BARE WEALTH ADVISORS

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure March 18, 2026 Bare Wealth Advisors 835 Houston Run Drive, Suite 260 Gap, PA 17527 www.BareWealthAdvisors.com Firm Contact: Curtis Burkholder Chief Compliance Officer This brochure provides information about the qualifications and business practices of Bare Financial Services, Inc. dba Bare Wealth Advisors. If clients have any questions about the contents of this brochure, please contact us at (717) 407-5200. 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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #328043. Please note that the use of the term “registered investment advisor” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Bare Wealth Advisors is required to notify clients of any information that has changed since the last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can request a full copy of our Brochure or contact us with any questions that they may have about the changes. Since the last Brochure filed on March 19, 2025, clarification was provided in Item 4 regarding the services we offer. This clarification explains that we offer Investment Management Services and Financial Planning Services. These services may be provided separately to clients, or Financial Planning Services may be included in conjunction with Investment Management Services. Item 5 was updated to reflect a planned change in our billing for investment management services from quarterly in advance to monthly in arrears effective July 1, 2026. ADV Part 2A – Firm Brochure Page 2 Bare Wealth Advisors  Item 3: Table of Contents Item 1: Cover Page .............................................................................................................................. 1 Item 2: Material Changes .................................................................................................................... 2 Item 3: Table of Contents ................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................ 6 Item 6: Performance-Based Fees & Side-By-Side Management .................................................... 8 Item 7: Types of Clients & Account Requirements .......................................................................... 9 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................ 9 Item 9: Disciplinary Information ...................................................................................................... 16 Item 10: Other Financial Industry Activities & Affiliations ............................................................ 16 Item 11: Code of Ethics, Participation or Interest in ..................................................................... 17 Item 12: Brokerage Practices........................................................................................................... 18 Item 13: Review of Accounts or Financial Plans ............................................................................ 22 Item 14: Client Referrals & Other Compensation ......................................................................... 23 Item 15: Custody ............................................................................................................................... 24 Item 16: Investment Discretion ....................................................................................................... 25 Item 17: Voting Client Securities ..................................................................................................... 25 Item 18: Financial Information ......................................................................................................... 26 ADV Part 2A – Firm Brochure Page 3 Bare Wealth Advisors  Item 4: Advisory Business Our firm provides individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed under the laws of the State of Pennsylvania in 2006 and has been in business as an investment advisor since 2023. Our firm is owned by Ronald Bare, Curtis Burkholder, Lamar King, and Ryan Kurtz who are also investment advisor representatives. The purpose of this Brochure is to describe our services, fees, and disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process facilitates the kind of working relationship we value. Types of Advisory Services Offered Investment Management Service: Our firm provides investment management services as a standalone engagement and, at times, includes financial planning services with investment management services, depending on the client’s needs and the terms of the client’s agreement with our firm. As part of our Investment Management service, we recommend a portfolios, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), mutual funds and other public and private securities or investments. Our firm tailors the client’s individual investment strategy to their specific needs and will include some or all the previously mentioned securities. Portfolios are designed to meet a particular investment goal, determined to be suitable for the client’s circumstances. Once our firm implements the recommended portfolio, the portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Our firm utilizes the service of sub-advisors to aid in the implementation of investment portfolios designed by our firm. Before selecting a firm or individual to serve as a sub-advisor, our firm will ensure that the chosen party is properly licensed or registered. We will obtain initial due diligence on sub-advisors and ongoing reviews of their management of client accounts. Our firm, at times, also offers advice on certain securities. To assist in the selection of a sub-advisor, our firm will gather client information pertaining to the financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will review sub-advisor reports provided to the client at least quarterly. ADV Part 2A – Firm Brochure Page 4 Bare Wealth Advisors  Financial Planning: Our firm provides financial planning services to clients as a standalone engagement and, at times, includes financial planning services with investment management services. Financial planning services are based upon an analysis of the client’s current situation, goals, and objectives. Financial planning services typically involves preparing a financial plan or rendering a financial consultation for clients based on the client’s needs. This planning encompasses all or some of the following: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Farm Succession Planning, Cash Flow Planning, Business Succession Planning, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. We will work closely with the client’s other advisors, particularly in matters that require legal or tax advice. Written financial plans or financial consultations rendered to clients include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. For financial plans, our firm typically provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Retirement Plan Services: For certain retirement plans, the Firm has agreed to provide advice to the plan sponsor, investment manager oversight, plan participant education and ongoing administrative support in partnership with third-party administrators (“TPAs”), recordkeepers, and investment advice as a 3(21) co-fiduciary Use of Third-Party Sub-Advisors: Our firm has contracted with EverSource Wealth Advisors, LLC (“EverSource”), a registered investment advisor, to act as a sub-advisor for certain client accounts. EverSource has the authority to supervise and direct, on a discretionary basis, investments for those accounts designated by our firm and in accordance with the direction of our firm. This will be through our firm’s selection of one or more investment strategies or models, individual securities, or a combination of investment strategies and individual securities. EverSource has the discretion to engage other third-party investment managers, who shall act as sub-sub-advisors, to implement parts of the investment strategies. Among the available investment strategies are several values based or faith-based models provided for clients who express interest in aligning their investments with their beliefs. This approach and underlying assumptions are described in Item 8, as well as the EverSource Form ADV Part 2A which is provided to client. ADV Part 2A – Firm Brochure Page 5 Bare Wealth Advisors  Tailoring of Advisory Services Our firm offers individualized investment advice to our Investment Management clients. Each Investment Management or client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our firm does not offer, sponsor, or participate in a wrap fee program. Regulatory Assets Under Management Our firm manages $640,758,505.43 on a discretionary basis and $21,505,969.84 on a non- discretionary basis as of December 31, 2025. Item 5: Fees & Compensation Compensation for Our Advisory Services Financial Planning: Our firm charges a flat fee for financial planning services. The total estimated fee, as well as the final fee charged, is based on the scope and complexity of the engagement. Fee arrangements are determined on a case-by-case basis and are outlined in the client’s signed consulting agreement. Financial planning fees are billed in arrears. If the engagement is terminated prior to the completion of the financial planning services, the client will be billed for services performed through the date of termination. Investment Management: The standard annual fee charged for this service is up to 1.50% based on such factors as account size and complexity. Fees to be assessed will be specified in the advisory agreement signed by the Client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the first day of the quarter. Investment Advisory Services fees are billed within ten (10) days following the close of each calendar quarter when billing in advance. When billing in advance, adjustments are made for deposits and withdrawals of over $100,000 during the quarter. When funds over $100,000 are deposited or withdrawn, advisory fees are correspondingly increased or decreased based on the number of days the funds are in or out ADV Part 2A – Firm Brochure Page 6 Bare Wealth Advisors  of the account. In the event of termination, we are entitled to fees earned through the effective date of termination, which is 30 days from written notice, unless we shorten that time period in our sole discretion. We calculate the refund of unearned advisory fees due to the client based upon the number of days from the start of the quarter to the effective date of termination. If additional payments are due to us but client’s funds or accounts are no longer accessible to us, the client will receive an invoice requiring payment. Effective July 1, 2026, we will bill all client accounts monthly in arrears, with the amount of the fee based upon the average daily balance of the account over the previous month. With monthly billing in arrears, Investment Advisory Services fees are billed within ten (10) days following the close of each calendar month. In the event of termination, we are entitled to payment of our fee up to the end of the month wherein the notice of termination was received. On accounts held directly with the sponsor company, the sponsor company bills the fees monthly or quarterly in arrears based upon their process and pays the fee to our firm. In rare cases and upon a client’s request, our firm will agree to directly invoice. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. c) Our firm will send an invoice directly to the custodian; and If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. The maximum annual fee charged to clients by our firm that are utilizing sub advisors will not exceed our firm’s total maximum fee published above for the investment services we provide. The sub advisors debit fees for investment management services as disclosed in the executed advisory agreement between the client and our firm. This fee shall be in addition to any fees assessed by the chosen sub-advisor. The sub-advisor we recommend will not directly charge you a higher fee than they would have charged without us introducing you to them. Sub-advisors establish and maintain their own separate billing processes. We have delegated to the sub-advisor the authority to deduct their fee directly from client accounts and, by agreement with our Firm, will bill quarterly or monthly, based upon either the average account value over the previous quarter or the account value on the last business day of the previous quarter. Retirement Plan Services: For certain retirement plans, the Firm has agreed to provide advice to the plan sponsor, investment manager oversight, plan participant education and ongoing administrative support in partnership with third-party administrators (“TPAs”), recordkeepers, and investment advice as a 3(21) co-fiduciary. We will not accept discretionary authority over or handle plan assets and will not serve in a 3(38) fiduciary role. We will ensure that our fee for these services is ADV Part 2A – Firm Brochure Page 7 Bare Wealth Advisors  reasonable and will provide the required disclosures to the plan sponsor or assure that a third party provides those disclosures. Third-Party Sub-Advisors: Our firm has contracted with EverSource Wealth Advisors, LLC (“EverSource”) for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. Our firm has also contracted with EverSource for sub-advisory services with respect to clients’ accounts, as described in Item 4 above. Our firm pays a fee for EverSource services based on management fees paid to our firm on accounts which use EverSource. The fee paid by our firm to EverSource consists of a portion of the fee paid by clients to our firm and is based on total client assets per account. These fees are not separately charged to advisory clients. The fee charged by our firm to our clients includes all sub-advisory fees charged by EverSource. For investment management services, our firm will obtain authority from the client to deduct quarterly payments directly from the client's account held by an independent custodian. Clients shall provide limited authorization to our firm or its designated service provider, EverSource, to deduct fees from the account. Clients will receive custodial statements at least quarterly showing the advisory fees debited from their accounts. Other Types of Fees & Expenses Clients will incur transaction fees for trades executed by Charles Schwab & Co., Inc. (“Schwab), either based on a percentage of the dollar amount of assets in the account(s) or via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by Schwab. Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds. Upon a client’s request, our firm will assist clients in researching other custodians. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution fees, surrender charges, IRA and qualified retirement plan fees, mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. ADV Part 2A – Firm Brochure Page 8 Bare Wealth Advisors  Item 7: Types of Clients & Account Requirements Our firm has the following types of clients:  Individuals and High Net Worth Individuals;  Trusts, Estates or Charitable Organizations;  Sponsors of Pension and Profit Sharing Plans; and  Corporations, Limited Liability Companies and/or Other Business Types.  In some cases, our firm contracts directly with third party broker-dealers to provide investment advice on assets owned by clients of our firm which are held by the broker dealer. Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: Duration Constraints: Our firm adheres to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Fundamental Analysis: Our firm on rare occasions will incorporate fundamental analysis. The analysis of a business's financial statements (usually to analyze the business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a stock, futures contract, or currency using fundamental analysis there are two basic approaches one can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis from other types of investment analysis, such as quantitative and technical. Fundamental analysis is performed on historical and present data, but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company stock valuation and predict its probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic value of the share. When the objective of the analysis is to determine what stock to buy and at what price, there are two basic methodologies investors rely upon: (a) Fundamental analysis maintains that ADV Part 2A – Firm Brochure Page 9 Bare Wealth Advisors  markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all information is reflected already in the price of a security. Technical analysts analyze trends and believe that sentiment changes predate and predict trend changes. Investors' emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also analyze historical trends to predict future price movement. Investors can use one or both of these different but complementary methods for stock picking. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. lack, since things Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on reports such as balance sheets. The two techniques, however, will often be used together in order to examine a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one. This approach depends on the kind of intelligence that machines like positive associations with a brand, management (currently) trustworthiness, customer satisfaction, competitive advantage and cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative analysis is that subjective judgment may prove incorrect. Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement patterns (trend following or mean reversion). The resulting strategies may involve high-frequency trading. The results of the analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Sector Analysis: Sector analysis involves identification and analysis of various industries or economic sectors that are likely to exhibit superior performance. Academic studies indicate that the health of a stock's sector is as important as the performance of the individual stock itself. In other words, even the best stock located in a weak sector will often perform poorly because that sector is out of favor. Each industry has differences in terms of its customer base, market share among firms, industry growth, competition, regulation and business cycles. Learning how the industry operates provides a deeper understanding of a company's financial health. One method of analyzing a company's growth potential is examining whether the amount of customers in the overall market is expected to grow. In some markets, there is zero or negative growth, a factor demanding careful consideration. Additionally, market analysts recommend that investors should monitor sectors that are nearing the bottom of performance rankings for possible signs of an impending turnaround. Sub-Advisor Analysis: The analysis of the experience, investment philosophies, and past performance of independent sub-advisors in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. ADV Part 2A – Firm Brochure Page 10 Bare Wealth Advisors  is completed by monitoring the manager’s underlying holdings, strategies, Analysis concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of the due diligence process, the manager’s compliance and business enterprise risks are surveyed and reviewed. A risk of investing with a sub advisor who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a sub advisor’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as our firm does not control the manager’s daily business and compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Values-Based Analysis: Values-Based also known as Faith Based Investing, which we previously referred to as Biblically Responsible Investing, seeks to identify investments that will make a positive impact on the world and to exclude investments which have a negative impact. Criteria and assumptions are set forth in the disclosures provided by the third-party asset managers we rely upon to perform the research and screening data for this analysis. In general, those values are based upon a Christian ethic and worldview. Associated with this type of investing there are additional risk factors that include, but are not limited to the following: • Potentially higher costs associated with screened investments. • Screening restricts the universe of available investments which may result in a more restricted investment universe, leading to investment underperformance in certain market environments. • Potential for decreased diversification in different asset classes due to limits of investable companies across the investment universe and the limited number of managers willing to manage these values or faith integrated mandates. • While third-party managers conduct diligence on values-based funds, they necessarily rely upon the data provided by third parties, which may be incorrect or incomplete. • While we conduct diligence on values-based funds, we necessarily rely upon the data provided by third parties, which may be incorrect or incomplete. If clients desire additional screening restrictions and have sufficient assets, direct indexing is an option that can be tailored to each client’s specific desires. Investment Strategies We Use We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Alternative Investments: Private market investments expose eligible clients to significantly more types and degrees of risks than traditional asset classes, including significantly higher illiquidity risk, credit risk, leverage risk, concentration risk, manager risks, operational risks, and due diligence risks. Hedge funds, private real estate, private credit, private equity, and real assets can be illiquid due to restrictions on transfer and lack of a secondary trading market. ADV Part 2A – Firm Brochure Page 11 Bare Wealth Advisors  Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector- specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small- cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Clients’ overall allocation of assets, including alternative assets will be taken into consideration when making asset allocation decisions. Alternative assets include but are not limited to hedge funds, private real estate, private credit, private equity, and real assets. There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core-satellite.  Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Generally, strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions.  Dynamic Asset Allocation: Dynamic asset allocation is like strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in the economic environment.  Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes.  Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while ADV Part 2A – Firm Brochure Page 12 Bare Wealth Advisors  applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or periodic income is received at regular intervals and at reasonably predictable levels. Fixed- income investors are typically retired individuals who rely on their investments to provide a regular, stable income stream. This demographic tends to invest heavily in fixed-income investments because of the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding their spending power. Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated with fixed-income investments is the borrower defaulting on his payment. Other considerations include exchange rate risk for international bonds and interest rate risk for longer-dated securities. The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local municipalities and major corporations. Fixed- income securities are recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products, such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss potential short-term gains that could have been profitable to your account, or it is possible that the security’s value may decline sharply before our firm decides to sell. Margin Transactions: Upon client’s request, our firm may purchase securities for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase securities without selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client. It should be noted that our firm bills advisory fees on securities purchased on margin which creates a financial incentive for us to utilize margin in client accounts. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; (4) you may not be ADV Part 2A – Firm Brochure Page 13 Bare Wealth Advisors  entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin balances which will reduce your returns over time. Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. The underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a fund or ETF, managers of different funds held by the Client may purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the Client’s portfolio. Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). Our firm does this in an attempt to take advantage of conditions that our firm believes will soon result in a price swing in the securities our firm purchase. Risk of Loss Investing in securities involves the risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk, and the loss of capital is generally a risk for any investment instrument. Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected ADV Part 2A – Firm Brochure Page 14 Bare Wealth Advisors  or required. Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk, which is the risk that their value will generally decline as prevailing interest rates rise, which may cause your account value to likewise decrease, and vice versa. How specific fixed income securities may react to changes in interest rates will depend on the specific characteristics of each security. Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of a bond to decline. Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than it can today. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. ADV Part 2A – Firm Brochure Page 15 Bare Wealth Advisors  In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest-paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further, regardless of how well individual companies perform, the value of your portfolio could also decrease if there are deteriorating economic or market conditions. It is important to understand that the value of your investment may fall, sometimes sharply, in response to changes in the market, and you could lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a guarantee of future returns. Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Asset Management and Comprehensive Portfolio Management services, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Our firm has a relationship with third-party insurance networking agencies that provide insurance and annuity education, comparisons, and solutions. These third-party insurance networking agencies have relationships with third party broker-dealers who facilitate variable annuities and insurance products. For an asset-based fee, our firm may contract directly with third party broker-dealers to provide advisory consulting services to shared clients. The ADV Part 2A – Firm Brochure Page 16 Bare Wealth Advisors  services provided by our firm under these third-party relationships are limited to a) serving as the client relationship manager, b) providing advice based on client relationship summaries, c) providing investment analysis based on disclosed client assets. Our firm does not receive nor share in commissions in these relationships. Through these same relationships, our firm may recommend non-variable life and annuity products and receive compensation in the form of advisory fees directly from insurance carriers. Our firm also operates as a state-licensed insurance agency, and we may recommend non- variable (i.e. fixed) insurance products to clients. Clients may be solicited to use these services, and our firm will receive commissions as a result of these transactions. A conflict of interest exists as these commissionable sales create an incentive to recommend products based on the compensation earned. To mitigate this potential conflict, our firm seeks to act in the client’s best interest and explain the conflict of interest. Representatives of our firm are insurance agents/brokers. Therefore, representatives of our firm receive commissions from the sale of non-variable insurance products. The receipt of insurance commissions can give us an incentive to recommend insurance products based upon the compensation rather than the client’s needs. However, as a fiduciary, representatives of our firm seek to always act in the client’s best interest, specifically with respect to insurance. We explain to clients the conflict of interest and emphasize that clients may purchase insurance products elsewhere, purchase other products, or not purchase insurance at all. As described above in Item 4, our firm has contracted with EverSource Wealth Advisors, LLC (“EverSource”) to act as a sub-advisor in the delivery and trading of model strategies. Our firm has also contracted with EverSource for back-office services and assistance with portfolio modeling. We have a fiduciary duty to select qualified and appropriate managers in the client’s best interest and believe that EverSource effectively provides both the back-office services that assist with its overall investment advisory practice and sub-advisory services. The management of our firm routinely analyzes and assesses its use of EverSource in this capacity. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts and to always act solely in the best interest of each of our clients. Our fiduciary duty is the underlying principle of our firm’s Code of Ethics, which includes procedures for personal securities transactions and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to always comply with all federal and state securities laws. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. ADV Part 2A – Firm Brochure Page 17 Bare Wealth Advisors  Our firm recognizes that the personal investment transactions of our representatives demand the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has a quarterly investment monitoring system and requires all staff members to attest to the disclosure of all securities transactions. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling securities that will be bought or sold in client accounts unless done so after the client execution or concurrently as a part of a block trade. Item 12: Brokerage Practices Selecting a Brokerage Firm Custodian & Brokers Used Our firm does not maintain custody of client assets (although our firm may be deemed to have custody of client assets if given the authority to withdraw assets from client accounts. See Item 15 Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when instructed. While our firm recommends that clients use Schwab as 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 18 Bare Wealth Advisors  custodian/broker, clients will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. Our firm does not open the account. Even though the account is maintained at Schwab, our firm can still use other brokers to execute trades, as described below. Upon a client’s request, our firm may assist that client in researching the custodian of their best interests. Additionally, our firm arranges for the execution of securities transactions with the operational assistance of EverSource. Through EverSource, our firm participates in the Schwab Advisor Services (SAS) services program offered to independent investment advisors by Charles Schwab & Company, Inc., ("Schwab"). Schwab is an SEC-registered broker dealer and FINRA member broker dealer. It offers to independent advisors services which include custody of securities, trade execution, clearance and settlement transactions. How Brokers/Custodians Are Selected Our firm seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. A wide range of factors are considered, including, but not limited to:  combination of transaction execution services along with asset custody services (generally without a separate fee for custody)  capability to execute, clear and settle trades (buy and sell securities for client accounts)  capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.)  availability of investment research and tools that assist in making investment decisions quality of services  competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them reputation, financial strength and stability of the provider   prior service to our firm and our other clients  availability of other products and services that benefit our firm, as discussed below (see “Products & Services Available from Schwab”) Custody & Brokerage Costs Schwab generally does not charge a separate fee for custody services but is compensated by charging commissions or other fees to clients on trades that are executed or that settle into the Schwab account. For some accounts, Schwab may charge your account a percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s commission rates and/or asset-based fees applicable to client accounts were negotiated based on our firm’s commitment to maintain a minimum threshold of assets statement equity in accounts at Schwab. This commitment benefits clients because the overall commission rates and/or asset- based fees paid are lower than they would be if our firm had not made the commitment. In addition to commissions or asset-based fees, Schwab charges a flat dollar amount as a “prime ADV Part 2A – Firm Brochure Page 19 Bare Wealth Advisors  broker” or “trade away” fee for each trade that our firm has executed by a different broker- dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Schwab account. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, in order to minimize client trading costs, our firm has Schwab execute most trades for the accounts. Products & Services Available from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like our firm. They provide our firm and clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge to our firm. The availability of Schwab’s products and services is not based on the provision of particular investment advice, such as purchasing particular securities for clients. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Services that May Not Directly Benefit Clients Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  provides access to client account data (such as duplicate trade confirmations and  account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; facilitates payment of our fees from our clients’ accounts; and  provides pricing and other market data;   assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Our Firm Schwab also offers other services intended to help manage and further develop our business enterprise. These services include: ADV Part 2A – Firm Brochure Page 20 Bare Wealth Advisors  technology, compliance, legal, and business consulting;  educational conferences and events   publications and conferences on practice management and business succession; and  access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third- party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance the client experience, help clients reach their goals and put client interests before that of our firm or associated persons. Our Interest in Schwab’s Services. The availability of these services from Schwab benefits our firm because our firm does not have to produce or purchase them. Our firm does not have to pay for these services, and they are not contingent upon committing any specific amount of business to Schwab in trading commissions or assets in custody. In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive to require that clients maintain their accounts with Schwab based on our interest in receiving Schwab’s services that benefit our firm rather than based on client interest in receiving the best value in custody services and the most favorable execution of transactions. As part of our fiduciary duty to our clients, our firm always endeavors to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend Schwab and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Our firm believes that the selection of Schwab as a custodian and broker is the best interest of our clients. It is primarily supported by the scope, quality and price of Schwab’s services, and not Schwab’s services that only benefit our firm. Soft Dollars ADV Part 2A – Firm Brochure Page 21 Bare Wealth Advisors  Our firm does not receive economic benefits in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all our clients but not necessarily all at any one particular time. Client Brokerage Commissions Schwab does not make client brokerage commissions generated by client transactions available for our firm’s use. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are affected. Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Our firm recommends the use of Schwab. Each client will be recommended to establish their account(s) with Schwab if not already done. Our firm does not allow client-directed brokerage. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Item 13: Review of Accounts or Financial Plans Our management personnel or financial advisors review accounts on at least an annual basis for our Investment Management and sub advisor clients. In certain circumstances, clients may ADV Part 2A – Firm Brochure Page 22 Bare Wealth Advisors  also receive financial planning services with investment management services, as agreed upon in the client’s advisory agreement. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients are offered on at least an annual basis when our Investment Management and sub advisor clients are contacted. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients do not receive subsequent reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, , unless we also provide investment advisory services to that client, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post-financial plan meeting or update to their initial written financial plan. Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. Item 14: Client Referrals & Other Compensation Schwab Our firm receives economic benefit from Schwab in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Product Sponsors Our firm occasionally sponsors events in conjunction with our product providers in an effort to keep our clients informed as to the services we offer and the various financial products we utilize. These events are educational in nature and are not dependent upon the use of any specific product. While a conflict of interest may exist because these events are at least partially funded by product sponsors, all funds received from product sponsors are used for the education of our clients. We will always adhere to our fiduciary duty in recommending appropriate investments for our clients. ADV Part 2A – Firm Brochure Page 23 Bare Wealth Advisors  Representatives of our firm will occasionally accept travel expense reimbursement provided by product sponsors in order to attend their educational events. The reimbursement is not directly dependent upon the recommendation of any specific product. Although we may be incentivized to recommend products from product sponsors that reimburse our travel, our representatives will always adhere to their fiduciary duty in recommending appropriate investments for our clients. Client Referrals In accordance with Rule 206 (4)-1 of the Investment Advisors Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Item 15: Custody Deduction of Advisory Fees: While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further described below under “Third Party Money Movement.” All of our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Third Party Money Movement: On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐ 2 (“Custody Rule”) under the Investment Advisors Act of 1940 (“Advisors Act”). The letter provided guidance on the Custody Rule as well as clarified that an advisor who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian:  The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed.  The client authorizes the investment advisor, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. ADV Part 2A – Firm Brochure Page 24 Bare Wealth Advisors   The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer.  The client has the ability to terminate or change the instruction to the client’s qualified custodian.  The investment advisor has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction.  The investment advisor maintains records showing that the third party is not a related party of the investment advisor or located at the same address as the investment advisor.  The client’s qualified custodian sends the client, in writing, an initial notice confirming instruction. the instruction and an annual notice reconfirming the Item 16: Investment Discretion Our firm typically manages accounts on a discretionary basis but upon a client’s request, our firm would agree to manage accounts on a non-discretionary basis, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities , make recommendations regarding class action lawsuits relating to such securities, or otherwise seek to influence the behavior of company management. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Sub-advisors selected or recommended by our firm may vote proxies for clients, advise as to class actions, or engage with company management in order to influence company behavior in the event the client authorizes us to delegate this authority to the sub-advisor. Therefore, except in the event a sub-advisor votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by a sub-advisor), our firm ADV Part 2A – Firm Brochure Page 25 Bare Wealth Advisors  and/or the client shall instruct the qualified custodian to forward copies of all proxies and shareholder communications relating to the client’s investment assets. Item 18: Financial Information Our firm is not required to provide financial information in this Brochure because:  Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months.  Our firm does not take custody of client funds or securities.  Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 26 Bare Wealth Advisors