BALANCE WEALTH PARTNERS LLC

Item 1: Cover Page Balance Wealth Partners LLC Form ADV Part 2A Brochure Address: 5701 North High Street Suite 100 Columbus, OH 43085 Phone: (216) 965-5045 Email: info@balancewealth.com Website: https://balancewealth.com/ This brochure provides information about the qualifications and business practices of Balance Wealth Partners LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Balance Wealth Partners LLC is a registered investment adviser, but registration does not imply a certain level of skill or training. Additional information about Balance Wealth Partners LLC is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 329589. Page 1 of 22 Date of Brochure: August 6, 2025  Item 2: Material Changes In this Item, Balance Wealth Partners LLC is only required to identify and discuss material changes since filing its last annual amendment. Since the firm’s last annual updating amendment filed on March 20, 2024, we have had no material changes to report. Page 2 of 22 Date of Brochure: August 6, 2025  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 1 2 3 4 6 8 9 10 12 13 15 16 17 18 19 20 21 22 Page 3 of 22 Date of Brochure: August 6, 2025  Item 4: Advisory Business A. Balance Wealth Partners LLC (the “Adviser,” “we,” “us,” or “our”) is an investment adviser founded in 2018, registered with the U.S. Securities and Exchange Commission (“SEC”), and principally owned by Robert Gavlak and Shaun Carney via Balance Wealth Holdings LLC and Bolt Financial Holdings LLC, respectively. B. Adviser offers the following types of advisory services: i. Discretionary Investment Management. Adviser provides ongoing discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment decisions that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s investment decisions will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Adviser will retain the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by a client in his or her investment management agreement with Adviser. Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Adviser. Adviser generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, bonds, U.S. Government securities, and real estate investment trusts (“REITs”). ii. Financial Planning. When rendering financial planning services (either in conjunction with discretionary investment management services or as a standalone service), Adviser will evaluate and make recommendations with respect to various financial planning topics that are relevant to a particular client. Such topics can include, for example, retirement planning, education savings, cash flow management, debt reduction, estate planning, insurance needs, risk mitigation, tax planning, charitable giving strategies, and/or financial goal tracking. Implementation of Adviser’s recommendations will be at the discretion of the client. When rendering financial planning services, a conflict exists between Adviser’s interests and the interests of its clients; clients are under no obligation to act upon Adviser’s financial planning recommendations. If a client elects to act on any of the recommendations made by Adviser, the client is under no obligation to effect the transaction through Adviser or any of its personnel. iii. Pension Consulting Services. To the extent Adviser is retained by a defined contribution plan, defined benefit plan, or other employee benefit plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk tolerance, and goals, and shall work in partnership with applicable third-parties (such as the Plan’s recordkeeper, third-party administrator, and/or discretionary investment manager) to establish an appropriate investment policy statement and deploy applicable investment options into the Plan’s account. Adviser shall periodically review the investment options available to the Plan and, if applicable, will make recommendations to assist the Plan with respect to the selection of the Plan’s qualified default investment alternative (“QDIA”). Adviser will provide reports, information and recommendations, on a reasonably requested basis, to assist the Plan in monitoring the selected investments. If elected by the Plan, Adviser may also provide various Page 4 of 22 Date of Brochure: August 6, 2025  services related to the Plan’s governance, the education of Plan participants, and the review of other service providers to the Plan. In connection with Plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of 1986, as amended (the “Code”) Adviser acknowledges that it is a fiduciary under ERISA and the Code, shall render prudent investment advice that is in Plan’s best interest, shall avoid making misleading statements, and shall receive no more than reasonable compensation. C. Adviser does not participate in any wrap fee programs. D. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (the “Code”), as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and v. vi. Give you basic information about conflicts of interest. E. Adviser manages the following amount of discretionary and non-discretionary client assets calculated as of July 1, 2025: i. ii. iii. Discretionary: Non-Discretionary: Total: $348,405,283 $0 $348,405,283 Page 5 of 22 Date of Brochure: August 6, 2025  Item 5: Fees and Compensation A. Adviser is compensated for its advisory services primarily by fees charged based on a client’s assets under management with Adviser, by flat fees, or by a combination of both asset-based and flat fees. Fees are negotiable, and each client’s specific fee schedule is included as part of the investment advisory agreement signed by Adviser and the client. B. Asset-based fees. Adviser’s standard asset-based fee schedules generally range from 0.40% to 1.20% of assets designed to be under Adviser’s management, charged monthly in advance of each month and prorated from when assets are first designed to be under Adviser’s management through termination of an advisory agreement. Prorated fees are also charged or refunded based on a client’s deposits or withdrawals during a billing period, respectively. Adviser’s asset-based fee schedules may be either (i) a “tiered” or “blended” fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under Adviser’s management, (ii) a “cliff” fee schedule, which means that the entirety of a client’s assets under Adviser’s management are charged the listed annual fee based on Client’s total assets under Adviser’s management, or (iii) a “flat” fee schedule, which means that the entirety of a client’s assets under Adviser’s management are charged the same percentage fee, regardless of the assets designated to be under Adviser’s management. Fees are generally deducted in advance on a monthly basis from clients’ assets and based upon the market value of such assets managed by Adviser as of the last business day of the prior calendar month. Cash, cash equivalents, and held-away accounts are included in the assets upon which fees are assessed. Fees will generally either be (i) deducted from each respective managed account based on its value as of the valuation date on a prorated basis, or (b) deducted from one or more non-qualified accounts linked by the client to Adviser through the Qualified Custodian as Adviser may determine in its good faith judgment based on the available cash in such account(s) from time to time. C. Flat fees. Adviser generally charges a flat fee in consideration of its financial planning services. For one-time financial plans, the flat fee typically ranges from $500 to $10,000 depending on the nature and complexity of a client’s financial situation and financial planning needs. The flat fee for ongoing financial planning services typically range from $588 to $7,200 per year, which shall be charged either monthly or quarterly in advance of the applicable billing period. To the extent a client also engages Adviser for discretionary investment management services, Adviser reserves the right - in its sole and absolute discretion - to waive the separate flat financial planning fee that may otherwise apply. Financial planning fees are payable via ACH or credit card through a third-party payment processor, via check mailed to Adviser’s address of record, or - solely to the extent a client has separately engaged Adviser for discretionary investment management services - via deduction from the client’s designated account(s) under Adviser’s management. Flat fees are generally prorated from the date of engagement through the date of termination of an advisory agreement based on the number of days in the applicable billing period (or the percentage of work completed with respect to a one-time financial plan). Page 6 of 22 Date of Brochure: August 6, 2025  D. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Depending on the specific investment products held in a client’s account and the services provided, a client may also incur additional fees and costs charged by other independent and unaffiliated third-parties. Such additional fees and costs may include, but are not necessarily limited to, the internal fees and costs of an investment product (like a mutual fund or exchange traded fund), margin interest, account or asset transfer fees, subadvisory or third-party investment manager fees, account type fees, early redemption charges, market-maker or bid-ask spreads, retirement plan fees, trade-away or prime brokerage fees, fees for receiving paper copies of documents in lieu of electronically-delivered documents, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Adviser. Lower fees for comparable services may be available from other sources. E. Neither Adviser nor any of its supervised persons accepts compensation for the sale of securities or other investment products. Page 7 of 22 Date of Brochure: August 6, 2025  Item 6: Performance-Based Fees & Side-By-Side Management Neither Adviser nor any of its supervised persons accepts performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Neither Adviser nor any of its supervised persons engage in side-by-side management. Page 8 of 22 Date of Brochure: August 6, 2025  Item 7: Types of Clients Adviser generally provides its services to individuals and high-net-worth individuals, and defined contribution plans, defined benefit plans, or other employee benefit plans. Adviser does not require a minimum account value to open or maintain an account. Page 9 of 22 Date of Brochure: August 6, 2025  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. The investment strategies used by Adviser when formulating investment advice or managing assets include Fundamental Analysis, Modern Portfolio Theory, Quantitative Analysis, and Long-Term Trading. Investing in securities involves risk of loss that clients should be prepared to bear. Past performance does not guarantee future returns. B. Like any investment strategy, Fundamental Analysis, Modern Portfolio Theory, Quantitative Analysis, and Long-Term Trading involve material risks. Such material risks are described in further detail below: i. Investing for the long term means that a client’s account will be exposed to short-term fluctuations in the market and the behavioral impulse to make trading decisions based on such short-term market fluctuations. Adviser does not condone short-term trading in an attempt to “time” the market, and instead coaches clients to remain committed to their financial goals. However, investing for the long term can expose clients to risks borne out of changes to interest rates, inflation, general economic conditions, market cycles, geopolitical shifts, and regulatory changes. ii. Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an amount equal to inflation over time. General micro- and macro-economic conditions may also affect the value of the securities held in a client’s portfolio, and general economic downturns can trigger corresponding losses across various asset classes and security types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value, and may increase the likelihood that securities are purchased when values are comparatively high and/or that securities are sold when values are comparatively low. Geopolitical shifts may result in market uncertainty, lowered expected returns, and general volatility in both domestic and international securities. Regulatory changes may have a negative impact on capital formation and increase the costs of doing business, and therefore result in decreased corporate profits and corresponding market values of securities. iii. Investing in mutual funds does not guarantee a return on investment, and shareholders of a mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual funds invest into underlying securities that comprise the mutual fund, and as such clients are exposed to the risks arising from such underlying securities. Mutual funds charge internal expenses to their shareholders (which can include management fees, administration fees, shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.), and such internal expenses subtract from its potential for market appreciation. Shares of mutual funds may only be traded at their stated net asset value (“NAV”), calculated at the end of each day upon the market’s close. Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds as described above. However, shares of an ETF may be traded like stocks on the open market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate throughout the day and investors will be subject to the cost associated with the bid-ask spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the seller's offering (asking) price). Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be purchased for investment to obtain a full understanding of its respective risks and costs. Page 10 of 22 Date of Brochure: August 6, 2025  iv. Investing in common stocks means that a client will be subject to the risks of the overall market as well as risks associated with the particular company or companies whose stock is owned. These risks can include, for example, changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. Common stocks tend to be more volatile and more risky than certain other forms of investments, especially as compared to fixed income products like bonds. v. Investing in fixed income securities issued by the U.S. Government, including Treasury Bills, Treasury Notes, Treasury Bonds, Treasury Inflation-Protected Securities (“TIPS”), and Floating Rate Notes means that a client will be subject to the market prices of such debt securities, which typically fluctuate depending on interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and rise when interest rates fall. The longer the time to a security’s maturity, the greater its interest rate risk. Fixed income securities issued by the U.S. Government are also subject to inflation risk, reinvestment risk, redemption risk, and valuation risk. vi. Investing in corporate debt, including corporate bonds, carries additional risks to those noted above for fixed income securities. Corporate debt is also subject to credit risk - the risk that the bond issuer may default on one or more payments before the bond reaches maturity. In the event of a default, you may lose some or all of the income you were entitled to, and even some or all of the principal amount invested. Some corporate bonds may also be subject to early redemption risk, with the issuer having the principal repaid prior to the maturity date of the bond. vii. Investing in REITs means that clients will be subject to the risks associated with investments in mortgages and their related activities in addition to the general risk of equity and financial markets. Among the factors that the REIT industry is vulnerable to are: (1) change in government regulation, primarily the pass-through tax treatment of REIT income, (2) the market for residential mortgage assets, (3) the general level and term structure for interest rates. The common equity prices of REITs have historically been more closely correlated with changes in interest rates than other non-REIT equity securities. Additionally, REITs tend to be more illiquid in nature, may contain additional fees, and may experience disruptions in distributions in comparison to other types of securities. Page 11 of 22 Date of Brochure: August 6, 2025  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Adviser’s advisory business or the integrity of Adviser’s management. Page 12 of 22 Date of Brochure: August 6, 2025  Item 10: Other Financial Industry Activities & Affiliations A. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither Adviser nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Neither Adviser nor any of its management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. broker-dealer, municipal securities dealer, or government securities dealer or broker investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships Robert Gavlak is the Sole Member of Balance Insurance Solutions, LLC, an insurance company offering insurance services. This activity is separate and distinct from the activities of Adviser; however, it is anticipated that clients of Balance Insurance Solutions, LLC will become clients of Adviser, and clients of Adviser will become clients of Balance Insurance Solutions, LLC. This presents a conflict of interest due to the additional compensation that will be earned to the extent clients retain both the services of Adviser and Balance Insurance Solutions, LLC. Several of Adviser’s investment adviser representatives are licensed insurance agents through Balance Insurance Solutions, LLC and/or other insurance providers. Adviser addresses this conflict of interest by fully disclosing it in this brochure, by informing clients that they are under no obligation to retain the services of Balance Insurance Solutions, LLC, and by informing clients that they are free to retain any insurance agent they deem fit for the provision of insurance services. Robert Gavlak is a licensed insurance agent and from time to time will earn an ordinary and customary commission from the sale of an insurance product in such capacity. This creates a conflict of interest, because Robert Gavlak has the potential to earn both an insurance commission and advisory fee revenue from a client. Robert Gavlak addresses this conflict of interest by fully disclosing his relationship with the applicable insurance provider, and informing clients that they are under no obligation to purchase an insurance product through him. Timothy Power is a licensed insurance agent and from time to time will earn an ordinary and customary commission from the sale of an insurance product in such capacity. This creates a conflict of interest, because Timothy Power has the potential to earn both an insurance commission and advisory fee revenue from a client. Timothy Power addresses this conflict of interest by fully disclosing his relationship with the applicable insurance provider, and informing clients that they are under no obligation to purchase an insurance product through him. Certain investment adviser representatives of Adviser are also investment adviser representatives of Bolt Financial Group, Inc, a registered investment adviser that is affiliated with Adviser. Page 13 of 22 Date of Brochure: August 6, 2025  Certain investment adviser representatives of Adviser are also investment adviser representatives of Agdeavor Investments, LLC a registered investment adviser that is affiliated with Adviser. Bolt Financial Group, Inc. and Agdeavor Investments, LLC are affiliated with Adviser, but are in the process of transitioning all client relationships to Adviser and winding down due to the merger of Bolt Financial Group, Inc. with Adviser effective July 1, 2025. Page 14 of 22 Date of Brochure: August 6, 2025  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Adviser has adopted a code of ethics that will be provided to any client or prospective client upon request. Adviser’s code of ethics describes the standards of business conduct that Adviser requires of its supervised persons, which is reflective of Adviser’s fiduciary obligations to act in the best interests of its clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to Adviser’s Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither Adviser nor any of its related persons recommends to clients, or buys or sells for client accounts, securities in which Adviser or any of its related persons has a material financial interest. C. From time to time, Adviser or its related persons will invest in the same securities (or related securities such as warrants, options or futures) that Adviser or a related person recommends to clients. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to profit from the investment recommendations made to clients. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. D. From time to time, Adviser or its related persons will buy or sell securities for client accounts at or about the same time that Adviser or a related person buys or sells the same securities for its own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords Adviser or its related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Adviser’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Adviser will act in the best interests of its clients. Page 15 of 22 Date of Brochure: August 6, 2025  Item 12: Brokerage Practices A. Adviser considers several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows Adviser to fulfill its duty to seek best execution for its clients’ securities transactions. However, Adviser does not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, Adviser recommends Altruist Financial LLC ("Altruist") and Charles Schwab & Co., Inc. ("Schwab") as the custodial broker-dealers for client accounts. i. Adviser does not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer(s) recommended by Adviser do provide certain products and services that are intended to directly benefit Adviser, clients, or both. Such products and services include (a) an online platform through which Adviser can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer(s)’ educational conferences, (e) practice management consulting, and (f) occasional business meals and entertainment. In addition, Adviser receives direct compensation from Altruist in consideration of certain Adviser personnel speaking individually or on panels for the Altruist Academy – a recurring series of educational events for independent financial professionals. Such compensation takes the form of a flat fee, and does not vary based on the amount of assets held on the Altruist custody platform. Upon receipt of the compensation from Altruist, Adviser in-turn pays its personnel that spoke at such Altruist Academy events. The receipt of these products and services creates a conflict of interest to the extent it causes Adviser to recommend Altruist and Schwab as opposed to a comparable custodial broker-dealer. Adviser addresses this conflict of interest by fully disclosing it in this brochure, evaluating Altruist and Schwab based on the value and quality of their services as realized by clients, and by periodically evaluating alternative broker-dealers to recommend. ii. Adviser does not consider, in selecting or recommending custodial broker-dealers, whether Adviser or a related person receives client referrals from a custodial broker-dealer. iii. Adviser does not routinely recommend, request, or require that a client direct Adviser to execute transactions through a specified custodial broker-dealer other than Altruist and Schwab. B. Adviser retains the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Adviser, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Directing the purchase and sale of securities for clients’ accounts on an individual basis, rather than in aggregate blocks, may result in increased client transaction costs. Page 16 of 22 Date of Brochure: August 6, 2025  Item 13: Review of Accounts A. The investment adviser representatives of Adviser monitor client accounts on an ongoing basis, and typically review client accounts on an annual basis. Such reviews are designed to ensure that the client is still on track to achieve his or her financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to Adviser to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. If agreed to by Adviser and client, Adviser or a third-party report provider will also send clients reports to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 17 of 22 Date of Brochure: August 6, 2025  Item 14: Client Referrals and Other Compensation A. Only clients provide an economic benefit to Adviser for providing investment advice or other advisory services to them, except as otherwise described in this brochure. However, as described above in Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain products and services that are intended to directly benefit Adviser, clients, or both. Adviser has entered into arrangements with one or more independent third-parties (“Promoters”) that refer prospective advisory clients to Adviser. Such Promoters are compensated directly by Adviser, and the fees charged by Adviser to prospective advisory clients are not increased as a result of such referral. The compensation paid by Adviser to a Promoter will be memorialized in a written agreement, and is generally in the form of (i) a percentage of the advisory fees earned by Adviser from clients referred by the Promoter, (ii) flat per-referral fees, and/or (iii) a recurring flat fee that does not vary based on the number of prospective advisory clients referred. Prospective advisory clients referred to Adviser by a Promoter will receive a separate disclosure that describes the arrangement between the Adviser and the Promoter, including the specific referral fees to be paid. Adviser is independent and unaffiliated with the Promoters from whom it receives prospective advisory client referrals. As of the date of this brochure, Adviser has entered into prospective advisory client referral arrangements with SmartVestor and Sam’s List. Page 18 of 22 Date of Brochure: August 6, 2025  Item 15: Custody For clients that do not have their fees deducted directly from their account(s), Adviser will not have any custody of client funds or securities. For clients that have their fees deducted directly from their account(s), Adviser will generally be deemed to have custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. At no time will Adviser accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian, and at all times client accounts will be held by a third-party qualified custodian as described in Item 12, above. If a client receives account statements from both the custodial broker-dealer and Adviser or a third-party report provider, client is urged to compare such account statements and advise Adviser of any discrepancies between them. Page 19 of 22 Date of Brochure: August 6, 2025  Item 16: Investment Discretion Adviser accepts discretionary trading authority to manage securities accounts on behalf of clients only pursuant to the mutual written agreement of Adviser and the client through a power-of-attorney, which is typically contained in the advisory agreement signed by Adviser and the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in client’s account(s) without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 20 of 22 Date of Brochure: August 6, 2025  Item 17: Voting Client Securities A. Adviser does not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 21 of 22 Date of Brochure: August 6, 2025  Item 18: Financial Information A. Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. Adviser has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. C. Adviser has not been the subject of a bankruptcy petition at any time during the past ten years. Page 22 of 22 Date of Brochure: August 6, 2025