Pearl Wealth offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, foundations, retirement plans, and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Pearl Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Pearl Wealth provides discretionary investment management and related advisory services for its Clients. Pearl Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Pearl Wealth will then construct a portfolio, consisting primarily of exchange-traded funds (“ETFs”) and diversified mutual funds (including passive and active) to achieve the Client’s investment goals. The Advisor may also utilize other types of investments, such as alternatives, to meet the needs of Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Pearl Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Pearl Wealth, in connection with the Client, will develop an Investment Policy Statement (“IPS”) that describes the Client’s requirements and the Advisor’s approach. The Advisor will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Pearl Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Pearl Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Pearl Wealth may recommend specific positions to increase sector, asset class or cash weightings. Pearl Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the positions in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 4 Use of Independent Managers Pearl Wealth may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms by which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platforms, will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). Clients may also elect to utilize an Independent Manager to provide due diligence and monitoring services regarding private investment offerings. The Advisor in these engagements will contract directly with the Independent Manager on the Client’s behalf. At no time will Pearl Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices. Prior to engaging Pearl Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services include: • Establishing an Investment Strategy – Pearl Wealth, in connection with the Client, will develop an IPS that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Pearl Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Pearl Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Pearl Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio. Financial Planning Services Pearl Wealth also provides a variety of financial planning and consulting services to Clients. Services may be offered as a standalone engagement or included under an overall investment advisory relationship. Services are offered in several areas relating to a Client’s financial situation, depending on their goals, objectives and financial situation. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Pearl Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 5 Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the advisory fees paid to the Advisor. Clients have the right to choose whether to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client has the right to choose whether to implement the transaction through the Advisor or through another advisory firm or professional. Prior to engaging Pearl Wealth to provide financial planning services, each Client is required to enter into an agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the Client. Retirement Plan Advisory Services Pearl Wealth provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Monitoring • Vendor Analysis • • • Ongoing Investment Recommendation and Assistance These services are provided by Pearl Wealth serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Pearl Wealth’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Pearl Wealth does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Pearl Wealth. Assets Under Management - As of April 17, 2026, Pearl Wealth manages approximately $129,900,328 in discretionary assets. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Fees are based on the market value of the Client’s account[s] on the last business day of the prior calendar quarter. The market value of assets may include assets under management which are held away from the Client’s Custodian. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. The Advisor’s fees are based on the following schedule: Assets Under Management Up to $2,000,000 Next $2,000,000 Over $4,000,000 Annual Rate (%) 1.00% 0.75% 0.50% Clients will incur a minimum annual fee of $10,000. The minimum fee is negotiable at the sole discretion of the Advisor. The Advisor at its discretion may reduce and/or waive the minimum annual fee. Please see Item 7. Unless otherwise instructed, the Client’s fees will take into consideration the aggregate assets under management Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 6 with Advisor. All securities held in accounts managed by Pearl Wealth will be independently valued by the Custodian. Certain clients of Pearl Wealth may be billed according to a prior fee schedule. Pearl Wealth will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs charged by the Custodian. Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Custodian will then forward the investment advisory fee to the Advisor or deposit the fee into an account designated by the Advisor. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of each quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Pearl Wealth on the last business day of the prior calendar quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting Pearl Wealth to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Pearl Wealth is compensated for its services in advance of the quarter in which investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement without fee or penalty to the Client. Upon termination, the Advisor will promptly refund any unearned, prepaid fees. The Client’s investment advisory agreement with the Advisor may not be assigned without the Client’s prior consent. Use of Independent Managers For Clients referred by the Advisor to an Independent Manager, the Client’s fee will be separately billed or deducted from the Client’s account[s] by the Independent Manager and the Advisor. In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. Pearl Wealth will assist the Client with the termination and transition as appropriate. For Clients engaging with Advisor for Independent Manager due diligence and monitoring of private investments, the fee is determined initially based on the services to be provided and annually thereafter. These fees are charged quarterly in advance and deducted from the Client’s custodial account. The Advisor after deducting the fees for this service will pay the Independent Manager directly. The Advisor does not retain any portion of the fees collected for this service. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. Financial Planning Services Clients may be offered financial planning services annually as part of the investment management fee. Planning services outside the scope of the investment management fee will be billed at the Advisor’s hourly rate of $750 per hour. Clients with less than $3 million under management may receive planning as part of their agreement, or they may be offered financial planning services at an hourly rate or as a fixed engagement fee. Fixed fee engagements are dependent upon variables including the specific needs of the Client, scope, complexity, estimated time, duration, and personnel involved to provide services to you, among other factors Pearl Wealth deems relevant. For any planning engagements where a fee will be charged, an estimate for total hours and/or costs will be determined prior to engaging for these services. Financial planning fees are invoiced by the Advisor upon completion of the engagement deliverable[s] and are due upon receipt. Either party may terminate the financial planning agreement, at any time, by providing advance written Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 7 notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement without fee or penalty to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours worked or the percentage of the engagement scope completed by the Advisor for fixed fee engagements. The Client’s financial planning agreement with the Advisor may not be assigned without the Client’s prior consent. Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 1%, billed quarterly, in advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Fees are based on the market value of assets in the Plan at the end of the prior quarter. Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Pearl Wealth is compensated for its services in advance of the quarter in which retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement[s] with the Advisor is non-transferable without the Client’s prior consent. Other Costs Clients may incur certain fees or charges imposed by third parties, other than Pearl Wealth, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts but typically charges for mutual funds and other types of investments. The fees charged by Pearl Wealth are separate and distinct from these custody and execution fees. In addition, all fees paid to Pearl Wealth for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses relate to management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Pearl Wealth, but would not receive the services provided by Pearl Wealth which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Pearl Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Pearl Wealth does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Pearl Wealth does not charge performance-based fees for its investment advisory services and therefore does not engage in side-by-side management. Item 7 – Types of Clients Pearl Wealth offers investment advisory services to individuals, high net worth individuals, families, trusts, estates, foundations, retirement plans, and charitable organizations. Pearl Wealth generally requires a minimum relationship size of $3,000,000 to effectively implement its investment process. This minimum may be waived at the Advisor’s sole discretion. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Research and analysis from Pearl Wealth is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Pearl Wealth primarily employs a fundamental analysis method in developing investment strategies for its Clients. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Pearl Wealth generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Pearl Wealth will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Pearl Wealth may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Clients should be aware that buying and selling of positions that are more short-term in nature may result in additional securities transactions costs, which may reduce the amount of returns on the investments. Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Pearl Wealth will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. Following are some of the risks associated with the Advisor’s strategies. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor typically recommends long-term investment strategies. The following are some investment risks the Client should understand and consider: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 9 ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Alternative Investments (Limited Partnerships) The performance of alternative investments (including limited partnerships, BDCs and other) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self- liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). 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. Digital Assets Risks Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are loosely regulated. A Client could lose the entire value of their investment in digital assets and is only suitable for Clients with a high risk tolerance. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Pearl Wealth or its owner. Pearl Wealth values the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 296811. Item 10 – Other Financial Industry Activities and Affiliations The sole business of Pearl Wealth is to provide advisory services to its Clients. Neither Pearl Wealth nor its owner are involved in other business endeavors. Pearl Wealth does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 10 Use of Independent Managers As noted in Item 4, the Advisor may select Independent Managers to assist with the implementation of a Client’s investment strategy. In such arrangements, the Advisor and Independent Manager will collect their investment advisory fees individually. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pearl Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Pearl Wealth (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Pearl Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Pearl Wealth’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (303) 250- 0036. Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Pearl Wealth does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. Pearl Wealth does not have a material interest in any securities traded in Client accounts. Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Pearl Wealth conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non- public information. While Pearl Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Pearl Wealth, or any Supervised Person of Pearl Wealth, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices Pearl Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and execution services, except for the authorized trade-away transactions for certain fixed income trades. The Client will engage the Custodian (herein the "Custodian") to safeguard Client assets and authorize Pearl Wealth to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Pearl Wealth does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis at the Custodian. Pearl Wealth does not exercise discretion over the selection of the Custodian. Pearl Wealth does recommend the Custodian to Clients for custody and execution services. Pearl Wealth will typically recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC and a “qualified custodian”. Pearl Wealth maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab as detailed below. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or costs from the Advisor associated with using a custodian not recommended by Pearl Wealth. However, if Schwab is not utilized, the Advisor may have limitations in the services it can offer comparable to other Clients. recommends Schwab due to the Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 11 reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the quality of its trade execution. Pearl Wealth will periodically compare Schwab to other providers. Trade-Away Transactions As noted above, the Advisor may obtain an additional authorization to trade-away from the Custodian for access to fixed income securities. In such instances, the Client will complete additional authorizations with the Custodian for the discretionary authority to trade away from the Custodian. The Client may be charged a trade-away fee by the Custodian. The Advisor does not receive any additional compensation for such trades. 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Pearl Wealth does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Pearl Wealth does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – The Advisor will place trades within the established account[s] at the Custodian designated by the Client, unless separately authorized by the Client. Further, all Client accounts are traded within their respective brokerage account[s] at the Custodian. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). The Advisor will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Pearl Wealth will execute its transactions through the Custodian as authorized by the Client. Pearl Wealth may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre- allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts Securities in Client accounts are monitored on a regular and continuous basis by Ms. Huttner. Formal reviews with the Client are generally conducted at least annually or more frequently depending on the needs of the Client. Formal reviews are also conducted when a Client’s financial situation changes or as a result of major changes in economic conditions, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Pearl Wealth if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. The Client will receive statements no less than quarterly, but typically monthly, from the Custodian. These statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 12 Item 14 – Client Referrals and Other Compensation Pearl Wealth is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Pearl Wealth does not receive commissions or other compensation from product sponsors, broker-dealers or any unrelated third party. Pearl Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Pearl Wealth may receive non-compensated referrals of new Clients from various third parties. The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. The Advisor may be indirectly compensated by an Independent Manager as described in Item 5 above and does not receive any other forms of compensation with such arrangements. Pearl Wealth has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Pearl Wealth. As a registered investment advisor participating on the Schwab Advisor Services platform, Pearl Wealth receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to act in the best interest of its Clients. Clients should be aware, however, that the receipt of economic benefits from Schwab creates a conflict of interest since these benefits may influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. To mitigate this conflict, Pearl Wealth will periodically compare Schwab to other providers to assess its services, fees, trade execution and other factors. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Pearl Wealth that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Pearl Wealth believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian and compare to any reports provided by Pearl Wealth to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 13 As the Advisor has custody of the funds and securities solely as a consequence of its authority to make withdrawals from Client accounts to collect its fees, the Advisor is required to meet the following criteria: • The Advisor receives written authorization from the Client to deduct advisory fees from the Client’s account[s] held with the Custodian. • Each time a fee is directly deducted from a Client’s account[s], the Advisor concurrently sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the Client's account[s]. • The Advisor sends the Client an invoice or statement itemizing the fee, including 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. Item 16 – Investment Discretion Pearl Wealth requires discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client, unless the Advisor is managing a qualified participant level account for the Client. However, these purchases or sales are subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Pearl Wealth. The Client provides written authorization to provide the Advisor with discretionary authority over the Account[s] by executing an investment advisory agreement. All discretionary trades made by Pearl Wealth will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Pearl Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Pearl Wealth, nor Ms. Huttner, have any adverse financial situations that would reasonably impair the ability of Pearl Wealth to meet all obligations to its Clients. Neither Pearl Wealth, nor any of its advisory persons, has been subject to a bankruptcy or financial compromise. Pearl Wealth is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 14 Form ADV Part 2B – Brochure Supplement for Debra Herz Huttner, CFP® President and Chief Compliance Officer Effective: August 24, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Debra Herz Huttner, CFP® CRD# 6244041) in addition to the information contained in the Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”, CRD# 296811) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Pearl Wealth Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (303) 250-0036. Additional information about Ms. Huttner is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6244041. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 15 Item 2 – Educational Background and Business Experience Debra Herz Huttner, CFP®, born in 1970, is dedicated to advising Clients of Pearl Wealth as its President and Chief Compliance Officer. Ms. Huttner earned her JD from New York University School of Law in 1997 and an MBA from NYU Stern School of Business in 1997. In addition, Ms. Huttner earned a B.A. in English Literature from Brown University in 1992. Additional information regarding Ms. Huttner’s employment history is included below. Employment History: President, Pearl Wealth LLC Financial Advisor, Colorado Capital Management, Inc. Attorney, Private Practice Attorney, O'Brien Braun, P.C. 06/2018 to Present 08/2013 to 06/2018 01/2013 to 08/2013 01/2011 to 12/2012 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • 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. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 16 Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Huttner. Ms. Huttner has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Huttner. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Ms. Huttner. However, we do encourage you to independently view the background of Ms. Huttner on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6244041. Item 4 – Other Business Activities Ms. Huttner is dedicated to the investment advisory activities of Pearl Wealth’s Clients. Ms. Huttner does not have any other business activities. Item 5 – Additional Compensation Ms. Huttner is dedicated to the investment advisory activities of Pearl Wealth’s Clients. Ms. Huttner does not receive any additional forms of compensation. Item 6 – Supervision Ms. Huttner serves as the President and Chief Compliance Officer of Pearl Wealth. Ms. Huttner can be reached at (303) 250-0036. Pearl Wealth has implemented a Code of Ethics an internal compliance document that guides Ms. Huttner in meeting fiduciary obligations to Clients of Pearl Wealth. Further, Pearl Wealth is subject to regulatory oversight by various agencies. These agencies require registration by Pearl Wealth and Ms. Huttner. As a registered entity, Pearl Wealth is subject to examinations by regulators, which may be announced or unannounced. Pearl Wealth is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 17 Privacy Policy Effective: August 24, 2026 Our Commitment to You Pearl Wealth LLC (“Pearl Wealth” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Pearl Wealth (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Pearl Wealth does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 18 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Pearl Wealth does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Pearl Wealth or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients Pearl Wealth does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (303) 250-0036. Pearl Wealth LLC 2101 Pearl Street, Boulder, CO 80302 Phone: (303) 250-0036 | http://pearlwealth.net Page 19

Frequently Asked Questions