Jackson Wealth Management, LLC

Item 1: Cover Page Jackson Wealth Management, LLC 115 Wilcox St, Suite 220 Castle Rock, CO 80104 (303) 808-5229 Form ADV Part 2A – Firm Brochure Dated April 21st, 2026 This Brochure provides information about the qualifications and business practices of Jackson Wealth Management, LLC, (“JWM”). If you have any questions about the contents of this Brochure, please contact us at (303) 808-5229. 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. Jackson Wealth Management, LLC is registered as an Investment Adviser with the United States Securities and Exchange Commission (SEC). Registration of an Investment Adviser does not imply any level of skill or training. Additional information about JWM is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s CRD number, 310496. Page 1 of 30  Item 2: Material Changes The last annual update to this Brochure was filed on February 9th, 2026. Since that filing, we have made the following material changes: JWM is transitioning from a state-registered investment adviser in Colorado to a federally registered investment adviser with the Securities and Exchange Commission ("SEC"). This change in regulatory authority is administrative in nature; it does not materially impact the firm’s daily operations, investment strategies, client account management, or personnel. Item 5 – Added disclosure regarding legacy and acquired client fee schedules, explaining that certain clients may pay advisory fees that differ from JWM’s current standard schedule Item 15 – JWM will no longer provide a separate fee invoice at the time advisory fees are deducted by the custodian. Information regarding deducted advisory fees will continue to be reflected on your custodial account statements. -- This Brochure is provided to clients at least annually and when material changes occur. Clients may request a copy of the current Brochure at any time at no charge by contacting JWM at the number on the cover page. Page 2 of 30  Item 3: Table of Contents Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 10 Item 6: Performance-Based Fees and Side-By-Side Management 13 Item 7: Types of Clients 13 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 13 Item 9: Disciplinary Information 22 Item 10: Other Financial Industry Activities and Affiliations 22 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 22 Item 12: Brokerage Practices 24 Item 13: Review of Accounts 27 Item 14: Client Referrals and Other Compensation 27 Item 15: Custody 28 Item 16: Investment Discretion 29 Item 17: Voting Client Securities 29 Item 18: Financial Information 30 Page 3 of 30  Item 4: Advisory Business Description of Advisory Firm Jackson Wealth Management, LLC (“JWM”) is a registered investment adviser with the United States Securities and Exchange Commission (SEC). The firm was founded in 2020. Stefan Jackson, CFP® is the principal owner, founder, Chief Executive Officer, and Chief Compliance Officer of JWM. JWM currently reports $107 million in discretionary Assets Under Management. Assets Under Management were calculated as of April 21st, 2026 Types of Advisory Services JWM is a fee-only Registered Investment Adviser, and as such owes clients a fiduciary duty and is required to act in clients’ best interest. JWM is compensated only through advisory fees paid by clients for Wealth Management, which includes both investment management and financial planning services. JWM does not accept commissions, sales loads, or other transaction-based compensation. From time to time, JWM may recommend unaffiliated professionals (e.g., attorneys, CPAs, tax professionals, and insurance professionals). Clients are not required to use any recommended provider and may select professionals of their choosing. JWM is not affiliated with these providers and does not receive compensation (including referral fees) for such recommendations. Investment Management Discretionary investment management services are provided. Clients grant limited authority, as set forth in the advisory agreement, to buy and sell securities in their accounts without obtaining prior approval for each transaction. Ongoing investment advice and portfolio management are provided based on each client’s goals, objectives, and stated constraints. Through personal discussions, relevant information is gathered (which may include financial circumstances, investment experience, risk tolerance, time horizon, liquidity needs, tax considerations, and other relevant factors) to develop an investment strategy, including an asset allocation target, and the portfolio is implemented and managed consistent with that strategy. Clients are generally advised regarding investments in stocks, bonds, exchange-traded funds (“ETFs”), U.S. government and municipal securities, and cash and cash equivalents. Advice may also be provided regarding securities or other investments already held at the inception of the relationship and/or other investment types if appropriate to the client’s financial situation or at the client’s request. Account supervision is guided by the Client’s stated objectives, restrictions, and other relevant considerations, including tax considerations where applicable. Clients may impose reasonable restrictions in writing on investing in certain securities, types of securities, or industries/sectors. Page 4 of 30  Investment Strategies JWM offers investment management strategies through two primary portfolio approaches. A client may be managed using either approach on a standalone basis, or a combination of both, depending on the client’s circumstances, objectives, and preferences. The selected approach and key guidelines are documented in the client’s Investment Policy Statement (“IPS”) and related advisory documents. Item 8 provides additional detail regarding methods of analysis, investment strategies, and related risks. Guided Allocation Portfolios A portfolio is built around an appropriate mix of asset classes (such as stocks, bonds, and cash) for the client’s goals and risk tolerance, using historical market behavior and how asset classes have tended to move together or differently as a guide. Once the mix is established, the portfolio is monitored and managed to stay generally aligned through periodic rebalancing until a change is required. The primary goal is risk-appropriate growth through asset class diversification, with a secondary goal of consistency and risk control by staying disciplined through market cycles, including difficult markets. Adaptive Allocation Portfolios This approach is designed to make more meaningful changes to the portfolio mix over time in response to changing market conditions. It generally uses a structured, data-informed process to adjust exposure across investments, which may include sizable tactical shifts such as market timing and/or rotating among asset classes based on relative opportunities. The objective is to remain flexible and responsive— becoming more defensive or more fully invested as conditions change—rather than remaining primarily anchored to a more static asset mix. Dynamic Allocation Portfolios In some cases, a portfolio may combine both approaches by maintaining a Guided Allocation foundation while also using one or more Adaptive Allocations or frameworks that can be adjusted more actively over time. The intent is to blend the benefits of a steady, diversified core with the flexibility to make dynamic adjustments when appropriate, based on the client’s overall plan and agreed-upon guidelines. Third-Party Investment Strategy In addition to JWM’s in-house portfolio approaches, JWM may recommend third-party investment strategies or platforms when appropriate based on a client’s circumstances, preferences, or account type. These third-party solutions may be used within a broader JWM strategy or alongside JWM-managed assets as a complementary component of the Client’s overall investment plan. Depending on the solution selected, they may differ from JWM’s in-house management in how portfolios are constructed, the investments used, and how actively allocations are adjusted. Separately Managed Accounts (“SMA”) JWM may recommend or engage unaffiliated third-party investment managers, sometimes referred to as separately managed accounts (“SMAs”), sub-advisers, or outside managers. When SMAs are used, JWM assists the client with selecting an appropriate strategy and allocation, coordinating implementation, and monitoring the manager’s ongoing performance and fit within the client’s overall portfolio. SMAs may be used for a portion of a client’s current strategy or for a secondary investment objective. JWM also meets with the client periodically to discuss changes in the client’s financial situation, suitability, and any new or revised restrictions to be applied to the SMA account. JWM’s process for evaluating and Page 5 of 30  reviewing SMAs and third-party managers is discussed further in Item 8. Fees for SMA services are separate from and in addition to JWM’s standard advisory fees as disclosed in Item 5 and/or in the client’s advisory agreement and related documents. Held-Away Accounts At a client’s direction, JWM may also provide investment management services for certain client assets that are not maintained with JWM’s primary custodian, including employer-sponsored retirement plans (“held- away accounts”), through a third-party technology platform. The third-party platform provides JWM with limited access to account information and the ability to place trades within the client’s existing retirement plan. Clients must separately authorize the platform and maintain control over their login credentials. JWM does not have custody of client assets held in these accounts. JWM’s access is limited to investment selection and trading and does not permit withdrawals, distributions, transfers, or changes to account ownership or beneficiary designations. Clients retain full ownership and control of the accounts and may revoke JWM’s access at any time. Wrap Fee Programs We do not participate in any wrap fee programs. All our services are provided on a fee-basis as described in Item 5 of this Brochure Financial Planning Financial planning is a collaborative process designed to help a client organize and evaluate their financial life and make informed decisions over time. Planning generally involves gathering and reviewing information about the client’s financial circumstances and stated goals, identifying key priorities and tradeoffs, and developing recommendations across relevant areas such as retirement, cash flow, investment strategy, risk management, tax and estate planning coordination, and other planning topics as applicable. The planning process may incorporate assumptions and estimates to model future cash flows, asset values, and withdrawal strategies. Because financial planning is forward-looking and depends on changing conditions and the accuracy of inputs, results are not guaranteed. A financial plan is intended to support decision-making and progress tracking and should not be viewed as a promise of future performance or outcomes. As part of JWM’s Wealth Management, and at no additional charge beyond the advisory fee described in Item 5, JWM may provide financial planning at the client’s election. Planning may be delivered in written and/or electronic form, and clients may be provided access to financial planning software to view and update plan inputs and outputs. The scope and depth of planning services varies based on the client’s circumstances, the information provided, and the areas the client elects to address. Financial Planning Scope Financial planning may address one or more of the topics described below. The client and advisor work together to determine which areas to cover, and the depth of analysis provided. Client Responsibilities and Limitations Financial planning relies on the accuracy and completeness of information provided by the client (and, if applicable, third parties). Clients are responsible for promptly notifying JWM of material changes to their Page 6 of 30  financial situation, goals, risk tolerance, time horizon, or other relevant factors. Recommendations may be limited if information is incomplete, inaccurate, or not provided on a timely basis. Unless otherwise agreed in writing, JWM does not provide legal advice, tax advice, or accounting services. Any recommendation involving taxes, legal matters, insurance coverage, or estate planning should be reviewed with the client’s qualified attorney, CPA, and/or insurance professional. Implementation Unless otherwise agreed in writing, clients are responsible for implementing financial planning recommendations, including engaging outside professionals (e.g., attorneys, CPAs, insurance professionals) and acting on recommended items. At the client’s request and with appropriate authorization, JWM may coordinate with outside professionals and may participate in joint meetings or calls. Updates and Ongoing Planning Financial planning is typically reviewed and updated over time as a client’s circumstances change. Updates may be triggered by life events, changes in income, changes in goals, market conditions, and/or changes in tax laws. The frequency and depth of updates vary based on the client’s needs and the scope of services agreed upon. Financial Planning Topics Financial planning may address one or more of the topics described below. The client and advisor work together to determine which areas to cover, and the depth of analysis provided. Financial Goals and Priorities JWM may help clients identify and prioritize goals and develop an action plan. This may include establishing time horizons, forecasting required resources, and identifying tradeoffs when goals compete for limited resources. Retirement Planning Planning may include projections of a client’s ability to meet stated retirement goals, often focused on financial independence. If projections indicate a lower likelihood of meeting goals, JWM may discuss adjustments to variables such as savings, spending, retirement age, withdrawal rates, investment risk, and other assumptions. For clients near or in retirement, planning may also include distribution strategies and sustainable spending approaches; however, outcomes depend on market performance, withdrawal behavior, and other factors. Cash Flow and Debt Management Planning may include reviewing income and expenses, budgeting approaches, and strategies to improve cash flow. JWM may discuss debt repayment priorities based on factors such as interest rates, repayment terms, and potential tax considerations, as well as emergency reserves and cash management. Investment Analysis Planning may include developing or reviewing an asset allocation approach aligned to goals and risk tolerance, reviewing investment accounts and holdings, discussing investment vehicles and strategies, and evaluating concentrated positions or employer equity/stock options where applicable. JWM’s investment management strategies and related risks are further discussed in Item 8. Page 7 of 30  Risk Management and Insurance Review Planning may include reviewing major personal and financial risks (such as premature death, disability, liability exposure, property and casualty losses, and long-term care needs) and discussing potential approaches to managing those risks, including insurance and “self-insurance” tradeoffs. JWM does not sell insurance and does not provide legal advice regarding coverage terms. If appropriate, JWM may recommend that the client consult with a licensed insurance professional for product evaluation, quotes, and implementation. Tax Planning JWM may discuss tax planning concepts as they relate to the overall financial plan (e.g., tax-efficient asset location, capital gains strategies, charitable giving strategies, retirement distribution sequencing, and Roth conversion considerations). Tax laws and interpretations change, and outcomes are not guaranteed. Clients should consult with a qualified tax professional before implementing tax strategies. At the client’s request, JWM may coordinate with and participate in meetings with the client’s tax professional. Employee Benefits Optimization Planning may include reviewing employer benefit elections and planning opportunities (e.g., retirement plans, stock plans, HSAs, ESPPs). For business owners, planning may include retirement plan considerations and coordination with qualified providers and tax professionals. College Savings Planning may include education funding projections and savings strategy guidance, including review of vehicles such as 529 plans where appropriate, and discussion of how education funding goals interact with retirement and other priorities. Business Planning For business owners or prospective business owners, planning may include cash flow considerations, retirement plan concepts, compensation strategy considerations, succession/exit planning concepts, and coordination with the client’s attorney and tax professional. Estate Planning Planning may include reviewing estate planning goals and existing documents at a high level (e.g., wills, trusts, beneficiary designations, powers of attorney) and discussing general strategies intended to improve alignment with the client’s objectives. JWM does not draft legal documents and recommends that clients work with a qualified estate planning attorney. At the client’s request, JWM may coordinate with and participate in meetings with the client’s attorney. Client Tailored Services and Client-Imposed Restrictions JWM’s services are tailored to each client’s individual circumstances. While clients generally have access to the same categories of Wealth Management (investment management and financial planning), the scope of planning, specific recommendations, and portfolio implementation vary based on factors such as the client’s goals and objectives, time horizon, liquidity needs, risk tolerance, tax considerations, cash flows, net worth, and existing holdings. These factors are typically documented in the client’s Investment Policy Statement (“IPS”) and/or other written planning and investment materials. Page 8 of 30  In certain cases—particularly when onboarding a client with existing investments—JWM may continue to manage or monitor legacy holdings for a period of time where immediate changes may be impractical or tax- inefficient. Over time, and consistent with the client’s IPS and circumstances, such holdings may be retained, repositioned, or transitioned as appropriate. When appropriate, JWM may recommend unaffiliated third-party managers and/or alternative investments (including private funds, where suitable). JWM may also discuss insurance-related solutions (such as annuities) as part of financial planning; however, JWM does not sell insurance or receive insurance commissions, and any implementation is completed through properly licensed insurance professionals as required by applicable law. Clients may request reasonable restrictions or customizations to JWM’s discretionary authority, including restrictions related to specific securities, types of securities, industries/sectors, and/or allocation parameters. Restrictions must be provided in writing and accepted by JWM. Certain restrictions may limit available investments, reduce diversification, increase deviation from benchmarks or model allocations, and/or adversely affect performance. If a restriction or customization materially changes the investment objective or risk profile reflected in the IPS, the IPS will be updated and the client’s written acknowledgment will be obtained. Third-Party Cash Management Services To support clients’ cash management needs, JWM may offer access to Flourish Cash, an unaffiliated cash management platform that may provide competitive interest rates and access to expanded FDIC insurance coverage through a network of participating banks. This service allows clients to hold cash balances outside of their investment portfolios for liquidity and cash reserve purposes. Use of Flourish Cash is optional. Clients retain full ownership and control of their Flourish Cash accounts, and JWM may provide guidance regarding cash allocation as part of our financial planning services. To the extent permitted, account information may be viewable for planning and reporting purposes to help us understand a client’s overall financial picture. Third-Party Estate Planning Services As part of our financial planning, JWM may provide clients access to Wealth.com. (“Wealth”), an unaffiliated third-party technology platform that facilitates the preparation, organization, and storage of certain estate planning documents (e.g., wills, trusts, and powers of attorney), depending on the client’s needs and selections. Use of the platform is optional, and clients are not obligated to use Wealth or any provider we recommend. JWM pays for client access to the Wealth platform as part of our service offering. Clients must agree to Wealth’s terms and conditions available at wealth.com. JWM does not provide legal advice or legal services, and JWM does not draft legal documents. Wealth may offer the option to consult with licensed attorneys in certain jurisdictions and/or other services beyond the platform; any such services are typically outside the scope of JWM’s advisory services and may involve additional fees and separate terms between the client and the provider. Page 9 of 30  Item 5: Fees and Compensation Wealth Management JWM provides discretionary Wealth Management, which include investment management and financial planning services. Clients enter into a written Wealth Management Client Agreement that governs the terms of the advisory relationship. Termination and Proration A client may terminate the Wealth Management Client Agreement within five (5) business days of execution without incurring any advisory fees or penalties. Thereafter, either party may terminate the agreement at any time upon written notice. Advisory fees are billed quarterly in arrears and are prorated for partial billing periods. Upon termination, fees are owed only for services provided through the termination date and because they are calculated in arrears, a refund will not be required. Fee Changes No increase in a client’s advisory fee will be effective without the client’s agreement, which will be documented through a new Wealth Management Client Agreement or a written amendment to the existing agreement. Advisory Fee Schedule JWM’s advisory fee is based on the market value of assets under management (“AUM”) and includes both investment management and financial planning services. Unless otherwise agreed in writing, JWM applies a progressive (blended) fee schedule, under which different portions of a client’s household assets are billed at different rates. JWM’s current standard advisory fee schedule is below (annualized). Note: Legacy & Acquired Client Fee Schedules Certain clients may be serviced under advisory fee schedules that differ from JWM’s current standard schedule, including legacy client arrangements, existing contractual arrangements assumed in connection with an acquisition or transition of client relationships, or other negotiated fee arrangements. Any such variation is disclosed and agreed to in the client’s Wealth Management Client Agreement (or an amendment), and JWM does not increase a client’s advisory fee without the client’s approval. Household Account(s) Value Advisory Fee Rate On the first $1,000,000 1.50% On the next $1,000,000 1.00% On the amount over $2,000,000 0.50% Minimum Household Investment $500,000 Advisory fees are expressed as an annualized percentage, are negotiable, and are billed quarterly in arrears. Fees are calculated using the average daily balance of the client’s household AUM during the billing period. Page 10 of 30  Fee Calculation Hypothetical Example | Average daily balance = $1,250,000; 90-day quarter) Annual fee = (first $1,000,000 × 1.50%) + (next $250,000 × 1.00%) = $15,000 + $2,500 = $17,500 Quarterly fee = $17,500 × (90 ÷ 365) = $4,315.07 Payment Method Advisory fees for Wealth Management are deducted directly from the client’s account(s) maintained at the client’s qualified custodian (for example, Charles Schwab & Co., Inc.), as authorized in the client’s Wealth Management Client Agreement. Additional details regarding fee deduction are provided in Item 15 of this brochure. Held-Away Accounts If JWM provides discretionary management for certain held-away accounts (e.g., employer retirement plan accounts) using a third-party platform, JWM’s standard advisory fee generally applies. Held-away accounts typically cannot be debited directly for advisory fees; accordingly, JWM’s advisory fee is billed and deducted from the client’s primary custodial account (for example, a brokerage account at the client’s qualified custodian) as authorized in the client’s Wealth Management Client Agreement. The value of held-away assets included for fee calculation (if applicable) is based on information available through the third-party platform, account statements, or information provided by the client. Minimum Household Investment JWM generally requires a minimum household investable asset level of $500,000 to establish a new Wealth Management relationship. This minimum reflects the scope and ongoing nature of the services provided. JWM may, in its discretion, accept or continue to serve clients below the stated minimum, including for legacy relationships, existing contractual arrangements, family or related household relationships, or as part of an acquisition or transition of client accounts. Minimum Annual Advisory Fee For clients accepted below the $500,000 household minimum, JWM generally charges a minimum annual advisory fee of $7,500. The minimum annual fee is billed quarterly in arrears and prorated for partial billing periods as applicable. The minimum fee is intended to reflect the ongoing service and oversight provided through the wealth management relationship. Because the minimum fee is a fixed dollar amount, it may result in a higher effective advisory fee rate (when expressed as a percentage of assets) that may exceed 2.00% for clients with lower asset levels. Clients should consider the minimum fee in light of their account size and the scope of services being provided and understand that similar advisory services may be available from other advisors at lower fee levels. Any negotiated fee arrangements, including whether the minimum annual fee applies or is waived, are disclosed in the client’s Wealth Management Client Agreement and related documents. Separately Managed Account (“SMA”) Fees JWM may recommend unaffiliated third-party investment managers, sub-advisers, or outside managers (often referred to as separately managed accounts or “SMAs”). If a client engages a SMA, the client Page 11 of 30  generally pays both JWM’s advisory fee and the SMA manager’s fee, as applicable. As a result, the client’s total advisory costs may be higher than if JWM managed the assets without a SMA. JWM does not receive any portion of the SMA manager’s fee unless specifically disclosed and agreed to in writing. Any SMA arrangement, including the portion of assets allocated to the SMA (if applicable), will be documented in the client’s advisory agreement and/or an addendum. The SMA’s fees, billing methodology, and related terms are described in the SMA manager’s Form ADV brochure and program documents, which the client should review carefully. SMA fees are generally assessed only on the assets allocated to the SMA account and are charged by the SMA manager (or sponsor) pursuant to its documents. SMA fees may be deducted directly from the SMA account at the Custodian or billed as described in the SMA disclosures. Clients should consider the SMA’s fees together with JWM’s fees to understand the overall cost of the arrangement. Third-Party Cash Management Service Fees If a client uses Flourish Cash for cash management, JWM does not charge an additional advisory fee solely for recommending or monitoring these accounts as part of the client’s overall planning. JWM does not receive compensation or referral fees from Flourish Cash for client use of the platform. Flourish Cash is an unaffiliated third-party platform and may impose its own fees, terms, and conditions (including minimums or other requirements), which are disclosed by Flourish prior to account opening. Clients are encouraged to review Flourish’s disclosures to understand any costs and program features. Third-Party Estate Planning Service Fees JWM may provide clients access to Wealth.com. (“Wealth”) as part of JWM’s financial planning services. JWM pays for client access to the Wealth platform and does not charge an additional advisory fee for providing access to the platform. JWM does not receive compensation or referral fees from Wealth for client use of the platform. Clients may elect optional attorney consultations or other services offered through Wealth or third parties beyond the platform’s scope, which may involve additional fees and separate terms. Clients should review Wealth’s terms and conditions and any applicable service disclosures prior to use. Other Types of Fees and Expenses JWM’s advisory fees are separate from and in addition to other fees and expenses clients may incur in connection with investing and maintaining their accounts. These may include brokerage commissions, transaction and trading costs, custody or account maintenance fees, mark-ups/mark-downs, odd-lot differentials, transfer taxes, ticket charges, wire and electronic fund transfer fees, account termination or transfer fees, and other fees or taxes assessed by custodians, broker-dealers, or other third parties. In addition, mutual funds and exchange-traded funds (“ETFs”) impose internal operating expenses (e.g., management fees and other fund expenses) that are reflected in each fund’s expense ratio and described in the fund’s prospectus or offering documents. These internal expenses reduce investment returns and are not included in JWM’s advisory fee. JWM does not receive a share of these fund-level fees. Item 12 describes factors considered in selecting or recommending custodians and broker-dealers, including considerations related to the overall reasonableness of costs and services. JWM is a fee-only advisory firm and does not accept commissions or other transaction-based compensation for the sale of securities or other investment products (including sales loads or ongoing distribution/service fees such as 12b-1 fees), except as otherwise disclosed in this brochure if applicable. Page 12 of 30  Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and therefore do not engage in side-by-side management, where an investment advisor ties compensation to a share of the capital gains or capital appreciation of the assets of the client, which carries conflicts-of-interest. Item 7: Types of Clients JWM provides investment advisory services primarily to Individuals and families, and trusts, estates, and closely held entities, and other entities on a case-by-case basis. JWM generally charges a minimum annual advisory fee for discretionary investment management services (as part of Wealth Management), who fall under our $500,000 minimum household investment. In certain circumstances, JWM may accept or continue to serve clients under different fee arrangements, including for legacy relationships or prior contractual terms. Any applicable fee terms are disclosed in the client’s Wealth Management Client Agreement and are described further in Item 5. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis JWM uses a variety of analytical methods to evaluate investments, construct portfolios, and manage risk. These methods may include asset allocation and diversification analysis (including Modern Portfolio Theory (“MPT”) concepts), fundamental analysis, technical and charting analysis, cyclical analysis, quantitative analysis, and interest rate/fixed income analysis. Asset Allocation and Diversification JWM may use asset allocation frameworks to design diversified portfolios intended to balance risk and return across asset classes and investment styles that may behave differently over time. These frameworks rely on assumptions regarding risk, correlations, and expected returns that may change, including during periods of market stress. Investment Selection and After-Tax Considerations JWM generally recommends the use of ETFs and individual securities. In evaluating investments, JWM may consider objectives and exposures, liquidity, internal expenses, tracking characteristics (if applicable), and overlap with other holdings, as well as how each investment fits within the client’s overall allocation and constraints. Where appropriate and based on information provided by the client, JWM may consider after-tax factors such as realized and unrealized gains, holding periods, asset location, and the timing of trades. Tax laws and individual circumstances vary, and JWM does not provide tax advice. Page 13 of 30  Additional Analytical Methods Depending on the strategy and circumstances, JWM may evaluate issuer and economic fundamentals, market trends and other market-based indicators, business and market cycles, systematic/data-informed models, and fixed income risks such as interest rate sensitivity, duration, credit risk, and inflation exposure. Implementation and Limitations These methods may be applied in portfolios designed to maintain an established allocation over time, portfolios that adjust allocations more materially as conditions change, or a blend of both, depending on the portfolio approach selected. Depending on the approach, some portfolios may involve more frequent trading than others. No method of analysis or strategy can eliminate investment risk or guarantee results. Use of Third-Party Research and Tools JWM may use internal research or independent third-party research, data providers, analytics, and model resources to assist in evaluating markets, investments, strategies, and portfolio positioning. JWM remains responsible for evaluating the reasonableness of third-party inputs and applying them in a manner consistent with each client’s objectives and constraints. Investment Strategies Asset Allocation Portfolios JWM may utilize Guided Allocation, Adaptive Allocation, or a combination of both (Dynamic Allocation), depending on the client’s objectives and approved Investment Policy Statement (“IPS”). Asset allocation is generally a primary driver of a portfolio’s overall risk and return characteristics over time. JWM uses asset allocation to align the portfolio to a client’s goals, risk tolerance, and time horizon, to diversify across investments that may behave differently in varying market environments, and to provide a disciplined framework for portfolio decisions. The specific approach selected, implementation guidelines, and portfolio parameters for each client are set forth in the client’s IPS and related advisory documents, including the specific risks most relevant to the client’s selected strategy and circumstances. Asset allocation involves risks and tradeoffs. Asset classes can experience extended periods of underperformance, and correlations can change—particularly during periods of market stress. An allocation that is appropriate at one point in time may become less appropriate if a client’s circumstances, objectives, liquidity needs, or risk tolerance change. Guided Allocation Portfolios Guided Allocation establishes an intended mix across asset classes (for example, stocks, bonds, and cash) based on the client’s goals, time horizon, liquidity needs, and risk tolerance. The allocation is informed in part by historical market behavior and how different asset classes have tended to move together or differently (correlation) across a variety of market environments. How It Is Managed Once established, the portfolio is generally managed to remain aligned with the intended mix through ongoing monitoring and periodic rebalancing (adjusting holdings to bring the portfolio back toward targets when market movements cause meaningful deviations). Depending on the client’s circumstances, Page 14 of 30  implementation may also consider tax-aware trading and the management of legacy holdings where immediate changes may be impractical or tax-inefficient. Key Risks and Considerations Guided Allocation does not seek to avoid market declines. The portfolio may experience meaningful drawdowns (periods of decline) during adverse markets, including significant stock market declines, rising rate environments, or periods of economic stress. Diversification may reduce the impact of losses from any single holding or asset class, but it does not eliminate loss, and diversification may be less effective during market stress when correlations rise, and multiple asset classes decline at the same time. A target allocation approach may also experience periods of underperformance versus more concentrated allocations or more dynamic approaches in certain environments. Rebalancing can reduce exposure to asset classes that continue to outperform and increase exposure to asset classes that continue to underperform, which may reduce returns during persistent trends. Inflation, interest rate changes, and changes in credit conditions can also negatively affect returns, including in fixed income allocations. The specific allocation targets, rebalancing guidelines, and strategy-related risks are established with the client and documented in the client’s Investment Policy Statement (“IPS”) and related advisory documents. Adaptive Allocation Portfolios Adaptive Allocation is designed to adjust portfolio exposures more meaningfully over time as market and economic conditions change. Rather than remaining primarily anchored to a single static target mix, this approach generally uses a structured, data-informed process to guide allocation changes, which may incorporate indicators and models based on market behavior (e.g., price trends or “technical” signals), economic conditions (“fundamental” inputs), business-cycle considerations (“cyclical” analysis), and quantitative measures (systematic, data-driven factors). How It Is Managed Adaptive Allocation is typically implemented within agreed client guidelines. An upper range for exposure to higher-risk assets (such as stocks) is generally established based on the client’s objectives and risk tolerance, while exposure may be reduced materially during certain market environments. In some periods, the portfolio may become more defensive by shifting a portion—or in some cases, all of the portfolio allocation toward lower-risk asset classes or cash and cash equivalents, and may later increase exposure again as conditions improve. The intent is to remain flexible and responsive within the client’s agreed parameters, rather than relying solely on a static mix. Key Risks and Considerations There is no assurance that the indicators, models, or decisions used will perform as intended in all market conditions. Allocation changes may occur too early, too late, or not at all, and the approach may underperform more stable allocations during extended rising markets or rapid recoveries. Adaptive Allocation may also differ materially from broad market benchmarks (e.g., S&P500) and may experience periods of relative underperformance even when it is working as designed. Because the approach may involve more frequent changes, it can increase turnover of securities and transaction costs, potentially increasing realized taxable gains in taxable accounts. The specific Adaptive Page 15 of 30  strategy selected, its guidelines (including any ranges or limits), and the strategy-related risks are documented in the client’s Investment Policy Statement (“IPS”) and related advisory documents. Dynamic Allocation Dynamic Allocation combines elements of both Guided and Adaptive approaches. In general, it maintains a diversified core intended to provide long-term discipline, while also allowing a defined portion of the portfolio to be adjusted more actively when appropriate. How It Is Managed This structure may be used when a client’s circumstances suggest a benefit from maintaining a steady framework while also incorporating flexibility to adjust certain exposures as conditions change. The allocation between the more static foundation and the more adaptive components may vary by client and may change over time based on the client’s circumstances and agreed guidelines. Key Risks and Considerations Dynamic Allocation is intended to blend the benefits of diversification and consistency with the ability to make meaningful adjustments over time. Because it combines approaches, it may add complexity and can reflect the risks of both Guided and Adaptive elements. Results may differ materially from either approach used on a standalone basis, and the allocation between components can significantly affect outcomes. Depending on implementation, it may increase portfolio turnover, trading costs, and taxable activity compared to a purely Guided Allocation approach. The specific design, allocation ranges, implementation guidelines, and related risks are established with the client and documented in the client’s Investment Policy Statement (“IPS”) and related advisory documents. Portfolio Implementation and Investment Vehicles JWM selects investments and builds portfolios to fit each client’s goals, comfort with risk, time horizon, cash needs, tax situation, and any written restrictions. Portfolios may be implemented using exchange-traded funds (“ETFs”), individual securities, third-party managers (including separately managed accounts or “SMAs”), or a combination. The mix used for a particular client depends on the type of exposure being sought, the account type, liquidity needs, costs and expenses, tax considerations, existing (“legacy”) holdings, and the client’s preferences and restrictions. ETFs are often used to gain broad, diversified exposure to a market or asset class in a cost-efficient and transparent way. Individual securities may be used when more customization is needed, such as managing a large position, addressing legacy holdings, and/or managing taxes (including managing gains). In some cases, JWM may recommend a third-party manager when specialized expertise, a specific investment approach, or certain implementation capabilities are needed, or when a third-party strategy may fit alongside the client’s overall portfolio plan. When third-party managers are used, JWM monitors the relationship, but does not control the manager’s day-to-day investment decisions. All implementation choices involve tradeoffs. Diversified portfolios can still lose value and experience meaningful declines. Approaches that involve more selection decisions—such as choosing individual securities, choosing third-party managers, or making larger allocation changes over time—may not improve results and may underperform broader market approaches. Some strategies may also increase costs, trading, complexity, and tax impacts depending on how they are implemented and the type of account. Page 16 of 30  Additional Investment Strategies When appropriate, JWM may recommend holding a basket of individual stocks instead of, or alongside, a fund. A basket may be designed to represent a broad market (such as large U.S. companies) or a narrower segment (such as a particular industry or group of companies). This approach may be used to increase customization or improve tax management, such as capturing losses for tax purposes or managing large, long-held positions over time. A basket-of-stocks approach may involve more complexity and more trading than a fund-based approach and may perform differently than a broad market index. It may also create differences in results depending on which stocks are included, how the basket is maintained, and the timing of trades. Other Factors to Consider In selecting and monitoring investments, JWM considers multiple factors, including what the investment holds, how it fits with the overall portfolio, how easy it is to buy or sell, the costs built into the investment, the trading costs associated with owning it, tax considerations, and whether it creates too much exposure to any one area. These factors may or may not result in selecting the lowest-cost option available; however, JWM seeks to keep overall costs reasonable in light of the client’s objectives and the services provided. Client accounts may also include investments selected before working with JWM (for example, holdings recommended by a prior advisor) or investments available inside employer retirement plans or other accounts that are managed but not held at the primary custodian (“held-away” accounts). Certain legacy holdings may be maintained, in whole or in part, due to taxes or other constraints. For these reasons, Item 8 continues below discussing risks for investment types that may be present in client accounts even if not typically recommended for new purchases. Risk of Loss All investing involves risk, including the possible loss of principal. No account, model, portfolio, or investment strategy is guaranteed. Market conditions and events may negatively affect portfolio value over short or extended periods, including during otherwise favorable markets. Certain portfolio approaches may incorporate risk-management techniques that include increasing or decreasing exposure to equities or other risk assets based on indicators, models, or structured decision frameworks. There is no assurance that these approaches, signals, or decisions will be correct or beneficial at any point in time. Reducing exposure to equities or other risk assets may reduce volatility, but it may also reduce return potential and may cause underperformance relative to portfolios that remain more fully invested during rising markets or rapid recoveries. Material Risks – Investment Strategies JWM’s investment strategies are designed to align with a client’s objectives and guidelines, but all strategies involve risk and may result in losses. Different approaches may perform differently across market environments. Portfolios that remain invested and diversified may experience significant declines during market declines, while portfolios that adjust exposures over time may reduce risk in some periods but can underperform during rising markets, rapid recoveries, or sudden reversals. In addition, strategy outcomes can be affected by changing market relationships, imperfect or mistimed decisions, model limitations, trading and tax impacts, liquidity conditions, and client-imposed restrictions. The specific strategy selected Page 17 of 30  for a client, and the key guidelines and risks applicable to that strategy, are documented in the client’s Investment Policy Statement (“IPS”) and related advisory documents. Market Risk There is no guarantee that investments will achieve their objectives, and clients may lose some or all of their invested capital. Investment outcomes are affected by numerous factors, including general market declines, issuer-specific developments, interest rate changes, inflation, economic and geopolitical events, and changes in laws and regulations. Market risk can affect all asset classes, and correlations between asset classes may increase during periods of stress, reducing the effectiveness of diversification. Strategy Risk JWM’s investment strategies and techniques may not work as intended. A strategy that performs well in one market environment may perform poorly in another. Strategy results may also be affected by incorrect assumptions, client restrictions, implementation limitations, trading considerations, and tax considerations. Asset Allocation / Diversification Assumption Risk Approaches that rely on diversification and strategic or target allocations depend on assumptions about expected return patterns, volatility, and correlations. These assumptions may not hold, particularly during periods of market stress when assets that historically behaved differently may decline at the same time. A strategically allocated portfolio may also underperform in certain environments or may not fully adapt to changing market conditions. Model / Indicator Risk Some strategies may use models, indicators, or rules to adjust portfolio exposures over time, including raising or lowering equity exposure. Such approaches may incorporate technical/chart-based signals, cyclical measures, quantitative factors, fundamental inputs, and other market data. There is no assurance that any indicator, rule set, signal, or model will be accurate, timely, or effective in all market environments. Models may generate signals that are early, late, or incorrect and may lead to repeated allocation changes during choppy markets (“whipsaw”), reduced exposure during rallies, or increased exposure before declines. Method-of-Analysis Risk Technical/charting analysis attempts to identify patterns or trends from market data, but markets may not follow repeatable patterns and signals may fail or change over time, particularly during sudden news- driven moves or regime shifts. Cyclical analysis assumes patterns in business or market cycles that may be interrupted or altered by policy changes, shocks, geopolitical events, or structural economic changes. Quantitative strategies may perform differently than expected due to the factors used, changes from historical relationships (“regime change”), data issues, model overfitting, and implementation/execution slippage. Fundamental analysis relies on information and assumptions that may be incomplete or incorrect, and perceived value may not be recognized by markets within the expected timeframe. Trading Time Horizon, Turnover, and Tax Impact Risks Some approaches are designed to be maintained primarily over longer periods, while others may incorporate shorter-term trading or more frequent adjustments. More frequent trading can increase transaction costs and, in taxable accounts, may increase realized capital gains and reduce tax efficiency. Page 18 of 30  More frequent trading can also increase timing risk and whipsaw risk, and may be impacted by reduced liquidity and wider bid/ask spreads during periods of market stress. Opportunity Cost / Defensive Positioning Risk Strategies that reduce exposure to risk assets to manage volatility or significant portfolio declines may reduce return potential. If markets rise sharply after exposure is reduced or rebounds occur quickly, portfolios may underperform more fully invested strategies. Concentration, Company Size, and Related Equity Risks Certain strategies may focus on particular asset classes, sectors, industries, or investment types, which can increase sensitivity to adverse developments and amplify gains and losses. Securities of smaller companies may be more volatile and less liquid than large company securities and may be more sensitive to economic downturns and disruptions. Interest Rate, Inflation, and Credit Risks Bond and other fixed income investments are subject to interest rate risk; rising rates generally reduce bond prices, particularly for longer-duration securities. Fixed income performance may also be adversely affected by yield curve changes and credit spread widening. Inflation may erode purchasing power and can influence interest rates, corporate profit margins, and valuations. Credit risk reflects the possibility that an issuer’s financial condition deteriorates, is downgraded, or defaults, which can reduce value and liquidity. Liquidity and Counterparty Risks Certain securities may become difficult to buy or sell at desired prices or within desired timeframes, particularly during periods of market stress, reduced trading activity, or heightened volatility. Portfolios are also subject to counterparty risk with brokers, custodians, clearing firms, issuers, exchanges, and other agents; a counterparty failure or insolvency could result in delays or losses, including limited recovery in bankruptcy proceedings. Currency Risk Investing in foreign securities exposes clients to currency exchange rate fluctuations, which can increase or decrease returns independently of the underlying investment’s local-market performance. Currency movements may be affected by inflation differences, interest rate policy, geopolitical events, capital controls, and changes in global risk sentiment. Operational, Cybersecurity, and Legal/Regulatory Risks Errors, system failures, cybersecurity events, trade-processing issues, pricing or data issues, and other operational matters can adversely affect trading, reporting, and investment outcomes. Legislative changes, regulatory actions, or court rulings may impact the value of investments, trading costs, and tax treatment. SMA / Third-Party Manager Risk When a client utilizes a SMA or third-party manager, JWM does not control the underlying day-to-day investment decisions or the manager’s operations. A third-party manager may deviate from a stated approach, take unintended risks, underperform, experience personnel turnover, or encounter Page 19 of 30  operational and compliance issues. Using SMAs may increase total costs to the client (see Item 5), and the strategy may not perform as expected in all market environments. Illiquid Investments / Alternative Investment Risk Illiquid or alternative investments may be difficult to value or sell and may involve lockups, redemption limits, or transfer restrictions. Such investments may have limited transparency, may involve leverage or complex structures that can magnify losses, and may create more complex tax reporting and tax consequences. Material Risks - Investment Securities Apart from the general risks described above, specific investment types may present additional risks. The discussion below is not intended to be exhaustive. The securities present in a client’s accounts may include investments recommended by JWM as well as legacy holdings and investments held in employer plans or other held-away accounts that may be impractical or tax-inefficient to replace immediately. The risks most relevant to a client’s selected strategy and holdings are addressed in the Client’s IPS and related advisory documents. Common Stocks Stocks represent ownership interests in companies and are subject to market risk and company-specific risk. Stock prices may decline due to factors affecting the overall market, an issuer’s financial condition, management decisions, competitive pressures, sector/industry developments, or regulatory changes. Liquidity can vary, particularly for smaller companies, which may increase volatility and the impact of adverse news. Corporate Bonds and Other Debt Securities Debt securities are subject to interest rate risk, credit risk, liquidity risk, and valuation risk. Bond prices generally move inversely to interest rates, and longer-maturity (or longer-duration) bonds typically have greater sensitivity to rate changes. Credit deterioration, downgrades, or default can result in losses and reduced liquidity. Zero-coupon and discounted bonds can be more sensitive to interest-rate changes and price volatility. Money Market Funds and Cash Equivalents Money market funds and similar vehicles are generally designed to seek stability and liquidity, but they are not risk-free. They can be affected by interest rate changes, issuer/credit events in underlying holdings, liquidity pressures, and the risk that a fund’s share price may fall below $1.00 per share. Bank Obligations (Including Certificates of Deposit) Bank obligations such as CDs are subject to risks affecting the banking sector and the issuing institution, including interest rate exposure, regulatory changes, and issuer financial condition. Certain bank products may also involve early-withdrawal restrictions, limitations on liquidity, or other terms that affect access to funds. Municipal Bonds Municipal bonds involve many of the same risks as other bonds, including interest rate risk, credit risk, liquidity risk, call/redemption risk, and valuation risk. Municipal bonds also involve tax-related Page 20 of 30  considerations, including the risk that tax treatment changes or that an investor’s after-tax return differs from expectations due to changes in law or the investor’s tax circumstances. U.S. Treasury Bonds, Notes, and Bills U.S. Treasury securities are primarily subject to interest-rate risk and inflation risk. Changes in rates and market conditions can reduce the market value of Treasuries, particularly for longer-duration holdings. Options and Other Derivatives Options and other derivatives can involve significant risks, including leverage, pricing complexity, and the potential for losses that occur quickly. If covered call writing is used, option premiums may provide limited downside offset, but the underlying investment can still decline and gains may be limited if the position is called away. Exchange-Traded Funds (“ETFs”) ETFs are subject to market risk and may not track their benchmarks as expected. ETF shares may trade at prices above or below net asset value, and trading may be halted due to market conditions, exchange actions, or market-wide circuit breakers. The overall risk of an ETF depends on the ETF’s underlying holdings and techniques, which may include concentration, derivatives, leverage, or less-liquid instruments, depending on the ETF. Mutual Funds and Closed-End Funds (Legacy Holdings / Held-Away Accounts) JWM generally does not recommend mutual funds for new purchases as part of its core implementation; however, clients may hold mutual funds within employer retirement plans (e.g., 401(k) accounts) where mutual funds are a primary investment option, and certain clients may also hold legacy mutual funds in taxable accounts that are maintained, in whole or in part, due to tax considerations. Mutual funds and closed-end funds are subject to the risks of their underlying holdings, as well as fund-level risks such as expenses, liquidity constraints, operational considerations, and, for closed-end funds, the possibility of trading at a premium or discount to net asset value. In some cases, fund features (share class limitations, redemption policies, trading windows, or plan constraints) may restrict the ability to implement changes quickly or efficiently. Cryptocurrency Exposure Through ETFs If a client gains cryptocurrency exposure through an exchange-traded product (such as an ETF), the investment may be subject to substantial volatility and rapid price changes. Crypto-related products may also involve evolving regulation, market integrity concerns, custody and operational risks, tracking and pricing risk, liquidity constraints, and technology risks unique to digital assets and related infrastructure. Trading halts and large price gaps may occur during periods of market stress. Illiquid and Alternative Investments (Including Private Placements, SDIRAs, Non-Traded REITs, and Commodities/Precious Metals) Certain clients may hold illiquid or alternative investments, which may include private placements in self-directed IRAs, non-traded REITs or real estate vehicles, private credit or private equity, commodity or precious metal exposures (including gold-related investments), and other non-traditional holdings. These investments may be difficult to value, may have limited transparency or limited benchmarks, and may involve lockups, redemption limits, transfer restrictions, or other constraints that limit the ability to sell or reposition holdings. Some alternatives involve leverage or complex structures that can magnify losses, and tax reporting and tax consequences may be more complex than for traditional securities. Page 21 of 30  Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of JWM or the integrity of JWM’s management. JWM and its management persons have not been involved in any legal or disciplinary events that are material to such an evaluation. Item 10: Other Financial Industry Activities and Affiliations JWM is a fee-only advisory firm and receives compensation solely from advisory fees paid by clients. JWM does not sell insurance and is not a broker-dealer and is not affiliated with a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. From time to time, JWM may recommend or facilitate the use of unaffiliated third-party service providers or platforms (for example, custodians, third-party investment managers/SMAs, and financial planning or cash management technology providers). JWM does not receive commissions or transaction-based compensation in connection with such recommendations, and any referral compensation or other material conflicts of interest would be disclosed to clients as required. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have 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 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. Code of Ethics This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined below. Integrity Associated persons shall offer and provide professional services with integrity. Page 22 of 30  Objectivity Associated persons shall be objective in providing professional services to Clients. Competence Associated 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 Associated 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 Associated 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 Associated persons' conduct in all matters shall reflect the credit of the profession. Diligence Associated 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. Participation or Interest in Client Transactions and Personal Trading Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest JWM and its related persons seek to avoid recommending to a client, or effect a transaction for a client, involving any security in which JWM or a related person has a material financial interest (for example, as an underwriter, advisor to an issuer, or in another capacity that would create a material conflict), except as may be disclosed to the client and permitted by applicable law. Advisory Firm and Related-Person Trading in Securities Also Recommended to Clients JWM and its related persons may buy or sell securities that are also purchased, sold, or recommended for client accounts. This creates the potential for conflicts of interest. JWM maintains policies and procedures designed to address these conflicts, which may include restricting or prohibiting personal transactions in certain reportable securities, requiring pre-clearance for certain trades, and maintaining records of personal securities transactions as required by applicable regulations and the firm’s Code of Ethics. JWM’s policies are intended to prevent trading that disadvantages clients, including “front running,” which refers to trading by JWM or a related person ahead of client transactions in order to benefit from anticipated price movements. Page 23 of 30  Trading at or Around the Same Time as Client Transactions From time to time, JWM or its related persons may buy or sell securities for their own accounts at or around the same time as transactions are executed for client accounts. Such trading could create a conflict of interest if a related person were to benefit from client trading activity or recommendations. JWM’s Code of Ethics and related policies are designed to mitigate these conflicts, including prohibiting trading intended to take advantage of client transactions and requiring oversight of personal trading activity. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers JWM does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to the client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. Research and Other Soft-Dollar Benefits JWM receives economic “soft dollar” benefits as a result of our relationship with Charles Schwab since we do not have to produce or pay for the research, products or services and we may have an incentive to select or recommend Charles Schwab’s services based on our interest in receiving research or other products or services, rather than on our clients’ interest in receiving most favorable execution. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use We generally require clients engaging in Wealth Management to utilize Charles Schwab as their custodian. The Custodian and Brokers We Use (Charles Schwab & Co., Inc.) The custodian and brokers we use maintain custody of your assets that we manage, although we may be deemed to have limited custody of your assets due to our ability to withdraw fees from your account (see Item 15 – Custody, below). We generally recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”) Page 24 of 30  How We Select Brokers/Custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are overall most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: ■ 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 ■ Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) 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. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. Products and Services Available to Us From Schwab Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms like JWM. They provide JWM’s clients and JWM 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 clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (JWM does not have to request them) and at no charge to JWM. Following is a more detailed description of Schwab’s support services: Services That Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You Page 25 of 30  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 to: ■ Provide access to client account data (such as duplicate trade confirmations and account statements) ■ Facilitate trade execution and allocate aggregated trade orders for multiple client accounts ■ Provide pricing and other market data ■ Facilitate payment of our fees from our clients’ accounts ■ Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us Schwab also offers other services intended to help JWM manage and further develop its 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 do not require that you maintain your account with Schwab, based on JWM’s interest in receiving Schwab’s services that benefit JWM’s business and Schwab’s payment for services for which JWM would otherwise have to pay rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. JWM believes, however, that the selection of Schwab as custodian and broker is in the best interests of JWM’s clients. JWM’s selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only JWM. Aggregating (Block) Trading For Multiple Client Accounts Generally, JWM combines multiple orders for shares of the same securities purchased for advisory accounts JWM manages (this practice is commonly referred to as “block trading”). JWM will then distribute a portion of the shares to participating accounts based on the appropriate allocation for each client account. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Accounts owned by the firm or persons associated with the firm may participate in block trading with your accounts; however, they will not be given preferential treatment. There may be transaction fees for ETFs and individual stocks. Directed Brokerage While JWM generally requires clients to utilize Charles Schwab & Co., Inc. as their qualified custodian, JWM may, in its sole discretion, permit clients to direct brokerage to a different custodian or broker-dealer. In such "directed brokerage" arrangements, the client negotiates terms and arrangements for their account directly with that broker-dealer. Page 26 of 30  Clients who direct brokerage should understand that JWM will not be able to negotiate commissions or transaction costs, seek better execution services or prices from other broker-dealers, or "batch" the client's transactions for execution with orders for other accounts managed by JWM. As a result, clients directing brokerage may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if JWM selected the broker-dealer. Item 13: Review of Accounts Stefan Jackson, Founder and Chief Compliance Officer (“CCO”) of JWM, works with clients to obtain and maintain current information regarding their financial circumstances, assets, and investment holdings and reviews this information as part of JWM’s wealth management services. Financial plans may be reviewed and updated as appropriate based on the client’s circumstances, the scope of the engagement, and information provided by the client. Client accounts for which JWM provides ongoing investment management services are reviewed on a regular and ongoing basis by the firm’s responsible advisor(s) (including the Founder/CCO), with the frequency and depth of review varying based on factors such as the client’s objectives, portfolio complexity, holdings, market conditions, tax considerations, and any client-imposed restrictions. Accounts are reviewed with regard to each client’s investment policies and risk tolerance levels, as reflected in the client’s Investment Policy Statement (“IPS”) and advisory documentation. Certain events may prompt an additional review, including but not limited to: significant changes in market conditions or portfolio performance, material changes in a client’s financial situation or objectives, additions or deletions of client-imposed restrictions, excessive drawdown or increased volatility, significant cash flows, changes in holdings or asset allocation, and buy/sell decisions based on the strategy in use or the client’s needs. JWM communicates with clients throughout the relationship and schedules review meetings as appropriate based on the client’s preferences and circumstances. Clients receive trade confirmations for transactions in their accounts and receive account statements and tax reporting documents directly from their qualified custodian(s). JWM encourages clients to review and compare any reports or information provided by JWM with the account statements and confirmations provided by the custodian(s), which serve as the official record of account activity. JWM may also provides Wealth Management clients online access to certain financial information through a client portal. Reports and materials may be made available through the portal and/or delivered electronically, and the type and frequency of reporting may vary based on the client relationship and services provided. Item 14: Client Referrals and Other Compensation Our Custodian JWM receives an economic benefit from Charles Schwab & Co., Inc. (“Schwab”) in the form of support products and services made available to us (for example, practice management, technology, reporting, and related support). These benefits create a conflict of interest because they may influence JWM’s selection or Page 27 of 30  continued recommendation of Schwab as custodian. Schwab’s support is not contingent upon JWM providing any particular investment advice or directing any specific trades. The nature of these benefits and the related conflicts are described in Item 12 (Brokerage Practices). Other than these benefits, JWM does not receive commissions, sales compensation, or other transaction- based compensation in connection with the advisory services we provide to clients. Third-Party Cash Management Services JWM may make available access to Flourish Cash, an unaffiliated cash management platform. JWM does not receive referral fees, revenue sharing, or other non-advisory compensation from Flourish Cash in connection with client use of the platform. Clients are under no obligation to use Flourish Cash and may select alternative cash management solutions. Third-Party Estate Planning Services As part of our financial planning services, JWM may provide clients access to Wealth.com (“Wealth”), an unaffiliated technology platform that facilitates the preparation and organization of certain estate planning documents. JWM does not receive referral fees, revenue sharing, or other non-advisory compensation from Wealth in connection with client use of the platform. Clients are not obligated to use Wealth and may select alternative estate planning providers or work directly with an attorney. Third-Party Advertisements & Lead Generations JWM does not compensate any person or company for client referrals, leads, testimonials, or endorsements, and does not currently use paid lead-generation services or compensated promoters. If JWM engages in such arrangements in the future, this brochure will be updated and any required disclosures will be provided to clients. Item 15: Custody JWM does not accept custody of client funds or securities except to the extent that we are authorized to deduct advisory fees from client accounts. For client accounts in which JWM directly debits their advisory fee: • The custodian will send at least quarterly statements to the client showing all disbursements for the account, including the amount of the advisory fee. • The client will provide written authorization to JWM, permitting them to be paid directly for their accounts held by the custodian. Clients should receive account statements, at least quarterly, from the qualified custodian that holds and maintains the client’s investment assets. JWM urges clients to carefully review such statements and compare such official custodial records to any invoices and reports that JWM may provide, and to promptly notify JWM of any discrepancies. JWM’s invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Page 28 of 30  Third-Party Cash Management Services Cash held through Flourish Cash is maintained at third-party banks or financial institutions made available through Flourish, and not with JWM. JWM does not take custody of funds held in Flourish Cash accounts. To the extent permitted by the platform and authorized by the client, JWM may have view-only access for reporting or planning purposes and may provide advisory guidance regarding cash allocation; however, clients retain direct ownership and control over their Flourish Cash accounts.Held-Away Accounts In certain circumstances, JWM may be granted discretionary authority to implement investment allocation changes in held-away accounts (such as employer-sponsored retirement plan accounts) through a third-party platform. Under this arrangement, JWM does not obtain or use client login credentials and does not have authority to withdraw, transfer, or otherwise take possession of client funds or securities from the held-away account. The client maintains ownership and control of the held-away account, including the ability to change access permissions or terminate JWM’s authority at any time subject to the account provider’s procedures. Because held-away accounts typically cannot be debited directly for advisory fees, JWM’s advisory fees (if applicable) are generally deducted from the client’s account(s) held with the qualified custodian as authorized in the advisory agreement. Item 16: Investment Discretion For client accounts where JWM provides Wealth Management and investment management services on a discretionary basis, clients grant JWM limited discretionary authority to determine which securities are bought and sold and the amount of securities bought and sold within the account, consistent with the client’s Investment Policy Statement (“IPS”) and any written client-imposed restrictions. Investment discretion and the scope of JWM’s authority are explained to clients at the commencement of the advisory relationship. Clients authorize JWM’s discretion by executing the custodian’s Limited Power of Attorney (“LPOA”) and/or other required trading authorization forms, as applicable. The discretionary relationship and fee arrangement are also described in the client’s Wealth Management Client Agreement, which is executed by the client. Item 17: Voting Client Securities JWM does not vote client proxies. Therefore, clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the client’s investment assets. The client shall instruct the client’s qualified custodian to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. If the client has any questions on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, clients will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Page 29 of 30  In addition to not voting proxies, JWM does not advise or act on behalf of clients in any legal proceedings involving companies whose securities are held, or were previously held, in the client's account(s). This includes, but is not limited to, the filing of “Proofs of Claim” in class action settlements or participating in bankruptcy proceedings. Clients retain sole responsibility for evaluating and participating in any such legal actions or class action settlements. If requested, JWM will make commercially reasonable efforts to forward any class action notices received by the firm directly to the client. Item 18: Financial Information Registered investment advisers are required to disclose certain financial information in this Item. JWM has not been the subject of a bankruptcy petition during the past ten years. JWM does not require or solicit prepayment of more than $1200 in fees per client, six months or more in advance. Because JWM has discretionary authority to deduct advisory fees and/or manage client accounts, JWM is required to disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. JWM has no such financial condition. Page 30 of 30