ADC WEALTH MANAGEMENT, LLC

ADC Wealth Management, LLC Firm Brochure This brochure provides information about the qualifications and business practices of ADC Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (516) 308-7514 or by email at: Douglas@ADCWealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about ADC Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. ADC Wealth Management, LLC’s CRD number is: 159083. 30 D Broadway, Suite 200 Massapequa, NY 11758 (516) 308-7514 (516) 308-7517 - Fax douglas@adcwealth.com www.adcwealth.com Registration does not imply a certain level of skill or training. Version Date: 02/17/2026  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of ADC Wealth Management, LLC on 01/22/2025 are described below. Material changes relate to ADC Wealth Management, LLC’s policies, practices or conflicts of interests. • ADC Wealth Management, LLC has updated its assets under management. (Item 4.E) • ADC Wealth Management LLC no longer receives soft dollar benefits. (Item 12.A) i  Item 3: Table of Contents Item 2: Material Changes ........................................................................................................................................ i Item 3: Table of Contents ....................................................................................................................................... ii Item 4: Advisory Business ......................................................................................................................................1 A. Description of the Advisory Firm ................................................................................................................1 B. Types of Advisory Services ...........................................................................................................................1 Investment Supervisory Services ..................................................................................................................1 Financial Planning ...........................................................................................................................................1 Services Limited to Specific Types of Investments .....................................................................................1 C. Client Tailored Services and Client Imposed Restrictions ........................................................................2 D. Wrap Fee Programs ........................................................................................................................................2 E. Amounts Under Management ......................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................3 A. Fee Schedule ....................................................................................................................................................3 Investment Supervisory Services Fees ..........................................................................................................3 Financial Planning Fees ..................................................................................................................................3 B. Payment of Fees ...............................................................................................................................................4 Payment of Investment Supervisory Fees ....................................................................................................4 Payment of Financial Planning Fees .............................................................................................................4 C. Clients Are Responsible For Third Party Fees ............................................................................................4 D. Prepayment of Fees ........................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients .....................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................4 Item 7: Types of Clients ..........................................................................................................................................5 Minimum Account Size ..................................................................................................................................5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .......................................5 A. Methods of Analysis and Investment Strategies ..................................................................................5 Methods of Analysis ........................................................................................................................................5 Charting analysis .............................................................................................................................................5 Fundamental analysis .....................................................................................................................................5 ii  Technical analysis ............................................................................................................................................5 Cyclical analysis ...............................................................................................................................................5 Investment Strategies ......................................................................................................................................5 B. Material Risks Involved ...........................................................................................................................6 Methods of Analysis ........................................................................................................................................6 Charting analysis .............................................................................................................................................6 Fundamental analysis .....................................................................................................................................6 Technical analysis ............................................................................................................................................6 Cyclical analysis ...............................................................................................................................................6 Investment Strategies ......................................................................................................................................6 C. Risks of Specific Securities Utilized ........................................................................................................6 Item 9: Disciplinary Information ...........................................................................................................................7 A. Criminal or Civil Actions .........................................................................................................................7 B. Administrative Proceedings ....................................................................................................................7 C. Self-regulatory Organization (SR) Proceedings ....................................................................................8 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................8 A. Registration as a Broker/Dealer or Broker/Dealer Representative ..................................................8 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ..................................................................................................................................................8 Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests .................................................................................................................................................................8 D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ..............................................................................................................................................................8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................8 A. Code of Ethics ............................................................................................................................................8 B. Recommendations Involving Material Financial Interests .................................................................9 C. Investing Personal Money in the Same Securities as Clients ..............................................................9 D. Trading Securities At/Around the Same Time as Clients’ Securities ...............................................9 Item 12: Brokerage Practices ..................................................................................................................................9 A. Factors Used to Select Custodians and/or Broker/Dealers................................................................9 1. Research and Other Soft-Dollar Benefits ............................................................................................9 2. Brokerage for Client Referrals .............................................................................................................9 iii  3. Clients Directing Which Broker/Dealer/Custodian to Use ..........................................................10 B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................10 Item 13: Reviews of Accounts ..............................................................................................................................10 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..............................10 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................10 C. Content and Frequency of Regular Reports Provided to Clients .....................................................10 Item 14: Client Referrals and Other Compensation ..........................................................................................11 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ...................................................................................................................................11 B. Compensation to Non – Advisory Personnel for Client Referrals ...................................................11 Item 15: Custody ....................................................................................................................................................11 Item 16: Investment Discretion ............................................................................................................................11 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................11 Item 18: Financial Information .............................................................................................................................12 A. Balance Sheet ...........................................................................................................................................12 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................................................................................................................................................................12 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................12 iv  Item 4: Advisory Business A. Description of the Advisory Firm ADC Wealth Management, LLC is a Limited Liability Company organized in the state of New York. This firm has been in business since September 2011, and the principal owner is Douglas Castro. B. Types of Advisory Services ADC Wealth Management, LLC (hereinafter “ADC”) offers the following services to advisory clients: Investment Supervisory Services ADC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ADC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring ADC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Services Limited to Specific Types of Investments ADC generally limits its money management to mutual funds, equities, bonds, fixed income, ETFs, REITs, and government securities. ADC may use other securities as well to help diversify a portfolio when applicable. 1  Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions ADC offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ADC from properly servicing the client account, or if the restrictions would require ADC to deviate from its standard suite of services, ADC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. ADC DOES NOT participate in any wrap fee programs. E. Amounts Under Management ADC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 $ 206,122,106.00 December 2025 2  Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees Equities Accounts: Total Assets Under Management Annual Fee All Assets 1.25% Fixed Income Accounts: Total Assets Under Management Annual Fee All Assets 1.25% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid quarterly in advance, and clients may terminate their contracts with thirty days’ written notice. Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination. Fees that are collected in advance will be refunded based on the prorated amount of work completed up to the day of termination within the quarter terminated. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Financial Planning Fees Fixed Fees The rate for creating client financial plans is $3,000. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. 3  B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance. Payment of Financial Planning Fees Fixed Financial Planning fees are withdrawn directly from client account with client written authorization. Fees are paid quarterly in advance. C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by ADC. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees ADC collects fees in advance. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Fees will be deposited back into client’s account within fourteen days. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). E. Outside Compensation For the Sale of Securities to Clients Neither ADC nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management ADC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 4  Item 7: Types of Clients ADC generally provides management supervisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit Sharing Plans Minimum Account Size There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis ADC’s methods of analysis include charting analysis, fundamental analysis, technical analysis, and cyclical analysis. Charting analysis involves the use of patterns in performance charts. ADC uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies ADC uses long term trading, short term trading, and options writing (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 5  B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in solely using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying to take advantage of. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short term trading and options writing generally hold greater risk and clients should be aware that there is a material risk of loss using any of those strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized ADC generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, it will utilize options writing. Options writing generally hold greater risk of capital loss and clients should be aware that there is a material risk of loss using this strategy. Mutual Funds: Investing in mutual funds carries the risk of capital loss. Mutual funds are not guaranteed or insured by the FDIC or any other government agency. You can lose 6  money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss. Fixed Income is an investment that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these securities are not guaranteed or insured by the FDIC or any other government agency. REITs have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability and inflation. Options writing involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. 7  C. Self-regulatory Organization (SR) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither ADC nor its representatives are registered as or have pending applications to become a broker/dealer or as representatives of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither ADC nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither ADC nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ADC does not utilize nor select other advisors or third-party managers. All assets are managed by ADC management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. 8  B. Recommendations Involving Material Financial Interests ADC does not recommend that clients buy or sell any security in which a related person to ADC or ADC has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of ADC may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of ADC to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. ADC will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of ADC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of ADC to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. ADC will always transact client’s transactions before its own when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers The custodians, Axos Advisor Services (CRD# 117176) and Interactive Brokers (CRD# 36418) where chosen based on their relatively low transaction fees and access to mutual funds and ETFs. ADC will never charge a premium or commission on transactions, beyond the actual cost imposed by the custodian. 1. Research and Other Soft-Dollar Benefits ADC receives no research, product, or services other than execution from a broker- dealer or third-party in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals ADC receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 9  3. Clients Directing Which Broker/Dealer/Custodian to Use ADC allows clients to direct brokerage. ADC may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage ADC may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers require their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts ADC maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing ADC the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least monthly only by Douglas Castro, Managing Member. Douglas Castro is the chief advisor and is instructed to review clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at ADC are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly from the custodian, a written report that details the client’s account including assets held and asset value which will come from the custodian. 10  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ADC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to ADC clients. B. Compensation to Non – Advisory Personnel for Client Referrals ADC does not compensate non-advisory personnel (solicitors/promoters) for client referrals. Item 15: Custody ADC, with client written authority, has limited custody of client’s assets through direct fee deduction of ADC’s Fees only. If the client chooses to be billed directly by Axos Advisor Services (CRD# 117176) and Interactive Brokers (CRD# 36418), ADC will have constructive custody over that account and must have written authorization from the client to do so. Clients will receive all required account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients will receive statements from the custodian. ADC urges clients to compare the account statements they received from custodian with those they received from ADC. ADC does not provide account statements to clients in addition to those provided by the custodian. Item 16: Investment Discretion ADC provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, ADC generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. Item 17: Voting Client Securities (Proxy Voting) ADC will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 11  Item 18: Financial Information A. Balance Sheet ADC does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ADC nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years ADC has not been the subject of a bankruptcy petition in the last ten years. 12