Overview

Headquarters
Leander, TX
Total Firm Assets
$146 million
Average High-Net-Worth Client Portfolio Size
$1.3 million

Fee Structure

Primary Fee Schedule (ADV PART 2A - ANKERSTAR WEALTH, LLC)

MinMaxMarginal Fee Rate
$0 $500,000 0.95%
$500,001 $1,000,000 0.90%
$1,000,001 $2,000,000 0.85%
$2,000,001 $3,000,000 0.80%
$3,000,001 $5,000,000 0.70%
$5,000,001 $7,500,000 0.60%
$7,500,001 $10,000,000 0.50%
$10,000,001 and above 0.40%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $9,250 0.92%
$5 million $39,750 0.80%
$10 million $67,250 0.67%
$50 million $227,250 0.45%
$100 million $427,250 0.43%

Clients

High-Net-Worth Share of Firm Assets
66.87%
Number of High-Net-Worth Clients
77
Total Client Accounts
881
Discretionary Accounts
844
Non-Discretionary Accounts
37

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
170819

Additional Brochure: ADV PART 2A - ANKERSTAR WEALTH, LLC (2026-08-31)

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Ankerstar Wealth, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Ankerstar Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at (512) 614-0085 or by email at: vipservices@ankerstarwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. information about Ankerstar Wealth, LLC is also available on the SEC’s website at Additional www.adviserinfo.sec.gov. Ankerstar Wealth, LLC’s CRD number is: 170819. 3835 CR 175, Unit #840 Leander, TX, 78641 (512) 614-0085 www.ankerstarwealth.com vipservices@ankerstarwealth.com Registration does not imply a certain level of skill or training. Version Date: 08/31/2026 i Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Ankerstar Wealth, LLC on 01/22/2026, are described below. Material changes relate to Ankerstar Wealth, LLC’s policies, practices or conflicts of interests. • Ankerstar Wealth LLC has updated its Assets Under Management. (Item 4 E) • Ankerstar Wealth LLC has updated its Financial Planning fees and services provided for each planning package. (Item 5) • Ankerstar Wealth LLC has updated other financial industry activities and affiliations. (Item 10) • Ankerstar Wealth LLC has disclosed sub-advisory arrangements. (Items 4, 5, 8, 10, 12 and 14) ii Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ...................................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................................ 9 Item 6: Performance-Based Fees and Side-By-Side Management .................................................................. 13 Item 7: Types of Clients ........................................................................................................................................ 13 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .................................... 14 Item 9: Disciplinary Information ......................................................................................................................... 20 Item 10: Other Financial Industry Activities and Affiliations ......................................................................... 20 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 22 Item 12: Brokerage Practices ................................................................................................................................ 23 Item 13: Reviews of Accounts .............................................................................................................................. 25 Item 14: Client Referrals and Other Compensation ......................................................................................... 26 Item 15: Custody .................................................................................................................................................... 27 Item 16: Investment Discretion ............................................................................................................................ 28 Item 17: Voting Client Securities (Proxy Voting) .............................................................................................. 28 Item 18: Financial Information ............................................................................................................................ 28 iii Item 4: Advisory Business Business Description We provide services to individuals and high-net-worth individuals concerning mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities and venture capital funds. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not hold customer funds or securities. A. Description of the Advisory Firm Ankerstar Wealth, LLC (hereinafter “AW”) formerly Afterburner Financial, LLC, is a Limited Liability Company organized in the State of Texas. The firm was formed in February 2014, and the principal owner is Steven Ankerstar. B. Types of Advisory Services Portfolio Management Services AW offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AW creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, desired retirement age, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation.. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring AW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AW will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. AW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AW’s economic, investment or other financial interests. To meet its fiduciary obligations, AW attempts to avoid, among other things, investment or trading practices that systematically advantage or 4 disadvantage certain client portfolios, and accordingly, AW’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is AW’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Participant Account Management (Discretionary) We use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Investment planning involves working with clients to make sure their investments match their respective risk tolerance and goals. Tax concerns are addressed by working with the client to determine and compare effective tax rates for income, capital gains and other earnings or investments, then attempting to allocate the client’s resources accordingly. Life insurance planning entails reviewing the life insurance and/or disability insurance needs of the client, together with any applicable dependents, spouse or other relatives, and assessing appropriate coverage for these individuals. College planning entails helping clients save for higher education, whether for the client or his/her children or other dependents, in the ideal manner to suit the client’s overall financial goals and means. Financial planning to address retirement entails making sure clients are financially equipped for retirement in light of the client’s anticipated income and expenses, investments, and other assets. Debt/credit planning consists of breaking down client budgets and aiding clients in decision-making as to current debt, anticipated significant expenses and potential debt, and avoiding excessive debt. 5 Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Proprietary Investment Models The Firm develops and manages proprietary investment models that may be made available through third-party investment platforms. Unaffiliated investment advisers may offer these models to their clients through such platforms as part of the advisory services they provide. The Firm is responsible for the ongoing management of the investment models, including changes to the model allocations and underlying securities, while the participating investment adviser remains responsible for determining whether the models are appropriate for its clients and for providing ongoing advisory services to those clients. Sub-Advisory Arrangement AW has entered into an arrangement with 55I, LLC ("55ip"), an SEC-registered investment adviser, under which 55ip provides discretionary sub-advisory services, including trade execution, portfolio rebalancing, and tax-management overlay services, for certain client accounts (the "Program"). Under this arrangement, 55ip has discretionary authority to trade and rebalance Program accounts in accordance with the selected model(s), subject to AW's right to override, restrict, or otherwise direct trading activity in individual client accounts. Clients invested in the Program are not charged an additional advisory or sub-advisory fee by 55ip beyond the Firm's standard advisory fee described in Item 5. AW has conducted and documented a due diligence review comparing the models and exchange- traded funds ("ETFs") required under the Program to the strategies and products AW 6 utilized prior to entering into the arrangement, and to other reasonably available alternatives, evaluating factors including expense ratios, tax efficiency, and anticipated net benefit to clients. Based on this review, AW has determined that use of the Program is consistent with, and in AW's assessment beneficial to, the best interests of clients for whom it is deemed suitable. AW will periodically re-evaluate this determination and the appropriateness of the Program for individual clients on an ongoing basis. AW receives an economic benefit in connection with this arrangement that creates a conflict of interest. See Item 14 below for a description of this benefit and how AW addresses the related conflict. Clients are under no obligation to participate in the Program and should discuss with their investment adviser representative whether the Program, and the models/ETFs required under it, are appropriate for their individual circumstances. Services Limited to Specific Types of Investments AW does not limit its investment advice to specific types of investments. The Adviser may recommend a variety of securities, including equities, fixed income securities, ETFs, mutual funds, and other investments as appropriate. C. Client Tailored Services and Client Imposed Restrictions AW will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by AW on behalf of the client. AW may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Model portfolios were solely designed by AW utilizing the expertise of the Investment Adviser Representatives. Each model portfolio is designed around a risk score and risk range. The process begins with a Risk Questionnaire for the client from Nitrogen® and continues with a conversation with the client after a thorough review of their financial situation and risk tolerance utilizing the risk methodology and scoring system provided by Nitrogen®. The agreed upon risk score and risk range are signed and attached as an Exhibit to the Investment Advisory Contract. AW then manages each account as well as the overall portfolio to remain within the contracted risk range. Any situation that would necessitate a change would be formalized by a contract amendment where the client can then change any specific account risk score/range and/or the overall portfolio risk score/range. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. 7 D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. AW does not participate in any wrap fee programs. E. Assets Under Management As of July 22, 2026, AW manages approximately $146M in regulatory assets under management (“RAUM”). RAUM represents client assets for which AW provides continuous and regular supervisory or management services in accordance with the definition of regulatory assets under management adopted by the U.S. Securities and Exchange Commission. In addition to RAUM, AW provides investment advice and recommendations regarding certain other client assets that are not included in RAUM (“Assets Under Advisement” or “AUA”). These assets may include, among other things, certain retirement plan accounts, such as 401(k) accounts, and private investments, for which AW provides investment advice but does not have discretionary authority, custody, or continuous and regular supervisory authority. AW reports AUA separately from RAUM because the methodology used to calculate AUA differs from the methodology required for calculating RAUM. AUA values may be based on information obtained from clients, account statements, custodians, plan providers, private investment sponsors, or other third-party sources. The value of AUA used for reporting purposes may not reflect the current market value of such assets and may be calculated differently from RAUM. AW may charge advisory fees based on certain AUA. The methodology used to calculate fees on AUA will be calculated for the quarter using an end of month average based on the valuations provided by the clients, account statements, custodians, plan providers, private investment sponsors, or other third-party sources. Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $137,259,668 $8,805,305 July 2026 8 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees For portfolio advisory and management services, the Firm does not charge implementation, set-up, upfront, or termination fees. Instead, clients pay a single ongoing advisory fee for the monitoring, management, and administration of their investment portfolios. The annual advisory fee is generally calculated as a percentage of assets and is billed according to the tiered fee schedule below. Under this schedule, each successive asset tier is charged at a lower annual rate than the preceding tier. The rates are additive; for example, the first $500,000 of assets is billed at an annual rate of 0.95%, the next $500,000 is billed at an annual rate of 0.90%, and so on as asset levels increase. Depending on the services provided and the terms of the applicable advisory agreement, advisory fees may be calculated based on Regulatory Assets Under Management ("RAUM") and/or Assets Under Advisement ("AUA"). For certain assets, including certain retirement plan accounts and private investments, the Firm provides investment advice and recommendations but does not have discretionary authority or continuous and regular supervisory authority over such assets. Accordingly, these assets are not included in the Firm's RAUM as reported in Form ADV Part 1A but may be included as AUA for purposes of calculating advisory fees if provided for in the applicable advisory agreement. When advisory fees are calculated based on AUA, the valuation methodology used to determine fees may differ from the methodology required to calculate RAUM under the Investment Advisers Act of 1940. Unless otherwise provided in the applicable advisory agreement, AUA-based fees are calculated quarterly using the average month-end value of the applicable assets during the billing period, based on valuations obtained from clients, custodians, account statements, retirement plan providers, private investment sponsors, or other independent third-party sources. As a result, the assets used to calculate advisory fees may differ from the assets reported as RAUM in Form ADV Part 1A. Compensation Based on Assets Under Advisement The Firm may receive advisory fees based on certain Assets Under Advisement, including assets held in retirement plan accounts or private investments where the Firm does not have discretionary authority. This creates a conflict because the Firm may have an incentive to recommend that clients retain assets in accounts or investments that generate advisory fees. The Firm seeks to mitigate this conflict by providing recommendations that are consistent with clients’ investment objectives, financial circumstances, and best interests. 9 NOTE: 0.95% annually is the maximum fee for all AUM clients. Total Assets Under Management Management Fee First $500K ($1-$500K) 0.95% annually (0.2375% quarterly) Next $500K ($500K - $1M) 0.90% annually (0.225% quarterly) Next $1M ($1M - $2M) 0.85% annually (0.2125% quarterly) Next $1M ($2M - $3M) 0.80% annually (0.200% quarterly) Next $2M ($3M - $5M) 0.70% annually (0.175% quarterly) Next $2.5M ($5M - $7.5M) 0.60% annually (0.150% quarterly) Next $2.5M ($7.5M - $10M) 0.50% annually (0.125% quarterly) Above $10M 0.40% annually (0.100% quarterly) The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Advisory fees are negotiable at the discretion of the Firm. As a result, similarly situated clients may pay different fees. Clients may terminate the agreement without penalty for a full refund of AW's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 1 days' written notice. All Asset-based portfolio management fees are withdrawn directly from a client account that AW has authorization to deduct fees from with client's written authorization or may be invoiced/billed directly to the client. Clients may select the method in which they are billed. All fees are paid quarterly in arrears. The AW advisory fee is based on the valuation provided by the custodian at the end of each quarter with adjustments being made for cash flows throughout the quarter. Any AW managed investments whose custodian is unable to be linked to our billing platform will be calculated for the quarter using an end of month average based on the valuations provided by the client. Additional Fees for Separately Managed Accounts and Third-Party Managers If Client elects (this is not common) to allocate assets to one or more separately managed accounts("SMAs") or other vehicles managed by unaffiliated third-party investment 10 managers ("External Managers" or "Asset Managers"), Client understands and agrees that:(i) Client will be required to execute a separate investment management or sub- advisory agreement directly with each External Manager;(ii) Client will be solely responsible for paying all fees and expenses charged by the External Manager(s) pursuant to the terms of such separate agreement(s), which fees are in addition to, and not included in, the advisory fee charged by Adviser under this Agreement;(iii) Such additional fees may be deducted directly from the Client's Account by the custodian or paid separately by Client, as specified in the External Manager's agreement; and(iv) Adviser receives no compensation from the External Manager(s) in connection with such allocations unless otherwise specifically disclosed to Client in writing. Adviser will provide Client with information regarding the External Manager's fees and terms prior to any allocation, but Client remains responsible for reviewing and agreeing to those terms independently. Financial Planning Fees Fixed Fees Our initial half-hour discovery meeting is complimentary, where we can interview each other. This meeting will conclude with a recommendation and specific price quote which will depend on the client’s unique circumstances and needs. Clients will have the option to choose the service package after consultation with the Adviser. The fixed rate for creating Client financial plans is below. Fixed financial planning fees are paid via check, cash, or wire. These fees are charged in arrears upon completion. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. • Basic Planning Package – $500, for 1-hour meeting & basic plan. • Comprehensive Planning Package – $1,500, for 1-hour meeting & full plan. • Continuous Planning Package - $3,000, for initial 2-hour meeting plus three quarterly 2hour meetings & full plan. Clients may terminate the agreement without penalty for a full refund of AW's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Model Subscription Compensation In addition to the advisory fees described above and as described in Item 4, the Firm makes proprietary investment models available through a third-party investment platform (Autopilot). The Firm receives compensation in connection with the availability of these models. Clients who elect to subscribe to these models through the platform pay subscription fees established by the platform. The Firm receives a percentage of those subscription fees pursuant to its agreement with the platform and/or participating adviser. 11 The receipt of subscription fee revenue creates a conflict of interest because the Firm has a financial incentive for investors to subscribe to its proprietary models. The Firm addresses this conflict by managing the models in accordance with its fiduciary obligations and maintaining policies and procedures reasonably designed to ensure that investment decisions are made in the best interests of clients. Sub-Advisory Program Fees For clients participating in the Program described in Item 4, AW's standard advisory fee, as described elsewhere in this Item 5, applies and is not increased as a result of Program participation. Clients do not pay a separate or additional advisory, sub-advisory, or platform fee to 55I, LLC ("55ip") in connection with the Program; AW's arrangement with 55ip, including the fee waiver described in Item 14, does not result in any additional direct or indirect fee or cost being charged to clients. Clients should be aware that the underlying investment models and/or exchange-traded funds ("ETFs") utilized within the Program carry their own internal expense ratios, as is the case with any pooled investment vehicle, which are borne by the client as an investor in those funds and are separate from, and in addition to, AW's advisory fee. These internal fund-level expenses are not compensation to AW or to 55ip and are disclosed in each fund's prospectus or offering documents. AW's due diligence process, described in Item 4, includes a comparison of expense ratios associated with the Program's required models/ETFs relative to the strategies and products previously utilized by AW. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Financial Planning Fees Fixed financial planning fees are paid via check, cash, or wire. These fees are charged in arrears after the first meeting or upon completion depending on the scope of services performed. 12 C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by AW. These fees can include service providers managing separately managed accounts or subscription fees paid to service providers. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees AW collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither AW nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management AW does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients AW generally provides advisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Corporations or Business Entities There is no account minimum for any of AW’s services. 13 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis AW’s methods of analysis include fundamental analysis, technical analysis, cyclical analysis and the use of model portfolios. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Model portfolios are designed to capture return and risk at market rates. This seeks to provide clients with diversification benefits help to smooth returns, reduce volatility and decrease asset-class and single-strategy risks. Investment Strategies AW uses long term trading, short term trading, short sales, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always 14 follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Investment Strategies AW's use of short sales, margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Model portfolios are designed to capture return and risk at market rates. This seeks to provide clients with diversification benefits help to smooth returns, reduce volatility and decrease asset-class and single-strategy risks. Risks specific to using model portfolios include the possibility that the model portfolio will underperform the market and the possibility that the model will not be able take advantage of opportunities that a nonmodel portfolio management approach might capture. Model portfolios entail inflation 15 (purchasing power) risk, interest rate risk, economic risk, market risk, political/regulatory risk, and asset allocation risk – meaning that any given asset allocation strategy does not guarantee any specific result or profit nor protect against a loss. Program Investment Strategy and Limitations For client accounts participating in the Program described in Item 4 (55ip), assigned investment models are limited to a subset of investment products, rather than the Firm's full universe of otherwise available products. Models on 55ip used by the Firm only include investments that fall into the following subset: publicly traded ETFs, equities, and mutual funds. Client accounts may still utilize investments that fall outside of that subset at the discretion of their Advisor, but those investments will typically not be traded by 55ip, nor considered in their tax-efficient outcome software. Additionally, certain client accounts may be invested in the JPMorgan Investment Management Strategic model set on 55ip. This model set is invested in exclusively JPMorgan-issued ETFs and Mutual Funds. Because the JPMorgan model set draws exclusively from a single fund family, client accounts using that model set have less diversification across investment managers and fund sponsors than an account allocated across multiple fund families and are correspondingly more exposed to risks specific to JPMorgan as a manager and product sponsor (including manager, operational, and product-level risk). These limitations are a factor clients should consider, together with the conflict-of-interest disclosure in Item 14, in evaluating whether Program participation is appropriate for their circumstances. Within these parameters, for taxable accounts on the platform, 55ip utilizes a tax- management overlay methodology intended to pursue tax-efficient outcomes for client accounts, including techniques such as tax-loss harvesting, coordination of wash-sale rules, and tax-aware transition management when accounts are initially funded or rebalanced. 55ip's methodology relies on proprietary, rules-based technology to implement and maintain target portfolios, which may deviate in its analytical approach from methods used elsewhere in the Firm's business. In addition to the general risks described elsewhere in this Item 8, clients participating in the Program should understand the following: Sub-adviser discretion: 55ip exercises discretionary trading authority over Program accounts, subject to the Firm's override rights described in Item 4. There is a risk that trading or rebalancing activity may occur that the Firm would not have independently initiated, and a risk that the Firm's override, when exercised, may not fully mitigate the effect of a given trade. Tax-management strategy risk: Tax-loss harvesting and related tax-management techniques involve trading decisions made primarily to pursue tax efficiency, which may, in some circumstances, result in transaction costs, tracking error relative to a stated benchmark, or outcomes that differ from a purely investment-merit-based trading approach. The tax benefits of these techniques are not guaranteed and depend on each client's individual tax circumstances; clients should consult their own tax advisor 16 regarding the application of these strategies to their personal situation. Tax-loss harvesting and related techniques generally provide no benefit to accounts held in tax- deferred or tax-exempt vehicles (such as IRAs, Roth IRAs, or other qualified retirement accounts). Wash-sale coordination limitations: 55ip's wash-sale coordination applies only to accounts participating in the Program of which the Firm and 55ip are aware. The Firm and 55ip cannot monitor or coordinate wash-sale activity with respect to securities held in accounts outside the Program, including accounts held away from the Firm, accounts held by a client's spouse, or employer-sponsored retirement accounts. Trading within the Program could inadvertently trigger a wash sale as a result of holdings or transactions in those other accounts. Reliance on third-party technology and processes: The Program's execution and tax- management functions depend on 55ip's proprietary technology and operational processes, which are outside the Firm's direct control, though subject to the Firm's ongoing due diligence and monitoring described in Item 4. Model and technology risk: 55ip's rules-based models and technology may contain errors, may not perform as intended, and may not adapt effectively to unusual, volatile, or fast-moving market conditions. Reliance on automated, rules-based processes involves the risk that trading decisions may not reflect the judgment the Firm would apply if managing the account directly. Model and provider change risk: JPMorgan or another model provider may modify, restrict the availability of, or discontinue a given model, and 55ip may substitute or modify the models available on its platform. Any such change could alter a client account's risk and return characteristics, potentially without an affirmative decision by the client or the Firm at the time the change occurs. Transition and onboarding risk: When an account is initially funded into, or transitioned between, models on the platform, the process of aligning the account to its target model may generate realized capital gains and cause the account to deviate from its target model allocation for a period of time until the transition is complete. Dependence on data accuracy: 55ip's tax-management techniques rely on the accuracy and completeness of cost-basis and other account information provided to it by the account custodian and/or the client. Errors, delays, or gaps in this data could affect the accuracy of tax-management outcomes, including tax-loss harvesting and wash-sale coordination. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 17 C. Risks of Specific Securities Utilized AW's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Cryptocurrency ETPs are exposed to cryptocurrency, which are decentralized digitized assets that often rely on blockchain technology. Cryptocurrency ETPs are highly 18 speculative and extremely volatile. Cryptocurrency is part of a new and evolving industry, and neither the technology nor regulatory regime for cryptocurrency is settled. Cryptocurrency ETPs may trade in over-the-counter markets and may not be afforded all of the investor protections of other exchange-traded products. Complex exchange-traded products, such as cryptocurrency ETFs are often designed to not be held long term. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, 19 sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither AW nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 20 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AW nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Steven Eric Ankerstar serves as a member of the Advisory Board of AdvizorStack, a provider of technology platforms and operational support services to independent registered investment advisers. In this role, Mr. Ankerstar provides strategic guidance and industry input to AdvizorStack. This relationship may present a conflict of interest because AdvizorStack offers services and technology solutions that AW could potentially use in its operations or recommend to clients. AW’s selection and use of any third-party technology platform or service provider, including AdvizorStack, is based solely on an objective evaluation of factors such as functionality, pricing, reliability, security, integration with existing systems, and overall benefit to clients. AW does not receive any compensation, referral fees, or other economic benefit from AdvizorStack in connection with client assets or referrals. No client is obligated to use AdvizorStack or any particular technology platform or service provider. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections For client accounts participating in one or more of AW's sub-advisory programs, AW selects and utilizes the following unaffiliated, SEC-registered investment advisers as discretionary sub-advisers: 55I, LLC ("55ip"), Charles Schwab Investment Management's Direct Indexing SPI program ("Schwab Direct Indexing"), and Legacy Investment Solutions, LLC, doing business as Ancorato ("Ancorato"). AW may utilize one or more investment strategies offered by Ancorato for client accounts, depending on individual client circumstances. For all other client accounts, assets continue to be managed directly by AW. AW receives an economic benefit in connection with its selection and use of 55ip as described in Item 14 below. AW receives no compensation from Schwab Direct Indexing or Ancorato in connection with its selection and use of those sub-advisers or any of their strategies. 21 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics AW has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AW's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests AW does not recommend that clients buy or sell any security in which a related person to AW or AW has a material financial interest. If a security falls under this category , the CCO will publish this security on a “no trade” list using the CCO read file which will be acknowledged by all AW personnel. C. Investing Personal Money in the Same Securities as Clients Representatives of AW, from time to time, purchase or hold securities or other investments that are also recommended to advisory clients. This creates a potential conflict of interest because a related person may have a personal financial interest in securities or investment themes that are also considered for client portfolios. The Firm employs a thematic investment approach in evaluating investment opportunities and constructing portfolios. The Firm's investment professionals may personally invest in securities that are consistent with these investment themes and research views. Examples of the Firm's high-conviction investment themes include: •Drones and Modern Warfare • Space Technology • Artificial Intelligence Infrastructure • Quantum Computing • Humanoid Robotics • Cybersecurity • Digital Assets, including Bitcoin These themes represent areas that the Firm believes may provide attractive long-term investment opportunities and may influence investment research, portfolio construction, 22 and recommendations. However, the Firm does not recommend investments solely based on a theme, and client recommendations are based on each client's individual investment objectives, financial circumstances, risk tolerance, and investment profile. The Firm manages potential conflicts arising from personal trading through its Code of Ethics and Personal Securities Trading Policy, which are designed to ensure that client interests are placed ahead of personal interests and that supervised persons comply with applicable reporting, review, and monitoring requirements. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of AW may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of AW to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, AW will never engage in trading that operates to the client’s disadvantage if representatives of AW buy or sell securities at or around the same time as clients. To avoid said conflicts of interest, AW defines a “Blackout Period” for IARs regarding their trading. The “Blackout Period” will begin once an IAR transacts in a security on a given trading day, defined as a full one-day cycle of pre-market trading through after- market extended hours. Upon a transaction triggering a “Blackout Period,” the IAR will not transact in the specific security for clients until the “Blackout Period” expires. In effect, to respect this “Blackout Period: on a security-by-security basis, AW IARs will always complete their personal transactions after client transactions during a trading day. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on AW’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and AW may also consider the broker dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in AW's research efforts. AW will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker dealer/custodian. 23 AW will require clients to use Charles Schwab & Co., Inc. Member FINRA/SIPC (“Schwab”). Schwab is an independent and unaffiliated SEC-registered broker-dealer. 55ip Program Trade Execution For client accounts participating in AW's tax-managed model/ETF program offered in connection with 55I, LLC ("55ip") (the "Program"), trade execution, rebalancing, and tax- management overlay trading is performed by 55ip acting as discretionary sub-adviser. 55ip executes trades for Program accounts through Client's existing account custodian; AW does not select or recommend a different broker-dealer for Program accounts as a result of Program participation, and Program participation does not change Client's custodial relationship. 55ip's trade execution for Program accounts is therefore subject to the same brokerage and custodial arrangements otherwise described in this Item 12. 1. Research and Other Soft-Dollar Benefits AW does not participate in soft dollar arrangements and does not receive research, products, or services in exchange for directing client brokerage transactions. AW does not receive products or services that are paid for with client brokerage commissions within the meaning of Section 28(e) of the Securities Exchange Act of 1934. AW may receive customary products, services, and support made generally available by custodians, including Schwab Advisor Services, to institutional advisory firms. These services may include technology, educational resources, practice management support, and other administrative services. These products and services are not provided in exchange for client brokerage transactions or commissions and are not considered soft dollar benefits 2. Brokerage for Client Referrals AW receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use AW will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If AW buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to 24 seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, AW would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. AW would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with AW’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts, including accounts which utilize model portfolios for AW's advisory services are provided on an ongoing basis by the assigned financial advisor and are reviewed at least monthly by Steven Ankerstar, CCO with regard to clients’ respective investment policies and risk tolerance levels. All accounts at AW are assigned to this reviewer. For all financial planning-only clients, all financial plans will be created by the assigned financial advisor and are reviewed prior to delivery to the client by Steven Ankerstar, CCO. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews for all client accounts, including accounts which utilize model portfolios may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, AW’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients The custodian or other qualified third party holding the client’s funds and securities will send the client a confirmation of every securities transaction and a custodial statement at least quarterly. AW also provides periodic statements to clients which state account holdings and value of portfolio holdings. This will typically be provided on an annual basis during the contract update period. For financial planning-only clients, each client will receive the written financial plan upon completion. 25 Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides AW with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For AW client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to AW other products and services that benefit AW but may not benefit its clients’ accounts. These benefits may include national, regional or AW specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of AW by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist AW in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of AW’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of AW’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to AW other services intended to help AW manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange 26 and/or pay vendors for these types of services rendered to AW by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to AW. AW is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. AW receives compensation from third-party investment platforms in connection with making its proprietary investment models available through those platforms. This compensation is described in greater detail in Item 5. AW does not receive compensation for client referrals in connection with these arrangements. AW receives an economic benefit from 55I, LLC ("55ip"), an unaffiliated sub-adviser, in the form of a waiver of platform and/or sub-advisory fees that AW would otherwise be required to pay in connection with the sub-advisory arrangement described in Item 4. This fee waiver is conditioned on AW committing to place and maintain an agreed-upon level of client assets in specified investment models and/or exchange-traded funds made available through 55ip's platform. This arrangement creates a conflict of interest: because AW's own cost of using the platform is reduced or eliminated based on client asset placement, AW has a financial incentive apart from its standard advisory fee to recommend the Program and the specific models/ETFs required under it. This incentive could, in the absence of appropriate safeguards, conflict with AW's duty to recommend investments that are in each client's best interest. This benefit does not result in any additional fee or cost to clients beyond AW's standard advisory fee described in Item 5. B. Compensation to Non – Advisory Personnel for Client Referrals AW does not compensate non-advisory personnel (solicitors/promoters) for client referrals. C. Employee Referrals The Firm may pay bonuses or other compensation to supervised persons or employees for referring prospective clients to the Firm. Such compensation is paid solely by the Firm and does not result in any additional fee or cost to the client. Item 15: Custody When it deducts fees directly from client accounts at a selected custodian, AW will be deemed to have limited custody of client’s assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. 27 Item 16: Investment Discretion AW provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, AW generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, AW’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to AW. AW will also have discretionary authority to determine the broker or dealer to be used for a purchase or sale of securities for a client's account. Clients may, but typically do not, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Item 17: Voting Client Securities (Proxy Voting) AW will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. AW has engaged a third‐party service provider, Chicago Clearing Corporation (CCC), to monitor and file securities claims class action litigation paperwork with claims administrators on behalf of the Firm’s clients. When a claim is settled and payments are awarded to Ankerstar Wealth clients, it may be necessary to share client information, such as name and account number, with CCC in connection with this service. AW does not receive any fees or remuneration in connection with this service nor does it receive any fees from the third‐party provider(s). CCC earns a fee based on a flat percentage of all claims it collects on behalf of Ankerstar Wealth, LLC’s clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. Clients may opt out of this service at any time. If a client opts out, AW does not have an obligation to advise or take any action on behalf of a client with regard to class action litigation involving investments held in or formerly held in a clients account. Item 18: Financial Information A. Balance Sheet AW neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. 28 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither AW nor its management has any financial condition that is likely to reasonably impair AW’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years AW has not been the subject of a bankruptcy petition in the last ten years. 29

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