Alo Financial Planning

Item 1: Cover Page Alo Financial Planning Form ADV Part 2A Brochure Address: 200 E Evergreen Ave Suite 127 Mount Prospect, IL 60056 Phone: (224) 250-9373 Email: hello@alo.financial Website: https://alo.financial/ This brochure provides information about the qualifications and business practices of Alo Financial Planning (the “Adviser,” “we,” “us,” or “our”). If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. 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. Alo Financial Planning is a registered investment adviser, but registration does not imply a certain level of skill or training. Additional information about Alo Financial Planning is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 297002. Page 1 of 24 Date of Brochure: May 14, 2026  Item 2: Material Changes In this Item, we are only required to identify and discuss material changes since filing our last annual amendment. Since filing our last annual updating amendment on March 21, 2025, we have no material changes to report. Page 2 of 24 Date of Brochure: May 14, 2026  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 7 9 10 11 14 15 16 17 19 20 21 22 23 24 Page 3 of 24 Date of Brochure: May 14, 2026  Item 4: Advisory Business A. Alo Financial Planning is an investment adviser founded in 2018, registered with the U.S. Securities and Exchange Commission (“SEC”), and solely owned by John Nowak. B. We offer the following types of advisory services: i. Discretionary Investment Management. We provide ongoing discretionary investment management services to our clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of the client’s accounts. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy or plan and allocation targets. Our investment decisions will allocate portions of the client’s accounts to various asset classes classified according to historical and projected risks and rates of return. We will retain the discretion to buy, sell, or otherwise transact in securities and other investments in the client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by the client in our services agreement. The client may impose restrictions on investing in certain securities or types of securities so long as we can reasonably implement such restrictions. We typically implement our investment strategy by allocating clients’ investable assets across a diversified risk-based portfolio of exchange traded funds (“ETFs”), mutual funds, stocks, bonds, municipal securities, and money market funds. ii. Financial Planning. We offer an initial financial planning service to new clients covering topics such as retirement planning, risk management, financial goal tracking, insurance coverage assessment, college savings, cash flow, debt management, employee benefits optimization, tax planning, and estate and incapacity planning. We may also refer clients to an accountant, attorney, or other specialist as appropriate for their unique situation. An initial financial plan is typically completed within two (2) months of engagement, assuming all requested information is promptly provided to us. Implementation of our recommendations will be at the discretion of the client. We also offer ongoing financial planning services as a continuation of our initial financial planning service, which is generally provided in conjunction with our ongoing discretionary investment management services. Our ongoing financial planning services are designed to assist clients with the implementation of their initial financial plan, and to update their initial financial plan as needed over the course of our relationship. When rendering financial planning services, a conflict exists between our interests and the interests of our clients. The client is under no obligation to act upon our financial planning recommendations. If the client elects to act on any of the recommendations we make, the client is under no obligation to effect the transaction through us or any of our personnel. For insurance related products and services, we may consult with DPL Financial Partners, LLC (“DPL”) to help clients obtain or replace insurance products. DPL is an independent and unaffiliated third-party provider of a platform of insurance consultancy services to registered investment advisers (“RIAs”) that have clients with a current or future need for insurance products. DPL offers RIAs memberships to its platform for a fixed annual fee and, through its licensed insurance agents who are registered Page 4 of 24 Date of Brochure: May 14, 2026  representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member, offers members a variety of services relating to fee-based insurance products. These services include, among others, providing members with analyses of their current methodology for evaluating client insurance needs, educating and acting as a resource to members regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing members access to and product marketing support regarding fee-based products that insurers have agreed to offer to members’ clients through DPL’s platform. For providing platform services to RIAs, DPL receives service fees from the insurers that offer their fee-based products through the platform. These service fees are based on the insurance premiums received by the insurers. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. Our personnel are not licensed insurance agents or registered representatives of the Leaders Group (or any other broker-dealer), and thus does not earn insurance or other product commissions in connection with this partnership with DPL. iii. Selection of other investment advisers. From time to time and when appropriate for a particular client, we will recommend or retain an independent and unaffiliated third-party investment adviser (“Third-Party Adviser”) to manage all or a portion of a client’s portfolio. Third-Party Advisers are evaluated based on a variety of factors, not the least of which include performance return history, asset class specialization, management tenure, and risk profile. We will conduct due diligence as appropriate to confirm that such Third-Party Advisers are duly registered and otherwise well-equipped to manage applicable clients’ accounts. We generally retain the discretionary authority to hire or fire Third-Party Advisers with or without notice to the client. As of the date of this brochure, we generally recommend the retention of Focus Partners Advisor Solutions, LLC (“FPAS”) as the Third-Party Adviser. iv. Pension Consulting Services. To the extent we are retained by a defined contribution plan, defined benefit plan, or other employee benefit plan (a “Plan”), we shall review the Plan’s investment objectives, risk tolerance, and goals, and shall work in partnership with applicable third-parties (such as the Plan’s recordkeeper, third-party administrator, and/or discretionary investment manager) to establish an appropriate investment policy statement and deploy applicable investment options into the Plan’s account. We shall periodically review the investment options available to the Plan and, if applicable, will make recommendations to assist the Plan with respect to the selection of the Plan’s qualified default investment alternative (“QDIA”). We will provide reports, information and recommendations, on a reasonably requested basis, to assist the Plan in monitoring the selected investments. If elected by the Plan, we may also provide various services related to the Plan’s governance, the education of Plan participants, and the review of other service providers to the Plan. In connection with Plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of 1986, as amended (the “Code”) we acknowledge that we are a fiduciary under ERISA and the Code, shall render prudent investment advice that is in the Plan’s best interest, shall avoid making misleading statements, and shall receive no more than reasonable compensation. v. Educational Workshops / Seminars: We may provide seminars on an “as announced” basis for groups seeking general advice on investments and other areas of personal finance. The content of these seminars will vary depending upon the needs of the Page 5 of 24 Date of Brochure: May 14, 2026  attendees. These seminars are purely educational in nature, are free of charge, and do not involve the sale of any investment products. Information presented will not be based on any individual’s person’s need, nor do we provide individualized investment advice to attendees during these seminars. C. We do not sponsor or participate in any wrap fee programs. D. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and v. vi. Give you basic information about conflicts of interest. E. We manage the following amount of discretionary and non-discretionary client assets calculated as of December 31, 2025: Discretionary: Non-Discretionary: Total: $120,915,635 $0 $120,915,635 Page 6 of 24 Date of Brochure: May 14, 2026  Item 5: Fees and Compensation A. We charge asset-based and/or flat fees for our services, depending on the specific services for which you engage us. Our fees and fee ranges as set forth herein reflect the typical fees we charge to clients; however, the specific fees charged to a particular client will vary from client to client. Each client should review the services agreement signed with us for the fees that will be charged and how fees will be payable. Our fees may vary from client to client due to historical or ‘grandfathered’ fee schedules that are no longer offered, the nature and scope of the services to be provided to the client, personal or familial relationships with the client, and other factors that we deem relevant. Fees are negotiable, but we reserve the right to accept or reject different fees proposed by the client. B. Discretionary Investment Management. We are compensated for our discretionary investment management and ongoing financial planning services by fees charged based on a client’s assets under our management, which are generally charged at the rates set forth in the table below and subject to a minimum quarterly fee of $2,500: Client Assets Under Management For the first $0 - $3,000,000 For the next $3,000,001 - $10,000,000 For any amount above $10,000,000 Annual Fee Percentage 0.80% 0.40% 0.30% The asset-based fees set forth above reflect a “tiered” or “blended” fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under our management. Fees are deducted in arrears on a quarterly basis from one or more client accounts under our management, and asset-based fees are based upon the gross market value of assets designated to be under our management as of the last business day of the prior calendar quarter. Fees are prorated from the effective date of our engagement up to the termination date of our engagement. To the extent a Third-Party Adviser such as FPAS is retained to manage all or a portion of a client’s portfolio, the client will not pay any additional fee to FPAS. We, and not the client, pay the fee charged by FPAS in consideration of its services. C. Initial Financial Planning. In consideration of our initial financial planning services, we charge a flat fee that typically equals $3,000. The flat fee will be agreed upon before the start of services. Half of the flat fee is due upon engagement with the balance due upon the completion of the initial financial planning engagement. Fees for this service may be paid through a third-party payment processor or check. In the event of early termination before the initial financial plan is delivered, any prepaid but unearned fees will be refunded to the client based on the percentage of financial planning services completed up to the date of termination; any completed deliverables will be provided to the client upon termination. D. Pension Consulting Services. We are compensated for our pension consulting services by fees charged based on a Plan’s assets designated to be under our management or advisement, which are generally charged at the rates set forth in the table below: Annual Fee Percentage Plan Assets Under Management or Advisement $0 - $10,000,000 $10,000,001 and Above 0.35% negotiable Page 7 of 24 Date of Brochure: May 14, 2026  The asset-based fees set forth above reflect a “tiered” or “blended” fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under our management or advisement. Fees are deducted in arrears on a quarterly basis from the Plan or pro rata from participant accounts, and are based upon the gross market value of assets designated to be under our management or advisement as of the last business day of the prior calendar quarter. Fees are prorated from the effective date of our engagement up to the termination date of our engagement. E. General Fee Disclosures. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities or other investment products. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Depending on the specific investment products held in a client’s account and the services provided, a client may also incur additional fees and costs charged by other independent and unaffiliated third-parties. Such additional fees and costs may include, but are not necessarily limited to, the internal fees and costs of an investment product (like a mutual fund or exchange traded fund), margin interest, account or asset transfer fees, subadvisory or third-party investment manager fees, account type fees, early redemption charges, market-maker or bid-ask spreads, retirement plan fees, trade-away or prime brokerage fees, fees for receiving paper copies of documents in lieu of electronically-delivered documents, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Adviser. Lower fees for comparable services may be available from other sources. Page 8 of 24 Date of Brochure: May 14, 2026  Item 6: Performance-Based Fees & Side-By-Side Management Neither we nor any of our supervised persons accept performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Neither we nor any of our supervised persons engage in side-by-side management. Page 9 of 24 Date of Brochure: May 14, 2026  Item 7: Types of Clients We generally provide our services to individuals, high-net-worth individuals, and defined contribution plans, defined benefit plans, or other employee benefit plans. We do not require a minimum account value to open or maintain an account, though we do charge a minimum quarterly fee of $2,500 for investment management services. Please note that the Third-Party Advisers we retain may separately impose minimum account value requirements. Page 10 of 24 Date of Brochure: May 14, 2026  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. Our investment strategies include passive investment management. Passive investing involves building portfolios that are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve the desired relationship between correlation, risk, and return. The funds that are used to build passive portfolios are typically mutual funds or exchange traded funds. We will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of clients. We may also make tactical decisions to buy and sell positions for tax purposes. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance does not guarantee future returns. B. Like any investment strategy, ours involves material risks. Such material risks are described in further detail below: i. Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market and the behavioral impulse to make trading decisions based on such short-term market fluctuations. We do not condone short-term trading in an attempt to “time” the market, and instead coach clients to remain committed to their financial goals. However, investing for the long term can expose clients to risks borne out of changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and regulatory changes. ii. Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an amount equal to inflation over time. General micro- and macro-economic conditions may also affect the value of the securities held in a client’s portfolio, and general economic downturns can trigger corresponding losses across various asset classes and security types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value, and may increase the likelihood that securities are purchased when values are comparatively high and/or that securities are sold when values are comparatively low. Geopolitical shifts may result in market uncertainty, lowered expected returns, and general volatility in both domestic and international securities. Regulatory changes may have a negative impact on capital formation and increase the costs of doing business, and therefore result in decreased corporate profits and corresponding market values of securities. iii. Investing in mutual funds does not guarantee a return on investment, and shareholders of a mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their shareholders (which can include management fees, administration fees, shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from its potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset value (“NAV”), calculated at the end of each day upon the market’s close. Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above. However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the seller's offering (asking) price). Page 11 of 24 Date of Brochure: May 14, 2026  Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be purchased for investment to obtain a full understanding of its respective risks and costs. iv. Investing in common stocks means that a client will be subject to the risks of the overall market as well as risks associated with the particular company or companies whose stock is owned. These risks can include, for example, changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. Common stocks tend to be more volatile and more risky than certain other forms of investments, especially as compared to fixed income products like bonds. v. Investing in municipal securities carries unique risks, depending on the type of bond offered. General obligation bonds are issued by governmental entities and are not backed by revenues from a specific project or source. In some instances, municipalities may not have taxing authority to repay bondholders. Revenue bonds are backed by revenues from a specific project or source and can vary greatly in terms of credit risk. Some revenue bonds are “non-course” bonds, meaning that should the revenue stream dry up or the conduit borrower fails to pay, the bondholder will not have a claim to the underlying revenue or against the conduit borrower. vi. Investing in corporate debt, including corporate bonds, carries additional risks to those noted above for fixed income securities. Corporate debt is also subject to credit risk - the risk that the bond issuer may default on one or more payments before the bond reaches maturity. In the event of a default, you may lose some or all of the income you were entitled to, and even some or all of the principal amount invested. Some corporate bonds may also be subject to early redemption risk, with the issuer having the principal repaid prior to the maturity date of the bond. vii. Investing in certificates of deposit (“CDs”), while relatively safe, can still carry some risks. CDs have terms of different lengths, ranging up to 10 years. During the term length, your funds invested in the CD will be inaccessible; if you opt to withdraw early, you will be subject to early withdrawal fees, which can erode any interest accrued and can decrease the principal amount originally invested. It is also subject to inflation risk, as CD rates tend to lag behind rising inflation and drop more quickly than inflation on the way down. viii. Investing in money market funds carries interest rate risk. Securities with longer maturities typically offer higher yields, but have greater interest rate sensitivity. There is also liquidity risk - the money market fund may impose a fee upon the sale of your shares, or may temporarily suspend your ability to sell shares, if the fund’s liquidity falls below required minimums because of market conditions or other factors. ix. Investing in options has the potential to amplify losses as well as to limit potential gains, and whether or not an option will result in a gain or a loss is wholly dependent on the market value of the option’s underlying security. Options require the payment of a premium (which may not be recouped), and have the potential to trigger a purchase or sale obligation within a shorter timeframe than a more traditional long-term investment. Implementing certain options strategies creates certain time sensitivities, such that an options strategy may not be successful if exercises are not executed within an applicable period of time. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. When purchasing puts, there is a risk that the premium paid will be a sunk cost if the option expires unexercised. x. Relying on the investment advisory or management services of an independent and unaffiliated third-party adviser means that clients will be subject to such third-party adviser’s continued ability to achieve its investment mandates, as well as specific client investment objectives and restrictions. To the extent that a third-party adviser is Page 12 of 24 Date of Brochure: May 14, 2026  dependent on the services or intellectual capital of a select few individuals, the departure or death of such individuals may have a material impact on the continued viability of such third-party adviser and its ability to continue serving client accounts. There can be no guarantee that a third-party adviser will meet its performance expectations, or that its services will be free of trading or management-related errors. Page 13 of 24 Date of Brochure: May 14, 2026  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Page 14 of 24 Date of Brochure: May 14, 2026  Item 10: Other Financial Industry Activities & Affiliations A. Neither we nor any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither we nor any of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Neither we nor any of our management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. x. xi. broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) other investment adviser or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm insurance company or agency pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships D. Though John Nowak and Samantha Bordiuk are Certified Public Accountants (“CPAs”), neither provide accounting services to our clients or otherwise, and therefore such professional designations do not create any material conflicts of interest. E. As described earlier in Item 4 of this brochure, we retain the authority to recommend or retain one or more Third-Party Advisers to provide investment advisory, administrative, and other back-office services to Adviser for the benefit of Adviser and its clients. We do not receive any compensation directly from any Third-Party Adviser, but they do offer services that are intended to directly benefit us, clients, or both. Such services include (a) an online platform through which we can monitor and review client accounts, create model portfolios, and perform other client account maintenance matters, (b) access to technology that allows for client account aggregation, (c) quarterly client statements, (d) invitations to educational conferences, (e) practice management consulting, (f) full or partial sponsorship of client appreciation or education events, and (g) occasional business meals and entertainment. The availability of such services from a Third-Party Adviser creates a conflict of interest, to the extent we may be motivated to retain a Third-Party Adviser as opposed to an alternative Third-Party Adviser (or to not retain one at all). We address this conflict of interest by performing appropriate due diligence on Third-Party Advisers to confirm their respective services are in the best interests of clients, periodically evaluating alternatives, and evaluating the merit of Third-Party Advisers without consideration of the benefits we receive. As a fiduciary, we have certain legal obligations, including the obligation to act in clients’ best interest. We maintain a Business Continuity and Succession Plan and seek to avoid a disruption of service to clients in the event of an unforeseen loss of key personnel, due to disability or death. To that end, we have entered into a succession agreement with Focus Partners Wealth, LLC (an affiliate of FPAS), effective March 11, 2025. AFP can provide additional information to any current or prospective client upon request Page 15 of 24 Date of Brochure: May 14, 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. We have adopted a code of ethics that will be provided to any client or prospective client upon request. Our code of ethics describes the standards of business conduct that we require of our supervised persons, which is reflective of our fiduciary obligations to act in the best interests of clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to our Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither we nor any of our related persons recommends to clients, or buys or sells for client accounts, securities in which we or any of our related persons has a material financial interest. C. From time to time, we or our related persons will invest in the same securities (or related securities such as warrants, options or futures) that we or a related person recommend to clients. This has the potential to create a conflict of interest because it affords us or our related persons the opportunity to profit from the investment recommendations made to clients. Our policies and procedures and code of ethics address this conflict of interest by prohibiting such trading by us or our related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances, we will act in the best interests of our clients. D. From time to time, we or our related persons will buy or sell securities for client accounts at or about the same time that we or a related person buys or sells the same securities for our own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords us or our related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Our policies and procedures and code of ethics address this conflict of interest by prohibiting such trading by us or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances, we will act in the best interests of our clients. Page 16 of 24 Date of Brochure: May 14, 2026  Item 12: Brokerage Practices A. We consider several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows us to fulfill our duty to seek best execution for client securities transactions. However, we do not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, we recommend Fidelity Brokerage Services LLC ("Fidelity") as the custodial broker-dealer for client accounts. FIdelity generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your account. Certain trades (for example, many mutual funds and ETFs) may not incur commissions or transaction fees. Fidelity is also compensated by earning interest on the uninvested cash in your account. In addition to commissions, Fidelity charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Fidelity account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. B. We do not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer we recommend does provide certain products and services that are intended to directly benefit us, clients, or both. Such products and services include (a) an online platform through which we can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer’s educational conferences, (e) practice management consulting, (f) occasional business meals and entertainment, and (g) occasional business meals and entertainment. The receipt of these products and services creates a conflict of interest to the extent it causes us to recommend Fidelity as opposed to a comparable custodial broker-dealer. We address this conflict of interest by fully disclosing it in this brochure, evaluating Fidelity based on the value and quality of its services as realized by clients, and by periodically evaluating alternative custodial broker-dealers to recommend. C. We do not consider, in selecting or recommending custodial broker-dealers, whether we or a related person receives client referrals from a custodial broker-dealer. D. We do not routinely recommend, request, or require that a client direct us to execute transactions through a specified custodial broker-dealer other than Fidelity. E. We retain the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If we aggregate client trades, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Directing the purchase and sale of securities for clients’ accounts on an individual basis, rather than in aggregate blocks, may result in increased client transaction costs. To the extent the securities purchased and sold by us are mutual funds (each of which generally price at the same respective net asset value at the end of each trading day), we believe that the Page 17 of 24 Date of Brochure: May 14, 2026  potential for increased client transaction costs by not aggregating orders is substantially eliminated. Page 18 of 24 Date of Brochure: May 14, 2026  Item 13: Review of Accounts A. Our investment adviser representatives monitor client accounts on an ongoing basis, and typically review client accounts on at least a quarterly basis. Such reviews are designed to ensure that the client is still on track to achieve the client’s financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to us to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. We or a third-party report provider may also agree to make certain reports available to clients to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 19 of 24 Date of Brochure: May 14, 2026  Item 14: Client Referrals and Other Compensation A. Only clients provide an economic benefit to us for providing investment advice or other advisory services to them, except as otherwise described in this brochure. However, as described above in Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain products and services that are intended to directly benefit us, clients, or both. B. Neither we nor a related person directly or indirectly compensates a person who is not our supervised person for client referrals. Page 20 of 24 Date of Brochure: May 14, 2026  Item 15: Custody For clients that do not have their fees deducted directly from their accounts, we will not have any custody of client funds or securities. For clients that have their fees deducted directly from their accounts, we will generally be deemed to have custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. At no time will we accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian, and at all times client accounts will be held by a third-party qualified custodian as described in Item 12, above. If a client receives account statements from both the custodial broker-dealer and us or a third-party report provider, such client is urged to compare such account statements and advise us of any discrepancies between them. Page 21 of 24 Date of Brochure: May 14, 2026  Item 16: Investment Discretion We accept discretionary trading authority to manage securities accounts on behalf of clients only pursuant to the mutual written agreement of us and the client through a power-of-attorney, which is typically contained in the advisory agreement signed by the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in clients’ accounts without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 22 of 24 Date of Brochure: May 14, 2026  Item 17: Voting Client Securities A. We do not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 23 of 24 Date of Brochure: May 14, 2026  Item 18: Financial Information A. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. We have no financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. C. We have not been the subject of a bankruptcy petition at any time during the past ten years. Page 24 of 24 Date of Brochure: May 14, 2026