Overview

Headquarters
Auburn, CA
Total Firm Assets
$121 million
Average High-Net-Worth Client Portfolio Size
$1.6 million

Fee Structure

Primary Fee Schedule (ADV PART 2A/2B SEC)

MinMaxMarginal Fee Rate
$0 $500,000 1.45%
$500,001 $1,000,000 1.25%
$1,000,001 $5,000,000 1.00%
$5,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,500 1.35%
$5 million $53,500 1.07%
$10 million $91,000 0.91%
$50 million $391,000 0.78%
$100 million $766,000 0.77%

Clients

High-Net-Worth Share of Firm Assets
56.27%
Number of High-Net-Worth Clients
44
Total Client Accounts
516
Discretionary Accounts
516

Services Offered

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

Regulatory Filings

SEC CRD Number
290853

Primary Brochure: ADV PART 2A/2B SEC (2026-06-22)

View Document Text
F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Arrow Wealth Advisors, Inc. California Office Address: 10831 Combine Rd. Suite A Auburn, CA 95602 Texas Office Address: 400 N Loop 1604 E Suite 280 San Antonio, TX 78232 Tel: 210-541-9967 Fax: 210-541-9967 Dan@ArrowWealthAdvisors.com Website: www.ArrowWealthAdvisors.com J U N E 2 2 , 2 0 2 6 This brochure provides information about the qualifications and business practices of Arrow Wealth Advisors, Inc. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 210-541-9967. 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. Additional information about Arrow Wealth Advisors, Inc. (CRD #290853) is available on the SEC’s website at www.adviserinfo.sec.gov i Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing on February 19, 2026, the following is being updated: • The entire brochure for SEC Registration. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 3 Wrap Fee Programs ......................................................................................................................................................... 3 Client Assets Under Management .............................................................................................................................. 3 Item 5: Fees and Compensation ....................................................................................................... 3 Method of Compensation and Fee Schedule .......................................................................................................... 3 Client Payment of Fees ................................................................................................................................................... 6 Additional Client Fees Charged ................................................................................................................................... 6 Prepayment of Client Fees ............................................................................................................................................ 6 External Compensation for the Sale of Securities to Clients ........................................................................... 6 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6 Sharing of Capital Gains ................................................................................................................................................. 6 Item 7: Types of Clients ....................................................................................................................... 7 Description .......................................................................................................................................................................... 7 Account Minimums .......................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7 Methods of Analysis ......................................................................................................................................................... 7 Investment Strategy ........................................................................................................................................................ 8 Security Specific Material Risks .................................................................................................................................. 8 Item 9: Disciplinary Information ..................................................................................................... 9 Criminal or Civil Actions ................................................................................................................................................ 9 Administrative Enforcement Proceedings .......................................................................................................... 10 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 10 iii Item 10: Other Financial Industry Activities and Affiliations ............................................. 10 Broker-Dealer or Representative Registration ................................................................................................. 10 Futures or Commodity Registration ...................................................................................................................... 10 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 10 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 10 Code of Ethics Description ......................................................................................................................................... 10 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 11 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 11 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 11 Item 12: Brokerage Practices ......................................................................................................... 12 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 12 Aggregating Securities Transactions for Client Accounts ............................................................................. 15 Item 13: Review of Accounts ........................................................................................................... 15 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 15 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 16 Content of Client Provided Reports and Frequency ........................................................................................ 16 Item 14: Client Referrals and Other Compensation ................................................................ 16 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 16 Advisory Firm Payments for Client Referrals .................................................................................................... 16 Item 15: Custody .................................................................................................................................. 16 Account Statements ...................................................................................................................................................... 16 Item 16: Investment Discretion ..................................................................................................... 17 Discretionary Authority for Trading...................................................................................................................... 17 Item 17: Voting Client Securities ................................................................................................... 17 Proxy Votes ...................................................................................................................................................................... 17 Item 18: Financial Information ...................................................................................................... 17 Balance Sheet .................................................................................................................................................................. 17 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 17 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17 iv Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19 Principal Executive Officer – Daniel Seltzer, CFP® ........................................................................................... 19 Item 2 - Educational Background and Business Experience ....................................................................... 19 Item 3 - Disciplinary Information ........................................................................................................................... 20 Item 4 - Other Business Activities Engaged In ................................................................................................... 21 Item 5 - Additional Compensation .......................................................................................................................... 21 Item 6 - Supervision ..................................................................................................................................................... 21 v Item 4: Advisory Business Firm Description Arrow Wealth Advisors, Inc. (“Arrow Wealth”) was founded in 2014 and became a Registered Investment Advisor in 2017. Daniel Seltzer is 100% owner. Arrow Wealth, its representatives or any of its employees will disclose to Clients all material conflicts of interest. Types of Advisory Services FINANCIAL PLANNING AND CONSULTING If financial planning services are applicable, a thorough review of all applicable topics including but not limited to, Wills, Estate Plans and Trusts, Investments, Taxes, Qualified Plans, Insurance, Retirement Income, Social Security, Divorce Planning, and College Planning will be reviewed. If a conflict of interest exists between the interests of Arrow Wealth and the interests of the Client, the Client is under no obligation to act upon Arrow Wealth’s recommendation. If the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction through Arrow Wealth. Financial plans will be completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. ERISA PLAN SERVICES Arrow Wealth provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Arrow Wealth may act as a 3(21) advisor: Limited Scope ERISA 3(21) Fiduciary. Arrow Wealth may serve as a limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment decisions on a non-discretionary basis. As an investment advisor Arrow Wealth has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan, though using Arrow Wealth can help the plan sponsor delegate liability by following a diligent process. 1. Fiduciary Services are: • Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client will make the final decision regarding the initial selection, retention, removal and addition of investment options. Arrow Wealth acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii). • Assist the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS. • Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Client retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5) and 404(a)-5. - 1 - • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. • Meet with Client on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services are: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Client understands Arrow Wealth’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Arrow Wealth does not provide fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Arrow Wealth may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Arrow Wealth and Client. 3. Arrow Wealth has no responsibility to provide services related to the following types of assets (“Excluded Assets”): • Employer securities; • Real estate (except for real estate funds or publicly traded REITs); • Stock brokerage accounts or mutual fund windows; • Participant loans; • Non-publicly traded partnership interests; • Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or • Other hard-to-value or illiquid securities or property. Excluded Assets will not be included in calculation of Fees paid to Arrow Wealth on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. ASSET MANAGEMENT Arrow Wealth offers discretionary asset management services to advisory Clients. Arrow Wealth will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Arrow Wealth discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. - 2 - Arrow Wealth also offers discretionary direct asset management services to advisory Clients depending on the one of the programs below: Betterment Platform For Advisory Clients with accounts that fall below the minimum investment requirements associated with other investment strategies, Arrow Wealth may offer discretionary direct asset management services utilizing The Betterment for Advisors platform for digital services. On this platform, Arrow Wealth has the discretion to delegate the management of all or part of the Assets to one or more independent investment managers or independent investment management programs (“Independent Managers”). To the extent utilized, Independent Managers will have limited power-of-attorney and trading authority over those assets Arrow Wealth directs to them for management. Arrow Wealth will supervise the Independent Managers and monitor and review asset allocation and asset performance. Arrow Wealth may terminate or change Independent Managers when, in Arrow Wealth’s sole discretion, Arrow Wealth believes such termination or changes is in your best interest. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs Arrow Wealth does not sponsor or participate in any wrap fee programs. Client Assets Under Management Arrow Wealth has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $121,234,291 $0 Date Calculated: May 31, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule FINANCIAL PLANNING AND CONSULTING Arrow Wealth charges a fixed or hourly fee for financial planning. The fixed fee charge is based on the complexity and unique Client needs for financial planning services. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of ninety (90) days contingent upon timely delivery of all required documentation. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Arrow Wealth. Arrow Wealth reserves the right to waive the fee should the Client implement the plan through Arrow Wealth. Client will agree to the fee schedule before signing Agreement. Fees for financial plans may be billed 50% in advance with the balance due upon plan delivery or may be due, in full, at the commencement of the contract. FIXED FEES Financial Planning Services are offered based on a flat fee between $1,250 and $8,000. - 3 - HOURLY FEES Financial Planning Services are also offered based on an hourly rate of $225 per hour. ERISA PLAN SERVICES The annual fees are based on the market value of the Included Assets and will not exceed 1%. The annual fee is negotiable and may be charged as a percentage of the Included Assets or as a flat fee. Fees may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or distribution of assets) on the last business day of the previous quarter or month. If the services to be provided start any time other than the first day of a quarter or month, the fee will be prorated based on the number of days remaining in the quarter or month. If this Agreement is terminated prior to the end of the fee period, Arrow Wealth shall be entitled to a prorated fee based on the number of days during the fee period services were provided or Client will be due a prorated refund of fees for days services were not provided in the billing cycle. The fee schedule, which includes compensation of Arrow Wealth for the services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees deducted from Plan Assets. Arrow Wealth does not reasonably expect to receive any additional compensation, directly or indirectly, for its services under this Agreement. If additional compensation is received, Arrow Wealth will disclose this compensation, the services rendered, and the payer of compensation. Arrow Wealth will offset the compensation against the fees agreed upon under this Agreement. ASSET MANAGEMENT Arrow Wealth offers direct asset management services to advisory Clients. Arrow Wealth charges a maximum annual investment advisory fee based on the total assets under management. Total fees to Client will never exceed the safe harbor threshold of 3% of assets under management per year. The table below illustrates the maximum client fee schedule. Annual Fee 1.45% 1.25% Quarterly Fee 0.3625% 03125% 1.00% 0.2500% Assets Under Management For the first amount $500,000 For the next amount from $500,001 - $1,000,000 For the next amount from $1,000,001 - $5,000,000 For the amount above $5,000,000+ 0.75% 0.1875% - 4 - This is a blended fee schedule; the asset management fee is calculated by applying different rates to different portions of the portfolio. Arrow Wealth may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. For example, a Client with $1,000,000 under management would pay $13,500 on an annual basis. First $500,000 x .0145 = $7,250 Next $500,000 x .0125 = $6,250 The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. For accounts opened or closed mid-billing period, unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Betterment Platform When utilizing the Betterment Investment platform, Arrow Wealth’s fee will be prorated and billed quarterly in arrears, based on the Client’s average daily balance for the prior quarter multiplied by the annual percentage rate of no more than 1.50% of Assets charge. Fees are negotiable and will be automatically deducted from your account. Betterment for Advisors will make quarterly adjustments for deposits and withdrawals in Client accounts. As part of this process, you understand and acknowledge the following: • Betterment Securities as the custodian will send statements at least quarterly to Clients showing all disbursements for their account, including the amount of the advisory fees paid to Arrow Wealth; • The Client has provided authorization permitting fees to be directly paid by these terms; • Betterment Institution calculates the advisory fees and deducts them from the Client’s account. The fees are based on a Client’s average balance of their entire account. Client will see the total fee of no more than 1.50% (to include the Betterment for Advisors platform fee of 0.25% in addition to the annual percentage of assets charge by Arrow Wealth) The investment advisory fee will be billed directly to the Custodian, with an informational copy of the invoice sent by the Custodian to the Client. The Custodian will deduct the fee for the Account upon receipt of the invoice, or shortly thereafter. Arrow Wealth will not be - 5 - compensated based on the basis of a share of capital gains or capital appreciation of the assets in the Account. Client Payment of Fees Investment management fees may be billed quarterly in advance, meaning that we bill you before the billing period has begun. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans are billed 50% in advance with the balance due upon plan delivery or may be due upon commencement of the Advisory Agreement. Arrow Wealth, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Arrow Wealth does not require any prepayment of fees of more than $1,200 per Client and six months or more in advance. Fees for financial plans may be billed 50% in advance with the balance due upon plan delivery or may be due, in full, at the commencement of the contract. Investment management fees may be billed quarterly in advance. Fees for ERISA 3(21) services may be billed in advance. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Arrow Wealth. External Compensation for the Sale of Securities to Clients Arrow Wealth does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of Arrow Wealth. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Arrow Wealth does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for Arrow Wealth to recommend an investment that may carry a higher degree of risk to the Client. - 6 - Item 7: Types of Clients Description Arrow Wealth generally provides investment advice to individuals, high net worth individuals, charities, and corporations or business entities. Client relationships vary in scope and length of service. Account Minimums Arrow Wealth does not require a minimum to open an account. However, Betterment may require account minimums to invest in their platform. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Our approach to investing begins with an understanding of financial science and the power of free market economies. Rather than attempting to predict the future or rely on outguessing other market participants, we draw information about expected returns from the market itself; leveraging the collective knowledge of millions of buyers and sellers as they set security prices through their buying and selling decisions. We trust markets to efficiently drive information into security prices. Embracing this investment philosophy frees our team to spend time on areas where we believe we have an advantage. These areas include how we interpret decades of research, the design, construction and management of client portfolios, and adding value, when possible, through tax efficient investing. We take a less subjective, more systematic approach to investing that can be implemented consistently. This is an approach that investors can understand and stick with, even in challenging market environments. Investing in securities involves the risk of loss that our clients should be prepared to bear. We believe this preparation comes from setting realistic expectations about market risk and providing ongoing client education. These are the hallmarks of a successful investing experience. Past performance is not a guarantee of future returns, but an understanding of what has happened in the past can be a helpful tool in preparing investors for what lies ahead. Moreover, embracing an investment approach grounded in economic theory backed by decades of research can bring financial peace of mind in times of uncertainty. When it comes to selecting securities, research has shown that securities offering higher expected returns share certain characteristics. We help our client’s structure broadly diversified portfolios that emphasize these characteristics while addressing the tradeoffs that arise when executing these portfolios. We are convinced that investing should always be a means to an end; namely the pursuit of clearly defined financial goals laid forth in a client’s financial plan. When developing financials plans for clients, Arrow Wealth bases their analysis on the client’s cashflow, risk capacity, risk tolerance, tax obligations, and estate planning considerations. The plan is based on information gathered in client meetings, and a detailed strategy is tailored to each client’s specific situation. The main sources of information for a client’s analysis include the client’s tax returns, risk profile, cashflow statements, annual reports, prospectuses, and filings with the Securities and Exchange Commission. - 7 - Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to Arrow Wealth. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Arrow Wealth will not recommend any particular type of security to clients. Arrow Wealth will review the client's risk tolerance, investment objectives, and investment time horizon in order to determine which investments are in the client's best interest. Arrow Wealth's recommendations may include any public security available on the custodian’s platform. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investing in securities involves risk of loss that clients should be prepared to bear. Investors face the following investment risks and should discuss these risks with Arrow Wealth: • Market Risk: The prices of securities held by mutual funds in which Clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market - 8 - as a whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. The risks associated with utilizing third party money managers include: • Manager Risk o Third party money manager fails to execute the stated investment strategy • Business Risk o Third party money manager has financial or regulatory problems • The specific risks associated with the portfolios of the third party money manager’s which is disclosed in the third party money manager’s Form ADV Part 2. Item 9: Disciplinary Information Criminal or Civil Actions Arrow Wealth and its management have not been involved in any criminal or civil action in a domestic, foreign or military court of competent jurisdiction. - 9 - Administrative Enforcement Proceedings Arrow Wealth and its management have not been involved in administrative enforcement proceedings before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. Self- Regulatory Organization Enforcement Proceedings Arrow Wealth and its management have not been involved in any self-regulatory organizational proceedings that are material to a Client’s or prospective Client’s evaluation of Arrow Wealth or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Neither Arrow Wealth nor its affiliated representatives are registered or have an application pending to register with a broker-dealer. Arrow Wealth is not registered as a broker-dealer. Futures or Commodity Registration Neither Arrow Wealth nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest President Daniel Seltzer is the only management person for Arrow Wealth, and he has no financially affiliated businesses or conflicts of interests to disclose. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest As part of our relationship with Betterment and Betterment Securities, Betterment may offer us services intended to help us manage and further develop our business enterprise, such as access to webinars and advice about using the Betterment for Advisors platform to grow our business. Betterment may offer different or expanded services in the future. These services could create an incentive for us to recommend that our Clients invest through the Betterment for Advisors platform. This is a potential conflict given that our interest in recommending Betterment could be influenced by our receipt of Betterment’s and Betterment Securities’ services to our business. Other potential conflicts may exist regarding our use of the Betterment for Advisors platform. Arrow Wealth ensures that before selecting other advisors for Client that the other advisors are properly licensed or registered as an investment advisor. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of Arrow Wealth have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Arrow Wealth affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of Arrow Wealth. The Code reflects Arrow Wealth and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not - 10 - allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Arrow Wealth’s policy prohibits any person from acting upon or otherwise misusing non- public or inside information. No advisory representative or other affiliated person, officer or director of Arrow Wealth may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Arrow Wealth’s Code is based on the guiding principle that the interests of the Client are our top priority. Arrow Wealth’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. Arrow Wealth will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest Arrow Wealth and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Because Arrow Wealth does not recommend Client securities in which we have a material interest, there is no conflict of interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Arrow Wealth and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide Arrow Wealth with copies of their brokerage statements. The Chief Compliance Officer of Arrow Wealth is Daniel Seltzer. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Arrow Wealth does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Arrow Wealth with copies of their brokerage statements. - 11 - The Chief Compliance Officer of Arrow Wealth is Daniel Seltzer. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions Arrow Wealth will recommend the use of a particular custodian to custody Client assets. Arrow Wealth receives a benefit because it does not have to pay for the research, services, or product and it may have an incentive to recommend a custodian based on its interest rather than the Clients. Arrow Wealth will select appropriate custodians based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. Arrow Wealth relies on its custodian to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by Arrow Wealth. Arrow Wealth will recommend the use of Charles Schwab, Pershing, or Betterment Securities. • Directed Brokerage Arrow Wealth does not allow Clients to use directed brokerage. With respect to the Betterment Platform, Arrow Wealth does not maintain custody of your assets, although we may be deemed to have custody of your assets if you give us authority to withdraw advisory fees from your account. Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We may recommend that our Clients use MTG, LLC dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of the SIPC, as the qualified custodian. Arrow Wealth is not affiliated with Betterment Securities. Betterment Securities will hold your assets in a brokerage account and buy and sell securities when Arrow Wealth and/or you instruct them to. While Arrow Wealth recommends that you use Betterment Securities as custodian/broker, you will decide whether to do so and will open your account with Betterment Securities by entering into an account agreement directly with them. Arrow Wealth does not open the account for you, although we may assist you in doing so. If you do not wish to place your assets with Betterment Securities, then Arrow Wealth cannot manage your account on Betterment for Advisors. • Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a custodian involves a number of considerations and is subjective. Factors affecting custodian selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the ability to effect the transaction where a large block is involved, the operational facilities of the custodian, the value of an ongoing relationship with such custodian and the financial strength and stability of the custodian. Arrow Wealth does not receive any portion of the trading fees. - 12 - For Arrow Wealth’s Client accounts that Betterment Securities maintains, Betterment Securities does not charge you separately for custody/brokerage services but is compensated as part of the Betterment for Advisors platform fee, which is charged for a suite of platform services, including custody, brokerage, and sub-advisory services provided by Betterment and access to the Betterment for Advisors platform. The platform fee is an asset-based fee charged as a percentage of assets in your Betterment account. Clients utilizing the Betterment for Advisors platform may pay a higher aggregate fee than if the investment management, brokerage and other platform services are purchased separately. Nonetheless, for those Clients participating in the Betterment for Advisors platform, Arrow Wealth has determined that having Betterment Securities execute trades is consistent with our duty to seek best execution of your trades. • Brokerage for Client Referrals Arrow Wealth has a relationship with an unaffiliated custodian wherein Arrow Wealth receives client referrals. This results in a conflict of interest with the client since Arrow Wealth has an incentive to select or recommend a broker-dealer based on receiving these referrals rather than selecting the broker with the most favorable execution. This conflict is mitigated by the fact that Arrow Wealth has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. Additionally, Arrow Wealth does not make commitments to any broker-dealer to compensate that broker-dealer through brokerage transactions for client referrals. • Soft Dollar Arrangements The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by Arrow Wealth from or through a custodian in exchange for directing Client transactions to the custodian. As permitted by Section 28(e) of the Securities Exchange Act of 1934, Arrow Wealth receives economic benefits as a result of commissions generated from securities transactions by the custodian from the accounts of Arrow Wealth. These benefits include both proprietary research from the custodian and other research written by third parties. Arrow Wealth does not cause clients to pay commissions (or markups or markdowns) higher than those charged by the custodian in return for soft dollar benefits. Arrow Wealth utilizes the services of custodians. Economic benefits are received by Arrow Wealth which would not be received if Arrow Wealth did not give investment advice to Clients. These benefits include: A dedicated trading desk, a dedicated service group and an account services manager dedicated to Arrow Wealth's accounts, ability to conduct "block" Client trades, electronic download of trades, balances and positions, duplicate and batched Client statements, and the ability to have advisory fees directly deducted from Client accounts. A conflict of interest exists when Arrow Wealth receives soft dollars. This conflict is mitigated by the fact that Arrow Wealth has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. Soft dollar benefits are used to service all clients’ accounts. There were no products or services any related persons acquired with client brokerage commissions (or markups or markdowns) within our last fiscal year. - 13 - With respect to the Betterment Platform, Betterment Securities serves as broker- dealer to Betterment for Advisors, an investment and advice platform serving independent investment advisory firms like us (“Betterment for Advisors”). Betterment for Advisors also makes available various support services which may not be available to Betterment’s retail customers. Some of those services help us manage or administer our Clients’ accounts, while others help us manage and grow our business. Betterment for Advisors’ support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to Arrow Wealth. Following is a more detailed description of Betterment for Advisors’ support services: 1. SERVICES THAT BENEFIT YOU. Betterment for Advisors includes access to a low-cost portfolio of ETFs, execution of securities globally diversified, transactions, and custody of Client assets through Betterment Securities. In addition, a series of model portfolios created by third-party providers are also available on the platform. Betterment Securities’ services described in this paragraph generally benefit you and your account. 2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment for Advisors also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our Clients’ accounts, such as software and technology that may: • Assist with back-office functions, recordkeeping, and Client reporting of our Clients’ accounts. • Provide access to Client account data (such as duplicate trade confirmations and account statements). • Provide pricing and other market data. 3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment for Advisors, we may be offered other services intended to help us manage and further develop our business enterprise. These services include: • Consulting (including through webinars) on technology and business needs. • Access to publications and conferences on practice management and business succession. The availability of these services from Betterment for Advisors benefits us because we do not have to produce or purchase them. In addition, we do not have to pay for Betterment Securities’ services. Arrow Wealth may have an incentive to recommend that you maintain your account with Betterment Securities, based on our interest in receiving Betterment for Advisors and Betterment Securities’ services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Betterment Securities as custodian and broker is in the best interests of our Clients. Our selection is primarily supported by the scope, quality, and price of Betterment Securities’ services (see “How we select brokers/custodians”) and not Betterment for Advisors and Betterment Securities’ services that benefit only us or that may not directly benefit you. - 14 - When using the Betterment for Advisors platform, Arrow Wealth and Clients are subject to the trading policies and procedures established by Betterment. These policies and procedures limit our ability to control, among other things, the timing of the execution of certain trades (including in response to withdrawals, deposits, or asset allocation changes) within your account. You should not expect that trading on Betterment is instant, and, accordingly, you should be aware that Betterment does not permit you or us to control the specific time during a day that securities are bought or sold in your account (i.e., to “time the market”). Betterment describes its trading policies in Betterment LLC’s Form ADV Part 2A. As detailed in that document, Betterment generally trades on the same business day as it receives instructions from you or us. However, transactions will be subject to processing delays in certain circumstances. In particular, orders initiated on non-business days and after markets close generally will not transact until the next business day. Betterment also maintains a general approach of not placing securities orders during approximately the first thirty minutes after the opening of any market session. Betterment also generally stops placing orders arising from allocation changes in existing portfolios approximately thirty minutes before the close of any market session. Betterment continues placing orders associated with deposit and withdrawal requests until market close. Betterment maintains a general approach of not placing orders around the time of scheduled Federal Reserve interest rate announcements. Furthermore, Betterment may delay or manage trading in response to market instability. For further information, please consult Betterment LLC’s Form ADV Part 2A. Aggregating Securities Transactions for Client Accounts Arrow Wealth is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of Arrow Wealth. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved While the underlying investment accounts are continually monitored (whether the investments are managed by a TPM or by Arrow Wealth) account reviews for accounts managed by Arrow Wealth and TPM or accounts delegated to additional third parties are performed annually by Daniel Seltzer, the Chief Compliance Officer of Arrow Wealth. Reviews of Client accounts include, but are not limited to, examination of account performance against the investment policy established for each client, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target bans of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Additional account reviews for accounts managed by Arrow Wealth and/or TPM are performed more frequently when market conditions dictate. Factors that may trigger additional account review may be due to the client’s individual circumstances, economic conditions, general factors affecting the stock market, etc. - 15 - Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, Arrow Wealth suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by Arrow Wealth’s custodian. Client receives written confirmations of each transaction in account from Custodian and an additional written statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest With respect to the Betterment Platform, Arrow Wealth may receive a non-economic benefit from Betterment for Advisors and Betterment Securities in the form of the support products and services it makes available to us and other independent investment advisors whose Clients maintain their accounts at Betterment Securities. These products and services, how they benefit us, and the related conflicts of interest are described above in Item 12. The availability to us of Betterment for Advisors’ and Betterment Securities’ products and services is not based on us giving particular investment advice, such as buying particular securities for our Clients. Advisory Firm Payments for Client Referrals Neither Arrow Wealth nor any related persons for the firm, directly or indirectly, receive compensation for Client referrals. Neither Arrow Wealth nor any related persons for the firm, directly or indirectly, compensate any person who is not a supervised person for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by Arrow Wealth. Arrow Wealth is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Arrow Wealth. Arrow Wealth is not affiliated with the custodian. The custodian does not supervise Arrow Wealth, its agents or activities. - 16 - Item 16: Investment Discretion Discretionary Authority for Trading Arrow Wealth requires discretionary authority to manage securities accounts on behalf of Clients. Arrow Wealth has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize Arrow Wealth discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Arrow Wealth allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to Arrow Wealth in writing. Arrow Wealth does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes Arrow Wealth does not and will not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, Arrow Wealth will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Arrow Wealth does not serve as a custodian for Client funds or securities and Arrow Wealth does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Arrow Wealth has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years Neither Arrow Wealth nor its management has had any bankruptcy petitions in the last ten years. - 17 - Item 1 Cover Page S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B Daniel Seltzer, CFP®, MSFP Arrow Wealth Advisors, Inc. California Office Address: 10831 Combine Rd. Suite A Auburn, CA 95602 Texas Office Address: 400 N Loop 1604 E Suite 280 San Antonio, TX 78232 Tel: 210-541-9967 Fax: 210-541-9967 Dan@ArrowWealthAdvisors.com Website: www.ArrowWealthAdvisors.com This brochure supplement provides information about Daniel Seltzer and supplements the Arrow Wealth Advisors, Inc’s brochure. You should have received a copy of that brochure. Please contact Daniel Seltzer if you did not receive the brochure or if you have any questions about the contents of this supplement. J U N E 2 2 , 2 0 2 6 Additional information about Daniel Seltzer (CRD #5962042) is available on the SEC’s website at www.adviserinfo.sec.gov. - 18 - Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – Daniel Seltzer, CFP® • Year of birth: 1983 Item 2 - Educational Background and Business Experience Educational Background: • Oklahoma State University; Bachelor of Science in Finance, 2010 • Bentley University; Master of Science in Financial Planning; 2011 Business Experience: • Arrow Wealth Advisors, Inc.; President/Investment Advisor Representative; 10/2017 – Present • LPL Financial LLC; Registered Representative; 09/2011 – 12/2017 • US Financial Advisor, LLC; Investment Advisor Representative; 01/2012 – 11/2017 • LPL Financial LLC; Investment Advisor Representative; 10/2011 – 03/2013 • Bentley University; Student; 01/2011 – 12/2011 • Oklahoma State University; Student; 05/2006 – 12/2010 • US Army; Airborne Infantryman; 02/2003 – 04/2006 Professional Designations: The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with Clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and Client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and - 19 - • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their Clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Item 3 - Disciplinary Information A. Daniel Seltzer has never been involved in a criminal or civil action in a domestic, foreign or military court of competent jurisdiction for which he: a. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b) misdemeanor that involved investments or an investment-related business, fraud, false statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; b. Is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; c. Was found to have been involved in a violation of an investment-related statute or regulation; or d. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or otherwise limiting, him from engaging in any investment related activity, or from violating any investment-related statute, rule, or order. B. Daniel Seltzer never had an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or the subject of an order by the agency or authority; b. Was found to have been involved in a violation of an investment-related statute or regulation or was the subject of an order by the agency or authority a. (a)denying, suspending or revoking the authorization of the supervised person to act in an investment-related business; (b) barring or suspending his association with an investment-related business; (c) otherwise significantly limiting his - 20 - investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on him. C. Daniel Seltzer has never been the subject of a self-regulatory organization (SRO) proceeding in which he: a. Was found to have caused an investment-related business to lose its authorization to do business; or b. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or suspended from membership or from association with other members or was expelled from membership; (b) otherwise significantly limited from investment-related activities; or (c) fined more than $2,500. D. Daniel Seltzer has not been involved in any other hearing or formal adjudication in which a professional attainment, designation, or license of the supervised person was revoked or suspended because of a violation of rules relating to professional conduct. Item 4 - Other Business Activities Engaged In President Daniel Seltzer has no financially affiliated businesses or conflicts of interests to disclose. Daniel Seltzer is not engaged in any investment-related business or occupation. He has no application pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of an FCM, CPO, or CTA. Item 5 - Additional Compensation Daniel Seltzer does not receive commissions nor receive any performance based fees and does not receive any additional compensation for performing advisory services other than what is disclosed in Item 5 of Part 2A. Item 6 - Supervision Daniel Seltzer is the sole owner of Arrow Wealth. He is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures described in the firm’s Compliance Manual. Daniel Seltzer can be reached by email at dan@arrowwealthadvisors.com or by phone at 210-541-9967. - 21 -

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