Overview

Assets Under Management: $881 million
Headquarters: WICHITA, KS
High-Net-Worth Clients: 208
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADAMSBROWN DISCLOSURE BROCHURE AND PRIVACY POLICY)

MinMaxMarginal Fee Rate
$0 and above 1.52%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,250 1.52%
$5 million $76,250 1.52%
$10 million $152,500 1.52%
$50 million $762,500 1.52%
$100 million $1,525,000 1.52%

Clients

Number of High-Net-Worth Clients: 208
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 51.80
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 3,991
Discretionary Accounts: 3,837
Non-Discretionary Accounts: 154

Regulatory Filings

CRD Number: 308410
Filing ID: 1995499
Last Filing Date: 2025-06-03 15:04:00
Website: https://adamsbrowncpa.com

Form ADV Documents

Primary Brochure: ADAMSBROWN DISCLOSURE BROCHURE AND PRIVACY POLICY (2025-10-02)

View Document Text
AdamsBrown Wealth Consultants, LLC Form ADV Part 2A – Disclosure Brochure Effective: October 2, 2025 This Form ADV Part 2A ("Disclosure Brochure") provides information about the qualifications and business practices of AdamsBrown Wealth Consultants, LLC ("AdamsBrown" or the "Advisor"). If you have any questions about the contents of this Disclosure Brochure, please contact the Advisor at (316) 683-2067. AdamsBrown is a registered investment advisor with U.S. Securities and Exchange Commission ("SEC"). The information in this Disclosure Brochure has not been approved or verified by the SEC 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 AdamsBrown to assist you in determining whether to retain the Advisor. Additional information about AdamsBrown and its Advisory Persons is available on the SEC's website at www.adviserinfo.sec.gov by searching with the Advisor's firm name or CRD# 308410. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com 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 AdamsBrown, which is provided as a separate document to this Disclosure Brochure. AdamsBrown believes that communication and transparency are the foundation of its relationship with Clients and will continually strive to provide its Clients with complete and accurate information at all times. AdamsBrown encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions they may have with the Advisor. And, of course, the Advisor always welcomes your feedback. Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on March 6, 2025: • The Advisor has amended Items 4 and 15 to disclose that they will maintain real custody in certain instances. • The Advisor has amended Item 10 to disclose a relationship with an affiliated trust company. • The Advisor has amended Item 10 to disclose that in certain instances they may cover fees for services provided by an affiliated entity. • The Advisor’s primary office address is 358 N Main Street, Suite 100, Wichita, KS 67202. • The Advisor offers the selection of other advisors. Please see Items 4, 5, and 14 for additional information. • The Advisor’s phone number is now (316) 683-2067. • The Advisor’s facsimile number is now (316) 683-2822. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations, and 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 online at the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 308410. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (316) 683-2067. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com 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 A. Firm Information ............................................................................................................................................ 4 B. Advisory Services Offered .............................................................................................................................. 4 C. Client Account Management .......................................................................................................................... 6 D. Wrap Fee Programs ...................................................................................................................................... 7 E. Assets Under Management ............................................................................................................................ 7 Item 5 – Fees and Compensation ............................................................................................................ 7 A. Fees for Advisory Services............................................................................................................................. 7 B. Fee Billing ..................................................................................................................................................... 8 C. Other Fees and Expenses ............................................................................................................................. 8 D. Advance Payment of Fees and Termination ................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................. 9 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................... 10 Item 7 – Types of Clients ....................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ............................................ 10 A. Methods of Analysis ..................................................................................................................................... 10 B. Risk of Loss ................................................................................................................................................. 10 Item 9 – Disciplinary Information .......................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ... 13 A. Code of Ethics ............................................................................................................................................. 13 B. Personal Trading with Material Interest ........................................................................................................ 13 C. Personal Trading in Same Securities as Clients ........................................................................................... 13 D. Personal Trading at Same Time as Client .................................................................................................... 13 Item 12 – Brokerage Practices............................................................................................................... 13 A. Recommendation of Custodian[s]................................................................................................................. 13 B. Aggregating and Allocating Trades............................................................................................................... 14 Item 13 – Review of Accounts ............................................................................................................... 14 A. Frequency of Reviews ................................................................................................................................. 14 B. Causes for Reviews ..................................................................................................................................... 15 C. Review Reports ........................................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation ............................................................................ 15 A. Compensation Received by AdamsBrown .................................................................................................... 15 B. Compensation for Client Referrals................................................................................................................ 16 Item 15 – Custody .................................................................................................................................. 16 Item 16 – Investment Discretion ............................................................................................................ 16 Item 17 – Voting Client Securities ......................................................................................................... 16 Item 18 – Financial Information ............................................................................................................. 16 Privacy Policy ......................................................................................................................................... 18 AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 3 Item 4 – Advisory Services A. Firm Information AdamsBrown Wealth Consultants, LLC ("AdamsBrown" or the "Advisor") is a registered investment advisor with the U.S. Securities and Exchange Commission ("SEC"). AdamsBrown is organized as a Limited Liability Company ("LLC") under the laws of the State of Kansas in October 2019 and became a registered investment advisor in April 2020. AdamsBrown is a wholly-owned subsidiary of AdamsBrown, LLC. Justin. T. Mitchell (Principal and Managing Wealth Consultant) serves as the principal officer of the Advisor. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by AdamsBrown. For information regarding this Disclosure Brochure, please contact Brenda Bickle (Chief Compliance Officer) at (785) 628-3046. B. Advisory Services Offered AdamsBrown offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses, 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. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services AdamsBrown provides customized wealth management solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related financial planning services. AdamsBrown works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to design a portfolio strategy. Investment Management Services – AdamsBrown will then construct an investment portfolio consisting of exchange-traded funds ("ETFs") and/or mutual funds to achieve the Client's investment goals. The Advisor may also utilize individual stocks, bonds, other types of investments, as appropriate. The Advisor may also 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. AdamsBrown's investment strategies are 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. AdamsBrown 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. AdamsBrown evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. AdamsBrown may recommend, on occasion, redistributing investment allocations to diversify the portfolio. AdamsBrown may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against the market movement. AdamsBrown 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 position[s] in the portfolio, changes in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client's risk tolerance. Selection of Other Advisors AdamsBrown will have discretionary authority to select one or more sub-advisor(s) (individually “Sub-Advisor” and collectively “Sub-Advisors”) to manage the Account or a portion of the assets of the Account. The decision to select a Sub-Advisor is based on each client’s individual needs. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 4 When a Sub-Advisor is selected by AdamsBrown, the Sub-Advisor will have discretionary authority over Client Accounts to place trades and make changes to the Account or the portion of the Account the Sub-Advisor is authorized to manage. AdamsBrown will conduct initial and ongoing due diligence of any recommended Sub-Advisor and monitor the performance of the Sub-Advisor with respect to the Sub-Advisor’s management of the designated assets of Account relative to appropriate peers and/or benchmarks. AdamsBrown will be available to answer questions clients have regarding any portion of client’s Account managed by a Sub-Advisor and will act as the communication conduit between Client and the Sub-Advisor. The recommendation of Sub-Advisors, or other products and funds, is done on a discretionary basis with the specific terms outlined in your Advisory Agreement. When a client authorizes the Advisor to have the ability to select Sub-Advisors or other products and funds on a discretionary basis, AdamsBrown will have the authority to select and terminate Sub-Advisors, products or funds without the client’s specific approval. A complete description of the Sub-Advisor’s services, practices and fees will be disclosed in the Sub-Advisor’s Form ADV Part 2A that will be provided to client. 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 earns a new (or increases 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. AdamsBrown accepts custody of a Clients funds or securities, through the deduction of management fees from the Client’s account[s] at the Custodian, and in certain situations due to common Clients between the Advisor and an affiliated trust company. Financial Planning Services – AdamsBrown will typically provide a variety of financial planning and consulting services to Clients. Financial planning services are typically included in an overall wealth management engagement. Services are offered in several areas of a Client's financial situation, depending on their goals, objectives, and financial circumstance. 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, insurance needs, 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. AdamsBrown 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 written 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 (6) months of the contract date, assuming all information and documents requested are provided promptly. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 5 Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated 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 is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services AdamsBrown provides 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 Oversight Services (ERISA 3(21)) Investment Management Services (ERISA 3(38)) ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● ● ● ● Performance Reporting ● Ongoing Investment Recommendation and Assistance ● ERISA 404(c) Assistance These services are provided by AdamsBrown 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 AdamsBrown's fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Retirement Plan Consulting Services AdamsBrown provides retirement plan consulting services on behalf of the retirement plans (each a "Plan") and the company (the "Plan Sponsor"). The Advisor's retirement plan consulting services are designed to assist the Plan Sponsor in meeting its needs to assist the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● Service Provider Analysis ● Plan Participant Education ● Group Enrollment Assistance ● Request for Proposal C. Client Account Management Prior to engaging AdamsBrown to provide wealth management 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 may include: • Establishing an Investment Strategy – AdamsBrown, in connection with the Client, will develop a strategy that seeks to achieve the Client's goals and objectives. • Asset Allocation – AdamsBrown will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance of risk for each Client. • Portfolio Construction – AdamsBrown will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – AdamsBrown will provide investment management and ongoing oversight of the Client's investment portfolio. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 6 D. Wrap Fee Programs AdamsBrown does not manage a wrap fee program. E. Assets Under Management As of December 31, 2024, AdamsBrown manages $880,935,144 in Client assets, $784,640,737 of which is managed on a discretionary basis and $96,294,407 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. 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. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid quarterly in advance, pursuant to the terms of the agreement. Wealth management fees are based on the market value of assets under management at the end of each quarter. Wealth management fees range from 0.50% to 1.525% annually based on several factors, including the complexity of the services to be provided, the inclusion of financial planning services, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, and other complexities may be charged a higher fee. The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client's fees will take into consideration the aggregate assets under management with the Advisor. Clients may be offered a fixed rate fee schedule or a tiered fee schedule. All securities held in accounts managed by AdamsBrown will be independently valued by the Custodian. AdamsBrown will conduct periodic reviews of the Custodian's valuations. Clients may make additions to and withdrawals from their account[s] at any time, subject to AdamsBrown's right to terminate an account. Additions may be in cash or securities provided that AdamsBrown reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client's account[s]. Clients may withdraw account assets on notice to AdamsBrown, subject to the usual and customary securities settlement procedures. However, AdamsBrown designs its portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client's investment objectives. AdamsBrown may consult with its Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge), and/or tax ramifications. Selection of Other Advisors For Clients referred to the unaffiliated investment advisor by the Advisor, the Client’s fee will be deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory fee will be provided to AdamsBrown. Please see Item 14 for additional details. Financial Planning Services AdamsBrown may offer financial planning services, as a separate engagement, on an hourly basis. Hourly fees range up to $250 per hour. Fees may be negotiable based on the on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging for these services. Financial planning fees are exclusive of and separate from the investment advisory fees above. Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual flat fee for the first $500,000 to $1,000,000, and once assets are over $1,000,000, Clients are charged an annual asset-based fee of up to 1.525% and are AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 7 billed in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are based on the market value of assets under management at the end of each quarter. Fees may be negotiable depending on the size and complexity of the Plan. Retirement Plan Consulting Services AdamsBrown offers retirement plan consulting services either on an hourly basis or for a fixed fee. Hourly fees range up to $200. Fixed engagement fees will be based upon the expected hours to complete the engagement at the hourly rate and are billed in advance. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging in these services. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client's account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client's account[s] following the end of each quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by the number of days in the year, multiplied by the number of days in the quarter) to the total assets under management with AdamsBrown at the end of the quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting the deduction of the wealth management fee. Clients provide written authorization permitting advisory fees to be deducted by AdamsBrown to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced by the Advisor with up to fifty percent (50%) of the expected total fee upon executing the financial planning agreement, and the balance shall be invoiced upon completion of the agreed-upon deliverable[s]. Retirement Plan Advisory Services Retirement plan advisory 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. Retirement Plan Consulting Services Retirement plan advisory 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. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client's account[s], including securities transaction fees, wire transfer fees, fees for trades executed away from the Custodian (if applicable), and other fees. The recommended Custodian does not charge Clients for purchases and sales of ETFs and Equity securities. Purchases and sales of mutual funds may be charged securities transaction fees by the Custodian. In addition, all fees paid to AdamsBrown for wealth management 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 will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. The Client should review both the fees charged by the fund[s] and the fees charged by AdamsBrown to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services AdamsBrown may be compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management agreement within AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 8 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. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client's wealth management agreement with the Advisor is non-transferable without the Client's prior consent. Financial Planning Services As noted above, financial planning engagements may be billed up to 50% in advance of the planning engagement. The Client may also terminate the financial planning 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. Upon termination, the Client shall be billed for actual hours logged on the planning project times the agreed upon hourly rate. The Advisor will refund any unearned, prepaid financial planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services AdamsBrown is compensated for its retirement plan advisory services at the advance of the quarter in which 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 shall be responsible for retirement plan advisory fees up to and including the effective date of termination. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the quarter. The Client's retirement plan advisory agreement with the Advisor is non-transferable without the Client's prior consent. Retirement Plan Consulting Services AdamsBrown is compensated for its retirement plan consulting services at the advance of the quarter in which services are rendered. Either party may terminate the retirement plan consulting agreement, at any time, by providing advance written notice to the other party. The Client shall be responsible for retirement plan consulting fees up to and including the effective date of termination. The Advisor will refund any unearned, prepaid retirement plan consulting fees from the effective date of termination to the end of the quarter. The Client's retirement plan consulting agreement with the Advisor is non-transferable without the Client's prior consent. E. Compensation for Sales of Securities AdamsBrown does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account other than the wealth management fees noted above. Broker-Dealer Affiliations Certain Advisory Persons are also registered representatives of Private Client Services, LLC ("PCS"), a registered broker-dealer (CRD No. 120222), member FINRA, SIPC. In one's separate capacity as a registered representative of PCS, the Advisory Person will implement securities transactions under PCS and not through AdamsBrown In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in one's capacity as a registered representative is separate and in addition to the Advisor's fees. This practice presents a conflict of interest because the Advisory Person, who is a registered representative, has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor or Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services implemented in the Advisory Person's separate capacity as a registered representative. Please see Item 10 – Other Financial Industry Activities and Affiliations. Insurance Agency Affiliations Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because the Advisory Person AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 9 has a financial incentive to recommend insurance products to the Client. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management AdamsBrown does not charge performance-based fees for its wealth management services. The fees charged by AdamsBrown are as described in Item 5 – Fees and Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client. AdamsBrown does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients AdamsBrown offers wealth management services to individuals, high net worth individuals, trusts, estates, businesses, retirement plans, and charitable organizations. AdamsBrown generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis AdamsBrown employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from AdamsBrown are 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. The fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria generally consists of 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. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that AdamsBrown will be able to predict such a reoccurrence accurately. As noted above, AdamsBrown generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. AdamsBrown 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, AdamsBrown 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. B. Risk of Loss 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. AdamsBrown will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 10 guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor's investment strategies as well as general risks of investing. 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. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor's strategies: 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. 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. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency's downgrade of the company's rating which impacts the investor's confidence in the company's ability to repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available market for the bond. 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. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 11 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). Past performance is not a guarantee of future returns. Investing in securities and other investments involves 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 AdamsBrown or its management persons. AdamsBrown values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom they partner. 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 firm name or CRD# 308410. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also registered representatives of PCS, a registered broker- dealer, member FINRA, SIPC. In one's separate capacity as a registered representative, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisory Person. Neither the Advisor nor the Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person's separate capacity as a registered representative. Insurance Agency Affiliations As noted in Item 5, Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one's role with AdamsBrown. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. The Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Persons or the Advisor. Adams Brown, LLC The Advisor is affiliated through common control and ownership with Adams Brown, LLC, a public accounting firm that provides tax, accounting, and related services. The Advisor may refer Clients to utilize the services of Adams Brown, LLC. Clients are advised that these services are separate and distinct from the advisory services offered by the Advisor and that the receipt of additional compensation by management persons poses a conflict of interest. Depending upon the relationship with each Client, the cost for certain tax preparation services provided by Adams Brown, LLC may be covered by the Advisor. Clients are not required to engage Adams Brown, LLC for accounting services in order to maintain a relationship with the Advisor. Heritage Trust Company The Advisor is affiliated through common control and ownership with Heritage Trust Company, a firm that provides trust administration, and trustee services. The Advisor may refer Clients to utilize the services of Heritage Trust Company. Clients are advised that these services are separate and distinct from the advisory services offered by the Advisor and that the receipt of additional compensation by management persons poses a conflict of interest. Clients are not required to engage Heritage Trust Company for trust services in order to maintain a relationship with the Advisor. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 12 Adams Brown Technology Specialists, LLC The Advisor is affiliated through common control and ownership with Adams Brown Technology Specialists, LLC, a technology firm that provides cybersecurity, network protection, and related services. The Advisor may refer Clients to utilize the services of Adams Brown Technology Specialists, LLC. Clients are advised that these services are separate and distinct from the advisory services offered by the Advisor and that the receipt of additional compensation by management persons poses a conflict of interest. Clients are not required to engage Adams Brown Technology Specialists, LLC for cybersecurity services in order to maintain a relationship with the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics AdamsBrown has implemented a Code of Ethics (the "Code") that defines our fiduciary commitment to each Client. This Code applies to all persons associated with AdamsBrown (our "Supervised Persons"). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. AdamsBrown and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of AdamsBrown'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 our Code, please contact us at (316) 683-2067. B. Personal Trading with Material Interest AdamsBrown allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. AdamsBrown does not act as a principal in any transactions. In addition, the Advisor does not act as the general partner of a fund or advise an investment company. AdamsBrown does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients AdamsBrown allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have 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 may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially 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 AdamsBrown requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”). We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While AdamsBrown allows our 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 afterward. At no time will AdamsBrown, or any Supervised Person of AdamsBrown, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] AdamsBrown does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize AdamsBrown to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, AdamsBrown does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-by-trade basis. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 13 Where AdamsBrown does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a Custodian not recommended by AdamsBrown. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. AdamsBrown may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian's offices. AdamsBrown will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. ("Schwab"), a FINRA-registered broker- dealer and member SIPC. Schwab will serve as the Client's "qualified custodian." AdamsBrown maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab (Please see Item 14 below.) Following are additional details regarding the brokerage practices of the Advisor: 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. AdamsBrown 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 – Client Referrals and Other Compensation. 2. Brokerage Referrals – AdamsBrown does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a "directed brokerage basis," where AdamsBrown will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage account[s]. 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]). AdamsBrown 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. B. Aggregating and Allocating Trades 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. AdamsBrown will execute its transactions through the Custodian as authorized by the Client. AdamsBrown may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer 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 Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Principals of AdamsBrown. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 14 B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client's request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client's financial situation, and/or large deposits or withdrawals in the Client's account[s]. The Client is encouraged to notify AdamsBrown 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. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage 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 brokerage 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. Item 14 – Client Referrals and Other Compensation A. Compensation Received by AdamsBrown AdamsBrown is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. AdamsBrown does not receive commissions or other compensation from product sponsors, broker- dealers, or any unrelated third party. AdamsBrown 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, AdamsBrown may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform AdamsBrown has established an institutional relationship with Schwab through its "Schwab Advisor Services" unit, a division of Schwab dedicated to serving independent advisory firms like AdamsBrown. As a registered investment advisor participating on the Schwab Advisor Services platform, AdamsBrown 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 put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. 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 the 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 support to AdamsBrown 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 AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 15 incentive for the Advisor to recommend Schwab, which results in a conflict of interest. AdamsBrown believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Selection of Other Advisors AdamsBrown may refer Clients to unaffiliated money managers, as detailed in Item 4. In such arrangements, AdamsBrown has a potential conflict of interest in that AdamsBrown will receive a portion of the unaffiliated money manager’s fee collected from the Client for the referral of the Client and the ongoing relationship management support provided by AdamsBrown. To mitigate this conflict of interest, AdamsBrown will not charge investment advisory fees on assets referred to an unaffiliated manager under such arrangements. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, Clients for whom AdamsBrown exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct AdamsBrown to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare them to any reports provided by AdamsBrown to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize AdamsBrown to move funds between their accounts, AdamsBrown and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Surprise Independent Examination - The Advisor is deemed to have custody over certain Client accounts and/or securities as part of their common control with Heritage Trust Company, pursuant to securities regulations the Advisor is required to engage an independent accounting firm to perform an annual surprise examination of those assets and accounts over which AdamsBrown maintains custody. Any related opinions issued by an independent accounting firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov). Item 16 – Investment Discretion AdamsBrown typically has 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. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by AdamsBrown. The discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by AdamsBrown will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities AdamsBrown 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 AdamsBrown nor its management have any adverse financial situations that would reasonably impair the ability of AdamsBrown to meet all obligations to its Clients. Neither AdamsBrown nor any of its Advisory Persons have been subject to a bankruptcy or financial compromise. AdamsBrown is not required to deliver a AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 16 balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 17 Privacy Policy Effective: October 2, 2025 Our Commitment to You AdamsBrown Wealth Consultants, LLC ("AdamsBrown" 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. AdamsBrown (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. AdamsBrown 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 Clients’ personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com 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 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. AdamsBrown shares Client information with Private Client Services, LLC ("PCS"). This sharing is due to the oversight PCS has over certain Supervised Persons of the Advisor. You may also contact us at any time for a copy of the PCS Privacy Policy. No Not Shared Yes Yes No Not Shared Marketing Purposes AdamsBrown 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 AdamsBrown 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 AdamsBrown 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 (316) 683-2067. AdamsBrown Wealth Consultants, LLC 358 N Main Street, Suite 100, Wichita, KS 67202 Phone: (316) 683-2067 | Fax: (316) 683-2822 www.adamsbrownwc.com Page 19