Overview

Assets Under Management: $235 million
Headquarters: VIRGINIA BEACH, VA
High-Net-Worth Clients: 103
Average Client Assets: $1.7 million

Frequently Asked Questions

ALTURA WEALTH ADVISORS charges 1.25% on the first $0 million, 0.75% on the next $1 million, 0.60% on the next $4 million, 0.45% on the next $5 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #337998), ALTURA WEALTH ADVISORS is subject to fiduciary duty under federal law.

ALTURA WEALTH ADVISORS is headquartered in VIRGINIA BEACH, VA.

ALTURA WEALTH ADVISORS serves 103 high-net-worth clients according to their SEC filing dated April 10, 2026. View client details ↓

According to their SEC Form ADV, ALTURA WEALTH ADVISORS offers financial planning, portfolio management for individuals, pension consulting services, and selection of other advisors. View all service details ↓

ALTURA WEALTH ADVISORS manages $235 million in client assets according to their SEC filing dated April 10, 2026.

According to their SEC Form ADV, ALTURA WEALTH ADVISORS serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (LCW SERVICES, LLC DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS)

MinMaxMarginal Fee Rate
$0 $500,000 1.25%
$500,001 $1,000,000 0.75%
$1,000,001 $3,500,000 0.60%
$3,500,001 $5,000,000 0.45%
$5,000,001 $10,000,000 0.25%
$10,000,001 and above 0.20%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $31,750 0.64%
$10 million $44,250 0.44%
$50 million $124,250 0.25%
$100 million $224,250 0.22%

Clients

Number of High-Net-Worth Clients: 103
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 74.42%
Average Client Assets: $1.7 million
Total Client Accounts: 898
Discretionary Accounts: 895
Non-Discretionary Accounts: 3
Minimum Account Size: None

Regulatory Filings

CRD Number: 337998
Filing ID: 2063081
Last Filing Date: 2026-04-10 09:51:24

Form ADV Documents

Primary Brochure: LCW SERVICES, LLC DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENTS (2026-04-10)

View Document Text
LCW Services, LLC d/b/a Altura Wealth Advisors Form ADV Part 2A – Disclosure Brochure Effective: April 10, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (757) 834-7606 or by email at info@alturawealth.com. Altura Wealth Advisors is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“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 Altura Wealth Advisors to assist you in determining whether to retain the Advisor. Additional information about Altura Wealth Advisors and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 337998. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.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 the Advisory Persons of Altura Wealth Advisors. For convenience, the Advisor has combined these documents into a single disclosure document. Altura Wealth Advisors believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Altura Wealth Advisors encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on January 26, 2026: • The Advisor has amended its fees for assets held at American Funds and DPL. Please see Item 5 for more information. • Certain Advisory Persons are no longer affiliated with Purshe Kaplan Sterling Investments, Inc. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you 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 the Advisor’s firm name or CRD# 337998. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (757) 834-7606 or by email at info@alturawealth.com. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 2 Item 3 – Table of Contents 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 .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 7 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services ............................................................................................................................................. 7 B. Fee Billing ....................................................................................................................................................................... 8 C. Other Fees and Expenses ............................................................................................................................................. 8 D. Advance Payment of Fees and Termination .................................................................................................................. 9 E. Compensation for Sales of Securities .......................................................................................................................... 10 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 10 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 A. Methods of Analysis ..................................................................................................................................................... 10 B. Risk of Loss .................................................................................................................................................................. 11 Item 9 – Disciplinary Information ....................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 A. Code of Ethics .............................................................................................................................................................. 12 B. Personal Trading with Material Interest ........................................................................................................................ 13 C. Personal Trading in Same Securities as Clients .......................................................................................................... 13 D. Personal Trading at Same Time as Client ................................................................................................................... 13 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 14 Item 13 – Review of Accounts ............................................................................................................................ 14 A. Frequency of Reviews .................................................................................................................................................. 14 B. Causes for Reviews ..................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ........................................................................................ 14 A. Compensation Received by Altura Wealth Advisors .................................................................................................... 14 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody ................................................................................................................................................ 15 Item 16 – Investment Discretion ......................................................................................................................... 15 Item 17 – Voting Client Securities ...................................................................................................................... 16 Item 18 – Financial Information .......................................................................................................................... 16 Form ADV Part 2B – Brochure Supplements .................................................................................................... 17 Privacy Policy ...................................................................................................................................................... 30 LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 3 Item 4 – Advisory Services A. Firm Information LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”) is a registered investment advisor with the SEC. The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the Commonwealth of Virginia. Altura Wealth Advisors was founded in January 2020 and became a registered investment advisor in 2025. The Advisor is owned by LCI LLC and RECJ LLC, and operated by Repp H. Lambert II (Founder), Roger (B.J.) E. Crook Jr. (Co-Founder and Chief Compliance Officer), and Rachel T. Wren (Director of Operations). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Altura Wealth Advisors. B. Advisory Services Offered Altura Wealth Advisors offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Altura Wealth Advisors' fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Altura Wealth Advisors provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services and a broad range of comprehensive financial planning. Investment Management Services – The Advisor provides discretionary investment management services. Altura Wealth Advisors works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Altura Wealth Advisors will then construct an investment portfolio utilizing model portfolios to meet the Client’s investment goals. These model portfolios primarily consist of exchange-traded funds (“ETFs”) and/or low-cost, diversified mutual funds Client’s investment goals. The Advisor may also utilize individual stocks, bonds and other types of investments, as appropriate, to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Altura Wealth Advisors’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Altura Wealth Advisors 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. Altura Wealth Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Altura Wealth Advisors may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Altura Wealth Advisors 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. Altura Wealth Advisors 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 4 At no time will Altura Wealth Advisors accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – The Advisor will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients as part of its wealth management services. The Advisor also provides stand-alone financial planning services pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Altura Wealth Advisors may also refer Clients to an accountant, attorney or other 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 (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of 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 implement the transaction through the Advisor. Insurance Consulting The Advisor has a relationship with DPL Financial Partners, LLC (“DPL”). The Advisor provides insurance review, analysis, education, and insurance solutions in collaboration with DPL. DPL is a third-party provider of a platform of LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 5 insurance consulting services to registered investment advisers that have clients with a current or future need for insurance products. The Advisor has engaged with DPL to gain access to DPL’s insurance platform for a fixed annual fee. The Advisor is provided access to fee-based insurance products through DPL’s licensed insurance agents who are also registered representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member. These services include, among others, providing the Advisor with analyses of the current methodology for evaluating Client insurance needs, educating and acting as a resource to the Advisor regarding insurance products generally and specific insurance products owned by Clients or that Clients are considering purchasing, and providing the Advisor access to and product marketing support regarding fee-based products that insurers have agreed to offer to the Advisor’s Clients through DPL’s platform. For providing platform services to the Advisor, DPL receives service fees from the insurers that offer fee-based products through the platform. These service fees are based on the insurance premiums received by the insurers. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. Retirement Plan Advisory Services The Advisor provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • Ongoing Investment Recommendation and Assistance • Performance Reports • ERISA 404(c) Assistance • Benchmarking Services These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Altura Wealth Advisors 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 – Altura Wealth Advisors, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – Altura Wealth Advisors will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Altura Wealth Advisors will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Altura Wealth Advisors will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Altura Wealth Advisors does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Altura Wealth Advisors. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 6 E. Assets Under Management As of December 31, 2025 Altura Wealth Advisors manages $234,907,065 in Client assets, $234,870,323 of which are managed on a discretionary basis and $36,742 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services Wealth management fees are paid in advance of each calendar quarter pursuant to the terms of the wealth management agreement. Wealth management fees are based on the average daily balance of the market value of assets under management throughout the prior calendar quarter. Wealth management fees are based on the following schedule: Assets Under Management ($) Up to $500,000 $500,001 to $1,000,000 $1,000,001 to $3,500,000 $3,500,001 to $5,000,000 $5,000,001 to $10,000,000 $10,000,001 and Over Annual Rate (%) 1.25% 0.75% 0.60% 0.45% 0.25% 0.20% The wealth management 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 the Advisor. All securities held in accounts managed by Altura Wealth Advisors will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent Manager fees are separate and in addition to the Advisor’s wealth management fees. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. American Funds The wealth management fee is billed quarterly, in arrears, for assets held at American Funds. The fee is based upon the average daily net value. Accounts with American Funds are subject to an asset-based fee of 0.25% annually which may be negotiable at the sole discretion of the Advisor. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 7 Financial Planning Services Altura Wealth Advisors offers financial planning services as part of its wealth management services. In connection with its wealth management services, Clients will be assessed an initial fixed financial planning fee ranging from $4,000-$25,000. The Advisor also offers ongoing stand-alone financial planning services on a monthly basis. Monthly fees range from $350 to $2,500 per month. 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. Insurance Consulting The wealth management fee is billed quarterly, in advance, for assets held at DPL. The fee is based upon the average daily value. Assets with DPL are subject to an asset-based fee of 0.50% annually which may be negotiable at the sole discretion of the Advisor. Retirement Plan Advisory Services Retirement plan advisory fees are charged an annual asset-based fee of up to 0.50%. Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated above. B. Fee Billing Wealth Management Services Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated as follows: (average daily balance of assets under management x annual rate) x (effective days in the billing period / days in the year). Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting wealth management fees to be deducted by Altura Wealth Advisors to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s overall fees will include Altura Wealth Advisors’ wealth management fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. Financial Planning Services Financial planning fees for ongoing engagements are invoiced monthly in advance. Financial planning fees for fixed engagements are due and payable upon execution of the financial planning agreement. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Altura Wealth Advisors, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 8 and other types of investments. The fees charged by Altura Wealth Advisors are separate and distinct from these custody and execution fees. In addition, all fees paid to Altura Wealth Advisors for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs 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 may be able to invest in these products directly, without the services of Altura Wealth Advisors, but would not receive the services provided by Altura Wealth Advisors 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 Altura Wealth Advisors to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Wealth Management Services Altura Wealth Advisors may be compensated for its wealth management services in advance of the quarter in which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management 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 Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers – In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for termination are set forth in the respective agreements between the Advisor and the Independent Managers. Financial Planning Services Altura Wealth Advisors requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, 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 the percentage of the engagement scope completed by the Advisor or in the case of an ongoing engagement, the Advisor will refund any unearned, prepaid planning fees from the effective date of termination to the end of the month. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Insurance Consulting Altura Wealth Advisors may be compensated for its wealth management services in advance of the quarter in which services are rendered for assets at DPL. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the wealth management 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 Advisor will refund any unearned, prepaid wealth management fees from the effective date of termination to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 9 responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Altura Wealth Advisors does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Insurance Agency Affiliation Altura Wealth Advisors is also a licensed insurance agency and certain Advisory Persons are licensed insurance professionals. Advisory Persons may earn commission-based compensation for selling insurance products, including insurance products offered to Clients. Insurance commissions earned by Altura Wealth Advisors and its Advisory Persons are separate and in addition to investment advisory fees. This practice presents a conflict of interest as Advisory Persons have an incentive to recommend insurance products to the Client for the purpose of generating commissions rather than solely based on the Client’s needs. Altura Wealth Advisors will never earn both a commission and an ongoing advisory fee on the same assets. Clients are under no obligation, contractual or otherwise, to purchase insurance products through any Advisory Person or Altura Wealth Advisors. Please see Item 10 below. Item 6 – Performance-Based Fees and Side-By-Side Management Altura Wealth Advisors does not charge performance-based fees for its investment advisory services. The fees charged by Altura Wealth Advisors are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Altura Wealth Advisors 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 Altura Wealth Advisors offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and retirement plans. Altura Wealth Advisors generally does not impose a minimum relationship size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Altura Wealth Advisors employs fundamental and cyclical analysis methods, as well as Modern Portfolio Theory in developing investment strategies for its Clients. Research and analysis from Altura Wealth Advisors are 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. This criteria consists generally of 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. 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 LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 10 particular company that Altura Wealth Advisors is recommending. The risks with cyclical analysis are similar to those of technical analysis. Modern Portfolio Theory (“MPT”) is a Nobel Prize-winning approach that is utilized as a formal process for investment selection. By comparing historical return, historical volatility, and historical correlation, MPT finds the most efficient portfolio for a given level of risk. The sensitive process of gathering suitable inputs and constructing constraints to create marketable portfolios requires the infusion of opinion, experience, and importantly, a deep understanding of financial theory and markets. An inherent risk in applying MPT is the understanding that the historical characteristics of an investment or index do not necessarily indicate future outcomes. The Advisor employs various measures to mitigate this risk, including, but not limited to: continuously challenging all assumptions, applying practical constraints to the portfolio models, and considering alternative courses of history. As noted above, Altura Wealth Advisors generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Altura Wealth Advisors 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, Altura Wealth Advisors 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. 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. Altura Wealth Advisors 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 associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 11 Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. 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. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Altura Wealth Advisors or management persons. Altura Wealth Advisors values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 337998. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliation As noted in Item 5, Altura Wealth Advisors is also a licensed insurance agency and certain Advisory Persons are licensed as insurance professionals. Altura Wealth Advisor may earn commission-based compensation for selling insurance products, including insurance products sold to Clients. Insurance commissions earned by Altura Wealth Advisors are separate and in addition to advisory fees. However, Altura Wealth Advisors will never earn both a commission and an ongoing advisory fee on the same assets. Clients are under no obligation to purchase insurance products through Altura Wealth Advisors or any person affiliated with Altura Wealth Advisors. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Altura Wealth Advisors has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Altura Wealth Advisors (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Altura Wealth Advisors and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Altura Wealth Advisors’ 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 the Code, please contact the Advisor at (757) 834-7661or via email at info@alturawealth.com. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 12 B. Personal Trading with Material Interest Altura Wealth Advisors allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Altura Wealth Advisors 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. Altura Wealth Advisors does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Altura Wealth Advisors allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has 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 have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can 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 Altura Wealth Advisors requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Altura Wealth Advisors allows 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 Altura Wealth Advisors, or any Supervised Person of Altura Wealth Advisors, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Altura Wealth Advisors does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Altura Wealth Advisors to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Altura Wealth Advisors does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Altura Wealth Advisors does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Altura Wealth Advisors. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Altura Wealth Advisors may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. The Advisor will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Altura Wealth Advisors does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 13 2. Brokerage Referrals - Altura Wealth Advisors 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 Altura Wealth Advisors will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective 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]). Altura Wealth Advisors 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 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 the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Altura Wealth Advisors will execute its transactions through the Custodian as authorized by the Client. Altura Wealth Advisors may aggregate orders in a block trade or trades when securities are purchased or sold through the 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 Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Roger E. Crook Jr., Chief Compliance Officer of Altura Wealth Advisors. Formal reviews are generally conducted at least annually or more 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 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 Altura Wealth Advisors 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. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Altura Wealth Advisors Altura Wealth Advisors is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Altura Wealth Advisors does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Altura Wealth Advisors may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Altura Wealth Advisors may receive non-compensated referrals of new Clients from various third-parties. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 14 Participation in Institutional Advisor Platform The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. 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 conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to the Advisor that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. The Advisor believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct Altura Wealth Advisors to utilize that Custodian for the Client’s security transactions in the account[s]. Clients should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Altura Wealth Advisors 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 Altura Wealth Advisors. 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 Altura Wealth Advisors will be in LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 15 accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Altura Wealth Advisors 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. Item 18 – Financial Information Neither Altura Wealth Advisors, nor its management, have any adverse financial situations that would reasonably impair the ability of Altura Wealth Advisors to meet all obligations to its Clients. Neither Altura Wealth Advisors, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Altura Wealth Advisors is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 16 Form ADV Part 2B – Brochure Supplement for Repp H. Lambert II, ChFC®, CLU® Founder Effective: April 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Repp H. Lambert II, ChFC®, CLU® (CRD# 2816247) in addition to the information contained in the LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”, CRD# 337998) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Altura Wealth Advisors Disclosure Brochure or this Brochure Supplement, please contact us at (757) 834-7661or by email at info@alturawealth.com. Additional information about Mr. Lambert is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2816247. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 17 Item 2 – Educational Background and Business Experience Repp H. Lambert II, ChFC®, CLU® born in 1970, is dedicated to advising Clients of Altura Wealth Advisors as its Founder. Mr. Lambert earned his Bachelor of Science from Radford University in 1994. Additional information regarding Mr. Lambert’s employment history is included below. Employment History: Founder, LCW Services, LLC d/b/a Altura Wealth Advisors Registered Representative, Purshe Kaplan Sterling Investments, Inc. Wealth Management Advisor, Northwestern Mutual Investment Services, LLC 10/2025 to Present 10/2025 to 2/2026 04/1996 to 10/2025 Chartered Financial Consultant™ (“ChFC®”) The Chartered Financial Consultant™ (ChFC®) program prepares you to meet the advanced financial planning needs of individuals, professionals, and small business owners. You'll gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments, and estate planning. The ChFC® requires three years of full-time, relevant business experience, nine two-hour course-specific proctored exams, and 30 hours of continuing education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of Ethics. Program Objectives: • Function as an ethical, competent and articulate practitioner in the field of financial planning • Utilize the intellectual tools and framework needed to maintain relevant and current financial planning knowledge and strategies. • Apply financial planning theory and techniques through the development of case studies and solutions. • Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate planning, retirement planning, or non-qualified deferred compensation. The Chartered Life Underwriter™ (“CLU®”) The Chartered Life Underwriter™ (CLU®) is a designation of insurance expertise, helping gain a significant advantage in a competitive market. This course of study helps by providing in-depth knowledge of the insurance needs of individuals, business owners, and professional clients. Program Learning Objectives: • Provide guidance to clients on types and amounts of life insurance needed • Make recommendations on aspects of risk management, including personal and business uses of a variety of insurance solutions • Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries • Assist clients in making decisions about estate planning, including the proper holding of assets and title to assets, as well as the implications of various wills and trust arrangements on financial, retirement and succession planning issues • Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Lambert. Mr. Lambert has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Lambert. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Lambert. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 18 However, we do encourage you to independently view the background of Mr. Lambert on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2816247. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Lambert is also a licensed insurance professional with Altura Wealth Advisors. As an insurance professional, Mr. Lambert will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Lambert is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Lambert or the Advisor. Mr. Lambert spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Lambert has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Lambert serves as the Founder of Altura Wealth Advisors and is supervised by Roger Crook, the Chief Compliance Officer. Mr. Crook can be reached at (757) 834-7661. Altura Wealth Advisors has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Altura Wealth Advisors. Further, Altura Wealth Advisors is subject to regulatory oversight by various agencies. These agencies require registration by Altura Wealth Advisors and its Supervised Persons. As a registered entity, Altura Wealth Advisors is subject to examinations by regulators, which may be announced or unannounced. Altura Wealth Advisors is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 19 Form ADV Part 2B – Brochure Supplement for Roger E. Crook Jr., CFP®, ChFC®, ChSNC®, CLU®, RICP®, WMCP® Co-Founder, Chief Compliance Officer Effective: April 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Roger E. Crook Jr., CFP®, ChFC®, ChSNC®, CLU®, RICP®, WMCP® (CRD# 5667037) in addition to the information contained in the LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”, CRD# 337998) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Altura Wealth Advisors Disclosure Brochure or this Brochure Supplement, please contact us at (757) 834-7661or by email at info@alturawealth.com. Additional information about Mr. Crook is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5667037. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 20 Item 2 – Educational Background and Business Experience Roger E. Crook Jr., CFP®, ChFC®, ChSNC®, CLU®, RICP®, WMCP®, born in 1988, is dedicated to advising Clients of Altura Wealth Advisors as its Co-Founder and Chief Compliance Officer. Mr. Crook earned his B.S. Finance (Financial Planning) and B.S. Business Management from Virginia Polytechnic Institute and State University in 2010. Additional information regarding Mr. Crook’s employment history is included below. Employment History: 10/2025 to Present Co-Founder, Chief Compliance Officer, LCW Services, LLC d/b/a Altura Wealth Advisors Registered Representative, Purshe Kaplan Sterling Investments, Inc. Wealth Management Advisor, Northwestern Mutual Investment Services, LLC 10/2025 to 2/2026 02/2011 to 10/2025 CERTIFIED FINANCIAL PLANNER® Professional I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 21 professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Chartered Financial Consultant™ (“ChFC®”) The Chartered Financial Consultant™ (ChFC®) program prepares you to meet the advanced financial planning needs of individuals, professionals, and small business owners. You'll gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments, and estate planning. The ChFC® requires three years of full-time, relevant business experience, nine two-hour course-specific proctored exams, and 30 hours of continuing education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of Ethics. Program Objectives: • Function as an ethical, competent and articulate practitioner in the field of financial planning • Utilize the intellectual tools and framework needed to maintain relevant and current financial planning knowledge and strategies. • Apply financial planning theory and techniques through the development of case studies and solutions. • Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate planning, retirement planning, or non-qualified deferred compensation. Chartered Special Needs Consultant™ (“ChSNC®”) The ChSNC® program teaches experienced financial professionals the technical and collaborative skills necessary to help clients make plans for the future security of a loved one who has special needs. To receive the ChSNC® designation, students must successfully complete all courses in the program, meet experience requirements, and hold a CLU®, ChFC®, CFP® certification, or MSFS degree. They must also adhere to The American College of Financial Services Code of Ethics and comply with The College’s Professional Recertification Program. If a student does not have a generalist designation (CLU®, ChFC®, or CFP®) and wants to become a ChSNC®, they must take and pass a challenge exam in order to meet this requirement. This designation requires 15 hours of continuing education every two years through The American College’s PACE recertification program. The Chartered Life Underwriter™ (“CLU®”) The Chartered Life Underwriter™ (CLU®) is a designation of insurance expertise, helping gain a significant advantage in a competitive market. This course of study helps by providing in-depth knowledge of the insurance needs of individuals, business owners, and professional clients. Program Learning Objectives: • Provide guidance to clients on types and amounts of life insurance needed • Make recommendations on aspects of risk management, including personal and business uses of a variety of insurance solutions • Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries • Assist clients in making decisions about estate planning, including the proper holding of assets and title to assets, as well as the implications of various wills and trust arrangements on financial, retirement and succession planning issues • Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients Retirement Income Certified Professional™ (“RICP®”) The RICP® designation teaches advisers techniques and best practices used to create sustainable streams of retirement income. The education covers retirement income planning, maximizing Social Security and other income sources, minimizing risks to the plan, and managing portfolios during the asset distribution phase. The designation LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 22 includes three required, college-level courses that represent a total average study time of more than 150 hours. RICP® designees must meet experience, continuing education and, ethics requirements. The credential is awarded by The American College, a non-profit educator with an 85-year heritage and the highest form of academic accreditation. Wealth Management Certified Professional™ (“WMCP®”) The Wealth Management Certified Professional® (WMCP®) program seeks to implement contemporary investment management, portfolio management, and financial planning strategies to bring a new level of value to the relationship between financial advisors and clients. Individuals learn the fundamentals of goal-based wealth management, which begins with client’s goals—whether they're saving for college tuition, planning for retirement, or passing wealth on to others through estate planning. Through a focus on tax-efficient portfolio management strategies that integrate the newest research on client behavior and financial planning, the WMCP® will develop expertise as an analyst in goal identification, risk management, and investment management plans tailored to the needs of investors. The ChFC® requires one year of full-time, relevant business experience, a four-hour course specific proctored exam, and 30 hours of continuing education every two years. Holders of the WMCP® designation must adhere to The American College’s Code of Ethics. Program Objectives: 1. Employ a goal-based financial services process for financial planning and investment management 2. Create an efficient investment portfolio and show exceptional portfolio management skills 3. Evaluate financial instruments as an analyst 4. Assemble a wealth management strategy using portfolio management, investment management, estate planning, and more 5. Provide solutions for complex wealth management needs Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Crook. Mr. Crook has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Crook. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Crook. However, we do encourage you to independently view the background of Mr. Crook on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5667037. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Crook is also a licensed insurance professional with Altura Wealth Advisors. As an insurance professional, Mr. Crook will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Crook is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Crook or the Advisor. Mr. Crook spends approximately 10% of his time per month in this capacity. Item 5 – Additional Compensation Mr. Crook has additional business activities where compensation is received that are detailed in Item 4 above. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 23 Item 6 – Supervision Mr. Crook serves as the Co-Founder, Chief Compliance Officer of Altura Wealth Advisors. Mr. Crook can be reached at (757) 834-7661. Altura Wealth Advisors has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Altura Wealth Advisors. Further, Altura Wealth Advisors is subject to regulatory oversight by various agencies. These agencies require registration by Altura Wealth Advisors and its Supervised Persons. As a registered entity, Altura Wealth Advisors is subject to examinations by regulators, which may be announced or unannounced. Altura Wealth Advisors is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 24 Form ADV Part 2B – Brochure Supplement for Rachel T. Wren, CLF®, RICP®, WMCP® Director of Operations Effective: April 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Rachel T. Wren, CLF®, RICP®, WMCP® (CRD# 2819174) in addition to the information contained in the LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”, CRD# 337998) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Altura Wealth Advisors Disclosure Brochure or this Brochure Supplement, please contact us at (757) 834-7661or by email at info@alturawealth.com. Additional information about Mrs. Wren is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2819174. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 25 Item 2 – Educational Background and Business Experience Rachel T. Wren, CLF®, RICP®, WMCP®, born in 1973, is dedicated to advising Clients of Altura Wealth Advisors as its Director of Operations. Mrs. Wren attended Christopher Newport College in 1995. Additional information regarding Mrs. Wren’s employment history is included below. Employment History: Director of Operations, LCW Services, LLC d/b/a Altura Wealth Advisors Director of Operations, Northwestern Mutual Investment Services, LLC 10/2025 to Present 02/2018 to 10/2025 Chartered Leadership Fellow™ (“CLF®”) The Chartered Leadership Fellow™ (CLF®) program provides financial services managers with the knowledge and tools they need to achieve critical organizational goals, such as recruitment and retention, setting performance standards, and developing business plans. The curriculum features a compelling mix of relevant business courses to prepare eligible candidates for today's leadership challenges and to help suitable candidates create a culture of success in their organization. To receive the CLF® designation, eligible candidates must complete all courses in their selected program, meet experience requirements and ethics standards, and agree to comply with The American College Code of Ethics and Procedures. Retirement Income Certified Professional™ (“RICP®”) The RICP® designation teaches advisers techniques and best practices used to create sustainable streams of retirement income. The education covers retirement income planning, maximizing Social Security and other income sources, minimizing risks to the plan, and managing portfolios during the asset distribution phase. The designation includes three required, college-level courses that represent a total average study time of more than 150 hours. RICP® designees must meet experience, continuing education and, ethics requirements. The credential is awarded by The American College, a non-profit educator with an 85-year heritage and the highest form of academic accreditation. Wealth Management Certified Professional™ (“WMCP®”) The Wealth Management Certified Professional® (WMCP®) program seeks to implement contemporary investment management, portfolio management, and financial planning strategies to bring a new level of value to the relationship between financial advisors and clients. Individuals learn the fundamentals of goal-based wealth management, which begins with client’s goals—whether they're saving for college tuition, planning for retirement, or passing wealth on to others through estate planning. Through a focus on tax-efficient portfolio management strategies that integrate the newest research on client behavior and financial planning, the WMCP® will develop expertise as an analyst in goal identification, risk management, and investment management plans tailored to the needs of investors. The ChFC® requires one year of full-time, relevant business experience, a four-hour course specific proctored exam, and 30 hours of continuing education every two years. Holders of the WMCP® designation must adhere to The American College’s Code of Ethics. Program Objectives: 1. Employ a goal-based financial services process for financial planning and investment management 2. Create an efficient investment portfolio and show exceptional portfolio management skills 3. Evaluate financial instruments as an analyst 4. Assemble a wealth management strategy using portfolio management, investment management, estate planning, and more 5. Provide solutions for complex wealth management needs LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 26 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mrs. Wren. Mrs. Wren has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mrs. Wren. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mrs. Wren. However, we do encourage you to independently view the background of Mrs. Wren on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2819174. Item 4 – Other Business Activities Insurance Agency Affiliations Mrs. Wren is also a licensed insurance professional with Altura Wealth Advisors. As an insurance professional, Mrs. Wren will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mrs. Wren is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mrs. Wren or the Advisor. Mrs. Wren spends approximately 10% of her time per month in this capacity. Item 5 – Additional Compensation Mrs. Wren has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mrs. Wren serves as the Director of Operations of Altura Wealth Advisors and is supervised by Roger Crook, the Chief Compliance Officer. Mr. Crook can be reached at (757) 834-7661. Altura Wealth Advisors has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Altura Wealth Advisors. Further, Altura Wealth Advisors is subject to regulatory oversight by various agencies. These agencies require registration by Altura Wealth Advisors and its Supervised Persons. As a registered entity, Altura Wealth Advisors is subject to examinations by regulators, which may be announced or unannounced. Altura Wealth Advisors is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 27 Form ADV Part 2B – Brochure Supplement for Brian Tran Associate Wealth Management Advisor Effective: April 10, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Brian Tran (CRD# 7367878) in addition to the information contained in the LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” or the “Advisor”, CRD# 337998) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Altura Wealth Advisors Disclosure Brochure or this Brochure Supplement, please contact us at (757) 834-7661or by email at info@alturawealth.com. Additional information about Mr. Tran is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7367878. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 28 Item 2 – Educational Background and Business Experience Brian Tran, born in 1999, is dedicated to advising Clients of Altura Wealth Advisors as an Associate Wealth Management Advisor. Mr. Tran earned his B.S. in Sport Management from Towson University in 2020. Additional information regarding Mr. Tran’s employment history is included below. Employment History: 10/2025 to Present 04/2023 to 10/2025 Associate Wealth Management Advisor, LCW Services, LLC d/b/a Altura Wealth Advisors Associate Wealth Management Advisor, Northwestern Mutual Investment Services, LLC Financial Representative, Northwestern Mutual Investment Services, LLC Front Desk Associate, Gold's Gym Club Operations Intern, LA Fitness 05/2021 to 01/2023 01/2021 to 02/2021 08/2020 to 12/2020 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Tran. Mr. Tran has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Tran. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Tran. However, we do encourage you to independently view the background of Mr. Tran on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7367878. Item 4 – Other Business Activities Mr. Tran is dedicated to the investment advisory activities of Altura Wealth Advisors’s Clients. Mr. Tran does not have any other business activities. Item 5 – Additional Compensation Mr. Tran is dedicated to the investment advisory activities of Altura Wealth Advisors’s Clients. Mr. Tran does not receive any additional forms of compensation. Item 6 – Supervision Mr. Tran serves as an Associate Wealth Management Advisor of Altura Wealth Advisors and is supervised by Roger Crook, the Chief Compliance Officer. Mr. Crook can be reached at (757) 834-7661. Altura Wealth Advisors has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Altura Wealth Advisors. Further, Altura Wealth Advisors is subject to regulatory oversight by various agencies. These agencies require registration by Altura Wealth Advisors and its Supervised Persons. As a registered entity, Altura Wealth Advisors is subject to examinations by regulators, which may be announced or unannounced. Altura Wealth Advisors is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 29 Privacy Policy Effective: April 10, 2026 Our Commitment to You LCW Services, LLC d/b/a Altura Wealth Advisors (“Altura Wealth Advisors” 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. Altura Wealth Advisors (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. Altura Wealth Advisors 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. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 30 No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No to: processing No Not Shared Yes Yes Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Altura Wealth Advisors 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 Altura Wealth Advisors 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 Altura Wealth Advisors 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. 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 (757) 834-7661or via email at info@alturawealth.com. LCW Services, LLC d/b/a Altura Wealth Advisors 4669 South Blvd, Ste 105, Virginia Beach, VA 23452 Phone: (757) 834-7606 | Fax: (757) 834-7606 Website: www.alturawealth.com Page 31