Advocacy Wealth Management, LLC

Item 1 – Cover Page Advocacy Wealth Management, LLC DISCLOSURE BROCHURE, Form ADV 2A 3455 Peachtree Road NE, Ste 1500 Atlanta, GA 30326-3280 404.836.7141 Office 866-915-8839 Fax CRD #141943 March 27, 2026 This Brochure provides information about the qualifications and business practices of Advocacy Wealth Management, LLC. If you have any questions about the contents of this Brochure, please contact us at (404) 836-7141. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Advocacy Wealth Management, LLC is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. This Brochure is intended, in part, to provide information which can be used to make a determination to hire or retain an Adviser. Additional information about Advocacy Wealth Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2 – Material Changes The parent company of Advocacy Wealth Management (“AWM”), The Forge Companies LLC (“Forge”), has received a significant growth equity investment from funds managed by TA Associates Management, L.P. (“TA”), an established private equity firm out of Boston, Massachusetts. Please see Item 10 for additional information about TA. Advocacy Wealth will provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. You can contact us at the number above or by emailing us at compliance@advocacywealth.com to request a copy of the Brochures. Our brochures are always available at the SEC’s website https://adviserinfo.sec.gov/ by searching for “Advocacy Wealth” or “Montag & Caldwell” at zip 30326. Additional information about Advocacy Wealth and Montag & Caldwell is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with Advocacy Wealth who are registered, or are required to be registered, as Investment Advisor Representatives of Advocacy Wealth. ii  Item 3 -Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 -Table of Contents ............................................................................................................................ iii Item 4 – Advisory Business ........................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................. 6 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 Item 9 – Disciplinary Information ............................................................................................................... 15 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 15 Item 11– Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 18 Item 12 – Brokerage Practices .................................................................................................................... 19 Item 13 – Review of Accounts..................................................................................................................... 22 Item 14 – Client Referrals and Other Compensation .................................................................................. 22 Item 15 – Custody ....................................................................................................................................... 23 Item 16 – Investment Discretion ................................................................................................................ 24 Item 17 – Voting Client Securities ............................................................................................................... 24 Item 18– Financial Information ................................................................................................................... 24 iii  Item 4 – Advisory Business Advocacy Wealth Management, LLC (“Advocacy Wealth”) was established and approved as a Registered Investment Adviser with the SEC in January 2007. As per the material changes described above, the Forge Companies, LLC (“Forge”) is the sole manager of Advocacy Wealth. TA Forge Aggregator indirectly controls Forge. Advocacy Wealth strives at all times to do no harm to you the client and act in your best interests at all times and without exception. (Hereafter, “you” and “your” refer to the individual client or client. “We” and “our” refer to Advocacy Wealth.) Information about Montag & Caldwell may be found in their separate Brochure, which we will provide upon request, or can be accessed as mentioned earlier at the SEC’s website https://adviserinfo.sec.gov/. As of December 31, 2025, Advocacy Wealth held $3,139,118,792 in discretionary assets and $105,775,411 in non-discretionary assets under management. Portfolio Management Advocacy Wealth offers investment advisory services to corporations, individuals, trusts, charities and estates. Advice and services are tailored to your stated objectives. Advocacy Wealth Investment Adviser Representatives (our “Financial Advisors”) work with you to identify your investment goals and objectives, as well as risk tolerance, to create an initial portfolio allocation designed to complement your financial plan. The portfolio could consist of equities, income securities, mutual funds, ETFs, options, and alternative investments. Generally, we create a limited financial plan at the least in connection with the initial portfolio allocation for an individual. In certain circumstances, we do accept restrictions on ownership or retention of certain securities by the clients themselves. We strongly advise individual clients that should your financial situation or investment goals or objectives change, you must notify Advocacy Wealth promptly of those changes. Advocacy Wealth manages the investments of trusts, which can be, though are not limited to, grantor, settlement, or testamentary in origin, on either a directed or a delegated basis. In a delegated relationship, Advocacy Wealth receives instructions from the trustee(s) for investment parameters and authority. In a directed relationship, Advocacy Wealth has full investment discretion and authority granted to it by the terms of the trust agreement. In general, trusts under management by Advocacy Wealth tend to seek asset conservation as a primary objective, income from the invested assets as a secondary objective, and growth as a tertiary objective. It is not uncommon for the priority of clients’ objectives to change over time. Until recently, persistent low levels of interest rates had required achieving secondary and tertiary objectives through total return. At the present time, the majority of Advocacy Wealth clients are recipients of a personal injury, wrongful death, or workers compensation settlements as well as their plaintiff attorneys. Many of these clients have an annuity component and a cash component to them. Advocacy Wealth manages the cash component, as well as the overall financial well-being – to the extent possible – of the individual client. Advocacy Wealth works with its affiliated entity, Forge Consulting, LLC, (a general insurance agency under the common control of Advocacy Wealth) to design a financial plan to promote financial well-being, including our clients who are not sourced from litigation. We define financial well-being as using our resources and advice to help a client find solutions for health, education, maintenance and support. Advocacy Wealth continues to monitor, modify and adjust as life situations, investment opportunities, and objectives change. 1  While the investments are being managed, the Advocacy Wealth service staff, affiliates, and outside partners can help clients buy houses and vehicles, medical equipment, find affordable insurance and other items necessary to support the client’s well-being as part of an overall financial plan. Advocacy Wealth can provide resources to help preserve governmental benefits. Advocacy Wealth does not charge an extra fee for any of these services. Financial Planning Advocacy Wealth will prepare and provide clients, upon request, a written financial plan designed to help them achieve their financial goals and investment objectives. The preparation of such a plan necessitates that the client provides Advocacy Wealth with personal data such as family records, budgeting, personal liability, estate information and additional financial goals. There is no additional charge to the client for the preparation of the financial plan if Advocacy Wealth is paid to manage the client’s investments. The financial plan can include any or all of the following upon request and/or as directed by the client: asset protection, tax planning, cash flow, insurance planning, asset allocation comparisons and risk management, long-term care and disability planning, education planning, retirement planning, estate planning and wealth transfer, charitable gifting, 401(k) plan evaluation, business succession and strategies for exercising stock options. Should a client choose to implement the recommendations contained in the financial plan, Advocacy Wealth strongly recommends that clients work closely with their attorney, accountant, insurance agent, and/or other financial advisors. Clients are not under any obligation to engage Advocacy Wealth when considering implementation of advisory plan recommendations. The client decides whether to implement any or all recommendations, which is solely at the discretion of and can be implemented through another Registered Investment Adviser. Advocacy Wealth Financial Advisors can also be licensed to sell life, health and group insurance as well as property and casualty through an affiliated insurance agency, Forge Consulting LLC. Clients are under no obligation to utilize services of associated persons in the purchase or sales of insurance products. However, if transactions are conducted through Advocacy Wealth’s affiliate, Forge Consulting LLC, then commissions and/or overrides will be earned by Forge in addition to any advisory fees charged by Advocacy Wealth. If a Trust is administered by Advocacy Trust, our affiliated Trust company will earn fees for that administration, whether Advocacy Wealth manages the investments or not. Advocacy Trust may invest available cash awaiting investment or distribution held in certain trust accounts in FDIC insured money market bank accounts. These accounts are selected by Advocacy Trust. In exchange for providing master account services to the depository institution for balances held in FDIC insured money market bank accounts, Advocacy Trust receives an interest concession from the depository institution. This interest concession is forty percent (40%) of the total interest payment, but at no time will the amount received by Advocacy Trust exceed fifty one-hundredths of one percent (0.50 of 1% = 0.005) per annum of the net assets invested in this product. From time to time, clients will ask Advocacy Wealth to design or review a financial plan for which neither Advocacy Wealth nor its affiliates will otherwise receive compensation. In such cases, Advocacy Wealth reserves the right to charge a fee commensurate with the work to be done with the approval of the client before work commences. 2  Standard of Care Advocacy Wealth has a fiduciary duty to serve its clients’ best interests before its own. Advocacy Wealth acknowledges that the investment adviser’s fiduciary duty under the Investment Advisers Act of 1940 (“Advisers Act”) comprises a duty of care and a duty of loyalty. This fiduciary duty means the adviser must, at all times, serve the best interest of its clients and not subordinate its clients’ interest to its own. The federal fiduciary duty is imposed through the antifraud provisions of the Advisers Act. The duty follows the contours of the relationship between the adviser and its client, and the adviser and its client may shape that relationship through contract when the client receives full and fair disclosure and provides informed consent. Although the ability to tailor the terms means that the application of the fiduciary duty will vary with the terms of the relationship, the relationship in all cases remains that of a fiduciary to a client. In other words, the investment adviser cannot disclose or negotiate away, and the investor cannot waive, the federal fiduciary duty. A. Duty of Care As fiduciaries, investment advisers owe their clients a duty of care. The duty of care includes, among other things: (1) the duty to act and to provide advice that is in the best interest of the client, (2) the duty to seek best execution of a client’s transactions where the adviser has the responsibility to select broker-dealers to execute client trades, and (3) the duty to provide advice and monitoring over the course of the relationship. i. Duty to Provide Advice that is in the Client’s Best Interest In this context, the duty of care includes a duty to make a reasonable inquiry into a client’s financial situation, level of financial sophistication, investment experience, and investment objectives (collectively, the client’s “investment profile”) and a duty to provide personalized advice that is suitable for and in the best interest of the client based on the client’s investment profile. An adviser must, before providing any personalized investment advice and as appropriate thereafter, make a reasonable inquiry into the client’s investment profile. The nature and extent of the inquiry turn on what is reasonable under the circumstances, including the nature and extent of the agreed-upon advisory services, the nature and complexity of the anticipated investment advice, and the investment profile of the client. For example, to formulate a comprehensive financial plan for a client, an adviser might obtain a range of personal and financial information about the client, including current income, investments, assets and debts, marital status, insurance policies, and financial goals. An adviser must update a client’s investment profile in order to adjust its advice to reflect any changed circumstances. The frequency with which the adviser must update the information in order to consider changes to any advice the adviser provides would turn on many factors, including whether the adviser is aware of events that have occurred that could render inaccurate or incomplete the investment profile on which it currently bases its advice. For example, a change in the relevant tax law or knowledge that the client has retired or experienced a change in marital status might trigger an obligation to make a new inquiry. An investment adviser must also have a reasonable belief that the personalized advice is suitable for and in the best interest of the client based on the client’s investment profile. A reasonable belief would involve 3  considering, for example, whether investments are recommended only to those clients who can and are willing to tolerate the risks of those investments and for whom the potential benefits may justify the risks. Whether the advice is in a client’s best interest must be evaluated in the context of the portfolio that the adviser manages for the client and the client’s investment profile. For example, when an adviser is advising a client with a conservative investment objective, investing in certain derivatives may be in the client’s best interest when they are used to hedge interest rate risk in the client’s portfolio, whereas investing in certain directionally speculative derivatives on their own may not. For that same client, investing in a particular security on margin may not be in the client’s best interest, even if investing in that same security may be in the client’s best interest. When advising a financially sophisticated investor with a high-risk tolerance, however, it may be consistent with the adviser’s duties to recommend investing in such directionally speculative derivatives or investing in securities on margin. The cost (including fees and compensation) associated with investment advice would generally be one of many important factors—such as the investment product’s or strategy’s investment objectives, characteristics (including any special or unusual features), liquidity, risks and potential benefits, volatility and likely performance in a variety of market and economic conditions—to consider when determining whether a security or investment strategy involving a security or securities is in the best interest of the client. Accordingly, the fiduciary duty does not necessarily require an adviser to recommend the lowest cost investment product or strategy. Advocacy Wealth will not recommend that a security is in the best interest of a client if its embedded costs, to the best of our knowledge, are higher than a security that is otherwise identical, including any special or unusual features, liquidity, risks and potential benefits, volatility and likely performance. For example, if an adviser advises its clients to invest in a mutual fund share class that is more expensive than other available options when the adviser is receiving compensation that creates a potential conflict and that may reduce the client’s return, the adviser may violate its fiduciary duty and the antifraud provisions of the Advisers Act if it does not, at a minimum, provide full and fair disclosure of the conflict and its impact on the client and obtain informed client consent to the conflict. Furthermore, an adviser would not satisfy its fiduciary duty to provide advice that is in the client’s best interest by simply advising its client to invest in the least expensive or least remunerative investment product or strategy without any further analysis of other factors in the context of the portfolio that the adviser manages for the client and the client’s investment profile. For example, it might be consistent with an adviser’s fiduciary duty to advise a client with a high risk tolerance and significant investment experience to invest in a private equity fund with relatively high fees if other factors about the fund, such as its diversification and potential performance benefits, cause it to be in the client’s best interest. Investment advice that is in the best interest of a client also requires that an adviser conduct a reasonable investigation into the investment sufficient to not base its advice on materially inaccurate or incomplete information. This obligation to provide advice that is suitable and in the best interest applies not just to potential investments, but to all advice the investment adviser provides to clients, including advice about an investment strategy or engaging a sub-adviser and advice about whether to rollover a retirement account so that the investment adviser manages that account. ii. Duty to Seek Best Execution An investment adviser’s duty of care in the context of trade execution where the adviser has the responsibility to select broker-dealers to execute client trades (typically in the case of discretionary accounts) has to seek best execution of a client’s transactions. In meeting this obligation, an adviser must 4  seek to obtain the execution of transactions for each of its clients such that the client’s total cost or proceeds in each transaction are the most favorable under the circumstances. An adviser fulfills this duty by executing securities transactions on behalf of a client with the goal of maximizing value for the client under the particular circumstances occurring at the time of the transaction. As noted below, maximizing value can encompass more than just minimizing cost. When seeking best execution, an adviser should consider “the full range and quality of a broker’s services in placing brokerage including, among other things, the value of research provided as well as execution capability, commission rate, financial responsibility, and responsiveness” to the adviser. In other words, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution. Further, an investment adviser should “periodically and systematically” evaluate the execution it is receiving for clients. iii. Duty to Act and to Provide Advice and Monitoring over the Course of the Relationship An investment adviser’s duty of care also encompasses the duty to provide advice and monitoring over the course of a relationship with a client. An adviser is required to provide advice and services to a client over the course of the relationship at a frequency that is both in the best interest of the client and consistent with the scope of advisory services agreed upon between the investment adviser and the client. The duty to provide advice and monitoring is particularly important for an adviser that has an ongoing relationship with a client (for example, a relationship where the adviser is compensated with a periodic asset-based fee or an adviser with discretionary authority over client assets). Conversely, the steps needed to fulfill this duty may be relatively circumscribed for the adviser and client that have agreed to a relationship of limited duration via contract (for example, a financial planning relationship where the adviser is compensated with a fixed, one-time fee commensurate with the discrete, limited-duration nature of the advice provided). An adviser’s duty to monitor extends to all personalized advice it provides the client. B. Duty of Loyalty The duty of loyalty requires an investment adviser to put its client’s interests first. An investment adviser must not favor its own interests over those of a client or unfairly favor one client over another. In seeking to meet its duty of loyalty, an adviser must make full and fair disclosure to its clients of all material facts relating to the advisory relationship. In addition, an adviser must seek to avoid conflicts of interest with its clients, and, at a minimum, make full and fair disclosure of all material conflicts of interest that could affect the advisory relationship. The disclosure should be sufficiently specific so that a client is able to decide whether to provide informed consent to the conflict of interest. Because an adviser must serve the best interests of its clients, it has an obligation not to subordinate its clients’ interests to its own. For example, an adviser cannot favor its own interests over those of a client, whether by favoring its own accounts or by favoring certain client accounts that pay higher fee rates or sums to the adviser over other client accounts. Accordingly, the duty of loyalty includes a duty not to treat some clients favorably at the expense of other clients. When allocating investment opportunities among eligible clients, an adviser must treat all clients fairly. This does not mean that an adviser must have a pro rata allocation policy, that the adviser’s allocation policies cannot reflect the differences in clients’ objectives or investment profiles, or that the adviser cannot exercise judgment in allocating investment opportunities among eligible clients. Rather, it means that an adviser’s allocation policies must be fair and, if they present a conflict, the adviser must fully and fairly disclose the conflict such that a client can provide informed consent. 5  An adviser must seek to avoid conflicts of interest with its clients, and, at a minimum, make full and fair disclosure to its clients of all material conflicts of interest that could affect the advisory relationship. Disclosure of a conflict alone is not always sufficient to satisfy the adviser’s duty of loyalty and section 206 of the Advisers Act. Any disclosure must be clear and detailed enough for a client to make a reasonably informed decision to consent to such conflicts and practices or reject them. An adviser must provide the client with sufficiently specific facts so that the client is able to understand the adviser’s conflicts of interest and business practices well enough to make an informed decision. For example, an adviser disclosing that it “may” have a conflict is not adequate disclosure when the conflict actually exists. A client’s informed consent can be either explicit or, depending on the facts and circumstances, implicit. It would not be consistent with an adviser’s fiduciary duty to infer or accept client consent to a conflict where either (i) the facts and circumstances indicate that the client did not understand the nature and import of the conflict, or (ii) the material facts concerning the conflict could not be fully and fairly disclosed. For example, in some cases, conflicts may be of a nature and extent that it would be difficult to provide disclosure that adequately conveys the material facts or the nature, magnitude and potential effect of the conflict necessary to obtain informed consent and satisfy an adviser’s fiduciary duty. In other cases, disclosure may not be specific enough for clients to understand whether and how the conflict will affect the advice they receive. With some complex or extensive conflicts, it may be difficult to provide disclosure that is sufficiently specific, but also understandable, to the adviser’s clients. In all of these cases where full and fair disclosure and informed consent is insufficient, an adviser must eliminate the conflict or adequately mitigate the conflict so that it can be more readily disclosed. Full and fair disclosure of all material facts that could affect an advisory relationship, including all material conflicts of interest between the adviser and the client, can help clients and prospective clients in evaluating and selecting investment advisers. Form CRS provides a brief relationship summary designed to help retail investors make informed choices regarding what type of relationship—brokerage, investment advisory, or a combination of both—best suits a retail investor’s particular circumstances and investment objectives. The relationship summary is intended to promote transparency, comparability and better-informed decision-making, through clear, concise disclosures, and by summarizing in one place selected information about a particular firm. This format is designed to allow retail investors to more easily compare different firms’ services, fees, conflicts of interest, disciplinary history and other important information. In addition, Part 2A of Form ADVknown as the “brochure” and evidenced by this document, sets out minimum disclosure requirements, including disclosure of certain conflicts, and requires Investment advisers to deliver the brochure to a prospective client at or before entering into a contract so that the prospective client can use the information contained relationship. in the brochure to decide whether or not to enter into the advisory Item 5 – Fees and Compensation Portfolio Management Fee Information Investment management fees are payable in arrears on a monthly basis, commencing when both the client investment management agreement is signed and the assets are deposited in the client’s account, unless otherwise stipulated. Deposits and withdrawals made during the month will be billed for the time that the funds were under management. Advocacy Wealth has the right to change any or all of its fee schedules with 30 days written notice. Advocacy Wealth is not compensated on the basis of a share of capital gains or capital appreciation in a client’s account. 6  The annual standard fee schedule for these services is: Investment Adviser Annual Fee Client Fee Assets Under Management 1.5% 1.0% Charged up to $500,000 Charged from $500,000 to $3,000,000 Negotiable above $3,000,000 Example: $2.75 million under management would pay an annual fee of 1.5% on the first $500,000 and 1% on $2,250,000. The firm can charge a maximum fee up to 2% under certain circumstances. All fees are subject to negotiation depending on a number of factors including, but not limited to, size, scope and complexity of the account. The fee amount charged will be disclosed in the advisory agreement. As authorized in the Client Agreement, Advocacy Wealth instructs the account custodian to withdraw advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures and pass through to Advocacy Wealth. The custodian sends the client a statement monthly indicating the amount disbursed from the account including the amount of advisory fees paid to Advocacy Wealth. The custodian of the account, not Advocacy Wealth, holds all customer assets. For these clients, the calculation of the fee charged can be requested from Advocacy Wealth. If requested, clients will be billed directly for advisory services. In this case, the client will receive an invoice indicating the amount of the fee, the value of the client’s assets on which the fee was based and the specific manner in which the fee was calculated. Clients should verify the accuracy of the computation; the custodian will not do an independent verification of the accuracy of the computation of fees. It is in the client’s best interest to review their invoice and the account statement and alert Advocacy Wealth immediately if there are any discrepancies. Clients can purchase shares of mutual funds directly from the mutual fund issuer, its principal underwriter or a distributor without purchasing the services of Advocacy Wealth or paying the advisory fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the public without a sales charge. In the case of mutual funds offered with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) can be more or less than the applicable advisory fee. Advocacy Wealth currently only invests client funds in institutional class or other class shares which do not further compensate Advocacy Wealth or its representatives. From time to time, clients may transfer in kind share classes that are not restricted to institutional class. Advocacy Wealth may continue to hold those non-institutional class shares to manage tax liability to the client or for other reasons. It is worth noting that, however, clients who act on their own would not receive the Financial Advisor’s assistance in developing an investment strategy, selecting securities, monitoring performance of the account, and making changes to the investment portfolio, as necessary. Margin loan balances are deducted from the account value when calculating fees. The minimum annual fee is $1,000. Accordingly, a client could pay an effective rate greater than the rate specified in the fee schedule shown above. Advocacy Wealth, in its sole discretion, can waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., size of account(s) already managed, historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, account composition, negotiations with clients, employee discount, etc.). 7  Fidelity Institutional Wealth Services, LLC (“Fidelity”), as well as others who have custody, charge brokerage transaction-based fees or “ticket charges” that vary by security and type of transaction and are passed through to the client. Some mutual funds are part of a “No Transaction Fee” program. Advocacy Wealth uses these funds, when those “No Transaction Fee” funds show utility over others analyzed in the client’s portfolio. Some mutual funds within this program pay 12b-1 service fees (normally 0.25% per year) to Fidelity. Advocacy Wealth does not receive any 12b-1 fees. Transaction fees charged can be higher than those otherwise available if the services were provided separately for a discrete fee or if an Investment Adviser were to select brokerage and negotiate commissions in the absence of the extra consulting service provided. Clients should consider the value of the additional consulting services when making such comparisons. The combination of custodial, consulting, and brokerage services may not be available separately or may require multiple accounts, documentation, and fees. Fees charged by Advocacy Wealth for advisory services cover the salaries and additional, non-commission-based compensation paid to Advocacy Wealth Investment Adviser Representatives and other members of the staff. Costs and transaction fees arising out of transactions effected by entities other than Advocacy Wealth or attributable to dealer mark-ups, mark-downs or “spreads” (in transactions where another entity acts as principal for its own account) will be separately borne by clients. All fees described herein are subject to negotiation depending on a range of factors including, but not limited to, account size and overall range of services requested. Advocacy Wealth provides financial planning, asset allocation advice, investment advice, tax planning and investment management. Our clients have access to a full range of life insurance products, including annuities, and trust services through our affiliates. Advocacy Wealth is affiliated through common ownership with Forge Consulting, LLC, a national general insurance agency, and Advocacy Trust LLC, a State of Tennessee chartered trust company, with trust powers in many states. As applicable, Advocacy Trust, LLC charges a fee based on assets under its administration and passes through other expenses incurred as allowed by the individual trust agreement, such as fees for tax preparation and legal expenses associated with complying with Medicaid and Medicare rules. Assets under administration include anything owned by your trust, but do not include the value of an annuity owned by the trust. Advocacy Trust, LLC deducts its fees and Advocacy Wealth’s fees from the client’s account monthly, in arrears. A detailed schedule of fees and standard charges passed through to the client is available on our website (www.advocacywealth.com/FeeSchedules) and is attached to the client agreement. The commission payments paid by the insurer are provided to you at the time of application if the policy is to be purchased by your qualified retirement account. Insurance commissions as well as investment management and trust administration fees and commissions collected by the affiliated companies -- Forge Consulting, LLC, Advocacy Wealth, Advocacy Trust, LLC, and Forge Capital – aggregate at the company level, and are not paid directly to individual employees. During 2023, the Property and Casualty agents transitioned to commission compensation. All employees of Advocacy Wealth have the following compensation structure, comprised of four components: 1. A base salary; 8  2. A bonus based on the profitability of the organization as a whole; 3. A bonus based on the individual’s contribution to the organization as a whole; and 4. 401K contributions matched by and healthcare premium subsidies provided by The Forge Companies. The beneficial owners of Advocacy Wealth take distributions based on profitability of the combined entities of The Forge Companies. Certain associated person or persons not employed by Advocacy Wealth but by an affiliate receive a base draw and variable compensation based solely on aggregate assets gathered into The Forge Companies, regardless of which product is placed. In addition, certain members of management based on tenure, performance and/or job responsibilities are awarded deferred compensation units in The Forge Companies that have value at the time of sale of The Forge Companies but have no current compensation value. These awards are not available to all employees. Upon occasion in the past Advocacy Wealth has established a program to use independent contractors as our agents to provide service at the local level to individual clients in certain geographies. These independent contractors do not deliver investment advice, though they are licensed to do so. Rather they function to assist the client with local needs or concerns, as well as to help educate the client about planning and investments generally. The contractors are paid a stipend for successful retention of the clients assigned to them. Such a program could be reestablished in the future. We structured compensation to remove sensitivity to how much revenue one product provides us versus another. We emphasize planning and service over sales. Those two elements encourage us to focus on your best interests – not our own. Account Termination You can terminate your Client Agreement for financial services with Advocacy Wealth without penalty within five business days after entering into the Agreement. You will be liable for any market losses which occur during the period of account liquidation or transfer. Thereafter, this Agreement may be terminated at any time by either party giving to the other at least thirty (30) days prior written notice of such termination. For the purposes of this provision, an agreement is considered entered into when all parties have signed it. Upon written receipt of notice to terminate the Client Agreement and unless specific transfer instructions are received, Advocacy Wealth and its agent(s) will, in an orderly and efficient manner, proceed with liquidation of the client’s account. There will not be a charge by us for such liquidation; however, the client should be aware that normal ticket charges will apply, and some custodians charge a termination fee as outlined in your custodial Client Agreement. Fees can be waived at management’s discretion. Certain mutual funds impose redemption fees as stated in each company’s fund prospectus. Termination of the contract will not affect any liabilities or obligations of the parties from transactions initiated before termination of the Agreement or a client's obligation to pay advisory fees paid in arrears (pro-rated through end of the month in which termination is effective). 9  Clients must keep in mind that the decision to liquidate security holdings including mutual funds can result in tax consequences that should be discussed with the client’s tax advisor. Factors that can affect the orderly and efficient manner of disposition would be size and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities markets be unavailable and trading suspended, efforts to trade will be made as soon as possible following their reopening. Due to the administrative processing time needed to terminate the client’s investment advisory service and communicate the instructions to client’s Investment Adviser, termination orders received from clients are not market orders; it can take several business days under normal market conditions to process the client’s request. During this time, the client’s account is subject to market risk. Advocacy Wealth and its agent(s) are not responsible for market fluctuations of the client’s account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Item 6 – Performance-Based Fees and Side-By-Side Management Advocacy Wealth does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Fund managers that Advocacy Wealth may recommend may charge a performance-based fee, in which Advocacy Wealth does not share, which fee is disclosed in the Private Placement Memorandum of the fund. Item 7 – Types of Clients Advocacy Wealth offers portfolio management services to individuals, corporations and business entities, estates and trusts, other investment advisors, charitable organizations, and pension and profit sharing plans. Any account minimum size would be subject to negotiation based upon account characteristics and service requirements. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our investment strategy begins with an understanding of a client’s financial goals. Financial Advisors use demographic and financial information provided by the client to assess the client’s risk profile and investment objectives in determining an appropriate plan for the client’s assets. Investment strategies ordinarily include long- or short-term trading of fixed and adjustable rate income securities, stock portfolios, ETFs, and mutual funds. Margin trading and option trading are used, when appropriate. Investment management takes place within a larger structure of financial management. We see our job as a lifelong process of enabling our clients’ well-being within various cycles of living, and the challenges some of those cycles bring. At Advocacy Wealth, we do not pretend to know what is going to happen in the future. What you make—or lose—by the price of what you own going up or down is unpredictable. While price swings are unpredictable, the size of those swings is fairly predictable in large groups of similar investments called “asset classes”. We call the size of those price swings "volatility." The income paid to you for use of your money in an investment is often relatively predictable, too. Advocacy Wealth balances the level of predictable income against the risks that can come along with achieving those income levels. We want you to meet your long-term cash flow, growth, and liquidity needs with an appropriate amount of risk. To succeed, we try to understand the relationship between the risk of an investment and its potential reward. A first step in this effort examines the characteristics of asset classes. 10  In our view, there are five primary asset classes: • Income, • Equities, • Cash and equivalents, • Real Estate, and • Commodities. Income includes assets such as bonds and other securities that act like bonds. Bonds are securities representing loans. You, the lender, receive interest paid to you, usually twice a year. On a certain date in the future, that loan “matures” and you own a contract to receive the full amount that you lent back from the borrower. When the income is "Fixed" or does not vary over the life of the loan, those income payments are highly predictable. Lending at a fixed rate performs well in stable or falling secular rate cycles. In a cycle where interest rates are rising, variable adjustable rate loans perform better than fixed rate. Both Companies and Governments issue bonds. Currently, for most clients we generally purchase pools of Fixed Income securities in the form of ETFs and mutual funds rather than individual bonds. Equities are stocks, whose shares represent ownership in a company. As a company does well and the overall economy grows, stock prices tend to increase. While some stocks do offer some predictable income, stocks add growth potential through appreciation in price to your investment holdings. This growth potential also usually comes with higher volatility levels in day to day price movements than bonds. Like Income, we mostly purchase pools of stocks rather than individual stocks. Pools of investments provide better diversification in our view. Diversification within asset classes and among asset classes can further reduce theoretical risk. Owning smaller pieces of many things prevents one single holding from sabotaging an entire portfolio. The income from Income assets alone may not be enough by itself to meet a client’s individual needs. Therefore, exposure to Equities, as well as other asset classes, may be necessary to meet a client’s objectives as well as provide additional diversification. From time to time, our Investment Committee could decide that investments in Cash, Real Estate or Commodities would be required to meet the client's needs. The Investment Committee can further decide to deploy differing investment strategies within the various asset classes. Our process requires portfolio models and strategies to be approved by the Advocacy Wealth Investment Committee, which is currently chaired by the CEO Emeritus. Other members of the Investment Committee can include internal as well as external investment professionals. Models and strategies are reviewed and updated both at the macro level, at the individual security level and at the account level regularly by the Investment Team which is comprised of the Chief Investment Officer, and one or more representatives from the Financial Advisors, and analyst(s). Upon occasion and only when suitable to the client’s investment needs and risk tolerance, we could recommend investing a part of the client’s assets in alternative investments, which could not be immediately liquid. When investing in alternatives, we ensure the client has a long-term view of investments, can tolerate the risk, and has ample liquidity outside this investment. 11  We can recommend Alternative Managers that provide exposure to asset classes outside of traditional stock, bond and cash portfolios. Alternative investments provide for additional diversification that often comes with additional risk. When selecting an Alternative Manager, we require historical returns to correlate no more than 0.7% with either stocks or bonds. Even with additional risk within the alternative investment, adding alternatives can reduce overall portfolio risk by adding diversification that is less correlated with stocks or bonds. Alternative investments come in many security structures. Some are 1940 Act Mutual Funds that can be redeemed at Net Asset Value by the fund manager for cash settling in one business day. Some are Exchange Traded Funds that can be sold on an exchange. All exchange traded securities now settle one day after a trade. Other alternative investments are registered with the Securities and Exchange Commission under the 1933 Act, but can only be sold at intervals – like once a month or once a quarter – and the fund manager has options as to whether to accept the redemption request, prorate the request, or even choose to deny the request. Still others are Private Placements. Private Placements are not regulated by the Securities and Exchange Commission. Private Placements can only be offered to clients with the means and sophistication to invest in these securities. Investors must meet the criteria set forth in each investment’s offering documents (i.e. accredited investor, qualified purchaser, qualified client, minimum commitment, etc.). Private Placements are subject to additional risks that do not exist in the public equity and public debt markets. One such material risk is that Private Placements are not marketable. No secondary market exists to buy and sell shares. The General Partner who manages the investments limits the terms and conditions of all redemptions. Some Private Placements may allow redemptions as often as monthly, while others may not allow redemptions at all for the entire term of the investment. Studies show that as much as 94% of your investment results come from the asset allocation decision— how much goes into each asset class.1 Only about 4% comes from what individual holdings are within the asset class. The last 2% comes from the timing of when you decide to change the mix of individual holdings. Generally, we focus our work on the 94% by designing a risk budget. Since neither we— nor anyone else, we believe —can consistently and accurately predict which way a price will move for any given asset class on any given day in the future, we start by balancing risk and using that budget among the asset classes. To help measure risk, we use standard deviation to see how much a set of prices moves over time. Said another way, how much prices move over time defines volatility, and standard deviation is how we measure volatility. Higher standard deviations indicate bigger price swings. 1 Brinson, Gary P., L. Randolph Hood, and Gilbert L. Beebower, 1986. “Determinants of Portfolio Performance.” Financial Analysts Journal 42(4):39-48. Brinson, Gary P., Brian D. Singer, and Gilbert L. Beebower, 1991. “Determinants of Portfolio Performance II: An Update.” Financial Analysts Journal 47(3):40-8. Ibbotson, Roger G., and Paul D. Kaplan, 2000. “Does Asset Allocation Policy Explain 40, 90, or 100 Percent of Performance?” Financial Analysts Journal 56(1):26-33. Jahnke, William W., 1997. “The Asset Allocation Hoax.” Journal of Financial Planning 10(1):109-13. Kritzman, Mark, and Sébastien Page, 2003. “The Hierarchy of Investment Choice.” Journal of Portfolio Management 29(4):11-23. Sharpe, William F., 1988. “Determining a Fund’s Effective Asset Mix.” Investment Management Review (November/December):59-69. Davis, Joseph H., Kinniry, Francis M. Jr., Sheay, Glenn, 2007. “The Asset Allocation Debate: Provocative Question, Enduring Realities”, Vanguard Marketing Corporation. Tokat, Y., Wicas, N. and Kinniry, F., 2006. “The Asset Allocation Debate: A Review3 and Reconciliation”. Journal of Financial Planning, 19(10):52-63. 12  How well cash flow can be predicted influences the amount of price movements. Income assets in the higher credit quality sector have historically tended to have less price movement than Equities when measured against broad benchmarks like the Standard & Poor’s 500 Index (“S&P 500®”). The cash flows in many of the Income assets we choose are largely governed by contract and produce relatively predictable income. But in rising interest rate cycles, we will likely seek to preserve capital by taking on variable income adjustable rate assets. Equities usually have lower expected income and a higher historical risk than Income assets. So why would you take on more risk from the riskier asset classes? Riskier asset classes over longer periods of time can offer growth potential in value, though perhaps not as much growth in income. That growth in value can be sold for capital gains and used to provide or purchase additional income. But that growth comes with risk—prices can, and do, move down as well as up. The higher the standard deviation is, the bigger those moves—up as well as down— tend to be. Beyond measuring the risk of one asset class versus the other, we also look at how prices “correlate.” Correlation indicates whether the prices of two things you own move in the same direction, opposite directions, or unrelated directions. Generally, prices of Equities tend to move in the opposite or an unrelated direction from Income assets – meaning when Equities increase in value, Income investments tend to stay relatively unchanged or even decrease in value, and vice versa. Therefore, adding assets that do not correlate in their price movements can reduce overall risk. But sometimes this correlation rule of thumb breaks down. The relationship between the riskiness of a security or an asset class may change over time as does the level of income that is produced. For those reasons, we periodically revisit our asset classes to maximize predictable income while trying to minimize overall volatility. We cannot erase the possibility of risk, so we budget for it, accepting what we believe to be a prudent amount of risk in exchange for income and growth. Investing in any asset classes involves risks that clients must be prepared to bear. Even Cash can lose value to inflation. Many of our client’s assets are held in Trust. Within a Trust, what we do to manage a client’s investments depends upon the Trust document and the distributions needed and allowed from that Trust. The Trust document is a binding agreement, often driven by the courts or state statutes. Advocacy Wealth Financial Advisors work with the client’s Trust Officer to manage that cash flow to cover distributions allowed under the Trust Agreement. Similarly, the Advocacy Wealth Financial Advisor will work with a client’s Conservator, whose investment restrictions tend to be even more stringent. Investment recommendations are based on an analysis of the client’s individual needs and goals and are drawn from research and analysis. As stated earlier, Advocacy Wealth spends most of its resources on developing the right asset allocation balance versus risk for the client. Once that balance is determined, individual securities and ETFs and other funds of individual securities or outside managers are analyzed. Security analysis methods include the following: • Fundamental analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors to determine if the company (or security itself) is underpriced or overpriced. Fundamental analysis does not attempt to anticipate market movements. This 13  presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. • Technical analysis and charting: We attempt to determine the trend of a security by studying past market data, using charts, graphs and other tools. This presents a potential risk, as the price of a security can change direction at any time and past performance is not a guarantee of future performance. • Cyclical analysis: We attempt to identify the industry cycle of a company or sector to determine whether the company or sector is in a market introduction phase, growth phase or maturity phase. Generally projected revenues, growth potential and business risk fluctuate based on the company’s cycle stage. Further, we look at economic cycles -- expansion, slowdown, recession and recovery -- to forecast how an asset might perform within that cycle. Among the risks here are misjudging which cycle may be in play, along with its duration and amplitude. Information for this analysis is drawn from data providers, financial websites and magazines, research materials prepared by others, annual reports, corporate filings, prospectuses, company press releases and corporate ratings services by Advocacy. It is important to note that investing in securities involves certain risks that are borne by the investor. For any risks associated with Investment Company products (mutual funds), please refer to the prospectuses for additional details about these risks. Our investment approach keeps the risk of loss in mind. These risks include, but are not limited to: • Interest-Rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • • Market Risk: The price of a security, including stock, bond, or mutual fund, can drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions can trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power erodes at the rate of inflation. • • Reinvestment Risk: Reinvesting future proceeds from investments at potentially lower market rates of return (i.e. interest rate) define this risk, primarily applying to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than perhaps an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many investors or traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’s operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations could result in bankruptcy and/or a declining market value. This risk can affect entire sectors – for example, real estate. 14  • Political Risk: Investing internationally in countries where the rule of law is different or non- existent can risk the entire loss of investment, or at a minimum, significant impairment to value. Item 9 – Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that are material to your evaluation of Advocacy Wealth or the integrity of Advocacy Wealth’s management. Advocacy Wealth has no information applicable to this item. Individual Financial Advisors may have disclosures which we do not find material. You are welcome to review those disclosures at https://adviserinfo.sec.gov/ by submitting the name of the individual of interest or Advocacy Wealth as a whole. Item 10 – Other Financial Industry Activities and Affiliations The Forge Companies LLC is sole manager of Advocacy Wealth Management LLC and the majority owner of Advocacy, Inc., a Delaware corporation, which is the holding company holding the interests of Advocacy Trust. Advocacy, Inc. is the 100% owner of Advocacy Trust, LLC, a Tennessee state-chartered trust company that was approved to do business on February 18, 2015. If trust services are needed, we will refer an advisory client to the affiliated trust company if the client profile and needs warrant. If trustee services are utilized, separate fees will be incurred and Advocacy Wealth will benefit through the common control interest in Advocacy Trust, LLC. On August 1, 2024, Advocacy Wealth acquired substantially all of the assets of Montag & Caldwell, LLC. As a result, Advocacy Wealth established a business unit within that it markets as “Montag & Caldwell, an Advocacy Wealth Company.” That business unit serves a distinct line of business focused on institutional and high net worth client markets. In 2022, Forge closed on the purchase of a Property and Casualty agency (Watkins Insurance) and purchased the ownership interest of Forge’s partner in the insurance brokerage business (Full Circle Insurance, LLC). Forge owns 100% of the ownership of the agency. At the end of 2021, Forge purchased Abacus Advisors (“Abacus”) which provides business services such as bookkeeping and Human Resources support to businesses, particularly though not limited to attorneys. Advocacy Wealth and Abacus have mutual clients, and Advocacy Wealth can and does refer clients to Abacus. Abacus is organized as Forge Capital Services, LLC D/B/A Abacus Advisors, wholly owned by Forge. Please see Item 12 for additional disclosures. Some Investment Adviser Representatives of Advocacy Wealth are licensed insurance agents offering insurance products through Forge Consulting, LLC, a national insurance agency. When applicable, these individuals recommend insurance products for advisory clients. All related compensation is separate from advisory services, and that compensation is described in detail in Item 5 above. Because Advocacy Wealth and its licensed employees have a financial incentive to recommend insurance products, trust services, and business services, this creates a conflict of interest. Advocacy Wealth is dedicated to acting in your best interests based on fiduciary principles. You have no obligation to purchase any insurance products or utilize trust or business services in order to receive service from Advocacy Wealth. 15  On January 30, 2026, TA Associates (“TA”) purchased a majority interest in The Forge Companies, the sole owner of Advocacy Wealth Management LLC. TA is a private equity firm that owns interests in various portfolio companies across multiple industries. Certain of these affiliates engage in financial or investment related activities. Current known affiliate relationships are: ‑ ‑ • Orion Portfolio Solutions, LLC, provides accounting (investment book of record), trading, and compliance solutions for Advocacy Wealth Management. Orion is considered an affiliate of Advocacy Wealth Management due to common ownership by TA. Advocacy Wealth Management pays Orion for these services at market based rates. Neither Advocacy Wealth Management nor its supervised associates receive compensation, referral fees, or other economic benefits from Orion as a result of client use of Orion’s services. • Wealth Enhancement Group (WEG), a Registered Investment Advisor, is owned by TA Associates. WEG and Advocacy Wealth Management offer investment services in overlapping markets but there are common or shared activities between the advisory groups. • OMNIA Partners is a group purchasing organization (GPO) owned by TA Associates. The Forge Companies and Advocacy Wealth Management leverage the purchasing discounts offered for purchases of equipment and supplies. This affiliation presents potential conflicts of interest because Advocacy Wealth Management’s owner has an economic interest in Orion. Advocacy Wealth Management addresses these conflicts by (i) retaining responsibility for all investment advice and client service decisions, (ii) periodically reviewing Orion’s services and pricing, and (iii) maintaining policies and procedures reasonably designed to ensure that the selection and continued use of Orion is based on the best interests of clients. Other Conflicts of Interest Ownership On January 30, 2026 the Forge Companies completed the sale of a majority interest of the company to TA Associates, a Boston based private equity firm. As part of that transaction, a new Limited Partnership TA <> Forge, L.P., was created to hold the ownership interest of all parties. In addition, intermediate entities (Forge Parent, L.P., Forge Midco, LLC, and Forge Borrower LLC) were created for the purposes to hold the equity and debt interests of the parties. All the newly formed entities have no operating activities and are strictly used to maintain the capital structure of the company." The Forge Companies, LLC owns 100% of Advocacy Wealth and 100% of the non-diluted and issued common shares of Advocacy, Inc. which owns 100% of the shares of Advocacy Trust, LLC. The Forge Companies, LLC owns 100% of Forge Capital Services, LLC D/B/A Abacus Advisors. The Forge Companies, LLC owns 100% of Forge Consulting, LLC. 16  The Forge Companies, LLC gains financial benefit when a client chooses to work with Advocacy Wealth through distributions of its profits to The Forge Companies, LLC. The Forge Companies, LLC will benefit when a client chooses to work with Advocacy Trust, LLC through future dividends paid to Forge through Advocacy Trust, LLC’s holding company Advocacy, Inc. The Forge Companies, LLC benefits from Forge Capital Services, LLC through distributions to it of profits earned in that business unit. Advocacy Wealth gains financial benefit when a client chooses Advocacy Trust, LLC and the Advocacy Wealth or the Montag & Caldwell business unit is selected to manage the assets in the trust for a fee either as a directed or as a delegated investment adviser. When all cross-owned entities prosper, capital can flow freely among the entities as needs and opportunities arise, thus benefiting the organization. The partners of The Forge Companies, LLC and all employees could have a conflict of interest when short term revenue is considered versus long term profit and reinvestment. Because certain life and annuity products as well as Property and Casualty products pay commissions as soon as the policy is issued, if recurring revenues are insufficient to cover ongoing overhead, there could be a push for products with immediate payouts instead of those with longer trailing revenues. The Forge Companies work very hard in concert with one another to remove or at least dampen this possible conflict of interest. Meanwhile, adherence to our fiduciary duties precludes offering any product whose features do not fit the client’s best interests, regardless of compensation. Regulatory The National Association of Insurance Commissioners and, more specifically, the individual commissioner in each state regulates Forge Consulting, LLC and the Property and Casualty unit under each state’s individual statutes. The Securities and Exchange Commission regulates Advocacy Wealth under the Investment Advisers Act of 1940. The Department of Financial Institutions of the State of Tennessee regulates Advocacy Trust, LLC. A client could be offered products which are more lightly regulated than others in order to receive less regulatory review. However, our planning is integrated across all product lines so as to avail our clients of what we believe best fits each individual’s need. Furthermore, our willingness to hold ourselves to a fiduciary standard in all cases, even those where it is not necessary or called for by regulation, speaks to our commitment to act in and put our clients’ best interests first. Relationships to External Advisers / Sub-Advisers On November 30, 2022, Advocacy Wealth entered an agreement with BlackRock to collaborate with their Custom Model Solutions group to develop a new series of investment portfolio models. The models would be maintained and updated by BlackRock with our input and under our supervision. We would be responsible for trading any suggested changes to the models, with veto ability. Within that agreement, there exists a clause that would require Advocacy to pay BlackRock for their work if assets in aggregate using those models did not equal or exceed $150 million within one year of signing 17  on. Advocacy did not meet that minimum within the time allowed under contract, but BlackRock did not enforce that provision. Nor, it should be noted, were all the holdings in those models BlackRock ETFs or mutual funds. In the last quarter of 2023, our Advisors began significantly favoring the models created with BlackRock, particularly as we rebalanced all the models over the yearend. As of December 31, 2025, our clients had approximately $1,308 million invested in those models Advocacy Wealth created with BlackRock. The $150 million minimum in assets to avoid fees presents a conflict in interest in that Advocacy Wealth could favor those models to meet that threshold. Advocacy Wealth must act in your best interests; therefore, we first choose whether any model or single investment suits your risk tolerance, needs, and goals. Whether a fee to us is involved or not cannot be part of that consideration. We do work with other investment managers to gain access to certain investments or strategies for clients that we pay for out the fee that the client pays to us. In November 2024, Advocacy entered into agreements with Aperio Group LLC, a wholly owned subsidiary of BlackRock Inc., and Orion Advisor Technology, LLC, to act as a sub-advisors on direct indexing for greater tax efficiency in certain accounts managed by Advocacy where the Client has granted discretionary authority. In December 2024, Advocacy entered into a similar agreement for the same sub-advisory service with Fidelity Brokerage Services LLC. Advocacy will be responsible for the advisory fee charged by the subadvisors. Clients will, as is the case otherwise, be responsible for transaction costs, if any, in addition to their agreed upon investment advisor fee with Advocacy. As part of the agreement with Orion, Advocacy enrolled in a loyalty program that discounts services provided to Advocacy by Orion if certain revenue hurdles are achieved. This loyalty program presents a conflict of interest in that Advocacy could favor Orion over Aperio or Fidelity to reduce part of the Orion program’s cost. However, Advocacy must always put the client’s best interest ahead of its own, and thus we will choose the provider that fits the overall strategy best on a client-by-client basis. Currently, Advocacy has sub-advisory agreements in place with Balentine, LLC (“Balentine”) and Pacific Investment Management Company LLC (“PIMCO”) that access particular strategies not internally available Item 11– Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Advocacy Wealth has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts or business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Advocacy Wealth must acknowledge the terms of the Code of Ethics annually, or as amended. Advocacy Wealth’s employees and certain persons affiliated with Advocacy Wealth are required to follow the Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Advocacy Wealth and its affiliated persons can trade for their own accounts in securities which are recommended to and/or purchased for Advocacy Wealth’s clients or have their accounts managed for a discounted fee by Advocacy Wealth. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Advocacy Wealth will not interfere with: (i) making decisions in the best interest of advisory clients; and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Individuals designated as Access Persons are required to preclear personal securities transactions and will be prohibited from transacting in 18  securities placed on the firm’s restricted stock list. Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interests of Advocacy Wealth’s clients. . Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees could benefit from market activity by a client. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Advocacy Wealth and its clients. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis when consistent with Advocacy Wealth's obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs based on their custodian and receive securities at a total average price. Advocacy Wealth will retain records of the trade order and its allocation specifying each participating account, which will be completed prior to the entry of the aggregated order. Advocacy Wealth’s clients or prospective clients can request a copy of the firm's Code of Ethics by contacting the Chief Compliance Officer at our main number. Item 12 – Brokerage Practices Advocacy Wealth recommends many of its clients for brokerage and custodian services to Fidelity Institutional Wealth Services, LLC (“Fidelity”), through its affiliates National Financial Services LLC or Fidelity Brokerage Services LLC, members NYSE and FINRA. For accounts belonging to Advocacy Wealth clients maintained in its custody, Fidelity generally does not charge separately for custody services but is compensated by account holders through transaction-related or asset-based fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts. Fidelity makes products and services available to Advocacy Wealth that benefit Advocacy Wealth but might not directly benefit its clients’ accounts. Many of these products and services are used to service a substantial number of Advocacy Wealth accounts. Some of these products and services provided by Fidelity include software and other technology that: (i) provides access to client account data (such as trade confirmations, account and tax statements); (ii) facilitates trade execution and allocates aggregated trade orders for multiple client accounts; (iii) provides research, pricing and other market data; (iv) facilitates payment of Advocacy Wealth fees from its clients’ accounts; and (v) assists with back-office functions, recordkeeping and client reporting. The foregoing arrangements and those with any other custodian with whom we may enter into an agreement pose a conflict of interest. Services provided create an incentive for Advocacy Wealth to suggest that clients maintain their assets in accounts at Fidelity on the basis of products and services available to Advocacy Wealth, rather than solely on the basis of the nature, cost or quality of custody and brokerage services provided by Fidelity to clients. Further, Advocacy Wealth frequently suggests the choice of Advocacy Trust, LLC, an affiliate under common control and ownership of Advocacy Wealth. When the Trustee is Advocacy Trust, LLC, Advocacy Wealth will benefit directly under common control. Alternatively, Advocacy Wealth could suggest an unaffiliated custodian and trust administrator from whom it could receive a referral fee. In addition to advisory fees, clients will be charged for custody and administration by the trustee. Advocacy Wealth is constrained by fiduciary principles to act in its clients’ best interests and will suggest a custodian to clients only when appropriate. In addition, Advocacy Wealth maintains an awareness of the services provided to clients by the custodians in an effort to ensure that clients are well-served. 19  Advocacy Wealth bases the recommendation of custodian or of a trustee on the individual client’s needs. A significant number of clients establish a special needs trust to preserve government benefits and services. Advocacy Trust, LLC, where it has authority, provides specialized administration services in this area. Where Advocacy Wealth’s own affiliate does not have trust powers, it will recommend a trustee that has adequate capabilities to serve the client’s needs. Another significant subset of clients have either spendthrift issues or endangerment from financial predation from family and friends, or both. In those circumstances we often recommend a Tennessee Investment Services Trust, because Tennessee has among the best asset protection statutes in the nation, in our view. For those clients where trusts do not appear a sound solution, we usually recommend Fidelity, which in our view, offers financial strength and stability in their custody area as well as the support Advocacy Wealth needs to meet its clients’ needs. Depending on the type of transaction, transactions could be executed through the custodian holding your account or could be directed to another specified broker-dealer. Although the brokerage and/or transaction fees paid by clients shall comply with the firm’s duty to seek to obtain best execution, a client can incur costs that are higher than another qualified broker-dealer charges to effect the same transaction. In executing transactions, the determinative factor is not necessarily the lowest possible cost, but whether the transaction is executed in the most advantageous manner in terms of quality. To assess quality, we evaluate many factors, including full range of a broker-dealer's services, competitiveness of price spreads, timeliness of execution and reporting, frequency and correction of trading errors, back office and trade settlement capabilities, and responsiveness to our orders and needs. Advocacy Wealth frequently aggregates orders in a bunched trade or trades when securities are purchased or sold through the same broker-dealer for multiple accounts. The trader for each account must reasonably believe that the bunched order is consistent with Advocacy Wealth’s duty to seek best execution and will benefit each client participating in the aggregated order. The average price per share of each bunched trade will be allocated to each account that participates in the bunched trade. Upon request, the client will be provided with average price trade details. Accounts that participate in the same bunched trade will be charged commissions or transaction fees, if applicable, in accordance with their advisory and brokerage contracts. Different accounts participating in a bunched transaction will not necessarily be charged the same commission rates or transaction fees dependent upon the individual services received. For example, we execute exchange traded securities through Fidelity Institutional. If we have a bunched trade that includes accounts custodied at Fidelity, those accounts who accept electronic document delivery pay no transaction fee. Accounts at Fidelity that still receive paper documents pay $4.95 a trade. If Advocacy Trust accounts are part of the bunched trade, those accounts not custodied at Fidelity will pay $0.01 per share to Fidelity for delivery services. Because Advocacy Wealth is bound to act in all clients’ best interests and seek best execution, bunching trades into an aggregate average price seems fair to all. The $0.01 commission that clients at Advocacy Trust pay is the same that they would pay were the trade executed through the trade system that Advocacy Trust offers and is commensurate with the going market rate for such executions. If a bunched order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day will 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 particular client accounts. For example, partial fills generally are filled pro rata 20  among participating accounts. If the amount to be allocated for each account is not indicated prior to placement of the trade, the Chief Compliance Officer must review and approve the allocation. Changes in allocation prior to final allocation must be made for good cause provided that all client accounts receive fair and equitable treatment. A written explanation of the reason for any material change in the allocation must be provided to and approved by the Chief Compliance Officer. If the change in allocation is the result of a condition that exists or a change in a client’s account outside of the portfolio manager’s control, then approval is not required. You are free to select a broker-dealer other than Fidelity or another trustee other than our recommendation to custody your account and execute your transactions. In such cases, you will negotiate the terms and arrangements with the broker-dealer or trustee of choice, and we will not be in a position to seek better execution services or prices from other broker-dealers or trustees. Furthermore, we will likely not be able to aggregate your transactions with orders from other accounts managed by us. Consequently, you might pay higher commissions or transaction costs than otherwise would be the case. Strategic Business Interests Fidelity Custody and Clearing provides custody of cash and securities, electronic funds transfers, dividend postings and retirement accounts for no fees. Fidelity does charge the client fees for some transactions and certain other services. In exchange for these transaction and service fees, Fidelity provides Advocacy Wealth with data from markets, research, client data and other services. It is possible that clients would pay less in transaction and service fees if Advocacy Wealth were to employ a different platform. When making a recommendation to a client of where to custody the account, Advocacy Wealth considers many factors, especially safety and security, not just costs. Fidelity Investments, one of the largest providers of investment services, owns National Financial Services, the clearing agent and custodian that holds client securities and cash. “SIPC”, the Security Investors Protection Corporation, which in the extraordinarily unlikely event that Fidelity and National Financial were to fail, would protect cash and securities up to $500,000 – similar to the way the FDIC (Federal Deposit Insurance Corporation) protects bank accounts when a bank fails. National Financial has $1 billion in aggregate excess SIPC coverage, and is a preferred custodian. The excess SIPC coverage has no per-customer dollar limit on coverage of securities, but there is a per-customer limit of $1.9 million on coverage of cash. Neither coverage protects against a decline in the market value of securities, nor does either coverage extend to certain securities that are considered ineligible for coverage. However, this coverage is the maximum excess of SIPC protection currently available.2 Forge Consulting, LLC’s Financial Consultants frequently recommend custody and administration of a trust by Legacy Enhancement, Inc. which is a not-for-profit institution operating as a pooled special needs trust under 42 U.S.C. §1396p(d)(4)(C) or as a pooled trust for the benefit of minors. Advocacy Wealth currently manages investments in these trusts under a delegated investment authority for each pool. It is possible that additional relationships could be established in similar fashion with other trusts operating under 42 U.S.C. §1396p(d)(4)(C), causing similar conflicts of interest. Advocacy Wealth affirms its duties as a fiduciary to act in all clients’ best interests. Forge Consulting, LLC Financial Consultants often will recommend another trustee other than Advocacy Trust or Legacy Enhancement. Those Trustees are other trust companies or corporate fiduciaries, who 2 https://www.fidelity.com/why-fidelity/safeguarding-your-accounts 21  could be the attorney who drafted the trust. In many such cases, Advocacy Wealth will manage the investments in the trust. Again, Advocacy Wealth affirms its duties as a fiduciary to act in the client’s best interests. Item 13 – Review of Accounts For those clients to whom Advocacy Wealth provides investment supervisory services, account reviews are conducted on an ongoing basis. Such reviews are typically conducted by the Financial Advisor, who is an Investment Adviser Representative, or by a professional to whom the review has been delegated. We designate our Investment Advisory Representatives as “Financial Advisors” because the advice they deliver is not limited solely to investments. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with their Financial Advisors and to keep their Financial Advisors informed of any changes. Financial Advisors shall seek to contact ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. You agree to inform the firm promptly of any material changes in your financial circumstances that might affect how your assets should be invested. Please contact your Financial Advisor concerning the management of your account(s). Item 16 contains information regarding the custody reports provided. Additional account reviews can be triggered by potential change (beyond client's needs) including changes in general economic and market conditions, analyst reports, company news and interest rate movement. There is no limit to the number of accounts assigned to any particular reviewer, though we target a maximun of 150 relationships per Financial Advisor. Item 14 – Client Referrals and Other Compensation While Advocacy Wealth does not provide cash compensation for client referrals, it does provide sponsorship and entertainment benefits to induce referrals, either directly or indirectly, through its affiliates. The Forge Companies and its subsidiaries sponsor events staged by organizations of trial attorneys. Advocacy Wealth and Advocacy Trust sponsor events staged by organizations of elder law, estate and trust attorneys. Meals and entertainment may be provided by any of the affiliates either concurrently with a sponsored event or in separate meetings. The Forge Companies and its subsidiaries receive casework from the individual attorneys who belong to the trial attorney associations. Advocacy Wealth and Advocacy Trust receive casework from elder law, estate and trust attorneys who may belong to a sponsored association that The Forge Companies did not originate. Advocacy Wealth has received referral fees in the past from trustees recommended to the client by Advocacy Wealth, but where Advocacy Wealth does not provide investment advice. Incentive Compensation Forge Consulting, LLC is paid a commission and, if earned by doing a high enough volume of business, an incentive cash override and incentive business trips for placing insurance policies. Those incentives are paid by either the insurance company that issues the policy involving you or the Insurance Marketing Organization (“IMO”) that aids us in processing the insurance business. There could be a conflict of interest if certain performance targets were close to being achieved which would trigger payment to Forge Consulting, LLC of either additional compensation or travel awards, or both. The partners and others could push and influence to achieve those targets. The compensation system is designed to mitigate such 22  influence were it to occur. Both Advocacy Wealth and Advocacy Trust are fiduciaries and regular company training reinforces the requirement to always put the client’s best interests first. The IMO also issued credits based on the amount of premium placed through them that could be (and were) used for marketing materials such as brochures, logo stamped merchandise, and video production. The Forge Companies’ Marketing Department determined the best use of those credits, some of which benefited Advocacy Wealth (e.g., the IMO produced three-ring binders branded with logos with section tabs to hold monthly statements and other documents for Advocacy Wealth clients). Many of the clients who purchase insurance products through the IMO from Forge also have accounts managed by Advocacy Wealth. The credit program ended in 2023 and was replaced with cash considerations instead, to accrue going forward. Again, regular company training reinforces the requirement to always put the client’s best interests first. ‑ Forge Consulting receives referral compensation from Legacy Enhancement Trust, a pooled trust service provider, in connection with referrals made to it. Advocacy Wealth does not receive any portion of this making process. Advocacy Wealth, referral compensation and is not involved in the referral decision however, is hired by Legacy to provide investment management services on behalf of the trust funds they administer. Given the above, this arrangement presents a potential conflict of interest because Advocacy Wealth and Forge Consulting are under common ownership and receive fees – indirectly or directly. Advocacy Wealth addresses this conflict by maintaining policies and procedures designed to ensure that advisory recommendations, client acceptance decisions, and the provision of advisory services are made in the best interests of clients and are not influenced by affiliated referral arrangements. Advocacy Trust maintains a referral arrangement with Cerity Partners, an independent registered investment advisory firm, pursuant to which Advocacy Trust pays referral compensation to Cerity Partners in connection with referrals made by Cerity Partners. Advocacy Wealth Management does not pay any referral compensation to Cerity Partners, does not receive any portion of such compensation, and is not involved in the referral decision making process. ‑ This arrangement presents a potential conflict of interest because Cerity Partners has a financial incentive to refer prospective clients to Advocacy Trust based on referral compensation received, and Advocacy Trust is an affiliated business of Advocacy Wealth Management through common ownership and control. Advocacy Wealth Management addresses this potential conflict by maintaining policies and procedures reasonably designed to ensure that its advisory recommendations, client acceptance decisions, and the provision of advisory services are made in the best interests of clients and are not influenced by referral arrangements involving affiliated entities. Item 15 – Custody Clients should receive statements at least quarterly from the qualified custodian that holds and maintains your investment assets. Advocacy Wealth urges you to review carefully such statements and compare the official custodial records to any account statements or reports that we provide you. Information we provide could vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 23  Because Advocacy Wealth believes it has custody as defined by its regulator, we engage a Public Company Accounting Oversight Board registered auditor to conduct a surprise audit of our clients’ cash and security holdings annually. This audit is filed with the Securities and Exchange Commission as Form ADV-E and can be found on the Investment Adviser Public Disclosure website: https://www.adviserinfo.sec.gov/Firm/141943. Item 16 – Investment Discretion Advocacy Wealth can and does receive discretionary authority from the client (with only a few exceptions) at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, discretionary authority must be authorized by the client in the written advisory agreement and such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Advocacy Wealth observes the investment policies, limitations and restrictions of the clients advised. Investment guidelines and restrictions must be provided to Advocacy Wealth in writing. Item 17 – Voting Client Securities As a matter of firm policy and practice, Advocacy Wealth will vote proxies on behalf of advisory clients, except for self-directed accounts or where Advocacy Wealth does not have authority. Advocacy Wealth has the responsibility for receiving and reviewing proxies for any and all securities maintained in client portfolios held in custody by National Financial Services and forwarded to Broadridge’s ProxyEdge service. Advocacy Wealth will make voting decisions on voting of proxies in accordance with our guidelines (as amended from time to time) which are available upon request. At least one member of the Proxy Committee will make proxy voting decisions within the framework established by our guidelines. In some instances, votes may be automated via a third party provider with the instructions based on the guidelines. You may request how we voted your shares. Proxies for trusts for which Advocacy Wealth is the investment manager are received, reviewed and voted by the trustee, unless the trustee delegates review and voting to Advocacy Wealth. In addition, Advocacy Wealth will take any action through its vendor Broadridge with respect to any securities held in any accounts that are named in or are subject to class action lawsuits. Clients retain the right at all times to vote their proxies or act on a class action lawsuit directly on their own by notifying Advocacy Wealth. Item 18– Financial Information Registered Investment Advisers are required to provide you with certain financial information or disclosures about Advocacy Wealth’s financial condition. Advocacy Wealth has no financial commitment or current liability that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of any bankruptcy proceeding. Advocacy Wealth does not require prepayment of fees from clients. 24 

Part 2A of Form ADV: Firm Brochure Item 1: Cover Page MONTAG & CALDWELL, An Advocacy Wealth Company 3455 Peachtree Road, N. E. Suite 1500 Atlanta, Georgia 30326-3280 (404) 836-7141 Rebecca M. Keister Chief Compliance Officer www.montag.com March 27, 2026 This brochure provides information about the qualifications and business practices of Montag & Caldwell, an Advocacy Wealth Company. Advocacy Wealth is registered as an investment adviser with the United States Securities and Exchange Commission. Such registration does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 404-836-7141 or rkeister@montag.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 Montag & Caldwell, an Advocacy Wealth Company, also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Material Changes The information provided below highlights the material changes since the last annual update of our brochure, dated March 25, 2025. The parent company of Advocacy Wealth Management (“AWM”), The Forge Companies LLC (“Forge”), has received a significant growth equity investment from funds managed by TA Associates Management, L.P. (“TA”), an established private equity firm out of Boston, Massachusetts. Please see Item 10 for additional information about TA. Within Item 4, we updated the business history of the Firm and information on Client Assets Under Management. 2  Item 3: Table of Contents Item Number Beginning on Page Item 4 Advisory Business .............................................................................................4 Investment Advisory Services • History of the Firm • • Wrap-Fee Programs • Unified Managed Accounts • Client Assets Under Management Item 5 Fees and Compensation .....................................................................................7 Item 6 Performance-Based Fees and Side-by-Side Management .................................8 Item 7 Types of Clients .................................................................................................9 Item 8 Methods of Analysis, Investment Strategies, Sell Disciplines and Risk of Loss ..............................................................................................10 Item 9 Disciplinary Information .................................................................................17 Item 10 Other Financial Industry Activities and Affiliations .......................................18 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................19 Item 12 Brokerage Practices .........................................................................................21 • Broker Selection and Trade Allocations • Best Execution • Trading Errors • Soft Dollars Item 13 Review of Accounts .........................................................................................23 Item 14 Client Referrals and Other Compensation .......................................................24 Item 15 Custody ............................................................................................................25 Item 16 Investment Discretion ......................................................................................26 Item 17 Voting Client Securities ...................................................................................27 Item 18 Financial Information ......................................................................................29 3  Item 4: Advisory Business History of the Firm Montag & Caldwell, an Advocacy Wealth Company, has over 75 years of experience offering professional investment management services. The story of the “Montag & Caldwell” brand name traces its roots back to 1945, when Louis A. Montag started one of Atlanta’s earliest independent investment advisory firms. The current brand name of “Montag & Caldwell” was adopted in 1956. Effective August 1, 2024, Montag & Caldwell operates as a distinct brand/ business unit within Advocacy Wealth Management, LLC, an SEC-registered investment adviser, pursuant to the terms of an asset purchase agreement. Advocacy Wealth was founded in 2007. The Forge Companies, LLC (“Forge”) is the sole manager of Advocacy Wealth. TA Forge Aggregator indirectly controls Forge. Hereafter, “We” and “our” refer to Montag & Caldwell. Information about Advocacy Wealth may be found in their separate Brochure, which we will provide upon request, or can be accessed as mentioned earlier at the SEC’s website https://adviserinfo.sec.gov/. Investment Advisory Services M&C’s principal service is investment counseling. We manage Client portfolios and advise on investments in equity and fixed income securities. For some portfolios (including asset allocation), we also advise on the use of exchange-traded funds (ETFs) and mutual funds. We provide specific investment advice solely based on our investment process and investment objectives and guidelines provided by our Clients. M&C’s investment approach generally involves selecting securities according to the investment disciplines of each respective investment strategy and including those in strategy-specific Model Portfolios. Please see Item 8 of this brochure for further information on our investment strategies. It is possible that different strategy Model Portfolios could hold the same security Also, there could be differing recommendations for those securities in the Model Portfolios. Client portfolios typically mirror the applicable Model Portfolio, limited only by a Client’s particular restrictions or circumstances. We typically select stocks for the Model Portfolios from the publicly traded largest capitalized U.S. companies as well as the largest capitalized foreign companies (often in the form of American Depository Receipts or “ADRs”). All securities we select for our Model Portfolios are listed on U.S. or foreign stock exchanges. While we generally do not make investment decisions based on tax considerations, we are sensitive to the tax implications associated with individual, trust and corporate Client accounts. For all Clients, although the investment decisions are of most importance, we will make an effort, when possible, to be flexible in the execution of trades for taxable accounts and may retain low basis names that are not in our model portfolios. All investment counsel Clients retain M&C by entering into a written agreement for either discretionary or non-discretionary services. (M&C has discretionary authority if it is authorized to decide which securities to purchase and sell for a client.) This agreement may be terminated by either party with written notice according to the terms of the agreement. 4  Wrap-Fee Programs In some instances, we provide investment advice under a wrap-fee program (in which an account at times may be referred to as a Separately Managed Account or SMA) where a broker-dealer or other financial institution sponsor 1) recommends us to a Client, 2) pays our management fees for the Client, 3) executes the Client’s trades without commission charges, 4) monitors our performance, and 5) may also act as custodian, or provide some combination of these or other services - - all for a single fee. The wrap-fee sponsor, rather than M&C, provides reports to wrap-fee Clients. The M&C investment strategy for wrap-fee accounts is the same as that for non-wrap separately managed accounts. In considering such a program, a Client should understand that in a wrap-fee program we do not have the ability to negotiate brokerage transaction commissions with the sponsor. We effect trades “net”, and a portion of the wrap-fee is usually considered to cover the commission cost. We will trade only with the designated broker for wrap-fee program Clients since the Client is required to pay all costs associated with trades executed through broker-dealers other than the designated broker. We expect the designated broker to make diligent efforts to seek to obtain best execution. Please see Item 12 of this brochure for further information on our brokerage practices. A Client considering entering such a program should consider portfolio activity, custodial or any other services provided, the value the Client places on performance monitoring by the wrap-fee program sponsor and whether the wrap-fee could exceed the cost of these services if provided separately and M&C were free to choose broker-dealers to execute the Client’s trades. Specific information on the wrap-fee programs is available in each wrap-fee program sponsor’s brochure. With regard to the record keeping requirement of the Investment Advisers Act of 1940 (“Advisers Act”), in most cases the wrap-fee program sponsor will be the primary record keeper of our wrap-fee Client records. We have been assured by our wrap-fee program sponsors that all such records will be made available upon request. In some cases, we do have electronic access to and do maintain some wrap-fee program Client records. In other cases, wrap fee sponsors provide their performance data to us for their wrap-fee Clients through their applications or systems of record. M&C uses this data in other performance databases employed by the Firm to produce reports. Unified Managed Accounts We also provide investment advice as part of a Unified Managed Account (“UMA”) program arrangement. In such an arrangement, multiple advisers provide portfolio models to an overlay manager, appointed by the bank, broker-dealer or other financial intermediary sponsor of the UMA program. In some cases, the sponsor and overlay manager may be the same entity. The overlay manager executes investment decisions across the sponsor’s customer portfolios based upon the investment advisers’ models. This type of program seeks diversification through asset allocation, typically for customer portfolios with lower minimum asset levels. In UMA program arrangements, we provide an updated M&C portfolio model to the overlay manager of each UMA program on an agreed upon, periodic basis which may vary from UMA program to UMA program depending upon the terms of our agreement with the particular UMA program sponsor. M&C rotates the release of the updated model portfolio either before or after orders are placed for M&C’s discretionary Clients and also rotates the order of submission within the UMA group. We typically do not have investment discretion in any UMA program, and it is the sole responsibility of each UMA 5  program’s overlay manager to make investment decisions for their respective UMA program customer accounts. The overlay manager of each UMA program may elect not to follow our provided Model Portfolio(s) in whole or in part. As a result, the investment performance of a particular UMA program customer account may differ from the investment performance of other portfolios of M&C Clients in the same strategy. In most instances we will not maintain UMA program customer records, nor will we have access to the identity of a UMA program’s customers. Customers participating in a UMA program are not Clients of M&C. Additionally, UMA program customer accounts may be positively or negatively impacted if companies of the securities included in the Model Portfolio(s) we provide to the overlay manager release important or material information before the UMA program overlay manager has finished trading those securities for their customers’ accounts. For a more detailed description of a particular UMA program, please refer to the Form ADV provided by the UMA program sponsor. Client Assets Under Management As of December 31, 2025, Advocacy Wealth held $3,139,118,792 in discretionary assets and $105,775,411 in non-discretionary assets under management. Of these amounts, the value of Client assets managed on a discretionary basis in Montag & Caldwell branded investment strategies amounted to $576,744,167 and $12,905,981 in non-discretionary assets under management. Combined assets in the UMA programs to which we provide our Model Portfolio(s), as of December 31, 2025 amounted to $65,430,344. As these assets are not Client assets, they have not been disclosed in Form ADV Part 1A. 6  Item 5: Fees and Compensation Our compensation for services is calculated and paid according to a schedule of fees agreed upon between M&C and the Client. Generally, an account’s schedule of fees is based upon a percentage of assets under management. We generally invoice fees for payment quarterly in advance (for the upcoming quarter), although Clients have the option to request to pay fees quarterly in arrears (for the past quarter). We apply the relevant schedule of fees to the fair market value of an account’s assets, as we reasonably determine, on the last business day of each billing period. Some Clients’ fees are based on daily valuations. If a Client terminates the account with us, we will prorate any fees paid in advance to the date of termination specified in the Client’s notice of termination and will promptly refund any unearned portion to the Client. For Montag & Caldwell Client portfolios invested in one of our Growth Equity investment strategies or our predominantly ETF-holdings GTAM strategy, we compute the market value of these Client account held securities that are listed on a national securities exchange by valuing the security on the valuation date using the price reported on the Orion Portfolio Accounting System, which prioritizes Clients’ respective custodian feed pricing as the primary price source, with the Orion Price acting as the secondary (backup) source, which may be a “plurality price” (i.e., the most common price among custodians for the day) or an averaged price across multiple custodians. For Montag & Caldwell Client portfolios invested in one of our Balanced or Fixed Income investment strategies, we rely on the price reported on the Orion Portfolio Accounting System; however, in an effort to standardize the bond/fixed income pricing across our client portfolios, we have employed a custom price feed hierarchy which overrides Orion's default settings, whereby all our Balanced and Fixed Income investment strategies will read pricing from the same select list of custodians feeding to Orion that we have chosen and in the same order of priority that we have instructed. The Orion Price remains the final option in the hierarchy list. Montag & Caldwell does not engage in an independent valuation of Client account assets, instead relying on valuations provided by the Orion Portfolio Accounting System and the respective underlying custodial data feeds Orion receives. The pricing source used for the portfolio valuation determines the Advisory Fee charged to the client. Using a price other than the Clients' respective custodian's may result in a different market valuation and fee than if the Clients' respective custodian's price was used. If requested by a Client, we will calculate compensation for services based on the value determined by the Client’s custodian on the last day of each period. A Client may authorize us either to bill its custodian for fees or to bill the Client directly; however, M&C will not actually deduct fees from a Client’s assets. Although we generally require a minimum annual fee and adhere to a schedule of fees, we may, in our sole discretion, agree to a fee different from the annual minimum or standard schedule of fees. Clients will also incur fee charges by the custodian of the Client’s assets as well as brokerage and other transaction costs, as described in Item 12 of this brochure. Some broker/dealer custodians charge additional fees for transactions we execute with other brokers. Asset allocation portfolios will also incur fees and expenses for ETFs or mutual funds as described in their respective prospectuses. 7  Item 6: Performance-Based Fees and Side-by-Side Management Performance-Based Fees We do not currently advise any accounts with performance-based fees. Side-by-Side Management We trade and monitor performance of all Client accounts in the same manner, without regard for fee structures. The controls in place to ensure fairness include: • Managing all accounts alike. For each M&C product, we implement the buy/sell decisions of the strategy’s Investment Team or lead portfolio managers similarly across all accounts, so the portfolio composition of an account is similar to the portfolio composition of the applicable M&C Model Portfolio and other accounts invested in the same strategy, allowing for Client restrictions or circumstances. Deviations from the Model Portfolio due to Client environmental, social or governance restrictions can occur only if written instructions have been received from the Client. In some instances and in response to Client request, an appropriate substitute investment may be recommended by Research. Our portfolio managers review Client holdings no less than weekly for conformance with the decisions of the particular Investment Team or lead portfolio managers. Security changes to our M&C Model Portfolios are known as “program” transactions. These buy or sell decisions for each Model Portfolio are optimized by our Trading department and applied across all of the managed accounts over which we have discretion and/or trading authorization. • Compensation structure. Portfolio manager compensation structure is not based on the performance of individual accounts or on the value of assets held in the Clients’ portfolios although some portion of their compensation may result from incentives paid for previously developed new business. See Item 14 of this brochure for further information about Compensation. Rather we compensate employees on the performance of the Firm as a whole, as well as individual job performance, which removes the potential incentive for portfolio managers to favor one Client account over another. • Cross-trades. As a matter of policy, we do not transact cross trades in Client portfolios. • Investment opportunities. Also as a matter of policy, we do not invest in limited availability investment opportunities, such as IPOs or private placements, for any Client portfolios. • Trade allocations. We have in place written policies and procedures that are reasonably designed to allocate investment opportunities across our Clients’ accounts on a fair and impartial basis, to ensure that no Client is advantaged or disadvantaged over another. This would include the allocation of transactions for any and all M&C proprietary accounts. Please see Item 12 of this brochure for further information on our brokerage practices. 8  Item 7: Types of Clients M&C serves a range of institutional and individual Clients through separate accounts. We are experienced in working with retirement plans, endowment funds and foundations, state and local governments, hospitals, insurance companies and credit unions, and Taft-Hartley funds. The minimum asset value for an individual or institutional M&C brand large cap growth, mid cap growth, thematic growth, balanced or fixed income separately managed relationship is $1 million. The minimum asset value for an individual or institutional M&C brand Global Tactical Allocation Model portfolio is $100 thousand. In our sole discretion, we may accept accounts under the stated minimums. 9  Item 8: Methods of Analysis, Investment Strategies, Sell Disciplines and Risk of Loss Methods of Analysis For our M&C Growth strategies (large cap, mid cap, and thematic), M&C’s stock selection process relies on the analysis of our research team, which is led by Chief Investment Officer M. Scott Thompson, CFA. Our research analysts use the valuation and earnings momentum data generated through their inputs to our stock selection models and fundamental research to develop specific investment recommendations, used in part or in whole depending upon the particular strategy. Our process for ranking a stock’s relative attractiveness is entirely proprietary. The models we use cannot be purchased from third-party providers. However, we do use inputs generated from a variety of external sources. The key inputs to our internally published research reflect the fundamental conclusions of our analysts as well as estimates and assumptions for 1) estimated near-term earnings per share, 2) estimated long- term earnings per share growth rates, 3) normalized earnings per share, and 4) dividend payout ratio. These estimates are linked to historical earnings data and to an appropriate discount rate, which we determine using our proprietary method of scoring historical financial data. These assumptions generate valuation and relative earnings momentum data. This earnings momentum data is grouped into deciles via our internal software. These sorts (along with other investment considerations such as tentative conclusions about evolving changes in an industry’s structure) prompt our analysts to explore potential investments based on the relative attractiveness of a company’s earnings momentum and valuation at a particular time. We perform fundamental analysis that supports our valuation inputs for all companies that meet our initial market capitalization, growth and quality criteria. Such analysis includes evaluation of a company’s 1) management, 2) products, 3) distribution channels, 4) industry position, 5) cash generation, and 6) many other factors, along with an assessment of the effects of global and domestic macroeconomic events upon a company’s earnings and growth rates. In our fundamental analysis we utilize a number of resources including: • Company-published data such as annual and quarterly reports filed with the SEC. • Historical company and industry data available from sources such as Value Line, FactSet, and Standard & Poor’s. • Discussions with company management or investor relations representatives (including in-person meetings with top management, facilitated by our location in a leading financial center but also in other venues such as company-sponsored field trips and sell-side hosted industry conferences). • Background discussions with economists and industry-appropriate professionals. • Extensive company and industry data available from national brokerage firms and independent sources. • Government-released data relating to macroeconomic variables and industry data (i.e., Department of Energy for energy, Federal Reserve Bank for bank industry data, etc.). Through FactSet, an online financial information service, M&C analysts have timely access to current economic and company news and published sell-side analyst reports and notes. More detailed company 10  and industry data is available in brokerage firms’ published reports, which we can also access electronically via FactSet. In addition, some of these firms’ analysts, who typically cover a small group of companies in a single industry, are available to our analysts both for timely answers to company specific questions and for broader discussions about industry issues. In the process of developing a buy or sell recommendation, M&C analysts typically consider a wide range of opinions from sell-side analysts on a particular stock. On the research front, we have created an interactive, proprietary database to house all of our valuation and earnings inputs. This database, named CORE or Collaborative Online Research Engine, allows the analyst to see in real-time the impact of changes made to assumptions in a stock’s earnings, growth rate, dividend policy, or discount rate. CORE maintains updates in real time. All reports can be viewed online at any time. CORE also allows the analyst much more flexibility in screening our stock universe. For example, an analyst can sort his or her coverage universe in a variety of fashions – such as by valuation, earnings momentum, annual earnings growth, etc. With CORE our analysts and portfolio managers have the ability to screen and sort our entire investable universe on a wide variety of data items stored in our database. Because CORE is maintained in the cloud, our Investment Team has access to this data at any time, either at the office or remotely via a web browser on any internet connected device. M&C believes that good investment returns are derived from the competent, disciplined, fundamental analysis of individual securities, performed by experienced professionals operating as a team. For each M&C product, our Investment Teams, composed of experienced investment professionals or lead portfolio managers, establish the investment strategies and review the securities to be bought or sold. Portfolio managers manage Client portfolios within the parameters established by the particular Investment Team or lead portfolio managers, with exceptions for Client restrictions or circumstances. Investment Strategies Growth Portfolios We are long-term, high quality investors focusing on growth opportunities. Our flagship product style is large cap growth. The investment process is primarily bottom-up in which we interrelate valuation with earnings momentum. Our strategy uses a present value model in which the current price of the stock is compared to the risk-adjusted present value of the company’s future earnings stream. The identification of appropriate stocks for consideration in our large cap growth product begins with a broad universe of stocks. We then screen this universe for market capitalization of at least $10 billion, an expected 10% long-term earnings growth rate, and a proprietary quality evaluation. The resulting universe of common stocks is then processed through our proprietary earnings and valuation models. Analyst judgment, based on qualitative factors and strong financial characteristics, further narrows the universe to a select list of focus stocks, upon which more rigorous due diligence is performed. Our objective is to identify high quality, large cap growth stocks that are selling at a discount to our estimate of intrinsic value and are expected to exhibit above-median near-term relative earnings strength. The mid cap growth strategy extends our equity capabilities into the mid cap asset class while leveraging the strength of our resources and our time-tested, fundamentally driven investment process. As with large cap, the mid cap equity selection process is a growth approach focusing on high quality companies. It employs the same bottom-up process in which we interrelate valuation with earnings momentum, but focuses on identifying investment candidates within the range of market capitalizations of companies encompassing the 201st largest company traded on U.S. stock exchanges and the 1000th. Our objective is to identify high quality, mid cap growth stocks that are selling at a discount to intrinsic value and are expected to exhibit above-median near-term relative earnings strength. 11  The thematic growth strategy is a concentrated growth strategy, primarily, although not exclusively, derived from our large and mid cap growth strategies. This strategy focuses on those industries and companies that we believe have the strongest secular growth trends. The strategy focuses on those sectors or industries identified in our fundamental work that offer strong growth potential over the next 3-5 years based on factors such as, but not limited to, new product cycles, new and emerging technologies, and/or changes in consumer behaviors. On a bottom up basis, the manager assembles a concentrated portfolio of stocks that best capitalize on the identified trends. Secondarily, the strategy will favor those companies that rank highly within the firm’s proprietary financial quality scoring process. For the above mentioned M&C growth strategies (large cap, mid cap, and thematic), our analysts follow these stocks closely, regularly assessing their valuation and relative earnings growth. We typically initiate a position in a stock that is trading at a discount to our estimate of its intrinsic value. We compute this using a modified present value model that incorporates our analysts’ assumptions for normalized earnings, secular earnings growth rate, dividend payout ratio, and an assigned stock specific risk-adjusted discount rate. The valuation model is a dynamic process in which the earnings base is adjusted each quarter. In addition, annually we re-evaluate the fundamental attributes that contribute to the risk-adjusted discount rate for each company and do so more frequently if market, industry, or specific company issues so demand. Daily we update our internal database that shows and sorts valuation and earnings momentum data. We consider above median relative earnings growth to be a primary catalyst driving share price appreciation. We determine this measure by comparing estimated and historical six-month annualized earnings growth to other companies in our universe and subsequently ranking companies by decile. Fixed Income Portfolios M&C employs an active, yet conservative, approach to the management of fixed income portfolios. We construct portfolios taking into consideration the benchmark index, which at the current time includes the ICE BofA US Corporate and Government Index and the ICE BofA 1-10 year US Corporate and Government Index, as well as Client guidelines. Our objective is to provide an above market return while assuming less credit risk than the market, and without excessive activity. We seek to accomplish this through actively managing and adjusting weighted average duration targets, and by changing the sector weights within the portfolio among government, corporate, mortgage- backed, asset-backed and other fixed income investments, according to our outlook. The Investment Team determines the outlook for the economy and interest rates through an analysis of the business cycle. Federal Reserve policy, GDP growth, inflation rate expectations, the unemployment rate, exchange rates, industrial production and capacity utilization are factors influencing the duration decision. We implement our duration decisions within a normal limit of +/- 20% of the benchmark index. Large percentage moves are avoided, with a typical change of 3%. We conduct an analysis of the yield curve to implement the duration distribution decision. By also analyzing the expected total return of a bond portfolio within a range of possible interest rate movements, we attempt to maximize our probability of success in structuring portfolios to outperform the market with lower risk over a complete interest rate cycle. We may under- or overweight various points along the yield curve versus the index based upon a relative rich/cheap analysis. The historical shape of the yield curve in the context of the current stage of the business cycle plays a role in this analysis. We do not utilize strict barbell/bullet strategies, as a percentage of our portfolios will always be maintained in the middle of the yield curve. However, if we anticipate a flattening of the yield curve, with long rates falling, a barbell strategy will be utilized, to the extent that we will underweight 12  the middle of the curve. Conversely, if we anticipate a steepening of the yield curve, a bullet strategy will be employed. Balanced Portfolios Balanced portfolios are composed of equity and fixed income. The equity portion of the portfolio is generally the driving force behind performance, while the use of high quality bonds diversifies the portfolio for capital preservation and helps to mitigate portfolio risk. Holdings in the equity segment of separately managed balanced portfolios typically mirror one of our M&C growth equity strategies, allowing for Client restrictions or circumstances. For the fixed income segment, we emphasize positioning along the yield curve and sector weightings and manage risk by changing the maturities and sector emphasis of the portfolio over time. We determine the appropriate asset mix among cash, equities, fixed income, ETFs and mutual funds through consultation with the Client concerning the Client's risk tolerance, income needs, and growth objective. We make minimal shifts around the Client’s strategic target asset allocation based upon the Investment Team’s outlook for the equity and fixed income markets, reflecting our judgment of the relative attractiveness of common stocks to other assets. Among the factors we consider are the economic environment, financial market valuation, economic and investor liquidity, and investor sentiment. We evaluate both short and long-term outlooks. Asset Allocation Portfolios The M&C Global Tactical Allocation Model (GTAM) Investment Team constructs Client portfolios using a hybrid approach of a top down macro view that emphasizes business cycle dynamics, coupled with fundamental and qualitative insights from decades of managed money experience. The team begins with a strategic allocation model that incorporates long-term capital market assumptions for different asset classes and geographies. This allocation is designed to represent a portfolio that compensates the investor for systematic market risks (risks that can’t be diversified away). The strategic allocation is represented by the strategy’s benchmark. The Investment Team will then make both short and intermediate term tactical adjustments relative to the strategic allocation to capitalize on market opportunities, or to avoid near-term risks. The Team monitors a variety of macroeconomic data points to assess where we are in the business cycle; we incorporate changes in monetary policy to our assumptions and a variety of valuation metrics and growth assumptions as well as technical and sentiment indicators. By managing the portfolio’s active risk, we believe we can achieve stronger risk-adjusted relative performance. Sell Disciplines M&C’s primary sell disciplines are summarized in the bullets below. Generally, if a company’s results remain consistent with our forecast, we could hold the position for a number of years. However, if a security becomes excessively valued or if we foresee a slowdown in earnings momentum, we could take profits. For most M&C growth strategies, we would also reduce a position when it significantly exceeds 5% of the equity portion of a portfolio or its weighting in the benchmark, whichever is greater. On occasion, in taxable accounts we might reduce a position for tax reasons. Growth Equity • Achieve the target price: We will review a holding for probable sale when it reaches our target price ratio, which is normally 120% of our determination of its fair value. Trimming the position, 13  rather than total sale, might be the decision in the case of a high-growth company with rapidly compounding earnings. • Earnings disappointment: For M&C large cap growth and mid cap growth, any significant earnings disappointment will trigger an immediate review of the holding and a decision to “add or sell”. Since our investment policy centers on positive earnings momentum within a six-month period, we make “add or sell” decisions within that framework. We may extend this time frame for one quarter out to nine months, in order to capture exceptionally good value occurring just prior to restored earnings momentum. Unless we discern visible earnings growth for the next six to nine months and the valuation is attractive enough to justify adding to positions, we will sell on earnings disappointments. For M&C thematic growth, given the strategy’s longer-term nature, the earnings disappointment rule is typically not centered on any afore-mentioned monthly period, but instead will only be applied if it undermines the intermediate/long-term investment thesis in the context of the strategy’s 3-5 year view. In addition to the primary sell disciplines, we may also sell stocks when experiencing weakening earnings momentum, declining relative price or when we find more attractive alternatives. Fixed Income • Bonds may be sold if a company’s credit profile deteriorates, if a bond’s spread to Treasury bonds is considered too low or in order to adjust the portfolio’s average duration. Asset Allocation • The Investment Team uses the same hybrid approach in its sell discipline. The Team monitors any signs of changes in the long-term secular growth forecasts and relative valuations. Asset classes become a candidate for sale based on the current position in the business cycle and intermediate term macro trends. The Team will then sell or trim positions based on changes in near-term fundamentals towards allocating capital to more compelling investment opportunities. Risk of Loss Clients should be aware that investing in securities involves risk of loss that Clients should be prepared to bear. Growth Equity Relative to equity investments, M&C focuses on individual stock/fundamental risk at the portfolio level. Our Investment Teams or lead portfolio managers for M&C large cap growth, mid cap growth, and thematic growth (“growth equity strategies”) are responsible for monitoring risk in the portfolios. We primarily manage risk through our fundamental valuation and quality work at the individual stock level. We then compensate for the various risk levels of these variables through our stock-specific, discount rate score. Additionally, we employ sector limits and cap allocations to individual names. Risk is also controlled through strict adherence to our sell discipline, which requires that we sell or reduce holdings in names when they reach a 20% premium to our estimate of their fair value. We do not maintain tracking error targets or excess return targets, nor do we manage our portfolios relative to beta, information ratio, or other standardized risk measures, as benchmarks themselves can 14  be skewed in irregular market environments. It is an important aspect of our investment process to be able either to over- or underweight various sectors of the market, based on our bottom-up work on which stocks will provide the best returns for our portfolios, and not be constrained by strict index weightings. We are also willing, if we do not find stocks with a combination of valuation and earnings, to exclude a sector from the portfolio. That being said, while such standardized risk measures are not explicitly considered as part of our portfolio construction process, the Investment Teams or lead portfolio managers for our growth equity strategies are continuously evaluating their respective M&C Model Portfolios, which are implemented across all fully discretionary accounts (subject to Client constraints and circumstances), and monitoring the dispersion of portfolio characteristics relative to the target benchmarks, to be sure that our portfolios are broadly in line with our expectations. Fixed Income With regard to fixed income investments, we incur risk in making duration and sector adjustments around the benchmark indices. There is also a risk of falling prices due to a general rise in interest rates. We strive to minimize credit risk through our investment process: • Weighted average portfolio duration is normally limited to +/- 20% of the benchmark index. • Corporate bonds typically are rated Baa3/BBB- or higher. Asset-backed securities are Aaa/AAA rated only. • Excluding Treasuries, the weighting in an issuer is normally limited to 5% of the market value of the fixed income portfolio. • We avoid credit risk on the long end by typically limiting corporate and asset-backed securities to maturities of 10 years or less. • Portfolios with small market values typically hold only Treasury and agency securities due to implicit liquidity costs. • We also analyze our risk along the yield curve by comparing the distribution of our portfolios to the benchmark indices. Asset Allocation With regard to our asset allocation portfolios, we incur risk in making asset allocation decisions, which may include and are not limited to, asset classes, equity styles, and sectors that are exposed to market risk through investments in exchange traded funds ("ETFs"). The value of any asset class can decline for many reasons including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, currency movements, regulatory changes, political developments, or relative country specific domestic growth rates. In addition, asset allocation selection is augmented by past price performance and volatility relationships to evaluate both current and future positioning. It is possible that different or unrelated (historically uncorrelated) asset classes may exhibit similar price changes in similar directions, which may adversely affect a Client's account, and may become more severe in times of market upheaval or high volatility. Historical returns, expected returns, or projections based on historical relationships may not reflect future performance. 15  The Global Tactical Allocation Model Investment Team is responsible for monitoring risk in the portfolios on the whole. Asset allocation Clients are also referred to the prospectuses of the ETFs in which their portfolios invest. 16  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of M&C’s advisory business or the integrity of management. 17  Item 10: Other Financial Industry Activities and Affiliations The Montag & Caldwell brand name and substantially all of the client assets previously under investment management at Montag & Caldwell, LLC became a division of Advocacy Wealth Management, LLC (herein "Advocacy Wealth"), an SEC registered investment adviser, effective August 1, 2024 pursuant to the terms of an asset purchase agreement. The Forge Companies, LLC owns 100% of Advocacy Wealth and 100% of the non-diluted and issued common shares of Advocacy, Inc. which owns 100% of the shares of Advocacy Trust, LLC. The Forge Companies, LLC also owns 100% of Forge Capital Services, LLC D/B/A Abacus Advisors as well as 100% of Forge Consulting, LLC. On January 30, 2026, TA Associates (“TA”) purchased a majority interest in The Forge Companies, the sole owner of Advocacy Wealth Management LLC. TA is a private equity firm that owns interests in various portfolio companies across multiple industries. Certain of these affiliates engage in financial or investment‑related activities. Current known affiliate relationships are: • Orion Portfolio Solutions, LLC, provides accounting (investment book of record), trading, and compliance solutions for Advocacy Wealth Management. Orion is considered an affiliate of Advocacy Wealth Management due to common ownership by TA. Advocacy Wealth Management pays Orion for these services at market‑based rates. Neither Advocacy Wealth Management nor its supervised associates receive compensation, referral fees, or other economic benefits from Orion as a result of client use of Orion’s services. • Wealth Enhancement Group (WEG), a Registered Investment Advisor, is owned by TA Associates. WEG and Advocacy Wealth Management offer investment services in overlapping markets but there are common or shared activities between the advisory groups. • OMNIA Partners is a group purchasing organization (GPO) owned by TA Associates. The Forge Companies and Advocacy Wealth Management leverage the purchasing discounts offered for purchases of equipment and supplies. This affiliation presents potential conflicts of interest because Advocacy Wealth Management’s owner has an economic interest in Orion. Advocacy Wealth Management addresses these conflicts by (i) retaining responsibility for all investment advice and client service decisions, (ii) periodically reviewing Orion’s services and pricing, and (iii) maintaining policies and procedures reasonably designed to ensure that the selection and continued use of Orion is based on the best interests of clients. All Investment Adviser Representatives are Investment Adviser Representatives of Advocacy Wealth, of which Montag & Caldwell is a distinct brand/business unit. Advocacy Wealth has entered into agreements with Aperio Group LLC, a wholly owned subsidiary of BlackRock Inc., and Orion Advisor Technology, LLC, to act as sub-advisors on direct indexing for greater tax efficiency in certain accounts managed by Advocacy Wealth where the Client has granted discretionary authority. In December 2024, Advocacy Wealth entered into a similar agreement for the same sub-advisory service with Fidelity Brokerage Services LLC. Advocacy Wealth will be responsible for the advisory fee charged by the sub-advisors. Clients will, as is the case otherwise, be responsible for transaction costs, if any, in addition to their agreed upon investment adviser fee with Advocacy Wealth. As part of the agreement with Orion, Advocacy Wealth enrolled in a loyalty program that discounts services provided to Advocacy Wealth by Orion if certain revenue hurdles are achieved. This loyalty program presents a conflict of interest in that Advocacy Wealth could favor Orion over Aperio or Fidelity to reduce part of the Orion program’s cost. However, Advocacy Wealth must always put the client’s best interest ahead of its own, and thus we will choose the provider that fits the overall strategy best on a client-by-client basis. 18  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As an Advocacy Wealth company, Montag & Caldwell adheres to the Advocacy Wealth Management, LLC Code of Ethics as amended from time to time, which meets the requirements of Rule 204A-1 of the Advisers Act and is available upon request. The Code of Ethics governs the investment in securities by all Access Persons. We consider certain individuals Access Persons since they have available to them information regarding our investment decisions. Access Persons are permitted to make personal trades in securities that we recommend to Clients in accordance with the provisions of the Code of Ethics. The purpose of the portion of the Code of Ethics dealing with Access Persons’ securities transactions is to assure that those transactions do not conflict with Client investments and, where there is a need to set priorities, that Clients’ interests come first. Every Access Person must provide an initial holdings report after the person becomes an Access Person and then annually thereafter. Quarterly, each Access Person will receive notification from the compliance system of record of his/her personal reportable securities transactions on record and complete a certification attesting that it accurately covers all transactions for the stated time period in all accounts covered by the Code of Ethics. M&C maintains a Restricted Stock List which is accessible by all employees within the compliance system of record’s Personal Trading Portal (“PTP”) and is used in the trade pre-clearance process. We place a security on the Restricted Stock List when the Research Department makes a recommendation or when approved by a particular Investment Team or lead portfolio managers or when purchased by a strategy to take an initial position in a security across all Client accounts, to eliminate a security position from all Client accounts, or to decrease or increase a security position across all Client accounts in the product. We also place on the Restricted Stock List securities which are under consideration by the Research Department, although not yet recommended. Securities for which we take investment actions remain on the Restricted Stock List for 7 days after the recommended action in Client accounts is complete. A security which involves a total sale of shares may be removed from the Restricted Stock List prior to the expiration of the 7 day period if all such shares have been sold from all Client portfolios. The review period for Code of Ethics compliance of Access Persons’ trading activity in a security for which M&C investment decisions have been made will include the 7 days prior to the commencement of the Firm’s investment action. If an Access Person is considering a personal trade in a security, he/she must first preclear the transaction within the PTP and then, upon receiving preclearance, promptly execute the transaction with his or her broker (i.e., the trade may be placed as a day order only). If a security is on the Restricted Stock List, the Access Person is prohibited from trading in that security or from disclosing that a security is on the Restricted Stock List. Preclearance will be authorized for securities that are not on the Restricted Stock List only so long as there are no unexecuted Client orders in the particular security held by the Trading Desk. The Access Person also must have no knowledge of Client orders in those securities which will or should be executed on that day. Access Persons are required to request that electronic feeds from their brokerage accounts be established to the PTP to provide transaction and holding information for all accounts covered by the Code of Ethics. If electronic feeds are not possible with a particular broker, each Access Person must submit copies of reportable transaction confirmations or statements to the Chief Compliance Officer who will forward the information to the compliance system of record for manual entry. 19  Securities not subject to reporting include: 1. Purchases or sales of shares of mutual funds, with the exception of purchases or sales of shares of any funds for which M&C or Advocacy Wealth or a control affiliate serves as the investment adviser or principal underwriter for the fund; 2. Transactions in units of a unit investment trust if the unit investment trust is invested exclusively in unaffiliated mutual funds; 3. Transactions in Certificates of Deposits and other money market instruments (i.e. high quality short-term debt/fixed income instruments); 4. Shares of money market funds; 5. Transactions and holdings in direct obligations of the United States government (although some of these may require preclearance as per the Code). 20  Item 12: Brokerage Practices Broker Selection and Trade Allocations For portfolios under M&C management, we select brokers to effect Client securities transactions unless the selection is made to follow a Client’s specific directives. A Client may direct us, in writing, to conduct all or a portion of its security transactions with designated brokerage firms. Client direction may be to a broker that provides custody or commission recapture benefits. In the event that a Client directs us to use a particular broker, we may not be able under those circumstances to negotiate commissions and may not be able to obtain volume discounts. In addition, under those circumstances a disparity in commission charges may exist between the commissions charged to Clients who direct us to use a particular broker and other Clients who do not direct us to use a particular broker. If a Client removes the broker selection decision from us, we can provide no assurance that we can obtain best execution for the Client. For separately managed accounts which may otherwise not have an established bank or broker custody relationship, we may recommend Charles Schwab due to its operational and trading efficiencies. Charles Schwab is also the recommended custodian for the Asset Allocation Portfolio strategy. While our Investment Teams or lead portfolio managers may recommend for purchase in Client portfolios the securities of Charles Schwab, we do not believe that the potential for a conflict of interest exists due to the size of assets in such accounts versus total assets of Schwab. We denote security changes to the Model Portfolios as “program” transactions. These buy or sell decisions are implemented across all of the managed accounts for which we have discretionary authority and/or trading authorization. Client orders that do not have designated brokerage direction are known as free/discretionary orders. Some Clients choose to direct their trading activity to specific broker-dealers, and these are referred to as directed orders. For program transactions, the trader will normally group orders by custodian; and when all orders have been approved for the particular program transaction by the Portfolio Manager; the group will be submitted at one time to the executing broker . While M&C proprietary account transactions will be grouped with other Client account transactions, M&C will not favor its proprietary accounts in the allocation of transactions and will not subordinate other Clients’ interests to its own. We will make an effort to ensure a fair and equitable placement of all orders. We execute and allocate trades by custodian to get an average price across all participating accounts, within a given custodian. We rotate the custodian in our trade order to give priority equally across our custodians. The average prices are then created on a Broker by Broker basis. The rotation and execution is intended to assure that no Client is advantaged or disadvantaged relative to others. We utilize the pro rata allocation methodology for all partially filled orders. Best Execution In selecting brokers for Client discretionary securities transactions, M&C seeks to obtain the best available price and execution. We do not, however, base broker selection decisions solely on whether the lowest possible commission costs may be obtained. Instead, we evaluate market liquidity and the various brokers as to the services they provide, including their reliability, responsiveness and trustworthiness, the quality of their research and general economic information, execution capability, operational capability, and financial condition. We rate these firms as to their performance with respect to these criteria and attempt to allocate commissions during the year in such a manner that brokers who 21  achieve the highest ratings receive a larger proportion of the commissions generated during the year. We have established an approved broker list which we maintain through joint coordination between our Research and Trading Departments. The traders’ ability to identify sources of liquidity will influence the selection of a broker for a particular trade. Trading Errors We define a trading error as 1) the failure to implement on a timely basis in a Client portfolio an Investment Team or lead portfolio manager’s decision with regard to the Model Portfolio unless not permitted by a Client guideline, restriction or constraint, or 2) implementing an Investment Team or lead portfolio manager’s decision which is not permitted by a Client guideline, restriction or constraint. We require that any trading error that may occur in Client accounts be reported immediately to the Chief Compliance Officer as well as to the Director of Operations, and that any such error be resolved promptly and, unless deemed immaterial, be communicated promptly to the Client. In every instance, we will prepare a written explanation detailing the circumstances and outcome of the error. In no case will we allow a Client account to suffer a loss resulting from a trading error caused by us. Soft Dollars Soft dollar practices or arrangements refer to the practice of an investment manager paying brokers for investment research and other brokerage services, either provided directly by the brokers or by others (known as third party providers), using commission dollars generated by client transactions. The research provided may be either proprietary for the broker or acquired externally. Under Section 28(e) of the Securities Exchange Act of 1934 (“Section 28(e)”), as interpreted by the SEC, investment managers are allowed to allocate brokerage transactions and to pay for brokerage and research services through higher commission costs, that is to pay for a bundled transaction which includes both execution and research costs, so long as the cost is commensurate with the value of research or services received and such services provide lawful and appropriate assistance in the performance of the investment decision-making responsibilities. Subject to meeting the primary objective of best execution, we select for portfolio transactions brokers which furnish research to us. To the extent permitted by Section 28(e) we may pay a commission on transactions in excess of the amount of commission another broker might have charged if we determine that such commission is reasonable in relation to the value of brokerage or research services provided by such broker, viewed in terms of either the particular account transaction or our overall responsibilities with respect to the Client. This research information is among many tools used in our analytical work, as described in Item 8 of this brochure, and in providing advice to Clients. We obtain research, as permitted under Section 28(e), which may benefit all of our Clients and not just those Clients that are paying for such research. We do not seek to allocate soft dollar benefits to Client accounts proportionately to the soft dollar credit the accounts generate. To the extent permitted by Section 28(e), we do receive some economic benefit as a result of soft dollar arrangements in that we do not have to produce or pay for the research. The following research is provided by various brokers through soft dollars: Economic, Stock & Industry Reports  Proprietary research information 22  Item 13: Review of Accounts M&C assigns each account to a portfolio manager; and at December 31, 2025, there are 4 in that position. The portfolio manager reviews Client holdings no less than weekly as to their conformance with the Model Portfolio of the respective strategy. Monthly performance numbers are reviewed by a designated officer to assure compliance with our written procedures relating to CFAI GIPS®. Our Procedures Manual requires portfolio managers and back-up portfolio managers to perform an annual review of their respective Clients’ investment objectives and guidelines. The number of accounts assigned to each portfolio manager depends upon the overall number of relationships for each as well as the levels of service required for individual portfolios. On an annual basis, the Compliance Department will select, unless all of a particular portfolio manager’s Clients have been recently reviewed, no fewer than one Client account per portfolio manager to review for compliance with the Client’s investment objectives and guidelines, and to verify the accuracy of the Client data in our proprietary databases. A report of this review is provided to the Chief Executive Officer as well as to any other portfolio managers for which information is missing or incorrect.. According to the Client’s specific requirements we provide monthly and/or quarterly written reports on their accounts. These reports can include (depending upon the Client’s request) a transaction ledger, an appraisal of portfolio holdings, a realized gain and loss statement, a performance report, and a purchase and sale report. In addition to monthly and/or quarterly correspondence discussing the portfolio and the investment outlook and regularly scheduled Client meetings, we encourage Clients to consult with us frequently about their portfolios. 23  Item 14: Client Referrals and Other Compensation In accordance with SEC Revised Marketing Rule 206(4)-1, we are allowed to compensate for Client referrals. Both cash and non-cash compensation must be considered, and the definition and scope of what constitutes “solicitation” have been expanded. Any arrangements we make for the payment of any referral fees to a solicitor will meet the requirements of SEC Rule 206(4)-1. M&C has an incentive plan that can pay ongoing cash bonuses for new business developed by members of the Firm. To the extent permitted by Section 28(e) and as described in response to Item 12, M&C has soft dollar arrangements and does receive some economic benefit as a result of these arrangements. 24  Item 15: Custody M&C does not directly maintain custody or possession of the funds or securities of Clients. Notwithstanding any language to the contrary within a Client’s agreement with its appointed Custodian, M&C does not have the authority to direct disbursements from a Client’s account except 1) to settle transactions, 2) for the payment of management fees, if applicable, and 3) to direct disbursements upon the written instructions from the Client. As a general rule, M&C does not accept standing letters of authorization from our Clients to initiate wire transfers to other accounts. However, we must be reasonably certain that the Client’s qualified custodian provides quarterly statements directly to them. We have procedures in place to perform due diligence in this regard, and we also include the following statement on the disclosure page of the appraisals we send to Clients on a monthly or quarterly basis: SEC Custody Rule 206(4)-2 encourages the comparison of our account statements with those received from your custodian. Please contact your custodian if you are not currently receiving a statement. 25  Item 16: Investment Discretion M&C’s standard investment management agreement states that we “shall have full power to supervise and direct the investment of the Account, making and implementing investment decisions, all without prior consultation with the Client, in accordance with such written objectives upon which Client and Investment Manager agree”. 26  Item 17: Voting Client Securities If directed by a Client, M&C will make decisions on voting of proxies in accordance with our guidelines (as amended from time to time) which are available upon request. We will consider proxies as a Client asset and will vote consistently across all Client portfolios for which we have discretionary voting authority in the manner we believe is most likely to enhance shareholder value. Where practical, we may consider requests to vote proxies in accordance with Client specified guidelines. If a Client’s shares are on loan at the time of voting, it is not our policy to request that the custodian recall the shares on loan. If we are authorized to make decisions on voting of proxies, we will have no obligation to furnish a Client any proxies, notices of shareholder meetings, annual reports or other literature customarily mailed to shareholders. Once we have been delegated discretionary voting authority, a Client may not direct how to vote the proxies. Clients who wish to adhere to a proprietary set of voting guidelines should exercise their right to reserve voting authority rather than delegating this responsibility to us. Potential Conflicts of Interest Should the situation arise where we act as an investment adviser to a company whose proxy we are authorized to vote or other potential conflicts arise, we will follow policy outlined in our Guidelines. It is against our policy for employees to serve on the board of directors of a company the stock of which we could purchase for our advisory Clients’ portfolios. Policy Guidelines We have established guidelines to outline our position on the most common issues addressed in proxy solicitations and to represent how we will generally vote such issues. However, an investment professional will review all proxy proposals to determine if shareholder interests warrant any deviation from these guidelines or if a proposal addresses an issue not covered in the guidelines. We have established a Proxy Committee that consists of at least three investment professionals and includes at least one research analyst and one portfolio manager. The Proxy Committee reviews proxy voting guidelines periodically and submits them to the Firm’s investment professionals for approval. We maintain electronically a record of proxy voting guidelines and their periodic updates. At least one member of the Proxy Committee will make proxy voting decisions within the framework established by our guidelines, which are designed to cast votes in the best interests of all Clients. We will maintain a record of any document created by us or procured from an outside party that was material to making a decision as to how to vote proxies on behalf of a Client or that memorializes the basis of that decision. 27  Administrative Procedures Where Investment Manager has been delegated discretionary voting authority, we will maintain records detailing receipt of proxies, number of shares voted, date voted and how each issue was voted. We will make these records available upon request to those Clients for whom we have proxy voting responsibility. We will maintain records of all written Client requests for information as to how we voted proxies on their behalf and of our written response to the Client’s written or verbal requests. We enlist the service of a third party to vote proxies according to our guidelines and to maintain such voting records. 28  Item 18: Financial Information Advocacy Wealth, inclusive of M&C, does not have any financial condition that is reasonably likely to impair our ability to meet contractual commitments to Clients. 29