Overview

Headquarters
Novato, CA
Average Client Assets
$0.9 million
Minimum Account Size
$100,000
SEC CRD Number
163917

Fee Structure

Primary Fee Schedule (ADV PART 2A - FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 $250,000 1.50%
$250,001 $500,000 1.40%
$500,001 $1,000,000 1.30%
$1,000,001 and above 1.20%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,750 1.38%
$5 million $61,750 1.24%
$10 million $121,750 1.22%
$50 million $601,750 1.20%
$100 million $1,201,750 1.20%

Clients

HNW Share of Firm Assets
67.81%
Total Client Accounts
1,417
Discretionary Accounts
1,416
Non-Discretionary Accounts
1

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting

Regulatory Filings

Primary Brochure: ADV PART 2A - FIRM BROCHURE (2026-03-26)

View Document Text
Item 1 – Cover Page Firm Contact: Andrei Jigalin, President & Chief Compliance Officer Additional Contact: Matt Fannin, Principal & Chairman Alpha Wealth Management and Planning LLC Form ADV Part 2A – Disclosure Brochure Effective: March 26, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Alpha Wealth Management and Planning LLC (“Alpha Wealth Management and Planning” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (415) 506-4569. Alpha Wealth Management and Planning is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Alpha Wealth Management and Planning to assist you in determining whether to retain the Advisor. Additional information about Alpha Wealth Management and Planning and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 163917. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about advisory personnel of Alpha Wealth Management and Planning. For convenience, we have combined these documents into a single disclosure document. Material Changes This Disclosure Brochure has been redrafted to streamline disclosures and presentation. However, there have been no material changes to the disclosures since the previous annual filing on March 29, 2025. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 163917. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (415) 506-4569. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 2 Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 – Table of Contents ........................................................................................................................ 3 Item 4 – Advisory Services ....................................................................................................................... 4 A. Firm Information ............................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................. 4 C. Client Account Management ........................................................................................................... 7 D. Wrap Fee Programs ....................................................................................................................... 7 E. Retirement Plan Rollovers ............................................................................................................... 7 F. Assets Under Management ............................................................................................................. 9 Item 5 – Fees and Compensation ............................................................................................................. 9 A. Fees for Advisory Services ............................................................................................................. 9 B. Fee Billing ..................................................................................................................................... 10 C. Other Fees and Expenses ............................................................................................................ 10 D. Cash Holdings ............................................................................................................................... 11 E. Mutual Fund Share Class Selection ............................................................................................... 11 F. Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees) .......................................... 11 G. Legacy Mutual Fund Holdings ....................................................................................................... 12 H. Advance Payment of Fees and Termination ................................................................................. 12 I. Compensation for Sales of Securities ............................................................................................. 12 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 13 Item 7 – Types of Clients ........................................................................................................................ 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 13 A. Methods of Analysis ...................................................................................................................... 13 B. Risk of Loss .................................................................................................................................. 14 Item 9 – Disciplinary Information ........................................................................................................... 17 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 18 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 18 A. Code of Ethics ........................................................................................................................... 18 B. Personal Trading with Material Interest ......................................................................................... 18 C. Personal Trading in Same Securities as Clients ............................................................................ 18 D. Personal Trading at Same Time as Client ..................................................................................... 19 Item 12 – Brokerage Practices................................................................................................................ 19 A. Recommendation of Custodian[s] ................................................................................................. 19 B. Aggregating and Allocating Trades ............................................................................................... 21 Item 13 – Review of Accounts ................................................................................................................ 21 A. Frequency of Reviews .................................................................................................................. 21 B. Causes for Reviews ...................................................................................................................... 21 C. Review Reports ............................................................................................................................. 21 Item 14 – Client Referrals and Other Compensation ............................................................................. 22 A. Compensation Received by Alpha Wealth Management and Planning.......................................... 22 B. Client Referrals from Solicitors ...................................................................................................... 22 Item 15 – Custody ................................................................................................................................... 22 Item 16 – Investment Discretion ............................................................................................................. 23 Item 17 – Voting Client Securities .......................................................................................................... 23 Item 18 – Financial Information .............................................................................................................. 23 Form ADV Part 2A – Appendix 1 ............................................................................................................ 24 Privacy Policy .......................................................................................................................................... 35 Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 3 Item 4 – Advisory Services A. Firm Information Alpha Wealth Management and Planning, LLC (“Alpha Wealth Management and Planning” or the “Advisor” and also referred to as “we or “us” throughout this Disclosure Brochure) is a registered investment advisor with the with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of the State of California. Alpha Wealth Management and Planning was founded in 2012 and is owned and operated by Andrei Jigalin, CFP® (President and Chief Compliance Officer) and Matt Fannin (Chairman and Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Alpha Wealth Management and Planning. B. Advisory Services Offered Alpha Wealth Management and Planning offers investment advisory services to individuals, high net worth individuals, pension and profit sharing plans, charitable organizations and businesses in the State of California and other states (each referred to as a “Client” and also referred to as “you throughout this Disclosure Brochure). Investment Management Services Alpha Wealth Management and Planning provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non- discretionary investment management and related advisory services. Our Investment Management Services encompasses asset management as well as providing financial planning and financial consulting to Clients. It is designed to assist Clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with Clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the Client. We generally propose an investment portfolio, that consists primarily of exchange traded equity securities, exchange traded funds, mutual funds (Please see Item 8 for a more comprehensive list of available investment types). Upon the Client’s agreement to the proposed investment plan, we work with the Client to establish or transfer investment accounts so that we can manage the Client’s investment portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust Client accounts under our management. If the Client experiences any significant changes to his/her financial or personal circumstances, the Client must notify us so that we can consider such information in managing the Client’s investments. Alpha Wealth Management and Planning’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Alpha Wealth Management and Planning will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Alpha Wealth Management and Planning may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Alpha Wealth Management and Planning may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Alpha Wealth Management and Planning may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Alpha Wealth Management and Planning accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12. Financial Planning Services We provide a variety of financial planning and consulting services to individuals, families and other Clients regarding the management of their financial resources based upon an analysis of the Client’s current situation, Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 4 goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for Clients based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Business and Personal Financial Planning Investment Planning • • Retirement Planning Estate Planning • • Charitable Planning Education Planning • • Corporate and Personal Tax Planning • Cost Segregation Study Stock Options Analysis • • Corporate Structure • Real Estate Analysis • Mortgage/Debt Analysis Insurance Analysis • Lines of Credit Evaluation • • Divorce Planning • Our financial plans or financial consultations rendered to Clients usually include general recommendations for a course of activity or specific actions to be taken by the Clients. For example, recommendations may be made that the Clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. For written financial planning engagements, we provide our Clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our Clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within twelve (12) months of the Client signing a contract with us, assuming that all the information and documents we request from the Client are provided to us promptly. Implementation of the recommendations will be at the discretion of the Client. Alpha Wealth Management and Planning may also refer Clients to an accountant, attorney or another specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to execute the transaction through the Advisor. Retirement Plan Consulting Alpha Wealth Management and Planning may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in either a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary investment management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants. More specifically, Alpha Wealth Management and Planning may assist Clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services. Investment advisor representatives may perform one or more of the following services, as selected by the Client in the Client agreement: Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 5 • Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based upon consultation with Client to ascertain Plan’s investment objectives and constraints. Acting as a liaison between the Plan and service providers, product sponsors or vendors. • • Ongoing monitoring of investment manager(s) or investments in relation to the criteria specified in the Plan’s IPS or other written guidelines provided by the Client to IAR. • Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks. • Ongoing recommendations, for consideration and selection by Client, about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. • Education or training for the members of the Plan investment committee with regard to various matters, including plan features, retirement readiness matters, service on the committee, and fiduciary responsibilities. • Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, IARs may provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, investment advisor representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or may obtain participant loans, investment advisor representatives do not provide any individualized advice or recommendations to the participants regarding these decisions. Furthermore, investment advisor representatives do not provide individualized investment advice to Plan participants regarding their Plan assets. Pursuant to California Code of Regulations Section 260.238(k), the Advisor, has disclosed all material conflicts of interests that could reasonably be expected to impair the rendering of unbiased and objective advice. Order Management System Alpha Wealth Management and Planning provides an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to implement tax- efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary All clients engaging in Investment Management Services must either engage in Comprehensive Financial Planning or meet a $150,000 minimum of assets under management. This fee will be assessed and billed quarterly. Specifically, the exact amount charged is determined by the daily average over the course of the quarter. The current exception for this is directly-managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if Alpha Wealth Management and Planning only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the daily average of the account value or the account value as of the last day of the previous quarter (per the paragraph above), resulting in a combined weighted fee. For example, an account valued at $2,000,000 would pay an effective fee of 1% with the annual fee being $20,000 (a quarterly fee of $5,00). Investment management fees are generally directly debited on a pro rata basis from client accounts. The exception for this is directly-managed held-away accounts, such as 401(k)s. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the client’s taxable accounts on a pro-rata basis. If the client does not have a taxable account, those fees will be billed directly to the client. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no rebate will be needed upon termination of the account. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 6 C. Client Account Management Prior to engaging Alpha Wealth Management and Planning to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Alpha Wealth Management and Planning, in connection with the Client, may a strategy that seeks to achieve the Client’s goals and destinations. The strategy is designed to address the Client’s personal goals, investment goals, and both long-term and short-term objectives. • Asset Allocation – Alpha Wealth Management and Planning will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. • Portfolio Construction – Alpha Wealth Management and Planning will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Alpha Wealth Management and Planning will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Alpha Wealth Management and Planning typically includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Alpha Wealth Management and Planning Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: • Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. Employer retirement plans generally have a more limited investment menu than IRAs. • • Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. Your current plan may have lower fees than our fees. • If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 7 contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services. • Our strategy may have higher risk than the option(s) provided to you in your plan. Your current plan may also offer financial advice. • • If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age. A 401(k) may offer more liability protection than a rollover IRA; each state may vary. • Participants may be able to take out a loan on your 401k, but not from an IRA. • • IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. • If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate. Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. • Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. When Advisor provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this sp ecial rule’s provisions, we must: Avoid misleading statements about conflicts of interest, fees, and investments; • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 8 Follow policies and procedures designed to ensure that we give advice that is in your best interest; • • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Advisor provides educational services to retirement plan participants with assets that could potentially be rolled- over to an IRA advisory account. Education is based on a particular Client’s financial circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. F. Assets Under Management As of March 2, 2026, Alpha Wealth Management and Planning manages the following assets: Discretionary Assets Non-Discretionary Assets Total Assets Under Management $309,519,000 $10,055,000 $319,574,000 Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule: Assets Under Management ($) Annual Rate (%) Up to $250,000 $250,001 to $500,000 $500,001 to $1,000,000 $1,000,001 and over 1.5% 1.4% 1.3% 1.2% The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by Alpha Wealth Management and Planning will be independently valued by the Custodian. Alpha Wealth Management and Planning will not have the authority or responsibility to value portfolio securities. Pursuant to California Code of Regulations Section 260.238(j), the Advisor discloses that the Client may be able to obtain similar services from other services providers for a lower fee. Clients with assets on Charles Schwab & Co., Inc.,'s platform will be charged an annual flat fee of $48,000, billed quarterly. SEI Managed Account Program This program offers Clients a managed account in which Alpha Wealth Management and Planning and Planning, through its investment advisor representatives, assists Clients in establishing an account with SEI Investment Management Corporation (“SIMCO”). The program seeks to manage taxes within individual separate accounts using U.S. equity and/or municipal bond components in order to meet Client’s long-term goals of managing taxes while controlling risk. The program may include the services of an integration manager that seeks to manage a consolidated portfolio of individual equity securities. The program may include a percentage of assets allocated to a portfolio of mutual funds Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 9 sponsored by SIMCO or its affiliates. The investment advisor representative assists the Client in selecting an asset allocation strategy appropriate for the Client by discussing the various levels of risk and helping the Client complete a Client questionnaire which details the Client’s annual income, net worth, and long-term goals and objectives. The investment advisor representative explains to the Client the various investing alternatives that are available in the program account, provides the Client with the prospectuses for any applicable SIMCO-affiliated mutual funds and explains the re-balancing guidelines used in the management of the portfolio. The Client appoints SIMCO to manage assets within the individual separate accounts and re- balance SIMCO- affiliated mutual funds pursuant to the Client’s goals and objectives. SIMCO may delegate its responsibility for management to one or more portfolio managers, including an integration manager. Account minimum is $50,000. Our advisor fee for SIMCO is 1.5%, or less, as negotiated per Client depending on the size scope and complexity of the account. Financial Planning Services Alpha Wealth Management and Planning offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly engagements range from $250 to $400 per hour. Fixed fee engagement fee range from $1,000 to $15,000. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Investment Management Services The amount due is calculated by applying the quarterly rate (annual rate divided by [4]) to the total assets under management with Alpha Wealth Management and Planning at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting Alpha Wealth Management and Planning to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may include certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Alpha Wealth Management and Planning may include securities transactions costs as part of its overall investment advisory fee through the Alpha Wealth Management and Planning Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. In addition, all fees paid to Alpha Wealth Management and Planning for investment advisory services or part of the Alpha Wealth Management and Planning Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client could invest in these products directly, without the services of Alpha Wealth Management and Planning, but would not receive the services provided by Alpha Wealth Management and Planning which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Alpha Wealth Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 10 Management and Planning to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Cash Holdings Cash balances invested in LPL’s multi-bank insured cash account (ICA) program are invested in Federal Deposit Insurance Corporation (FDIC) insured deposit accounts at one or more bank or other participating depository institutions. However, clients receive the same interest rate across all ICA deposit accounts taken in the aggregate based on a percentage of the average daily deposit balance. LPL receives a fee from the institutions participating in the ICA program based on the value of advisory assets held in the ICA program. This fee could be higher than the interest rate received by clients and/or could reduce the rate a client could receive elsewhere. E. Mutual Fund Share Class Selection Section 206 of the Investment Advisers Act of 1940 (“Advisers Act”) imposes a fiduciary duty to act in a client’s best interests and specifically prohibits investment advisers, directly or indirectly, from engaging in any transaction, practice, or course of business which operates as a fraud or deceit upon any client or prospective client. However, the fiduciary duty to which advisers are subject is not specifically defined in the Advisers Act or the Commission rules but reflects a Congressional recognition “of the delicate fiduciary nature of an investment advisory relationship” as well as a Congressional intent to eliminate, or at least expose, all conflicts of interest which might incline an investment adviser, consciously or unconsciously, to render advice which was not disinterested. All 12b-1 fees incurred by client accounts are retained by LPL Financial LLC (LPL) as the qualified custodian. The purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services such as the support services provided by LPL to offer the hybrid platform as well as “other expenses” such as the legal, accounting and administrative services also provided by LPL for a hybrid firm to leverage. The more beneficial share class depends on an analysis of all fees including ticket charges and expected 12b-1 fees. Investing in a 12b-1 fee paying share class can be less expensive for a client than investing in a share class with a lower expense ratio if the ticket charges on the lower-cost share class exceed the amount of ongoing 12b-1 fees. Depending on the anticipated trading volume, and the asset management fee that is determined based on account size, complexity and time requirements, investment advisor representatives have a fiduciary duty to determine the mutual fund share class that is in the best interest of each client as part of the overall fee analysis. For a wrap fee account, a different conflict of interest is introduced because the advisor now has an incentive to not trade as frequently (reverse churning) to avoid the ticket charges which can compromise the active management of an advisory account. This conflict is mitigated by an investment adviser representative’s fiduciary duty to act in a client’s best interest while also considering the higher asset management fee charged for wrap fee accounts. In addition, the firm is limited to the share class available through the custodian which can amount to a higher- cost share class in certain instances, the details of the different share classes are further provided in the fund prospectus. F. Mutual Fund Share Class Disclosure and Fiduciary Duty (12b-1 Fees) The firm will seek to determine the most advantageous share class available to each client. While institutional share classes are usually the lowest cost alternative, under certain circumstances clients may be better served to pay a higher annual expense ratio and avoid a transaction fee on each trade. When selecting a mutual fund for a client’s advisory account, the investment advisor representative has a fiduciary duty to select the share class that helps manage the overall fee structure of the account. The overall fee structure includes such fees as: Asset Management Fees, Expense ratio, which includes 12b-1 fees, generally .25% for A shares and/or trade ticket charges. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 11 • Investment Advisor Representatives must anticipate and monitor trading volume, and the asset management fee that is determined based on account size, complexity and time requirements. • • The firm will review mutual fund positions that clients transfer “in kind” to be included in assets managed by the firm and will advise the client as to alternatives available to them regarding share classes. The firm recognizes that in some situations, alternative share classes might not be available. For example, 529 and 401(k) Plans often have a limited array of investments and share classes available. G. Legacy Mutual Fund Holdings When the client transfers assets into a managed account, the portfolio advisor will review the client’s mutual fund holdings. If the account includes mutual funds the firm does not recommend, they will generally be sold unless the client needs to avoid a taxable gain or directs the investment advisor representative to hold the position. In some circumstances, if the legacy holding fits into the asset allocation of the portfolio, it may be held going forward. If in the client’s best interest to convert to an alternative share class and the position meets the minimum investment and eligibility criteria, The firm will place instructions for the custodian to convert the position on its next available share class conversion date. If not converted, the position will be re-evaluated, at least, during the annual review. All steps taken will be documented either in the client’s file or in the trading records of the firm. H. Advance Payment of Fees and Termination Investment Management Services Alpha Wealth Management and Planning is compensated for its services in advance of the quarter in which investment advisory services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Alpha Wealth Management and Planning requires an advance deposit as described above. Either party may terminate the financial planning agreement by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engage, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. I. Compensation for Sales of Securities Alpha Wealth Management and Planning, as a registered investment advisor, does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. However, certain investment advisor representatives of Alpha Wealth Management and Planning are also registered representatives of LPL Financial, a FINRA/SIPC member broker/dealer. They conduct securities business as Alpha Wealth Management and Planning on behalf of LPL Financial. LPL Financial charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). LPL Financial enables the Advisor to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. LPL Financial commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by LPL Financial may be higher or lower than those charged by other custodians and broker/dealers. Clients may Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 12 direct their brokerage transactions at a firm other than LPL Financial. Advisory fees are generally not reduced to offset commissions or markups. When the Advisory Persons of the Advisor sell an investment product on a commission basis, the Advisor does not charge an advisory fee in addition to the commissions paid by the Client for such product. When providing services on an advisory fee basis, RIA representatives do not also receive commission compensation for such advisory services (except for any ongoing 12b-1 trailing commission compensation that may be received as previously discussed). However, a Client may engage the Advisor to provide investment management services for an advisory fee and also purchase an investment product from our Advisory Persons’s representatives on a separate commission basis. Item 6 – Performance-Based Fees and Side-By-Side Management Alpha Wealth Management and Planning does not charge performance-based fees for its investment advisory services. The fees charged by Alpha Wealth Management and Planning are as described in “Item 5 – Fees and Compensation” above and are not based upon the capital appreciation of the funds or securities held by any Client. Alpha Wealth Management and Planning does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Alpha Wealth Management and Planning offers investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans, charitable organizations, and businesses. Alpha Wealth Management and Planning generally requires a minimum relationship size of $100,000, which may be reduced at the Advisor’s sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Alpha Wealth Management and Planning employs fundamental, technical, cyclical, charting analysis methods in developing investment strategies for its Clients. Research and analysis from Alpha Wealth Management and Planning is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to Clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Alpha Wealth Management and Planning will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that Alpha Wealth Management and Planning is recommending. The risks with cyclical analysis are similar to those of technical analysis. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 13 Charting analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1. 2. the markets do not always repeat cyclical patterns; and, if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. As noted above, Alpha Wealth Management and Planning generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Alpha Wealth Management and Planning will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Alpha Wealth Management and Planning may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Our investment strategies and advice may vary depending upon each Client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. 
 B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Alpha Wealth Management and Planning will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks the Client should consider: • Market Risk – the risk that the value of securities may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. This is a risk that will affect all securities in the same manner caused by some factor that cannot be controlled by diversification • Interest Rate Risk – the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Credit Risk – the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Business Risk – the measure of risk associated with a particular security. It is also known as unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally speaking, all businesses in the same industry have similar types of business risk. More specifically, business risk refers to the possibility Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 14 that the issuer of a particular company stock or a bond may go bankrupt or be unable to pay the interest or principal in the case of bonds. • Tax Risk – the risk that a security that was issued with tax-exempt status could potentially lose that status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond holders would end up with a lower after-tax yield than originally planned. • Call Risk – the risk specific to bond issues and refers to the possibility that a debt security will be called prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must find an investment that provides the same level of income for equal risk. Call risk is most prevalent when interest rates are falling, as companies trying to save money will usually redeem bond issues with higher coupons and replace them on the bond market with issues with lower interest rates. • Inflationary Risk – the risk that future inflation will cause the purchasing power of cash flow from an investment to decline. • Liquidity Risk – the possibility that an investor may not be able to buy or sell an investment as and when desired or in sufficient quantities because opportunities are limited. • Reinvestment Risk – the risk that falling interest rates will lead to a decline in cash flow from an investment when its principal and interest payments are reinvested at lower rates. • Social/Political Risk – the possibility of nationalization, unfavorable government action or social changes resulting in a loss of value. • Legislative Risk – the risk of a legislative ruling resulting in adverse consequences. • Currency/Exchange Rate Risk – the risk of a change in the price of one currency against another. • Pandemic Risk – Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries and causing significant economic, social, and political disruption. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Types of Investments (Examples, not limitations) Advisory Persons of Alpha Wealth Management and Planning allocate a Client’s assets as appropriate to help them reach their individual investment objectives within their time horizon in a manner consistent with their risk profile. Client funds are allocated appropriately in such investments as listed below: • Mutual Funds – a pool of funds collected from many investors for the purpose of investing in securities such as stocks, bonds, money market instruments and similar assets. o Open-End Mutual Funds – a type of mutual fund that does not have restrictions on the amount of shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature o Closed-End Mutual Funds – a type of mutual fund that raises a fixed amount of capital through an initial public offering (IPO). The fund is then structured, listed and traded like a stock on a stock exchange. Clients should be aware that closed-end funds available within the program are not readily marketable. To provide investor liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, Clients may be unable to liquidate all or a portion of their shares in these types of funds. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 15 • Alternative Strategy Mutual Funds – Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. • Unit Investment Trust (UIT) – An investment company that offers a fixed, unmanaged portfolio, generally of stocks and bonds, as redeemable “units” to investors for a specific period. It is designed to provide capital appreciation and/or dividend income. UITs can be resold in the secondary market. A UIT may be either a regulated investment corporation (RIC) or a grantor trust. The former is a corporation in which the investors are joint owners; the latter grants investors proportional ownership in the UIT’s underlying securities. • Equity – investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environment. • Exchange Traded Funds (“ETFs”) – An ETF is a diversified investment very much like a mutual fund. Mutual funds can be actively managed to beat a benchmark index or designed to replicate the index. Like mutual funds, shares of an ETF represent a partial ownership of an underlying portfolio of securities. However, unlike mutual funds, shares of an ETF can be traded intraday during market hours. • Exchange-Traded Notes (“ETNs”) – An ETN is a senior unsecured debt obligation designed to track the total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets, for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are listed on an exchange and can typically be bought or sold throughout the trading day. • Fixed Income – investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. • Structured Products – Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 16 • Hedge Funds and Managed Futures – Hedge and managed futures funds are available for purchase in the program by Clients meeting certain qualification standards. Investing in these funds involves additional risks including, but not limited to, the risk of investment loss due to the use of leveraging and other speculative investment practices and the lack of liquidity and performance volatility. In addition, these funds are not required to provide periodic pricing or valuation information to investors and may involve complex tax structures and delays in distributing important tax information. Client should be aware that these funds are not liquid as there is no secondary trading market available. At the absolute discretion of the issuer of the fund, there may be certain repurchase offers made from time to time. However, there is no guarantee that Client will be able to redeem the fund during the repurchase offer. • Annuities – are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long- term goals. An annuity is not a life insurance policy. o Variable Annuities – If Client purchases a variable annuity that is part of the program, Client will receive a prospectus and should rely solely on the disclosure contained in the prospectus with respect to the terms and conditions of the variable annuity. Client should also be aware that certain riders purchased with a variable annuity may limit the investment options and the ability to manage the subaccounts. Variable annuities typically offer: Regular stream of income or a lump sum payout at a future time Tax-deferred treatment of earnings Death benefits • • • Variable annuities are designed to be long-term investments, to meet retirement and other long- range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges apply if money is withdrawn early. Variable annuities also involve investment risks, like mutual funds. • Non-U.S. Securities – present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. • Long-Term Purchases – Securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than on year. • Short-Term Purchases – Securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. • Cash Positions – Based on a perceived or anticipated market conditions and/or events, certain assets may be taken out of the market and held in a defensive cash position. All cash may be included as assets subject to the agreed upon advisory fee. Other investment types may be included as appropriate for a particular Client and their respective trading objectives. Alpha Wealth Management and Planning generally invest Client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve a reasonable return on our Client’s cash balances through relatively low-risk conservative investments. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Alpha Wealth Management and Planning or any of its Supervised Persons. Alpha Wealth Management and Planning and its Supervised Persons value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 163917. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 17 Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Certain Advisory Persons are also registered representatives of LPL Financial, LLC (“LPL Financial” or “LPL”). In one’s separate capacity as a registered representative, the Advisory Person will typically receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisory Person. Neither the Advisor nor the Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Insurance Agency Affiliations Certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from one’s role with Alpha Wealth Management and Planning. As an insurance professional, the Advisory Person receives customary commissions and other related revenues from the various insurance companies whose products are sold. The Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Advisory Persons or the Advisor. Neither Alpha Wealth Management and Planning nor any of the management persons are registered or has a registration pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Alpha Wealth Management and Planning has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all persons associated with Alpha Wealth Management and Planning (our “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. Alpha Wealth Management and Planning and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Alpha Wealth Management and Planning’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (415) 506-4569. B. Personal Trading with Material Interest Alpha Wealth Management and Planning allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Alpha Wealth Management and Planning does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Alpha Wealth Management and Planning does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Alpha Wealth Management and Planning allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Alpha Wealth Management and Planning requiring reporting of personal securities trades pursuant to its Code of Ethics. We have also adopted written policies and procedures to detect the misuse of material, non-public information. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 18 D. Personal Trading at Same Time as Client While Alpha Wealth Management and Planning allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Alpha Wealth Management and Planning, or any Supervised Person of Alpha Wealth Management and Planning, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Alpha Wealth Management and Planning does not have the discretion to select the broker-dealer/custodian (herein the “Custodian”) for custody and execution services. The Client will engage the Custodian to safeguard Client assets and authorize the Advisor to direct trades to the Custodian as agreed in the investment advisory agreement. Where Alpha Wealth Management and Planning does not exercise discretion over the selection of the Custodian, it will recommend the Custodian to Clients for custody and execution services. As its Advisory Persons are also registered representatives of LPL Financial, the Advisor and its Advisory Persons are limited in the Custodian[s] in which they can recommend to Clients. Typically, Alpha Wealth Management and Planning will recommend that Clients establish their accounts at LPL Financial, where the Advisor has access to LPL Financial’s systems, back office support, research and other benefits. Alpha Wealth Management and Planning has an arrangement with LPL Financial that includes custody of securities, trade execution, clearance and settlement of transactions. We receive some non-soft dollar benefits from LPL Financial through its participation in the program. LPL Financial may make certain research and brokerage services available at no additional cost to the Advisor. These services may be directly from independent research companies, as selected by the Advisor (within specific parameters). Research products and services provided by LPL Financial may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by LPL Financial to the Advisor in the performance of our investment decision-making responsibilities. As a result of receiving the services Alpha Wealth Management and Planning may have an incentive to continue to use or expand the use of LPL Financial’s services. The Advisor examined this potential conflict of interest when we chose to enter into the relationship with LPL Financial and we have determined that the relationship is in the best interest of the Advisor’s Clients and satisfies our fiduciary obligations, including our duty to seek best execution. LPL Financial charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). LPL Financial enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. LPL Financial’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by LPL Financial may be higher or lower than those charged by other custodians and broker/dealers. Clients may pay a commission to LPL Financial that is higher than another qualified broker dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all Clients, we may not necessarily obtain the lowest possible commission rates for specific Client account transactions. Clients may direct their brokerage transactions at a firm other than LPL Financial. Client directed brokerage may cost Clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 19 less favorable prices. Likewise, Client directed brokerage accounts may also result in more favorable prices, depending on each Client’s individual situation. Alpha Wealth Management and Planning does not allow Client-directed brokerage. Directed brokerage may cost Clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices on transactions. We perform investment management services for various Clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration Client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Special Considerations for ERISA Clients A retirement or ERISA plan Client may direct all or part of portfolio transactions for its’ account through a specific broker or dealer in order to obtain goods or services on behalf of the plan.
Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Alpha Wealth Management and Planning may receive support services and/or products from LPL Financial, which may assist Alpha Wealth Management and Planning to better monitor and service program accounts maintained on behalf of Alpha Wealth Management and Planning Clients. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate, and may include the following: investment-related research pricing information and market data software and other technology that provide access to Client account data compliance and/or practice management-related publications consulting services attendance at conferences, meetings, and other educational and/or social events • • • • • • • marketing support • • computer hardware and/or software other products and services used by Advisor in furtherance of its investment advisory business operations Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers whereby an advisor enters into an agreement to place security trades with the Custodian in exchange for research and other services. Alpha Wealth Management and Planning does not participate in soft dollar programs sponsored or offered by any broker-dealer. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14. Support services provided by the LPL Financial are based on the overall relationship between Alpha Wealth Management and Planning and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with the Custodians that involve the execution of Client transactions as a condition to the receipt of services. Alpha Wealth Management and Planning will continue to receive the services regardless of the volume of Client transactions executed with LPL Financial. Clients do not pay more for services as a result of this Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 20 arrangement. There is no corresponding commitment made by the Alpha Wealth Management and Planning to LPL Financial or any other entity to invest any specific amount or percentage of Client assets in any specific securities as a result of the arrangement. 2. Brokerage Referrals – Alpha Wealth Management and Planning does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Alpha Wealth Management and Planning will place trades within the established account[s] at the custodian designated by the Client. Further, all Client accounts are traded within their respective brokerage account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). In selecting the Custodian, Alpha Wealth Management and Planning will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as: 1) price 2) size of order 3) difficulty of execution 4) confidentiality and 5) skill required of the Custodian Alpha Wealth Management and Planning will execute its transactions through the Custodian selected by the Client. Alpha Wealth Management and Planning may aggregate orders in a block trade or trades when securities are purchased or sold through the same Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Andrei Jigalin, Chief Compliance Officer of Alpha Wealth Management and Planning. Formal reviews are generally conducted at least annually or more or less frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Alpha Wealth Management and Planning if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 21 Financial planning Clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning Clients, but are willing to meet with such Clients upon their request to discuss updates to their plans, changes in their circumstances, etc. We may review Client accounts more frequently than described above. We generally do not provide written reports to Clients, unless asked to do so. Verbal reports to Clients take place on at least an annual basis when we meet with Clients who subscribe to Comprehensive Portfolio Management and Third-Party Money Management. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Alpha Wealth Management and Planning Alpha Wealth Management and Planning receive an economic benefit from LPL Financial in reimbursement for marketing related expenses. Please see detailed discussion of the categories of marketing related expenses and potential conflicts of interest in Item 12 Brokerage Practices. Alpha Wealth Management and Planning and employees may receive additional compensation from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings with investment advisor representative, Client workshops or events, marketing events or advertising initiatives, including services for identifying prospective Clients. Product sponsors may also pay for, or reimburse Alpha Wealth Management and Planning for the costs associated with, education or training events that may be attended by Alpha Wealth Management and Planning employees and investment advisor representatives and for Alpha Wealth Management and Planning sponsored conferences and events. Participation in Institutional Advisor Platform As disclosed under Item 12, above, the Advisor has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial: financial start-up support; reimbursement to Clients for transfer costs to the platform/custodian; receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. B. Client Referrals from Solicitors Alpha Wealth Management and Planning does not engage paid solicitors for Client referrals. Item 15 – Custody Alpha Wealth Management and Planning does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Alpha Wealth Management and Planning to utilize the Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Alpha Wealth Management and Planning to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Alpha Wealth Management and Planning urges you to carefully review the statements provided by the custodian and compare such official custodial records to the account statements that may be provided by Alpha Wealth Management and Planning. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 22 Item 16 – Investment Discretion Alpha Wealth Management and Planning generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Alpha Wealth Management and Planning. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client’s execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Alpha Wealth Management and Planning will be in accordance with each Client’s investment objectives and goals. Item 17 – Voting Client Securities Alpha Wealth Management and Planning does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. However, money managers of the funds selected or recommended by Alpha Wealth Management and Planning may vote proxies for Clients. Therefore, except in the event a money manager votes proxies, Clients maintain exclusive responsibility for: • directing the manner in which proxies solicited by issuers of securities beneficially owned by the Client shall be voted; and, • making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the Client’s investment assets. Therefore (except for proxies that may be voted by a money manager), Alpha Wealth Management and Planning shall instruct the qualified custodian to forward all proxies and shareholder communications to each Client. Item 18 – Financial Information Neither Alpha Wealth Management and Planning, nor its management persons, have any adverse financial situations that would reasonably impair the ability of Alpha Wealth Management and Planning to meet all obligations to its Clients. Alpha Wealth Management and Planning is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 23 Item 1 – Cover Page Firm Contact: Andrei Jigalin, President & Chief Compliance Officer Additional Contact: Matt Fannin, Principal & Chairman Alpha Wealth Management and PlanningLLC Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”) Effective: March 26, 2026 This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Alpha Wealth Management and PlanningLLC (“Alpha Wealth Management and Planning” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Alpha Wealth Management and Planning Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Alpha Wealth Management and Planning Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the Alpha Wealth Management and Planning Disclosure Brochure, please contact us at (415) 506-4569. Alpha Wealth Management and Planning is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about Alpha Wealth Management and Planning to assist you in determining whether to retain the Advisor. Additional information about Alpha Wealth Management and Planning and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 163917. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 24 Item 2 – Material Changes Form ADV 2 – Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs offering by the Advisor. Material Changes This Disclosure Brochure has been redrafted to streamline disclosures and presentation. However, there have been no material changes to the disclosures since the March 29, 2025 annual amendment. Future Changes From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Alpha Wealth Management and Planning Disclosure Brochure) or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Alpha Wealth Management and Planning. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 163917. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (415) 506-4569. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 25 Item 3 – Table of Contents Item 1 – Cover Page .............................................................................................................................................. 24 Item 2 – Material Changes ……………………………………………………………………………………………… 25 Item 3 – Table of Contents ……………………………………………………………………………………………... 26 Item 4 – Services, Fees and Compensation ………………………………………………………………………… 27 Item 5 – Account Requirements and Types of Clients …………………………………………………….……….30 Item 6 – Portfolio Manager Selection and Evaluation ……………………………………………………….……..30 Item 7 – Client Information Provided to Portfolio Manager(s) …………………………………………...……… 31 Item 8 – Client Contact with Portfolio Manager …………………………………………………………………..... 32 Item 9 – Additional Information ……………………………………………………………………………………….. 32 Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 26 Item 4 – Services Fees and Compensation A. Services This item includes a description of our services, including the types of portfolio management services, provided under each program. We must indicate the wrap fee charged for each program, or, if fees vary according to a schedule, provide such schedule. Further, we are required to indicate whether fees are negotiable and identify the portion of the total fee, or range of fees, paid to portfolio managers. Alpha Wealth Management and Planning LLC offers two wrap fee programs sponsored by our firm. • Technical Platform Wrap Fee Program PPG (Participate, Protect and Grow) investing uses a dynamic risk management process to increase or reduce risk exposure in an investment portfolio. Using a sophisticated software engine we will monitor price, pressure, momentum along with other proprietary metrics, to generate buy and sell information. • Fundamental Platform Wrap Fee Program Utilizing Modern Portfolio Theory (“MPT”) we will attempt to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Our wrap fee accounts are managed on an individualized basis according to the Client’s investment objectives, financial goals, risk tolerance, etc. Both our wrap fee program services encompass asset management as well as providing financial planning/financial consulting to Clients. It is designed to assist Clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with Clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the Client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the Client’s agreement to the proposed investment plan, we work with the Client to establish or transfer investment accounts so that we can manage the Client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust Client accounts under our management. If the Client experiences any significant changes to their financial or personal circumstances, the Client must notify us so that we can consider such information in managing the Client’s investments. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Alpha Wealth Management and Planning’s investment philosophy and related services. B. Program Costs Advisory services provided by Alpha Wealth Management and Planning are offered in a wrap fee structure whereby normal securities transaction costs are included in the overall investment advisory fee paid to Alpha Wealth Management and Planning. As the level of trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transactions costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity in the Client’s account[s]. A Wrap Fee structure has a potential conflict of interest as the Advisor may have an incentive to limit the number of trades placed in the Client’s account[s]. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 27 C. Fees Investment advisory fees are paid quarterly in advance pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the following schedule: Technical Platform Wrap Fee Program Annual Rate (%) Assets Under Management ($) Up to $250,000 $250,001 to $500,000 $500,001 to $1,000,000 $1,000,001 and over 2.5% 2.25% 2.0% 1.75% Fundamental Platform Wrap Fee Program Annual Rate (%) Assets Under Management ($) Up to $250,000 $250,001 to $500,000 $500,001 to $1,000,000 $1,000,001 and over 1.5% 1.4% 1.3% 1.2% A wrap fee program allows our Clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services may include portfolio management and/or advice concerning selection of other advisers, and the fee is not based directly upon transactions in your account. Your fee is bundled with our costs for executing transactions in your account(s). This results in a higher advisory fee to you. We do not charge our Clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to you by the executing broker. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. The advisory fee is deducted from the account by the custodian of assets based on a written authorization from the Client. The custodian calculates and deducts the advisory fee quarterly in advance. If the advisory agreement is terminated before the end of the quarterly period, Client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter after the termination date. Although Clients do not pay a transaction charge for transactions in a program account, Clients should be aware that Advisor pays custodial transaction charges for the transactions. The transaction charges paid by Advisor vary based on the type of transaction (e.g., mutual fund, equity or fixed income security) and range from $0 to $50. Because Advisor pays the transaction charges in program accounts, there is a conflict of interest. Clients should understand that the cost to Advisor of transaction charges may be a factor that the Advisor considers when deciding which securities to select and how frequently to place transactions in a program account. There are other fees and charges that are imposed by other third parties that apply to investments in program accounts. Some of these fees and charges are described below. If a Client’s assets are invested in mutual funds or other pooled investment products, Clients should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay Advisor the advisory fee with respect to those assets. Most of the mutual funds available in the program may be purchased directly. Therefore, Clients could generally avoid the second layer of fees by not using the management services of Advisor and by making their own investment decisions. Certain mutual funds impose fees and charges such as contingent deferred sales charges, early redemption fees and charges for frequent trading. These charges may apply if Client transfers into or purchases such a fund with the Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 28 applicable charges in a program account. Although only no-load and load-waived mutual funds can be purchased in a program account, Client should understand that some mutual funds pay asset based sales charges or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings. If Client holds a variable annuity as part of an account, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. Further information regarding fees assessed by a mutual fund, or variable annuity is available in the appropriate prospectus, which is available upon request from the Advisor or from the product sponsor directly. Other Important Considerations The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions and other administrative and custodial services. The advisory fee may cost the Client more than purchasing the program services separately, for example, paying an advisory fee plus commissions for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the type and size of the account, historical and or expected size or number of trades for the account, and number and range of supplementary advisory and Client-related services provided to the Client. The advisory fee also may cost the Client more than if assets were held in a traditional brokerage account. In a brokerage account, a Client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the Client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the Client should consider opening a brokerage account rather than a program account. The Advisor recommending the program to the Client receives compensation as a result of the Client’s participation in the program. This compensation includes the advisory fee and also may include other compensation, such as bonuses, awards or other things of value offered by the custodian to the Advisor or its associated persons. The amount of this compensation may be more or less than what the Advisor would receive if the Client participated in other custodial programs, programs of other investment advisors or paid separately for investment advice, brokerage and other Client services. Therefore, the Advisor may have a financial incentive to recommend a program account over other programs and services. The investment products available to be purchased in the program can be purchased by Clients outside of a program account, through broker-dealers or other investment firms not affiliated with Advisor. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by Alpha Wealth Management and Planning will be independently valued by the designated Custodian. Alpha Wealth Management and Planning will not have the authority or responsibility to value portfolio securities. Fees are generally negotiable. Further, our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the discretionary investment management services provided by Alpha Wealth Management and Planning. Securities transaction fees for Client-directed trades may be charged back to the Client. Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Under this Wrap Fee Program, Alpha Wealth Management and Planning includes securities transactions costs as part of its overall investment advisory fee. In addition, all fees paid to Alpha Wealth Management and Planning for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. The Client may also incur other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, fees for trades executed away from the Custodian and other fees. The Advisor does not control nor share in Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 29 these fees. The Client should review both the fees charged by the fund[s] and the fees charged by Alpha Wealth Management and Planning to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Alpha Wealth Management and Planning is the sponsor and portfolio manager of this Wrap Fee Program. Alpha Wealth Management and Planning receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with the normal trading activity in the Client’s account[s]. Item 5 – Account Requirements and Types of Clients We impose the following requirement(s) to open or maintain an account: • Minimum total account size of $100,000; • Minimum management fee of 1.00% for assets under management of $1,000,000 
and more with our firm. Types of Clients we typically manage wrap fee accounts on behalf of, include: Individuals and High Net-Worth Individuals; • • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, limited liability companies and/or other business types. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Alpha Wealth Management and Planning serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. There are no differences between how a wrap fee program is managed and how other accounts are managed. However, Alpha Wealth Management and Planning may charge a higher fee and receives a portion of the wrap fee for services provided. The program may cost more or less than purchasing such services separately. Related Persons Alpha Wealth Management and Planning personnel serve as portfolio managers for this Wrap Fee Program. Alpha Wealth Management and Planning does not serve as a portfolio manager for any third-party wrap fee programs. Performance-Based Fees Neither the firm or any supervised persons accepts performance-based fees, fees based on a share of capital gains on or capital appreciation of the assets of a Client such as a hedge fund or other pooled investment vehicle. Neither the firm or any supervised persons manages side-by- side accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee. Supervised Persons Alpha Wealth Management and Planning Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 30 Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Alpha Wealth Management and Planning will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account[s]. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Alpha Wealth Management and Planning does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. However, money managers of the funds selected or recommended by Alpha Wealth Management and Planning may vote proxies for Clients. Therefore, except in the event a money manager votes proxies, Clients maintain exclusive responsibility for: • directing the manner in which proxies solicited by issuers of securities beneficially owned by the Client shall be voted; and, • making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the Client’s investment assets. Therefore (except for proxies that may be voted by a money manager), Alpha Wealth Management and Planning shall instruct the qualified custodian to forward all proxies and shareholder communications to each Client. Item 7 – Client Information Provided to Portfolio Managers Alpha Wealth Management and Planning is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. The Advisor obtains this information by having the Client complete an advisory agreement and other documentation. Clients are encouraged to contact the Advisor if there have been any changes in the Client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Client should be aware that the investment objective selected for the program is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client should further be aware that achievement of the stated investment objective is a long-term goal for the account. The Firm policy requires an annual Client meeting (one review every 12 months) to determine if there have been any changes in the Client’s financial situation, investment objectives, or restrictions. In addition, the meeting should incorporate the account performance, appropriateness of the account, and any other information determined pertinent to the Client situation. The annual meeting may occur by phone, in person, via e-mail, or via video conference and documentation will be maintained to evidence that at a minimum the following topics were reviewed: The Client’s financial status • Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 31 Time Horizon Investment Objective and Goals Asset Allocation and/or Account Holdings • Risk Tolerance • • • Please also see the Alpha Wealth Management and Planning Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Alpha Wealth Management and Planning is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at Alpha Wealth Management and Planning. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations Alpha Wealth Management and Planning values the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for our firm name or by our CRD# 163917. Please see Item 9 of the Alpha Wealth Management and Planning Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Advisor is only in the business of providing investment advice. However, associated persons of Advisor are separately licensed as registered representatives through LPL Financial. In this capacity, the associated person can sell securities to Clients and receive normal and customary compensation in the form of commissions. Associated persons are also insurance agents. In such capacity, they may offer fixed and variable life insurance products and receive normal and customary commissions as a result of any purchases made by Clients. • Andrei Jigalin, President and CCO, is a registered representative of LPL Financial, member FINRA/SIPC. He may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create an incentive to recommend products based on the compensation Andrei Jigalin may earn and may not necessarily be in the best interests of the Client. • Matt Fannin, Principal and Chairman, is a registered representative of LPL Financial, member FINRA/SIPC. He may offer securities and receive normal and customary commissions as a result of securities transactions. A conflict of interest may arise as these commissionable securities sales may create and incentive to recommend products based on the compensation Matt Fannin may earn and may not necessarily be in the best interest of the Client. Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Alpha Wealth Management and Planning has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Alpha Wealth Management and Planning’s compliance program (our “Supervised Persons”). Complete details on the Alpha Wealth Management and Planning Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Review of Accounts Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Alpha Wealth Management and Planning under the supervision of the Chief Compliance Officer (“CCO”). Details of the Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 32 review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Participation in Institutional Advisor Platform The Advisor has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial: financial start-up support; reimbursement to Clients for transfer costs to the platform/custodian; receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by Alpha Wealth Management and Planning or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Client Referrals from Solicitors Alpha Wealth Management and Planning does not engage paid solicitors for Client referrals. Other Compensation Advisor and its associated persons may receive additional non-cash compensation from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or marketing or advertising initiatives. Product sponsors may also pay for education or training events that may be attended by Advisor’s employees and associated persons. Alpha Wealth Management and Planning does not directly or indirectly compensate any person who is not a supervised person for Client referrals. There are no other economic benefits provided by someone who is not a Client for providing investment advice. Custody LPL Financial and Charles Schwab & Co., Inc are the qualified custodians and maintain custody of Client funds and securities in a separate account for each Client under the Client’s name. These custodian sends account statements showing all transactions, positions, and all deposits and withdrawals of principal and income. The custodian sends account statements monthly when the account has had activity or quarterly if there has been no activity. Clients should carefully review those account statements. Although most securities available in program accounts are custodied at either LPL Financial or Charles Schwab & C., Inc, there are certain securities managed as part of the account that are held at third parties, and not at either qualified custodian. For example, variable annuities, hedge funds and managed futures are often held directly with the investment sponsor. For those outside positions, Client will receive confirmations and statements directly from the investment sponsor. For outside positions not custodied at LPL Financial or Charles Schwab & Co., Inc, these custodians may receive information (e.g., number of shares held and market value) from the investment sponsor and display that information on statements and reports prepared by the custodian. Such information also may be used to calculate performance in performance reports prepared by the custodian. Although Advisor believes that the information provided by the custodian is accurate, Advisor recommends that Clients refer to the statements and reports received directly from the investment sponsor and compare them with the information provided in any statements or reports from LPL Financial. The statements and reports provided with respect to outside positions should not Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 33 replace the statements and reports received directly from the investment sponsor. Brokerage Practices In the Alpha Wealth Management and Planning Wrap Fee Program, Advisor requires that Clients direct LPL Financial as the sole and exclusive broker-dealer to execute transactions in the account. LPL Financial is not paid a commission for executing transactions. Because associated persons of the Advisor are licensed with LPL Financial, this presents a conflict of interest. Clients should understand that not all advisors require their Clients to direct brokerage. By directing brokerage to LPL Financial, Clients may be unable to achieve the most favorable execution of Client transactions. Therefore, directed brokerage may cost Clients more money. Advisor may receive support services and/or products from LPL Financial, which assist the Advisor to better monitor and service program accounts maintained at LPL Financial. These support services and/or products may be received without cost, at a discount, and/or at another negotiated rate, and may include the following: investment-related research pricing information and market data software and other technology that provide access to Client account data compliance and/or practice management-related publications consulting services attendance at conferences, meetings, and other educational and/or social events computer hardware and/or software other products used by Advisor in furtherance of its investment advisory business operations • • • • • • • marketing support • • • Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Advisor to LPL Financial or any other entity to invest any specific amount or percentage of Client assets in any specific securities as a result of the arrangement. Advisor may aggregate transactions in equity and fixed income securities for a Client with other Clients to improve the quality of execution. When transactions are so aggregated, the actual prices applicable to the aggregated transactions will be averaged, and the Client account will be deemed to have purchased or sold its proportionate share of the securities involved at the average price obtained. Advisor may determine not to aggregate transactions, for example, based on the size of the trades, the number of Client accounts, the timing of the trades, the liquidity of the securities and the discretionary or non-discretionary nature of the trades. If Advisor does not aggregate orders, some Clients purchasing securities around the same time may receive a less favorable price than other Clients. This means that this practice of not aggregating may cost Clients more money. Financial Information Neither Alpha Wealth Management and Planning, nor its management has any adverse financial situations that would reasonably impair the ability of Alpha Wealth Management and Planning to meet all obligations to its Clients. Neither Alpha Wealth Management and Planning, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Alpha Wealth Management and Planning is not required to deliver a balance sheet along with this Disclosure Brochure, as the firm does not collect advance fees of $1,200 or more for services to be performed six months or more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 34 Privacy Policy Effective: March 26, 2026 Our Commitment to You Alpha Wealth Management and Planning LLC (“Alpha Wealth Management and Planning” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Alpha Wealth Management and Planning (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Alpha Wealth Management and Planning does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number(s) Income and expenses E-mail address(es) Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectlively implement its services. In the section below, we list some reasons we may share your personal information. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 35 Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes Servicing our Clients We share information with technology vendors and third-party service providers to manage and support operations and regulatory compliance (such as administrators, brokers, custodians, regulators, credit agencies, consultants and other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Alpha Wealth Management and Planning does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Alpha Wealth Management and Planning or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). No Not Shared Information About Former Clients Alpha Wealth Management and Planning does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations California In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (415) 506-4569. Alpha Wealth Management and Planning, LLC 350 Ignacio Blvd | Novato, CA 94949 Phone: (415) 506-4569 | Fax: (415) 508-3467 http://www.alphawmp.com Page 36

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