ALDRICH WEALTH LP

Aldrich Wealth LP 5665 SW MEADOWS RD., STE 200 PORTLAND, OR 97035 503-620-5329 www.wealthadvisors.com MARCH 5, 2026 This brochure provides information about the qualifications and business practices of Aldrich Wealth LP. If you have any questions about the contents of this brochure, please contact us at 503-468-7200 or 888-299-3102. 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. is also available on the SEC’s website at information about Aldrich Wealth LP Additional www.adviserinfo.sec.gov. Aldrich Wealth LP is a registered investment adviser. Registration does not imply any level of skill or training. The oral and written communications of an adviser provide you with information from which you may determine to hire or retain an adviser. i  Item 2 – Material Changes We are updating this brochure as part of our annual amendment filing, which was last updated on March 25, 2025. The following is a summary of the material changes: Item 4 – Advisory Business: • We expanded the description of our financial planning services and we added that in our corporate retirement plan services, we now serve as an investment manager to a pooled employer plan. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss: • We updated the description of investment vehicles used in portfolio management and added tender offer funds. Item 14 - Client Referrals and Other Compensation: • We expanded our disclosure regarding the following: o We implemented a bonus program under which certain employees may receive compensation for referring new prospective clients to the firm. o We may receive occasional non-cash benefits from vendors. We have made improvements to wording throughout this brochure to address formatting and to provide further clarity to clients and prospective clients regarding the nature of our services, fees, and business practices. Our brochure is available free of charge and can be obtained by making a request to Luan Dollens, Chief Compliance Officer at 503-468-7200 or ldollens@wealthadvisors.com. Our brochure is also available on our website www.wealthadvisors.com, also free of charge. New brochures will be provided as necessary based on changes or new information, at any time during the year, without charge. Additional information about Aldrich Wealth LP is available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with Aldrich Wealth LP who are registered or are required to be registered, as investment adviser representatives of Aldrich Wealth LP. 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 ......................................................... 9 Item 7 – Types of Clients..................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 9 Item 9 – Disciplinary Information ....................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 11 Item 11 – Code of Ethics ................................................................................................................... 12 Item 12 – Brokerage Practices ........................................................................................................... 13 Item 13 – Review of Accounts ........................................................................................................... 15 Item 14 – Client Referrals and Other Compensation ............................................................................ 15 Item 15 – Custody ............................................................................................................................ 16 Item 16 – Investment Discretion ........................................................................................................ 17 Item 17 – Voting Client Securities ...................................................................................................... 17 Item 18 – Financial Information ......................................................................................................... 18 Brochure Supplement(s) iii  Item 4 – Advisory Business Aldrich Wealth LP (“Aldrich Wealth,” “firm,” “we,” “us,” and “our”) provides investment management, financial planning, and consulting services to its clients. Where appropriate, we will recommend that clients engage our affiliate, Aldrich CPAs and Advisors LLP (“Aldrich CPAs”), for tax and accounting services. Clients are never obligated to engage Aldrich CPAs for these other services. When clients engage both tax and wealth services, we will collaborate, taking into consideration each client’s unique financial and tax situation. Aldrich Wealth LP was formed in 1998 and has been in business continuously since. Aldrich Wealth is a partnership whose primary owner is AKT Services, LLP (a partnership owned by over 30 individuals). Aldrich Wealth offers its investment management services to two distinct types of clients within separate business divisions of the firm. We offer investment management and advisory services to individuals, businesses, trusts, family offices, and other entities within our Private Wealth Division. We also offer investment management to self-directed and trustee-directed retirement plans within our Corporate Retirement Plan (“CRP”) Services Division. Aldrich Wealth also serves as a sub-advisor to certain pooled investment vehicles within insurance products, called insurance dedicated funds (“IDFs”). We generally offer our investment management and advisory services for a fee based on assets under management or advisement. In certain cases, we provide financial planning, reporting and/or consulting services for an additional fee, which can be a flat fee or hourly rate. Base asset allocation guidelines are set by the firm’s Investment Committee (“IC”). Additionally, the IC is responsible for maintaining the firm’s investment philosophy, core investment principles, capital market assumptions, and the selection and monitoring of securities and fund managers used within portfolios. We utilize a variety of investment strategies when constructing a client’s portfolio. When selecting securities and determining amounts, we observe the investment policies, limitations, and restrictions imposed by each client. Private Wealth Services Aldrich Wealth provides tailored investment recommendations for Private Wealth clients, adhering to the guidelines established in alignment with each client’s unique needs, long-term goals, and risk profile. Clients will work with a dedicated investment advisor representative (“IAR”) who is responsible for determining and documenting the clients’ investment objectives, income level, risk tolerance, investment time horizon, tax circumstances, and other relevant financial factors (collectively referred to as the client’s “Financial Profile”). Clients are allowed to propose reasonable restrictions on the types of investments to be made for their accounts at any time, and we will promptly notify clients of any inability to honor such restrictions. Based upon the client’s Financial Profile, the client and IAR will agree upon an investment and risk allocation strategy to guide the client’s asset allocation or investment policy. While not providing tax advice, Aldrich Wealth evaluates the tax impact of investment decisions, and we employ strategic asset placement to enhance tax efficiency. This involves allocating investments across taxable, tax-deferred, and tax-exempt accounts based on the characteristics of the investments and their expected tax implications. Additionally, Aldrich Wealth incorporates tax efficiency into portfolio management when appropriate, including strategies such as tax loss harvesting. This involves identifying opportunities to realize losses in taxable accounts to offset gains and reduce taxable income, while maintaining the client’s desired investment exposure through asset replacement or similar securities. This strategy is applied based on the client’s specific tax circumstances and goals. For investment products, Aldrich Wealth will primarily utilize registered mutual funds and exchange-traded funds (“ETFs”) in asset allocation strategies, and occasionally individual equity and fixed-income securities such as US Government bonds, municipal bonds, and corporate debt securities. A portion of the assets within an account may also consist of cash or cash equivalents. To provide client specialized expertise and services, and further customize our portfolio management capabilities, we will recommend the use of third-party money managers and/or sub-advisors (collectively, “Independent Managers”) to manage all or a portion of the portfolio’s assets, where appropriate. These arrangements are typically structed as separately managed accounts (“SMAs”) where the Independent Manager assumes responsibility for implementing the investment strategy(ies) or model(s), conducting all related investment research, and executing all trading 1  decisions concerning the allocated assets on a discretionary basis. Aldrich Wealth serves as a co-advisor for the allocated assets, with responsibilities for monitoring the Independent Manager’s investment performance, ensuring adherence to the desired investment strategy(ies) or model(s), and evaluating the strategy’s continued suitability for our client. Aldrich Wealth further acts as the client’s primary point of contact, communicating any changes in the client’s investment needs, objectives, and limitations to the Independent Manager. Aldrich Wealth will also recommend, when appropriate, investment in interval funds, tender offer funds, and other pooled investment vehicles, including hedge funds and private equity funds, limited partnerships, alternative investment managers, and other private investment vehicles (collectively, “Alternative Vehicles”). These Alternative Vehicles have longer-term horizons and limitations on redemptions. Clients may be required to complete a Subscription Agreement, pursuant to which the client shall attest that they are qualified for investment and acknowledge the various risk factors. Please note, Alternative Vehicles tend to carry higher internal fees, may not be as liquid as other assets, and may carry additional expenses. Aldrich Wealth is not affiliated with any Independent Manager or Alternative Vehicle and selects these professionals based on various factors such as expertise, performance history, and investment philosophy. Our investment strategies and analysis are further explained in Item 8 of this brochure. After assets are invested, we assist clients in monitoring their portfolios and addressing ongoing financial and investment needs. We will offer our clients advice on a regular basis, discuss their investment and financial goals, design a strategy to help achieve their stated goals, and regularly monitor their portfolio of investments. Aldrich Wealth will make every effort to conduct at least one review annually for all clients, client participation is essential to ensure the review reflects their current situation. Investment management services are offered on a discretionary or non-discretionary basis as granted by the client in a written advisory agreement. The majority of our clients select discretionary services, providing us the authority to purchase and sell securities and other investment instruments in their account without obtaining their approval for each specific transaction. We act in a fiduciary capacity and only utilize this authority in a manner that is aligned with the individual or entity’s unique Financial Profile. For non-discretionary engagements, the services will be similar, but we are required to obtain your approval (verbal or written) for each recommended investment transaction before implementation. Aldrich Wealth may also provide additional services to clients, such as extended personal financial planning, estate planning, philanthropic strategy and administration, various family office services, and tax planning services. These services are tailored to meet the individual needs of the client and are all contracted with clients separately from the investment management services referred to above. Sometimes multiple services will be covered by one fee schedule or may be broken into different fee arrangements. Tax preparation services are typically made available through our affiliate, Aldrich CPAs and are separately contracted. Clients are never obligated to engage any of our affiliates for any additional services. Clients have the option to engage Aldrich Wealth to manage certain retirement assets held within their employer sponsored plan (“Plan Participant Management Services”). This service permits Aldrich Wealth to provide discretionary management of our client’s employer-sponsored retirement plan accounts, using the investment options available in the employer-sponsored plan (most commonly, defined contribution plans). Aldrich Wealth engages a third-party platform, Pontera Solutions, Inc. (“Pontera”), to facilitate discretionary management of these account assets, while maintaining the account administration through the client’s employer sponsored plan. Clients will enter into a separate addendum with Aldrich Wealth for this service and an approval process to provide access to the employer plan on the platform, including agreeing to Pontera’s terms and conditions. Once connected, we will review the current account allocations and rebalance the account in consideration of the client’s unique investment goals, needs, and limitations, as well as the limitations of the retirement plan. We may also take into consideration the client’s other assets managed by Aldrich Wealth. These accounts will be monitored on an ongoing basis, and changes will be made as deemed necessary. Aldrich Wealth is not affiliated with the platform provider, and we receive no compensation from them for using their platform, though we are charged to use their services, we bear the costs of the services. 2  From time-to-time, we may provide clients with access to services offered by third-party vendors such as identity theft monitoring services, budgeting software, and other services intended to enhance and add value to our client relationships (collectively, “Vendor Services”). In some instances, access to Vendor Services will be provided to the client on a complimentary basis, while in other instances, our firm may recommend Vendor Services to the client and the client will pay the vendor. Clients elect to access Vendor Services at their own risk and will typically be required to agree to the Vendor’s terms of service. Clients have the option to choose Aldrich Wealth’s specialized cash reserve management service, the Short Duration Solution. This service provides discretionary investment management in high-quality short-term debt instruments within a designated account at the same custodian where the client’s other assets are managed. The objective of this service is to generate additional yield on cash reserves by investing in relatively low-risk and low-duration securities. As this is a separate add-on service, the Short Duration Solution operates independently of the client’s broader investment allocation and investment objective for other advisory accounts. The account undergoes a similar review and service process to our Private Wealth services. In certain circumstances Aldrich Wealth will enter into a separate non-discretionary agreement with clients who qualify as an “accredited investor1” and or a “qualified client2,” under federal law, to identify private market investment opportunities, which can involve direct investment with an issuer or non-traded entity. Such private market direct investments involve extremely high risk and illiquidity. Clients who engage us for these services understand that such investments represent risk capital within their overall investment portfolio. This service will generally be offered in conjunction with our customary investment management services, and only to those who qualify, as described. Financial Planning and Consulting Services Financial planning is typically offered and provided to Private Wealth clients in conjunction with our investment advisory services. The level of planning provided will depend upon the assets under management and the complexity of the client’s individual circumstances, goals, and needs, and is documented in a separate agreement. The financial plan is informed by conversations and the data provided. Our objective is to help clients meet both short-term and long-term goals through strategic planning. Our services may include but are not limited to planning and strategy related to estate, retirement, education, insurance, social security, equity compensation, charitable giving, and risk management, as well as investment management. These services are further detailed within the agreement. Financial plans can be provided on a comprehensive or limited focus, depending on need. Clients retain the option to decline planning services and are not obligated to act on any recommendation provided. Clients can also contract with us for financial planning as a stand-alone service for a fixed or hourly fee. All such services require a separate agreement, setting forth the terms and conditions. Aldrich Wealth also offers consulting services. Portfolio consulting services are generally more limited in scope and may include recommendations on asset allocation and security selection, monitoring, and performance reporting on the accounts, and other types of customized analysis and reporting as requested by the client. We also offer consulting services designed to support complex, multi-generational wealth management needs beyond traditional investment advisory services. These services may include family governance advisory, philanthropic planning, and other consultative support. Corporate Retirement Plan Services 1 As defined under Rule 501 of Regulation D under the Securities Act of 1933, an “accredited investor” is an individual (or joint with spouse) who has greater than $1,000,000 in Investable Net Worth, or individual having annual income in excess of $200,000 in each of the two most recent years, or $300,000 in joint annual income with a spouse, and who further has a reasonable expectation of reaching the same income level in the current year. 2 As defined under Rule 205-3 of the Advisers Act, generally speaking, an individual or entity is a “qualified client” if he, she, or it has (1) $1,100,000 or more of assets under management with an investment advisor immediately after the investment of funds or (2) a net worth of $2,200,000 or more prior to investing (excluding the value of his or her primary residence). The foregoing thresholds are subject to periodic adjustments and may change over time. 3  In our CRP Services Division, we offer discretionary investment management services, non-discretionary investment advisory services, and/or retirement plan consulting services to employer-sponsored retirement plans and their participants. Depending on the type of plan and the specific arrangement with the sponsor, we may provide one or more of these services. Prior to being engaged by the sponsor, an Investment Advisory Agreement (“Agreement”) that contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act of 1974 (“ERISA”), as applicable, will be executed by all parties. Discretionary investment management for clients within the CRP Services Division are designed to allow the plan fiduciary to delegate responsibility for managing, acquiring and disposing of plan assets that meet the requirements of ERISA. We will perform investment management services through our investment advisor representatives (“IARs”) and charge fees as described and negotiated in the client’s Agreement. If the plan is subject to ERISA, we will perform these services as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21). The following services are examples of what can be performed: • Selection, monitoring, and replacement of Designated Investment Alternatives (“DIA”): We will review with Sponsor the investment objectives, risk tolerance and goals of the plan and provide to sponsor an Investment Policy Statement (“IPS”) with criteria to select, monitor and evaluate the plan's DIAs. • • Creation and maintenance of model asset allocation portfolios: If requested, we will create a series of risk- based models comprised of the plan’s DIAs and periodically reallocate and rebalance in accordance with the IPS or other guidelines of the sponsor. Selection, monitoring and replacement of Qualified Default Investment Alternatives (“QDIA”): We will select, monitor and replace the plan’s QDIA(s) in accordance with the IPS. • Management of plan funds: We will review investment objectives, risk tolerance and goals of the plan to select, monitor and replace the plan’s investments options. Non-discretionary fiduciary services to CRP clients are designed to allow the sponsor to retain full discretionary authority or control over assets of the plan. We will solely be making recommendations to the sponsor. We will perform these non-discretionary investment advisory services through our IARs, and charge fees as described and negotiated in the client’s Agreement. If the plan is covered by ERISA, we will perform these investment advisory services to the plan as a "fiduciary" defined under ERISA Section 3(21). We can provide the following non-discretionary services as selected by the sponsor: • Assist in establishing the Investment Policy Statement • Advice regarding DIAs • Advice regarding model asset allocation portfolios • Advice regarding QDIAs • Participant investment advice Consulting services to CRP clients are designed to assist the sponsor in meeting their fiduciary duties to administer the plan in the best interests of plan participants and their beneficiaries. Retirement plan consulting services are performed so that they would not be considered “investment advice” under ERISA. These services can include administrative support in reviewing objectives and options available through the plan, a review of plan committee structure and administrative policies/procedures, and/or recommendation about participant education and communication policies under ERISA 404(c). As part of our corporate retirement plan services, we act as a named fiduciary and investment adviser to the RetireBridge 401K Plan, a Pooled Employer Plan (“PEP”). We provide the same services listed above as a 3(38)- investment manager, and work with unaffiliated third-party service providers to support plan operations. We may recommend participation in the RetireBridge 401K Plan to employers for whom a pooled plan may provide ease of plan establishment, reduced fiduciary responsibility, and potential cost efficiencies, depending on the employer’s specific facts and circumstances. IDF Sub-Advisory Services 4  When applicable, we may recommend that a client who has purchased an insurance product, invest in an IDF that we manage. Each of the IDFs is formed as a separate series of a multi-series domestic limited partnership (the “SALI Partnership”). The series is offered only to insurance company investors on behalf of certain of their segregated separate accounts that are funded by life insurance and variable annuity contracts issued to policy owners by such investors. SALI Fund Management, LLC (“SALI”) is the investment advisor of the SALI Partnership and has engaged Aldrich Wealth to serve as a sub-advisor with respect to investments made with the IDF. On the basis of discretionary investment recommendations made by Aldrich Wealth, SALI invests the assets of the IDF in Investment Vehicles, Separately Managed Accounts, private market securities, mutual funds, ETFs, and individual securities. We typically do not accept specific investment restrictions imposed by clients or investors with respect to the management of assets within an IDF. The IDFs are neither registered under the Securities Act of 1933, as amended, nor registered under the Investment Company Act of 1940, as amended. Accordingly, interests in the IDF are offered exclusively to investors satisfying the applicable eligibility and suitability requirements within private placement transactions. No offer to sell interests in the IDF is made by the descriptions in this brochure. Assets Under Management As of December 31, 2025, Aldrich Wealth calculated that we managed $7,615,331,850 of client assets, of which $6,412,231,464 are managed on a discretionary basis and $1,203,100,386 on a non-discretionary basis. IRA Rollovers Investors considering rolling over assets from a qualified employer-sponsored retirement plan to an individual retirement account (“IRA”), or from one IRA to another, should review and consider the advantages and disadvantages. Clients typically have options regarding assets as follows: (i) leave the money in the current account or plan, if permitted, (ii) roll over the assets to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an IRA, or (iv) cash out the account value (depending upon the client’s age, this could result in adverse tax consequences). When we provide investment advice to clients and prospects regarding their retirement plan accounts or IRAs, we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates a conflict of interest because it creates a financial incentive for our firm to recommend a rollover to a client (i.e., receipt of additional fee-based compensation). Due to the foregoing conflict of interest, we operate under a special rule that requires us to act in the client’s best interests and not put our interests ahead of the client. Under this special rule’s provisions, we must: follow policies and procedures designed to ensure that we give advice that is in each client’s best interests;  meet a professional standard of care when making investment recommendations (give prudent advice);  never put our financial interests ahead of the client when making recommendations (give loyal advice);  avoid misleading statements about conflicts of interest, fees, and investments;   charge no more than a reasonable fee for our services; and  give the client basic information about conflicts of interest. It is a conflict of interest for us to recommend clients roll retirement plan and IRA accounts to be managed by us because the assets increase our assets under management and, in turn, our advisory fees. Generally, we will provide retirement investors with education regarding the pros and cons of their choices and information about our services and allow them to make an independent decision about their assets. Should we make a recommendation to rollover assets from an employer plan or an IRA to an IRA to be managed by Aldrich Wealth, we will do so when we believe it is in your best interest. We have a fiduciary obligation to provide services aligned with client’s best interest. No client or prospect is under any obligation to roll over plan or IRA assets to an account managed by Aldrich Wealth or to engage Aldrich Wealth to monitor and/or manage assets while maintained by their employer. A plan participant may establish a client relationship with Aldrich Wealth in various ways, but in each case, the provision of services to that plan participant will be provided under a separate agreement. 5  Item 5 – Fees and Compensation Aldrich Wealth is a fee-based registered investment advisor, and we do not receive commissions on the sale of investment products to clients. We commonly charge an advisory fee based on all assets under management (including cash) for our services, however, in certain arrangements we charge an hourly fee or fixed fee. Fees are generally negotiable and may vary from the standard schedules below based on complexity, size, and other considerations at our discretion. We offer discounts on our fees to employees. It is possible that some individual clients pay fees higher or lower than the standard fee schedules below, based on various factors, including legacy fee schedules in place at the time the client relationship was initiated. If we amend any client’s fee schedule, we will provide the client with 30 days’ advance written notice before any increase becomes effective. We may reduce fees at any time without prior notice. Additional details regarding fees and calculations will be outlined within the Investment Advisory Agreement, which must be accepted by the client before rendering any services. All tax planning and tax preparation services are provided under separate agreements through Aldrich CPAs. Private Wealth Services Compensation to Aldrich Wealth for its services to clients within its Private Wealth division will be calculated quarterly, in advance, in accordance with the client’s written fee schedule within their Investment Advisory Agreement. Certain trustee-directed qualified plans are also managed on the Private Wealth standard fee schedule, depending upon the size and complexity of services the plan requires. Aldrich Wealth may provide some level of financial planning and estate planning in addition to investment management services to clients under this fee schedule. The level of planning provided will depend upon the assets under management and the complexity of the client’s situation. Fees are based on the entire value of the account (or portfolio of accounts), unless otherwise agreed in writing, as of the last business day of the previous quarter. Value of the account will include cash or cash equivalents, and accrued interest in bond/fixed income instruments, as well as investments with limited liquidity, such as Alternative Vehicles. Timing variations in transaction postings may cause slight differences between the value used for calculating the Advisory Fee and the custodian’s statement balance. Account balances for Held Away Services will also be included for the calculation of Advisory fees. Aldrich Wealth will adjust the fee for deposits and withdrawals within the quarter, typically at $10,000 or more. Below is our current standard fee schedule for Private Wealth investment services – fees are billed at a flat rate across the entire value of the account (or portfolio of accounts) within the client relationship, based on where the client assets fall within the fee schedule: Assets Under Management Annual Fee Up to $2,000,000* 1.00%* $2,000,001 to $5,000,000 0.85% $5,000,001 to $10,000,000 0.70% $10,000,001 to $25,000,000 0.60% Over $25,000,001 Negotiable *Minimum Annual Fee Requirement: A minimum annual advisory fee of $10,000 applies to each client relationship. If the advisory fee calculated at the standard asset-based schedule does not equal at least $2,500 per quarter the minimum fee will apply. As a result, for client relationships with less than $1,000,000 in assets under management, the effective advisory fee may exceed 1% annually. Aldrich Wealth reserves the right, at its discretion, to waive or reduce this minimum fee based on various factors that may include, but are not limited to, the scope and complexity of service provided, anticipated future business, and other overall client relationship considerations. Any fee adjustments are made on a case-by-case basis and at the sole discretion of Aldrich Wealth. Advisory fees for the initial billing period will be collected in arrears and added to the first full billing quarter billed in advance. The initial billing will be based on the market value of the Account at the end of the first full billing quarter 6  and pro-rated for the days in the quarter in which services were provided. As a result, the first full billing period may be higher than subsequent billing periods. Clients with more than $25 million in managed assets may be eligible for additional family office or ultra-high-net-worth consulting services. The scope of such services is determined based on the client’s needs and will be documented in a separate agreement or addendum. Fees for these consulting services are negotiated and are based on the nature, scope, and complexity of the services to be provided. Clients will generally choose to pay fees by check or have fees debited from their investment accounts by the account custodian upon submission of a request to the custodian by Aldrich Wealth. Payment of fees may result in the liquidation of a portion of the client’s securities if there is insufficient cash in the account at the time that fees are assessed. Fee invoices are provided to clients within their performance reports. If the relationship is terminated, or an account is closed, during the quarter a pro-rated refund of the fee will be provided shortly after the termination. For purposes of determining value, securities and other instruments traded on a market for which actual transaction prices are publicly reported shall be valued at the last reported sale price on the principal market in which they are traded (or, if no sales occur on such a date, then at the mean between the closing bid and asked prices on such date). Other securities and other instruments shall be priced using the last known value or the original investment value, or a pricing service or through quotations from one or more dealers. For Short Duration Solutions services, clients will pay an annual fee equal to thirty-five basis points (0.35%) on all assets held within the specified account. The value of the Short Duration Solution account will be independent of other advisory accounts held by the client subject to the advisory agreement and advisory fee, just as it is also independent of the investment allocation of the other accounts receiving investment management services. The fee for Short Duration Solutions services will be calculated separately and in the same manner as described above. For those clients engaging us for private market direct investment opportunities, depending upon the complexity of the investment, we may charge additional fees that will include performance-based fees and an asset under management fee, as described above. Fees for this service will be negotiated with the client and will vary from investment to investment. Performance Fees will be calculated and billed in arrears as further described and agreed upon within the private investment advisory agreement. Please also see Item 6 of this brochure for additional information. Financial Planning and Consulting Services Financial planning is typically offered and provided to Private Wealth clients in connection with our investment advisory services. However, we also offer financial planning as a stand-alone service outside of investment advisory services, and that will generally be billed at $2,500 per plan. We may charge an additional fee to update that plan in the future, upon request from the client. Fees for consulting services or more complex planning services are charged on an hourly or fixed basis. Hourly rates generally vary between $150 and $500 while fixed rates may also be negotiated. All rates will generally be based on the scope, complexity, and level of services provided. All fees and services for financial planning and consulting services will be detailed in a separate agreement or addendum prior to providing services. These fees are billed and invoices as agreed upon separate. If terminated prior to services being delivered, we will refund any prepaid fees on a prorated basis. Corporate Retirement Plan Services Compensation to Aldrich Wealth for its services to clients within its Corporate Retirement Plan Division will be calculated quarterly, in arrears, in accordance with the client’s written fee schedule within their Investment Advisory Agreement (however, some trustee-directed qualified plans are managed on the Private Wealth standard fee schedule as noted above). The fee will be charged in arrears, either by the recordkeeper or by Aldrich Wealth, based on our written agreement with the client. The fee will be calculated based on the plan’s quarter end market value or using 7  the average daily balance method – dependent on the recordkeeper’s fee calculation method or reporting capabilities. If the client terminates our services during the quarter, the fee due will be pro-rated by the number of days services were provided within the quarter. Corporate Retirement Plan clients may receive revenue sharing credits generated by certain mutual fund investments held within participant accounts. Aldrich Wealth does not retain any of these revenue sharing credits as compensation. Each plan determines how to handle any such revenue generation. The fee schedule below represents the tiers of our fee schedule for Corporate Retirement Plan Services. Clients may be on different fee schedules. Fees are negotiable and pricing will depend on the services being offered. Assets are generally billed at a flat rate. Assets Up to $2,500,000 $ 2,500,001 – $ 5,000,000 $ 5,000,001 – $10,000,000 $10,000,001 – $20,000,000 Over $20,000,000 Maximum Annual Fee 0.67% or $15,000 (the greater) 0.60% 0.50% 0.40% Negotiable In determining the value of the account for purposes of calculating any asset-based fees, Aldrich Wealth will rely upon the valuation of assets provided by the plan's custodian or recordkeeper without independent verification. Plan clients will either authorize the custodian or recordkeeper to collect and pay the fees directly to Aldrich Wealth from plan assets, or the plan sponsor will agree to pay the fee by check or other method. Certain plan clients may agree to a flat fee, payable quarterly in arrears, or a special project fee for services, including but not limited to financial wellness programs, additional participant engagement, or other special service projects. These fees will be negotiated directly with the plan client and will vary depending on the complexity of the plan and the service work requested. IDF Sub-Advisory Services For compensation for its sub-advisory services for IDFs, Aldrich Wealth receives a portion of the management fee received by SALI as the investment advisor to the IDF. The Management fee typically ranges from 0.15% per annum to 0.50% per annum of the net asset value and is generally payable on a monthly basis. SALI will calculate and debit the total fees due, retain their portion, and submit our share to us. Clients who invest in an IDF should refer to the private placement memorandum or other offering documents for detailed information with respect to the fees. This information is a summary only and is qualified in its entirety by such documents. Other Fees and Expenses The custodian will typically have additional fees that can include trading fees for execution of transactions (though not all trades have transaction fees), account fees, margin fees, wire fees or holding charges, depending upon the nature of the arrangement. These fees are separate from our firm’s advisory fees and will be disclosed by the custodian. Aldrich Wealth does not receive any portion of these fees. Item 12 further describes the factors that Aldrich Wealth considers in selecting or recommending custodians for client transactions and determining the reasonableness of their compensation. Separate and in addition to the advisory fees, the client shall also bear the client’s proportionate share of any mutual funds, ETFs, other pooled investment vehicles, and insurance products’ marketing and advertising expenses (12b-1 fees), management fees, and other operating expenses. These fees are disclosed in the prospectus issued by each mutual fund, ETF, other pooled investment vehicle, and/or insurance product. Aldrich Wealth does not receive any portion of these expenses as revenue. Where clients have assets allocated to SMAs or other Alternative Vehicles, they will pay an additional sub-advisor fee to those Independent Managers, depending upon the nature of the arrangement, which is separate from the advisory fee paid to Aldrich Wealth. These fees will be debited and paid directly from the Client’s assets being advised by the 8  appointed Independent Manager. The details of these fees will be disclosed in the prospectus or other offering or disclosure documents. Aldrich Wealth does not receive any portion of these fees. Item 6 – Performance-Based Fees and Side-By-Side Management Aldrich Wealth does not generally charge performance-based fees (fees based on appreciation of the client’s assets) as part of its customary investment management services. As an exception, for certain private market direct investment opportunities, Aldrich Wealth will enter into a separate non-discretionary agreement where the compensation to us is based on the performance of the investment. Performance fees create a financial incentive for us to recommend a client’s assets to riskier or more speculative investments than we would otherwise (in the absence of such an arrangement) to secure greater profits in the receipt of the performance fee. We address this conflict by only offering this type of arrangement to accredited investors and qualified clients as defined in federal law, and only to those clients who understand that such investments represent risk capital within their overall investment portfolio. We will additionally only make such recommendations when we believe they are in the client’s best interest. Assets subject to performance fees may also be subject to an asset under management fee, depending on the investment and amount of oversight required, that would be in addition to the performance fee. Item 7 – Types of Clients Aldrich Wealth provides investment management, consulting, planning, and tax services to individuals, high-net- worth individuals, corporations, limited liability companies, retirement plans (including 401(k), 457(b), 403(b) and 401(a) plans), other trusts, foundations, not for profit organizations, and/or other business entities. Minimum account sizes are negotiable and dependent upon a number of factors that go into our client acceptance process. Due to our $10,000 minimum annual advisory fee per client relationship, we may generally avoid relationships where fees could be considered excessive, though we may waive the minimum in our discretion. Certain issuers of private investment opportunities may require the Client to be an Accredited Investor and/or a Qualified Client Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our investment strategies and advice will vary depending upon your specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Additionally, restrictions and guidelines affect the composition of portfolios. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. In general, investing in securities involves the risk of loss – including the possible loss of principal - that clients should be prepared to bear. Aldrich Wealth has created multiple asset allocation models that are designed to provide different expected risk and return combinations. The allocations range from conservative (lower risk and lower expected returns) to aggressive (higher risk and higher expected returns). Each allocation is designed to provide an appropriate return for the selected level of risk (also called standard deviation). Portfolios are diversified across multiple asset classes to help ensure broad diversification. with respect to style (growth and value), geographic exposure, market capitalizations, duration, yield, and credit risk. Allocation ranges (minimums and maximums) are utilized to maintain a consistent strategic asset allocation and support rebalancing. Aldrich Wealth uses third-party asset allocation and trading software that is robust in terms of functionality and flexibility. Aldrich Wealth assembles risk, return, and correlation data from external sources and historical data to develop capital market assumptions that are employed directly in asset allocation modeling. Historical data is generally provided by Morningstar, Inc. Aldrich Wealth believes long-term historical data for the current market environment are reliable sources for framing clients’ expectations regarding future investment performance. To 9  supplement our in-house investment research and analytical work, we engage with an unaffiliated consultant, Fiducient Advisors. Aldrich Wealth considers a wide array of asset classes and styles when allocating accounts. Those that have historically provided competitive risk-adjusted returns are considered for inclusion. For clients with unique risk, return, and liquidity profiles, additional asset classes may be included to potentially enhance returns and/or reduce risks. Aldrich Wealth uses a combination of active and passive management.  Passive management is generally associated with investments where the portfolio’s performance closely tracks a particular market index by holding a similar portfolio or market/sector exposure.  Active management generally includes managers that conduct research and implement portfolios that diverge from benchmarks and typically have higher fees. Aldrich Wealth monitors asset classes and attempts to determine which asset classes offer the best opportunity to add value by using active managers. In situations where active management has generally failed to consistently improve risk-adjusted performance, a passive approach is generally used. Equity managers are generally divided based on market capitalization (large cap, mid cap, and small cap), management style (value, growth, and core), strategy (active or passive), and region (US or Non-US). The inclusion of value and growth styles supports shifting assets from one style to another in situations where a style bias may be beneficial. Aldrich Wealth also includes alternative investments where appropriate. Alternative investments offer some unique characteristics relative to traditional equity and fixed income investments. Historically, alternative investments are not highly correlated to stocks and bonds and provide additional diversification benefits. Some non-registered alternative investments and private equity investments typically require a long-term commitment and are generally illiquid in nature. Investors in these funds are subject to initial qualification based on income, net worth, and/or investment acumen. Where appropriate, Aldrich Wealth uses mutual funds, ETFs, SMAs, interval funds, tender offer funds, alternative investments offered through third-party platforms, and direct investments in unregistered funds through limited partnerships or private equity and private credit investments.  Mutual Funds: A mutual fund is an investment vehicle that pools money from many investors to purchase a diversified portfolio of securities, such as stocks, bonds, or other assets. Investors own shares of the fund and participate proportionally in their gains, losses, income, and expenses, which are managed by a professional investment manager.  ETFs: An ETF is an investment vehicle that holds a basket of securities, such as stocks or bonds, and is designed to track a specific index, sector, or investment strategy. ETF shares trade on an exchange like individual stocks, and investors generally benefit from diversification, transparency, and typically lower costs than mutual funds.  SMAs: To obtain specialized expertise and services to benefit the client we will recommend the use of SMAs, managed by unaffiliated Independent Managers. In an SMA, the client owns individual securities directly, and the portfolio is managed in accordance with the agreed-upon investment philosophy. Aldrich Wealth acts as an advocate for the client but does not have day-to-day control over an Independent Manager’s conflicts of interest, daily trading activity, and other internal operational practices.  Interval Funds: Continuously offered registered closed-end funds whose shares do not trade on a secondary market. Instead, the fund periodically (typically monthly or quarterly) offers to repurchase a limited portion of outstanding shares at the net asset value. Repurchase offers are subject to fund limitations and manager discretion and liquidity is not guaranteed. Accordingly, interval funds should be considered illiquid investments. 10   Tender Offer Funds: Tender offer funds are also continuously offered, registered closed-end funds with no secondary market for their shares. Liquidity is limited and provided only through periodic tender offers, which are made at the discretion of the fund’s board of directors and are not required to occur on a regular schedule. As a result, tender offer funds should be considered illiquid investments.  Alternative Investments: Investments in these assets may be accessed through alternative investment platforms that typically offer reduced minimum investment requirements, which commonly range from $100,000 or $250,000, although may vary by investment. The platforms may also provide due diligence support. Participation is generally limited to investors who meet applicable investor qualification standards such as Accredited Investors or Qualified Clients status. Liquidity varies depending upon the investment type and structure and may range from monthly liquidity to extended lock-up periods of up to 10 years or more. These investments are generally long term. Offering documents for each investment will describe associated risks and clients are encouraged to review and carefully consider those disclosures prior to investing.  Limited Partnerships or Private Market: For investors who meet the Qualified Purchaser definition under applicable regulations, we may introduce direct investments in limited partnership structures or other private market investments. These investments typically require long holding periods that can extend beyond 10 years and may also pose higher risk, as well as the potential for higher returns compared to traditional investments. Offering Documents for each investment will describe the associated risks, and clients are encouraged to review and carefully consider those disclosures prior to investing. Aldrich Wealth is focused on providing competitive after-tax returns. Therefore, the investment process considers such factors as clients’ tax rates, the types of accounts available (taxable or deferred), embedded and realized gains, tax loss harvesting, and where certain assets are held. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Aldrich Wealth or the integrity of Aldrich Wealth’s management. Aldrich Wealth has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Carl J. Pinkard, Principal and Vice President of Aldrich Wealth is also associated with Aldrich Capital Advisors LP and a Registered Representative of Pacific Coast Capital, LLC, a limited-purpose, FINRA-registered broker-dealer owned by Aldrich Services, LLP. Clients needing business transition consulting, or M&A services, may be referred to Aldrich Capital Advisors LP and, if broker-dealer services are required, to Pacific Coast Capital, LLC. Mr. Pinkard may receive commissions for transactions involving Pacific Coast Capital, LLC, which does not custody securities for Aldrich Wealth client accounts. These relationships create a potential conflict of interest, as Aldrich Wealth may favor affiliated entities over others. To mitigate this, we fully disclose these relationships before any client engagement. Aldrich Wealth LP is owned by AKT Services, LLP (“AKT”) and Aldrich Services LLP (“Aldrich Services”). Aldrich Wealth also shares a physical location with several of the affiliate companies listed here. AKT is a parent company and is owned by individual partners. AKT Business Services PVT LTD provides outsourced staffing services, including investment analysis support to Aldrich’s US companies, and is owned by AKT RPS International LLC and Aldrich Services. Aldrich CPAs also wholly-owns Aldrich HR & Payroll Solutions, LLC. Aldrich Services provides management services to many of its affiliated companies in the US and is owned by AKT and Aldrich CPAs and Advisors LLP. Aldrich Services owns Aldrich Solutions LLC, which offers consulting to assist its clients with business operations and technology efficiency. Aldrich CPAs provides accounting, tax, and consulting services, and is majority owned by AKT. The tax planning and tax preparation services are provided by Aldrich CPAs, an affiliate of Aldrich Wealth. This arrangement has the potential to create a conflict of interest because we have an incentive to recommend Aldrich CPAs to Aldrich Wealth clients needing these services over other unrelated accounting firms. Likewise, Aldrich CPAs will recommend Aldrich 11  Wealth to its clients needed investment management services over other unrelated wealth management firms. In order to mitigate this conflict of interest, we fully disclose the relationship between Aldrich Wealth and Aldrich CPAs to clients needing accounting services prior to the client entering into any agreement with Aldrich CPAs, and to any client entering into any agreement with Aldrich Wealth. Our firm and individuals associated with our firm do not have any proprietary or material interest in any Independent Manager or Alternative Vehicles that we recommend to our clients. However, clients are advised that certain employees of Aldrich Wealth may serve as board members of certain Independent Managers or direct private investment entities that we may recommend for investment to our clients. Our employees may receive reimbursements in connection with their board participation. Compensation for board positions may be allowed after approval and proper disclosure to affected clients. These arrangements are unrelated to our client’s participation but could be viewed as creating a conflict of interest insofar as they may create a financial incentive for Aldrich Wealth’s personnel. We will advise our clients promptly of the existence of any board positions or other managerial roles Aldrich Wealth or its personnel may possess in any issuers recommended for investment to clients. Item 11 – Code of Ethics Aldrich 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, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons at Aldrich Wealth must acknowledge the terms of the Code of Ethics annually, or as amended throughout the year. Our Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests of our employees will not interfere with making decisions in the best interest of our clients. Employees are permitted to maintain personal securities accounts (including accounts where they have beneficial interest), provided that any personal investing conducted by the employee is consistent with Aldrich Wealth’s personal trading guidelines and applicable regulatory requirements. Subject to satisfying this policy and applicable laws, officers, directors, and employees of Aldrich Wealth and its affiliates may trade for their own accounts in securities that are recommended to and/or purchased for Aldrich Wealth’s clients. Employee trading is monitored under the Code of Ethics, to reasonably prevent conflicts of interest between Aldrich Wealth and its clients. To request a copy of our Code of Ethics, please contact Luan Dollens, Chief Compliance Officer, at ldollens@wealthadvisors.com. Aldrich Wealth serves as a named fiduciary and investment adviser to the RetireBridge 401(k) Plan, a PEP. As a result, Aldrich Wealth has an incentive to recommend participation in the PEP to employers over other retirement plan options, which presents a conflict of interest. Aldrich Wealth addresses this conflict through its fiduciary obligations, by evaluating whether participation in the PEP is appropriate based on each employer’s specific facts and circumstances, and by providing full and fair disclosure regarding plan features, costs, and alternatives. We are not affiliated with the third-party administrator or recordkeeper engaged by the RetireBridge PEP. Certain employees and affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with Aldrich Wealth's obligation of best execution. In such circumstances, the employee/affiliated and client accounts can share commission costs equally and will receive securities at a total average price. Aldrich Wealth will retain records of the trade order (specifying each participating account) and its allocation. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any exceptions will be documented and reviewed by the Chief Compliance Officer. Aldrich Wealth has a policy prohibiting principal or agency cross securities transactions in client accounts. Additionally, the firm does not facilitate cross trades between client accounts. A principal transaction occurs when an adviser, acting on behalf of its own account or an affiliated broker-dealer’s account, buys from or sells securities to a client. An agency cross transaction occurs when an adviser, or a party under its control or common control, acts as a broker for both the client and another party in the same transaction. These types of transactions are typically associated with advisers 12  who are dually registered as broker-dealers or have affiliated broker-dealers. Aldrich Wealth is not dually registered, and our affiliated broker-dealer has a limited purpose providing services for mergers and acquisitions. Item 12 – Brokerage Practices Aldrich Wealth does not maintain custody of client assets, although we are deemed to have custody of assets when clients give us authority to withdraw assets for specific purposes from their account as described below in Item 15 – Custody. Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer, bank, and/or retirement plan platform or recordkeeper. Certain alternative or private investments will be held directly with the issuer. Aldrich Wealth will use its discretion in recommending a custodian, while the client will make the final decision by entering into an account agreement directly with such custodian. For Private Wealth services and some Retirement Plans, Aldrich Wealth will generally request and recommend clients to use Charles Schwab & Co., Inc. (“Schwab”) a registered broker-dealer, member FINRA & SIPC, as the qualified custodian. Aldrich Wealth contracts with custodians and in doing so, works to negotiate the best possible rates and fees for our Private Wealth clients as compared to the retail rates for similar services. Corporate Retirement Plans clients will select a custodial recordkeeper platform to maintain assets and will do so based on their plan criteria. Aldrich Wealth is independently owned and operated, and we are not affiliated with any custodian or recordkeeper. We will facilitate and assist clients with account-opening paperwork. In selecting or recommending a broker-dealer or custodian for Private Wealth clients, Aldrich Wealth will comply with its fiduciary duty to obtain best execution and with the Securities Exchange Act of 1934 and will take into account such relevant factors as price, reliability and financial responsibility, the ability to effect transactions, particularly with regard to such aspects as timing, order size and execution of orders, the research and related brokerage services provided, notwithstanding that the account may not be the direct or exclusive beneficiary of such services, breadth of available investment products, and any other factors Aldrich Wealth considers to be relevant. Once a broker/dealer or custodian is chosen, Aldrich Wealth does not generally permit clients to direct brokerage for specific trades. For client accounts maintained at Schwab, Schwab does not generally charge separately for custody services but is compensated by account holders through service fees and/or transaction-related fees (commissions) for securities trades that are executed through them and by earning interest on uninvested cash in your account in Schwab’s Cash Features Program. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. We have determined that having Schwab execute most trades (for Private Wealth services) is consistent with our duty to seek “best execution” of client trades. By using another broker or dealer clients may pay lower transaction costs. Schwab Advisor Services is Schwab’s business servicing independent investment advisory firms like Aldrich Wealth. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. These support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Schwab’s institutional broker services include access to a broad range of investment products, execution of securities transactions and custody of client assets. The investment products available include some to which we might not otherwise have access or that would require a significantly higher minimum investment by our clients. These services generally benefit clients. Schwab also makes available to us other products and services that benefit us, but do not directly benefit our clients. These services assist us in managing and administering our client’s accounts and operating our firm. These services may include research-related products and tools (both Schwab’s own and that of third parties); consulting services; access to a trading desk serving Advisor participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money 13  managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to Aldrich Wealth by third-party vendors. Additionally, publications and conferences on practice management, occasional business entertainment of personnel, information technology, business succession, regulatory compliance, and marketing. Some of these services may be offered directly by Schwab or arranged to be provided through third-party vendors to us. If client accounts were not maintained at Schwab, we would be required to pay for these services from our own resources. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on client interest in receiving the best value in custody services and the most favorable execution of your transaction. This is a conflict of interest. As a fiduciary, Aldrich Wealth endeavors to act in its clients' best interests. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. We will review all custodial options from time to time to ensure that clients continue to benefit in scope, quality, and price of services from our selection of available custodians. Please see further discussion under Item 14 below. In the past, Aldrich Wealth received client referrals from TD Ameritrade through participation in TD Ameritrade AdvisorDirect program. While this program has been discontinued, Aldrich Wealth still receives some benefits through its previous program participation. Please see the related disclosure under Item 14 below. Currently, Aldrich Wealth does not recommend broker-dealers to clients based on our interest in receiving client referrals. When appropriate to the management of the client’s account, Aldrich Wealth will, on occasion, recommend that all or a portion of the assets in the client account be managed by a third-party Independent Manager within a SMA or other Alternative Vehicle, as noted in Item 4 of this brochure. Except to the extent the client directs otherwise, Aldrich Wealth is authorized to use its discretion in selecting or changing an Independent Manager without prior notice to the client. The client may be required to execute a limited power of attorney with such Independent Manager selected by Aldrich Wealth under this section. Certain Alternative Vehicles will require clients to submit subscription documents in advance of making such an investment and when requesting a withdraw of assets. Order Aggregation: Aldrich Wealth is authorized in its discretion to aggregate purchases and sales and other transactions made for client accounts with purchases and sales and other transactions in the same or similar securities or instruments for other clients of Aldrich Wealth. Aggregating trades allows us to execute trades in a timely, more equitable manner. When transactions are aggregated, the actual prices applicable to the aggregated transactions will be averaged, and each client account transaction will be fulfilled at the average price obtained. Each transaction will be charged any applicable transaction fees at a flat rate – transaction fees are not pro-rated by the size of the transaction or any other criteria. Order aggregation is separately completed at each custodian. Should an order not be completely filled, we will pro-rate the order as previously described. There are times when we are unable to aggregate and execute orders across model groupings of accounts, necessitating the execution of orders over time. In such cases, we will trade rotation methodology by model grouping designed to avoid favoring one group of accounts over another and to treat clients equitably over time. We strive to implement allocation changes as quickly and equitably as possible. In rare cases, if we determine that pro rata allocation is not appropriate under the particular circumstances, the allocation will be made based on other factors that we deem appropriate, including, without limitation, the avoidance of a client holding odd lots or similar de minimis number of shares or the factors. In such cases, Aldrich Wealth will increase or decrease the number of securities that would otherwise be allocated to each client by reallocating the securities in a manner that Aldrich deems fair and equitable to clients over time. Trade Corrections: Aldrich Wealth has a policy to minimize the occurrence of trade errors. We strive to detect and resolve any errors in a timely manner. Errors will be corrected to the benefit of the client and clients will not bear financial harm from an error caused by our firm. Schwab will cover errors caused by our firm that amount to less than $100, thus providing an economic benefit to us. We will be responsible for errors over the amount of $100. Errors that create a profit that cannot legally be maintained by the client will be donated by the custodian to a charity that the custodian selects. 14  Item 13 – Review of Accounts Our investment team meets on a regular basis to review our investment strategies in the aggregate. When the team deems it necessary or appropriate, we will implement changes to our investment strategies. Private Wealth Services We will monitor client accounts on an ongoing basis. Based upon the client’s Financial Profile, the client and IAR will initially agree on an investment and risk allocation strategy to guide the client’s asset allocation or investment policy. Reviews are then generally conducted quarterly by the investment team and individual advisors, primarily for the purpose of assuring continued general alignment with the financial goals outlined in each client's investment policy and/or notes to the client file. Clients should notify their advisors of any changes in their personal situation or financial circumstances that may affect their investment policy or noted allocation created for them. Aldrich Wealth advisors will make every effort to conduct at least one review annually with each Private Wealth client, and client participation is essential to ensure the review reflects their current situation. Clients may decline this offer for an annual review. Material additions to, or subtractions from, an account will often trigger additional portfolio reviews. The Chief Investment Officer also reviews quarterly the composite performance of client accounts managed similarly. Individual account performance that diverges materially from the composite will also trigger specific portfolio review. Clients will receive statements directly from the custodian of their account at least quarterly. Custodial statements include a list of account holdings and their market value as well as transactions occurring during the report period. Some clients receive quarterly reports from Aldrich Wealth that include allocation of the portfolio, the performance of the portfolio during the specified date range, a comparison of the portfolio’s actual allocation versus its intended risk allocation, a list of portfolio assets and their market value, and a breakdown of the performance of the portfolio. Performance calculations are computed by our portfolio management software from downloads of account activity and security prices provided electronically by each of our broker/dealer custodians. Certain private investments will be held directly with the issuer and require a manual entry into our performance software system. Financial Planning and Consulting Reviews Financial Planning clients that receive standalone services do not receive updated reviews of their written plans unless the client takes action to schedule a financial consultation with us. Our firm does not provide ongoing services when financial planning is requested as a standalone service. Consulting clients will receive services as outlined in their advisory agreement. Such clients will receive ongoing services as stipulated for the agreed amount of time, which can be ongoing until such time the client wishes to terminate the service. Corporate Retirement Plan Reviews Aldrich Wealth will regularly meet with plan trustees and sponsors to assist them in meeting their fiduciary duties to administer the plan. The specific services and duties offered by Aldrich Wealth will be outlined in the advisory agreement. We will generally review the investment options within the plan on a quarterly basis. Other duties performed will be dependent upon the services we are contracted to perform and our appointment as a fiduciary or investment manager as defined under ERISA. We provide reports to aid trustees and sponsors in their fiduciary requirements. These reports are not custodial or recordkeeper statements, and as such they should be reviewed and compared to the custodial or recordkeeper statements. Item 14 – Client Referrals and Other Compensation Aldrich Wealth, at times, provides additional cash and non-cash compensation to employees of Aldrich Wealth and its affiliates, that is based, at least in part, on bringing new clients to the Firm. Aldrich Wealth employees who introduce or refer new clients to the firm are eligible to receive a bonus based on the first year of net revenue generated by those client relationships. This compensation arrangement presents a conflict of interest because persons receiving additional compensation have a financial incentive to recommend our services or additional accounts or assets for the purpose of receiving incentive compensation rather than solely based on client’s needs. We mitigate this conflict 15  through our compliance policies and procedures requiring employees to put the interest of our client first as part of our fiduciary duty. Additionally, clients and prospects of Aldrich Wealth are under no obligation to add additional assets or open accounts with us. As disclosed under Item 12 above, Aldrich Wealth directly or indirectly receives certain economic benefits from Schwab in the form of the support products and services they each make available to us and other independent investment advisors whose clients maintain accounts there. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit because the cost of these services would otherwise be borne directly by us. Clients should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above in Item 12— Brokerage Practices. Aldrich Wealth has entered into a subscription agreement with Hamilton Lane Advisors, LLC (“Hamilton Lane”), an issuer and manager of alternative investments, for access to research and analytics tools. The subscription fee may be discounted or waived based on the level of client assets invested in Hamilton Lane products. This creates a potential conflict of interest, as the firm may benefit financially when client assets are allocated to those products. Aldrich Wealth does not receive direct compensation from Hamilton Lane and makes all investment decisions based on independent due diligence and the client’s best interests. The availability of a discounted platform does not influence our investment recommendations. Vendors may occasionally provide us or our clients with gifts, meals, or entertainment of reasonable value consistent with applicable laws, rules, and industry standards. Vendors may also provide non-monetary compensation, such as payment or reimbursement of certain expenses related to training or educational events, event sponsorships, or travel and conference attendance. These arrangements present a conflict of interest because we receive an economic benefit, directly or indirectly. We mitigate this conflict by maintaining policies and procedures designed to ensure that vendor gifts or other non-monetary compensation do not influence our evaluation, selection, or ongoing use of any vendor. Aldrich Wealth previously received client referrals from TD Ameritrade through its participation in TD Ameritrade AdvisorDirect, a program TD Ameritrade established as a means of referring its brokerage customers and other investors seeking fee-based personal investment management services or financial planning services to independent investment advisors. The AdvisorDirect program has been discontinued, and Schwab purchased TD Ameritrade, however, we continue to pay a residual referral fee for existing clients referred while the program was still active. Clients referred through AdvisorDirect are on the same standard fee schedule offered to all clients. Item 15 – Custody Aldrich Wealth is deemed to have custody of client assets where clients have provided us with authority to instruct their custodian to deduct our advisory fees directly from the client’s account. The qualified custodian that holds your assets will send quarterly statements of account directly to you identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in your account during the period, including the amount of any fees paid to us. Clients are advised to review these statements carefully and compare the custodial records with any performance reports provided by Aldrich Wealth. Our performance reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Custodians do not verify the accuracy of our advisory fee calculation. If material discrepancies are noted, clients are encouraged to contact Aldrich Wealth at 503-468-7200. We are also deemed to have custody where clients have provided us authority to move money to another person’s account by means of executing a Standing Letters of Authorization (a “SLOA”). In these circumstances, we follow procedures designed to satisfy applicable SEC guidance, including:  The client provides written, signed instructions to the qualified custodian specifying the third-party payee’s identifying information; 16   The client authorizes us in writing to direct transfers to the named third-party payee either on a specified schedule or from time-to-time;  The client’s qualified custodian verifies the client’s authorization and provides prompt notice of each transfer;  The client can terminate or change the instruction at any time on notice to the custodian;  We have no authority or ability to designate or change the third-party payee or payees in the instruction;  We maintain records showing that the designated third-party payee or payees is/are not a related party of the firm or located at the same address as the firm; and  The qualified custodian sends a written initial and annual notice confirming the instruction. Except as described above regarding direct fee deduction authority and SLOAs, we do not have the ability to withdraw funds from our clients’ accounts for any other reason. A qualified custodian will maintain actual custody of all client and plan assets, while certain Alternative Vehicles and private offerings will be held directly with the issuer. In the latter instance, the issuer will typically provide quarterly reports directly to the client. Aldrich Wealth is not a qualified custodian. For Participant Plan Management Services, the third-party platform allows us to avoid having custody of client funds and securities since we do not have direct access to client log-in credentials to affect trades. Item 16 – Investment Discretion Clients usually grant Aldrich Wealth with discretionary authority at the outset of an investment management relationship. Additionally, clients will complete custodial paperwork or other authorizations that provide us with specific authorizations to direct trades in their accounts. This discretionary authority includes the ability to determine which securities to buy or sell, and the amount of the securities to buy or sell. In addition, it will include the ability to engage or terminate Independent Managers to provide portfolio management services. Our discretionary authority with respect to investments that have limited liquidity may be constrained by issuer-imposed restrictions. In all cases, we exercise discretion in a manner consistent with the stated investment objectives, investment policies, limitations and any restrictions for the particular client account. Other investment guidelines and restrictions must be provided to Aldrich Wealth in writing, and clients are allowed to limit or change this authority or any restrictions by providing written instructions. From time to time, Aldrich Wealth will accept client assets into portfolios as “unmanaged,” including legacy or client- directed holdings. These assets are held at the client’s request and are invested solely at the direction of the client. Where agreed upon, we may consider such assets when providing overall portfolio advice, risk analysis, or asset allocation recommendations for the client relationship. Accordingly, Aldrich Wealth is not responsible for the selection or ongoing management of such assets. We encourage clients to hold unmanaged assets in a separate account from their managed assets. When providing services to Retirement Plans, we may exercise discretionary authority or control over the investments specified in the Agreement. When applicable, we perform these services to the Plan as a fiduciary under ERISA Section 3(21) and investment manager under ERISA Section 3(38). We are legally required to act with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. Item 17 – Voting Client Securities Except when acting as an IDF sub-advisor, Aldrich Wealth does not have any authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for assets managed directly by Aldrich Wealth. From time-to-time and when clients request assistance, Aldrich Wealth may provide advice to clients regarding the clients’ voting of proxies or other corporate action. Independent Managers appointed to certain accounts, such as separately managed asset accounts, may assume the authority for voting proxies on behalf of clients. Generally, these Independent Managers request this permission from clients, and it is granted based on custodial paperwork signed by the client. 17  Item 18 – Financial Information Pursuant to SEC regulations, an audited balance sheet is not required to be provided because Aldrich Wealth does not require prepayment for services of more than $1,200 per client and six months or more in advance. Aldrich Wealth has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 18