Baseline Wealth Management Ltd.

Form ADV Part 2A: Firm Brochure March 31, 2026 BASELINE WEALTH MANAGEMENT LTD RUE DU RHÔNE 67, 1207 GENEVA TEL: +41 58 105 76 20 WWW.BASELINEWEALTH.COM LINDENSTRASSE 22, 8008 ZURICH TEL: +41 58 105 76 20 WWW.BASELINEWEALTH.COM I. Cover Page This brochure provides information about the qualifications and business practices of Baseline Wealth Management Ltd / AG / SA. (“Baseline” or “the firm”). If you have any questions about the contents of this brochure, please contact us by telephone at + 41 58 105 76 20 or by e-mail at info@baselinewealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Baseline is also available on the SEC’s website at www.adviserinfo.sec.gov. Baseline is a Registered Investment Advisor (“RIA”) with the SEC and is licensed by the Swiss Financial Market Supervisory Authority (“FINMA”) as a Portfolio Manager and further authorized to manage collective assets from occupational pension schemes in accordance with the de minimis rule of the Financial Institutions Act ("FinIA"). References to Baseline Wealth Management Ltd. As a “registered investment advisor” or any reference to being “registered” does not imply a certain level of skill or trailing. II. Material Changes We have made material changes to our Disclosure Brochure since the last Annual filing. The following are only material changes to our Disclosure Brochure since our 2025 Annual Amendment filing dated March 31, 2025. Item IV. - Advisory Business Starting January 8th 2026 Baseline is 100% owned by CPI Holdco B, LLC, Overland Park, Kansas (USA). This brochure has been updated to reflect those Items which are related to this new change of ownership, particularly in the following areas: - - Item IX – Disciplinary Information Item X – Other Financial Industry Activities and Affiliations There are no other material changes since the last filing of this brochure which took place in March 2025. You may request a new brochure at any time without charge by sending an e-mail to info@baselinewealth.com or by calling Baseline at +41 58 105 76 20. 1  Form ADV Part 2A: Firm Brochure March 31, 2026 III. Table of Contents I. II. III. IV. V. VI. IX. X. XI. XII. Cover Page ...................................................................................................................... 1 Material Changes ............................................................................................................ 1 Table of Contents ............................................................................................................ 2 Advisory Business ............................................................................................................ 4 Department of Labor Acknowledgement of Fiduciary Duty ................................................. 5 Fees and Compensation .................................................................................................. 5 Negotiability of Fees ................................................................................................................. 6 Billing Process ............................................................................................................................ 6 Deduction of Fees ..................................................................................................................... 6 Performance Based Fees and Side by Side Management ................................................. 6 Performance Based Fee Scheme .............................................................................................. 6 Side-by-Side Management ....................................................................................................... 7 VII. Types of Clients ............................................................................................................... 7 VIII. Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 7 Methods of Analysis and Research .......................................................................................... 7 Investment Strategies ............................................................................................................... 7 Risk of Loss ................................................................................................................................ 8 Types of Securities .................................................................................................................... 9 Unregistered and Unregulated Investments ........................................................................... 9 Structured Products and Derivatives ....................................................................................... 9 Disciplinary Information ................................................................................................. 10 Other Financial Industry Activities and Affiliations ......................................................... 10 Creative Planning, LLC............................................................................................................ 10 Business Advisory Services – Creative Planning Business Advisory LLC.............................. 10 Business Valuation Services – Creative Planning Business Valuations LLC ........................ 11 Legal Activities – Creative Planning Legal, P.A. .................................................................... 11 Trust Services – Creative Planning Trust Company, LLC ..................................................... 11 Accounting & Tax Services – Creative Planning Tax LLC and CP Strategic Advisors, LLC 11 Affiliated Non-Investment Advisory Retirement Plan Recordkeeping and Third-Party Administration Companies .................................................................................................... 12 Insurance Activities – Creative Planning Insurance, LLC, United Capital Risk Management, LLC,New SIS, LLC (SageView Insurance Services) and SageView Global Pensions, LLC. ......................................................................................................................... 12 Technology Services – Creative Planning Technology, LLC ................................................. 12 Creative Planning Lending, LLC ............................................................................................. 12 Creative Planning Business Accounting Services, LLC ......................................................... 13 BerganKDV, Ltd. and BerganKDV, LLC ................................................................................. 13 Creative Planning Payroll, LLC ............................................................................................... 13 Creative Planning Business Alliance, LLC .............................................................................. 13 United Capital Financial Advisors, LLC .................................................................................. 14 SageView Advisory Group, LLC ............................................................................................. 14 Code of Ethics, Participant or Interest in Client Transaction and Personal Trading ........ 15 Code of Ethics ......................................................................................................................... 15 Participation or Interest in Client Transactions ..................................................................... 15 Recommendations to Proprietary Strategies ........................................................................ 15 Brokerage Practices ....................................................................................................... 16 Use of Soft Dollars .................................................................................................................. 16 2  Form ADV Part 2A: Firm Brochure March 31, 2026 XIII. Review of Accounts ....................................................................................................... 17 XIV. Client Referrals and Other Compensation ..................................................................... 17 Custody ......................................................................................................................... 18 XV. Investment Discretion .................................................................................................... 18 XVI. XVII. Voting Client Securities ................................................................................................. 18 XVIII. Financial Information ..................................................................................................... 18 3  Form ADV Part 2A: Firm Brochure March 31, 2026 IV. Advisory Business Baseline Wealth Management, Ltd. (“Baseline,” “we, “us”, “our”, or the “Firm”) commenced investment advisory operations in January 2011. As permitted by the SEC, Baseline complies with the substantive provisions of the Advisers Act only with respect to its U.S. Clients. Baseline is majority-owned and controlled by Peter Mallouk through the Peter Mallouk Trust and the MJG Irrevocable Trust through subsidiaries. TPG IX Cardiff Debit Holdco I, LLC, is a minority owner of Baseline. Baseline’s principal business consists of providing investment management services to international high net worth clientele. This activity includes continuous advice and supervision concerning investment in assets consistent with the circumstances, preferences and objectives of each client. The investment management process includes an assessment of each client’s investment objectives and needs in terms of expected returns, risk tolerance, future liquidity requirements and potential tax and legal restrictions. Baseline provides services on both a discretionary basis and a non-discretionary basis. Discretionary Management Non-discretionary Management Baseline makes investment recommendations to a non-discretionary client, and the client makes all investment decisions about the investments held in the account. In order to implement the client’s decisions, the client may authorize Baseline to route orders for the execution of securities transactions in the client’s account. In such cases, Baseline does not select the broker or dealer used for effectuating such securities transactions and does not negotiate the commission rates paid. Baseline will route orders with the custodian bank or broker directed by the client. Baseline has the authority to manage and direct the investments for each discretionary client’s account without prior consultation with the client. Baseline determines which securities are bought and sold for the account and the total amount of the purchases and sales. Baseline’s authority may be subject to conditions imposed by individual clients. For example, a client may restrict or prohibit transactions in certain types of securities. Baseline does not select the broker or dealer for effectuating securities transactions and does not negotiate the commission rates paid to effectuate transactions. Baseline works with the broker determined by the custodian bank selected by the client, which may or may not be a broker registered with the SEC. The Firm provides investment advice on diversified portfolios, including currencies, equities (stocks), fixed income securities (bonds), mutual funds, exchange-traded funds (ETFs), and precious metals, as well as, to a limited extent, alternative investments such as structured products and impact investment vehicles. We do not limit our advice to these investment types and do not specialize exclusively in any particular type of advisory service. Our investment strategy is based on a long-term, diversified asset allocation approach, tailored to each client’s investment objectives, risk tolerance, and time horizon. We may adjust our investment strategy based on client-specific circumstances, including tax considerations, regulatory or country-of-residence restrictions, liquidity needs, time horizon, reference currency, and individual client preferences or constraints. Clients may also impose restrictions on investing in certain securities or types of securities, which we will incorporate into our advisory services to the extent reasonably practicable. As of February 27, 2026, Baseline manages approximately a total of USD 1,083,389,424. Within this amount approximately USD 658,893,510 is managed on a discretionary basis and approximately USD 424,495,914 on a non-discretionary basis. Investment advice is not provided on any other basis than those described above. 4  Form ADV Part 2A: Firm Brochure March 31, 2026 Department of Labor Acknowledgement of Fiduciary Duty When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. How 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 interests ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. V. Fees and Compensation Baseline charges investment advisory fees for its services consisting of a percentage of the market value of assets under management and any margin balance and accrued interest. We charge a minimum quarterly fee USD 1’000. The annual fee is charged quarterly in arrears and is calculated using the average assets under management computed on (i) the last business day of each of the first two months within the respective calendar quarter, and (ii) the 15th day (or the following business day if the 15th of the month is a holiday or falls on a weekend) of the last month of each respective quarter. The percentage will be prorated for any period less than a quarter. For new clients, the fee accrual begins on the date the initial funding is received and investable in the Account. For terminating clients, the fee accrual ceases on the earlier of the date the custodial account is closed or the date the Limited Power of Attorney ("LPOA") is revoked. In both cases, the fee is calculated by multiplying the applicable quarterly fee by a fraction, the numerator of which is the number of calendar days the agreement was in effect during the relevant quarter, and the denominator of which is the total number of calendar days in that quarter. The fee is calculated and charged in the reference currency of each account unless otherwise agreed to with the client. Fees are based on portfolio valuations generated and calculated by Baseline's portfolio management system and if applicable Swiss VAT will be added. The following is our standard fee: Annual Asset Management Fee Assets Under Management 1.20% p.a. 1.00% p.a. 0.85% p.a. 0.80% p.a. 0.70% p.a. 0.40% p.a. 0.30% p.a. 0.25% p.a. On the first USD 500,000, then On assets of USD 500’001 – USD 2’000’000, then On assets of USD 2’000’001 – USD 5’000’000, then On assets of USD 5,000,001 – USD 10,000,000, then On assets of USD 10,000,001 – USD 25,000,000 then On assets of USD 25,000,001 – USD 50,000,000 then On assets of USD 50,000,001 – USD 100,000,000 then On assets over USD 100,000,000 Baseline does not require clients to pre-pay advisory fees. 5  Form ADV Part 2A: Firm Brochure March 31, 2026 Negotiability of Fees To ensure equal treatment of all clients, Baseline generally does not negotiate fees, though the right to negotiate fees is reserved by Baseline. Billing Process Unless expressly excluded, we calculate our management fee against all assets in the investment account. Therefore, fee calculations include cash balances invested in money market funds, short-term investment funds, ETFs, mutual funds, the entire market value of margined assets and short positions (if any), private fund investments (if any), and all other investment holdings. Your advisory fee may sometimes exceed the money market yield, specifically during low-yield environments. The account values used to calculate your management fee are obtained from pricing services that we believe are reliable. However, we cannot guarantee their accuracy or that securities may be bought or sold at those prices. We rely on the most recent holding information made available through our aggregation software in relation to reporting, trading, and billing calculations. This may include pricing data gathered from third-party sources other than the custodian of your account(s). Valuation of a fund’s private fund investments may be complex, as there generally is no established market for these assets or for securities of privately held companies that the fund may own directly or indirectly. We calculate your management fee using the fund’s value available at the time of calculation. Private funds often update their value on a trailing basis after the time of calculation therefore the private fund value used to calculate your management fees may be higher or lower than the postdated private funds valuation published by the fund. Therefore, there may be differences in the values we use for reporting, trading, and billing calculations. Any security (or securities) excluded from billing will not be included in assets under management to determine our investment management fee. Deduction of Fees Unless otherwise agreed, Baseline will instruct the custodian bank to debit the account and credit the asset management with the advisory fee for the preceding period. Clients must provide the custodian bank written authorization to allow fees to be deducted from the account and paid to us. Client account statements will be sent at least quarterly showing account transactions including the advisory fee if deducted directly from the account. The fees charged by Baseline do not include custodian fees (which include any margin charged by the custodian for exchanging foreign currencies or physical gold), fees for trade settlement, brokerage commissions, or any other fee imposed by the custodian bank or the broker. It also does not include other costs and expenses such as the Swiss stamp duty that may be charged by the bank in relation to the Account. VI. Performance Based Fees and Side by Side Management Performance Based Fee Scheme On an exceptional basis, Baseline may accept performance-based fees – that is fees based on a share of capital gains on, or capital appreciation of, the assets under management in a client’s account. Performance-based fee arrangements may apply in the context of certain investment mandates, including but not limited to private equity investments and other specialized equity mandates, where such fee structures are consistent with the client's investment objectives and agreed upon in writing. Prior to charging any performance based fee to clients, Baseline will take the following actions: (i) clearly disclose the performance fee to such clients; (ii) ensure that clients understand and agree to the inherent conflict of interest which is a part of such performance based fees (including that Baseline may be incentivized to unduly speculate or take unnecessary risks on the client’s investments in hopes of generating a greater performance based fee); and (iii) ensure that each client who agrees to be charged a performance 6  Form ADV Part 2A: Firm Brochure March 31, 2026 based fee meets the definition of a “qualified client” as defined under Rule 205-3 of the Investment Advisers Act of 1940 (the “Advisers Act”). Finally, to mitigate any conflicts of interest associated with the performance-based fee, Baseline will only enter into a performance fee agreement upon the request of a client or in the case of specific investment objectives such as impact investments as described above. Side-by-Side Management Baseline manages many client accounts and as a result of differences in the fees charged on various accounts, Baseline has conflicts related to such side-by-side management of different accounts. For example, Baseline generally manages more than one account according to the same or a substantially similar investment strategy and yet have a different fee schedule applicable to such accounts as a result of the respective clients’ AUM with Baseline or a client’s election to compensate Baseline on a performance basis. Side-by-side management of different types of accounts may raise conflicts of interest when two or more accounts invest in the same securities or pursue a similar although not identical strategy. These potential conflicts include the favourable or preferential treatment of an account or a group of accounts, conflicts related to the allocation of investment opportunities, particularly with respect to securities that have limited availability, such as an initial public offering, and transactions in one account that closely follow related transactions in a different account. In addition, the results of the investment activities for one account may differ significantly from the results achieved for other accounts, particularly if Baseline individually tailors clients’ accounts. Baseline has policies and procedures in place aimed to ensure that all client accounts are treated fairly and equitably. Baseline strives to equitably allocate investment opportunities among relevant accounts over time. In addition, investment decisions for each Account are made with specific reference to the individual needs and objectives of the Account. Accordingly, Baseline may give advice or exercise investment responsibility or take other actions for some clients (including related persons) that may differ from the advice given, or the timing and nature of actions taken, for other clients. Investment results for different Accounts, including Accounts that are generally managed in a similar style, also may differ as a result of these considerations. Some clients may not participate at all in some investments in which other clients participate or may participate to a different degree or at a different time. VII. Types of Clients Baseline offers investment supervisory services to individuals, companies, trusts, estates, etc. entities. Generally, Baseline prefers clients to have a minimum of CHF 1,000,000 of assets under management. Baseline retains the right to accept accounts below the minimum requirement, or to retain accounts that have dropped below the minimum requirement due to market fluctuation or investment activity. Accounts that have a family, corporate or other relationship may aggregate accounts for purposes of establishing the minimum account size. VIII. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Research Baseline uses a disciplined investment process supported by fundamental research for its proprietary strategies. Baseline employs disciplined, research based, security selection process utilizing fundamental internal research with a macroeconomic overlay and supplemented by trusted third-party research providers. Investment Strategies Baseline offers its clients discretionary and non-discretionary mandates. 7  Form ADV Part 2A: Firm Brochure March 31, 2026 Baseline’s discretionary management services are provided through various proprietary investment objectives. Under the discretionary mandate, Baseline is authorized to manage the assets on a fully discretionary basis, according to the client’s investment needs, objectives and restrictions. After discussion and analysis with each client, an investment objective is selected by the client from one of the following six strategies: (i) Fixed Income; (ii) Conservative; (iii) Balanced; (iv) Growth; (v) Equity; and (vi) Tailormade. Each of these six discretionary strategies are described in greater detail, including the asset allocations which make up each strategy, in Baseline’s discretionary mandate. All mandates can have a certain allocation towards precious metals to seek diversification and stability. From time to time, derivatives instruments are used in a limited way to hedge a security/currency risk or to enhance yield. Baseline has a dedicated Investment Committee that meets regularly to: (i) determine asset allocations within each discretionary strategy; (ii) review the security and commodity markets on a regional and global basis; and (iii) evaluate the views of other third-party market professionals on various asset classes and current market outlooks. Baseline has a dedicated portfolio management team that receives the final asset allocations from the Investment Committee and, thereafter, conducts market research and decides upon individual security and commodity positions on a regular basis for its clients in order to be in line with the asset allocations previously determined by the Investment Committee. Although Baseline makes every reasonable effort to keep the allocation of the client’s assets in line with the client’s selected investment strategy, investments made on behalf of a specific client may deviate from the general investment strategy of the portfolio investment objectives chosen for the client where (i) there are unforeseen or drastic and rapid movements in the markets, or (ii) when Baseline decides it is in the best interest of the client to do so. Baseline’s non-discretionary mandates offer clients advice and recommendations on a trade-by-trade basis as requested by the client. Although Baseline offers its advice and recommendations to the clients, the client alone makes the final investment decision. Baseline’s non-discretionary advice extends to equity and debt securities, precious metals, ETFs, mutual funds, commodities, derivatives, private equity investments and other alternative investment vehicles. Risk of Loss Investing in financial instruments involves a risk of loss that clients should be prepared to bear. Risks related to investing in securities, commodities and other financial instruments include: (i) Market Risk, which means prices of securities can go up or down, sometimes rapidly or unpredictably, and can lead clients to lose up to their whole investment; (ii) Liquidity risk, which means some securities may become impossible to trade making it impossible to sell the investment for an acceptable price; (iii) Counterparty Risk , which means that the issuer fixed income security may default on its obligation to pay interest or principal which could lead the investor to realize a complete loss on the investment; (iv) Emerging Markets Risk, which means that foreign securities may involve the risk of loss due to political, economic and currency fluctuations. Investing in emerging markets is generally intended only for clients who are able to bear and assume the increased risk that they represent; and (v) Currency Risk which is a risk that comes from the change in price of one currency against another. Currency risks may not be always hedged and can result in significant losses to a client’s portfolio. Baseline make every effort to reduce the above risks as much as reasonably possible by proactively evaluating the global markets, economic conditions, regulatory environment, and industry concerns, along with analyzing changes to interest and currency rates, as well as adverse investor sentiment in general. Nevertheless, clients and prospects are advised to consider the above risks prior to investing in financial instruments. 8  Form ADV Part 2A: Firm Brochure March 31, 2026 Types of Securities Baseline provides investment supervisory services related to the following types of securities and transactions: exchange-listed, over the counter, foreign issuers, corporate debt securities, municipal securities, mutual fund shares, United States government securities, futures contracts on intangibles, commodities and foreign exchange transactions. Unregistered and Unregulated Investments For appropriate client portfolios, the services offered by Baseline include the evaluation, selection and monitoring of investments, including investments in private investment funds that are not registered with or regulated by the SEC. Structured Products and Derivatives In certain cases, Baseline may buy structured products or derivatives in the context of its discretionary management services mandate. In addition to the risks that apply to all investments in financial instruments, investing in structured products and derivative instruments may involve different types and levels of risks. These risks include, but are not limited to the following: • Possible Leverage. A derivative instrument or transaction may have the effect of disproportionately increasing an account’s exposure to the market for the securities or other assets underlying the derivative position and the sensitivity of an account’s portfolio to changes in market prices for those assets. Leverage will tend to magnify both the positive impact of successful investment decisions and the negative impact of unsuccessful investment decisions by Baseline on an account’s performance. • Counterparty Credit Risk. An account’s ability to profit from a derivative contract depends on the ability and willingness of the other party to the contract (a “counterparty”) to perform its obligations under the contract. Although exchange-traded futures and options contracts are generally backed by a guarantee from a clearing corporation, an account could lose the benefit of a contract in the unlikely event that the clearing corporation becomes insolvent. A counterparty’s obligations under a forward contract, over-the-counter option, swap or other over-the-counter derivative contract are not so guaranteed. If the counterparty to an over-the-counter contract fails to perform its obligations, an account may lose the benefit of the contract and may have difficulty reclaiming any collateral that an account may have deposited with the counterparty. • Lack of Correlation. The market value of a derivative position may correlate imperfectly with the market price of the asset underlying the derivative position. To the extent that a derivative position is being used to hedge against changes in the value of assets in an account, a lack of price correlation between the derivative position and the hedged asset may result in an account’s assets being in completely hedged or not completely offsetting price changes in the derivative position. • Illiquidity. Over-the-counter derivative contracts are usually subject to restrictions on transfer, and there is generally no liquid market for these contracts. Although it is often possible to negotiate the termination of an over-the-counter contract or enter into an offsetting contract, a counterparty may be unable or unwilling to terminate a contract with an account, especially during times of market instability or disruption. The markets for many exchange traded futures, options and other instruments are quite liquid during normal market conditions, but this liquidity may disappear during times of market instability or disruption. • Less Accurate Valuation. The absence of a liquid market for over-the-counter derivatives increases the likelihood that Baseline will not be able to correctly value these interests. Baseline will rely on the accuracy of a client’s representations in making corresponding representations on behalf of the client’s account in connection with certain derivative and other transactions. Baseline also requires notification by the client if the client’s representations become inaccurate. 9  Form ADV Part 2A: Firm Brochure March 31, 2026 IX. Disciplinary Information On September 18, 2018, the SEC instituted a settled order against Peter A. Mallouk, our major owner. Mr. Mallouk failed to report certain securities accounts in which he had a beneficial interest. Mr. Mallouk consented to a cease-and-desist order and a civil penalty of $50,000. X. Other Financial Industry Activities and Affiliations Baseline management personnel are neither registered, nor have an application pending to register as, broker-dealers, registered representatives of a broker-dealer, future commissions merchants, commodity pool operators, commodity trading advisors, or associated persons of the foregoing entities. Baseline relies on the International Adviser Exemption in section 8.26 of Regulation 31-103 since August 21st, 2020, in Québec and since Mai 2nd, 2022, in Ontario. Baseline provides the investment advisory services provided throughout this Brochure to both U.S. and non- U.S. clients. Baseline works with specific banks, each of which have been selected by Baseline’s clientele to serve as the client’s custodian, that are responsible for best execution and have accepted reduced fees for Baseline clients. Baseline may recommend clients to affiliates. Clients that choose to engage in affiliated services will sign a separate agreement with such service provider outlining the fees/rates that they will be responsible for, which will be in addition to the management fees paid to Baseline. Creative Planning, LLC Baseline is affiliated with Creative Planning, LLC (Creative). Creative is registered as an investment advisor with the SEC and provides financial planning, investment management, and related advisory services. Creative is headquartered in Overland Park, KS and has a investment advisor representative that is a dually registered investment adviser representative with Baseline. The services provided by Creative are similar, but in some instances differ from those provided by Baseline. Specific services provided by Creative include but are not limited to (1) financial planning, (2) investment management (3) referrals to affiliates and other third parties. Please refer to Creative Planning, LLC Form ADV 2A Brochure for more information regarding their services. We have a conflict of interest when recommending the services of Creative. Clients are never obligated to use the services of Baseline or Creative and are free to select any broker-dealer or investment advisor of their choice. If engaged, clients pay fees and expenses to Creative separate from and in addition to the fees charged by Baseline. Because both are related entities, it presents a conflict of interest as both firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. Business Advisory Services – Creative Planning Business Advisory LLC Baseline is under common ownership with Creative Planning Business Advisory, LLC (CPBA). Clients of Baseline may be referred to CPBA for advice and assistance in marketing and/or selling their privately held business. CPBA does not arrange financing or securities issuance to facilitate business transactions. Because Baseline and CPBA are related entities, it presents a conflict of interest. Both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends the services of CPBA to you, you are not obligated or required to use them. Other firms provide services like those offered by CPBA and may provide such services for less expensive rates. Whenever CPBA is recommended to you, you are encouraged to consider other firms too. The services of Baseline and CPBA are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. 10  Form ADV Part 2A: Firm Brochure March 31, 2026 Business Valuation Services – Creative Planning Business Valuations LLC Baseline is under common ownership with Creative Planning Business Valuation, LLC (CPBV). Clients of Baseline may be referred to CPBV for advice and assistance in preparing business valuations for established, closely held companies. Because Baseline and CPBV are related entities, it presents a conflict of interest. Both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends services of CPBV to you, you are not obligated or required to use them. There are other firms that provide services similar to those offered by CPBV and may provide such services for less expensive rates. Whenever CPBV is recommended to you, you are encouraged to consider other firms too. The services of Baseline and CPBV are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. Legal Activities – Creative Planning Legal, P.A. Baseline is under common ownership with a law firm, Creative Planning Legal, P.A. Clients of Baseline may be referred to Creative Planning Legal, P.A. for U.S. estate planning and other legal services. Because Creative Planning and Creative Planning Legal, P.A. are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends services of Creative Planning Legal, P.A. to you, you are never obligated or required to use them. Other law firms provide legal services similar to those offered by Creative Planning Legal, P.A. and may provide such services for a lower rate. Whenever Creative Planning Legal, P.A. is recommended to you, you are encouraged to consider other law firms too. The services of Baseline and Creative Planning Legal, P.A. are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. Trust Services – Creative Planning Trust Company, LLC Baseline is affiliated with Creative Planning Trust Company, LLC (CPTC). CPTC is domiciled in Nevada and is a non-depository retail trust company regulated by the Nevada Financial Institutions Division. CPTC was created to provide U.S. trust administrative services for clients who have financial, family, or business needs that require the services of a professional fiduciary and trust company. Because Baseline and CPTC are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. Specific services provided by CPTC include but are not limited to (1) corporate trustee services for personal trusts or certain retirement plan accounts, (2) corporate trustee for life insurance trusts, and (3) corporate trustee services for charitable trust accounts. These services entail the safekeeping of trust assets. CPTC also performs trust administration duties outlined in each trust document, such as distributions and principal and income trust accounting. Generally, no assets are held in the name of the trust company; all assets will be held via segregated trust accounts at qualified third-party custodians, identifying the trust company as trustee. If Baseline recommends services of CPTC to you, you are never obligated or required to use them. Clients are never obligated to use the services of CPTC and can establish their trust account at any custodian or trustee of their own choosing. Clients pay fees and expenses to the trust company, separate from and in addition to the fees charged by Creative Planning. Accounting & Tax Services – Creative Planning Tax LLC and CP Strategic Advisors, LLC Baseline is under common ownership with Creative Planning Tax, LLC and CP Strategic Advisors, LLC. Clients needing assistance with U.S. tax preparation and/or accounting services may be referred to either of these entities. Our affiliation with these entities presents a conflict of interest as each of the Firms has an economic incentive to refer clients to each other instead of referring clients to other like firms. Clients are not obligated to use the services of either entity for their U.S. tax or accounting needs. However, if a client chooses to engage either of these entities, they may pay fees and expenses for their services, separate from and in addition to the fees charged by Baseline. 11  Form ADV Part 2A: Firm Brochure March 31, 2026 Affiliated Non-Investment Advisory Retirement Plan Recordkeeping and Third-Party Administration Companies Baseline is under common ownership with Creative Planning TPA, LLC (CPTPA), which provides plan recordkeeping and/or third-party administration services to U.S. retirement plans. While our affiliate Creative Planning does not require plans to hire CPTPA, certain Retirement Plan Services offered by Creative Planning may be limited or unavailable on unaffiliated retirement plan recordkeeping platforms. For example, the managed asset allocation portfolio services are available when the plan sponsor hires CPTPA but may not be available on many other recordkeeping platforms due to capabilities and limitations associated with the recordkeeper’s services. Because Baseline, Creative Planning and CPTPA are related entities, it presents a conflict of interest as the Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. Insurance Activities – Creative Planning Insurance, LLC, United Capital Risk Management, LLC,New SIS, LLC (SageView Insurance Services) and SageView Global Pensions, LLC. Creative Planning Insurance provides the following services: Individual life, disability, and long-term care coverage through various insurance companies. Property and casualty coverage. • • • Medicare consultation, portfolio review, and coverage enrollment. United Capital Risk Management, SageView Insurance Services and SageView Global Pensions, LLC provide the following services: Life insurance Long-term care • • Annuities • Baseline affiliation with these entities presents a conflict of interest as each of the Firms has an economic incentive to refer clients to each other instead of referring clients to other like firms. Clients are never obligated or required to purchase insurance products from one of our affiliated insurance companies. They may choose an independent insurance agent and insurance company to buy insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale. As noted previously, the owner of Baseline has acquired other advisory firms. IARs of those firms may be licensed independent insurance agents for various companies not affiliated with those firms or Baseline. These IARs may still receive some trail commissions from insurance product sales before the acquisition. Technology Services – Creative Planning Technology, LLC Creative Planning Technology, LLC provides outsourced IT services, cloud management, etc., for small businesses that do not have internal IT departments. Clients of Baseline may be referred to Creative Planning Technology for this service. Because Baseline and Creative Planning Technology are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends the services of Creative Planning Technology to you, you are not obligated or required to use them. There are other firms that provide services like those offered by Creative Planning Technology and may provide such services for less expensive rates. You are encouraged to consider other firms whenever Creative Planning Technology is recommended to you. The services of Baseline and Creative Planning Technology are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. Creative Planning Lending, LLC Baseline is under common ownership with Creative Planning Lending, LLC. Baseline refers clients with residential and non-residential lending needs to Creative Planning Lending, which has formed partnerships for lending requests. Baseline receives no direct or indirect compensation when we make residential lending referrals. Creative Planning Lending receives a fee for non-residential lending referrals that result in the closing of a loan. The services of Creative Planning Lending and the partnered lenders are separate and 12  Form ADV Part 2A: Firm Brochure March 31, 2026 distinct from one another, each with a separate compensation arrangement typical for the services rendered. Because Baseline and Creative Planning Lending are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. Clients are not obligated or required to use Creative Planning Lending or any of its services and can choose to work with a different financial professional. Creative Planning Business Accounting Services, LLC Baseline is under common ownership with Creative Planning Business Accounting Services, LLC. Creative Planning Business Accounting Services provides accounting services to businesses. Clients of Baseline may be referred to Creative Planning Business Accounting Services. Because both are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends the services of Creative Planning Business Accounting Services to you, you are not obligated or required to use them. There are other firms that provide services like those offered by Creative Planning Business Accounting Services and may provide such services for less expensive rates. You are encouraged to consider other firms whenever Creative Planning Business Accounting Services is recommended to you. The services of Baseline and Creative Planning Business Accounting Services are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. BerganKDV, Ltd. and BerganKDV, LLC Baseline’s affiliated company Creative Planning works closely with BerganKDV, Ltd. and BerganKDV, LLC (jointly BerganKDV). BerganKDV leases professional staff from Creative Planning pursuant to a services agreement to provide audit and attest services to their clients. BerganKDV is an independent and separately governed and licensed CPA firm. If Baseline recommends the services of BerganKDV to you, you are not obligated or required to use them. There are other firms that provide services like those offered by BerganKDV and may provide such services for less expensive rates. You are encouraged to consider other firms whenever BerganKDV is provided to you. The services of Baseline and BerganKDV are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. Creative Planning Payroll, LLC Creative Planning Payroll, LLC provides human capital management solutions to businesses that can help manage most aspects of a business’ workforce which include recruitment, hiring, performance management and payroll processes. Clients of Baseline may be referred to Creative Planning Payroll. Because both are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends the services of Creative Planning Payroll to you, you are not obligated or required to use them. There are other firms that provide services like those offered by Creative Planning Payroll and may provide such services for less expensive rates. You are encouraged to consider other firms whenever Creative Planning Payroll is recommended to you. The services of Baseline and Creative Planning Payroll are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. Creative Planning Business Alliance, LLC Creative Planning Business Alliance, LLC provides a broad variety of services to business for challenges that fall outside of their core capabilities or expertise. These services include turnaround services, investment banking, succession planning, business valuations, mergers and acquisitions, litigation support and internal controls and operations. Clients of Baseline may be referred to Creative Planning Business Alliance. Because both are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends you the services of Creative Planning Business Alliance, you are not obligated or required to use them. There are other firms that provide services like those offered by Creative Planning Business Alliance and may provide such services for less expensive rates. You are encouraged to consider 13  Form ADV Part 2A: Firm Brochure March 31, 2026 other firms whenever we recommend Creative Planning Business Alliance. The services of Baseline and Creative Planning Business Alliance are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. United Capital Financial Advisors, LLC Baseline is affiliated with United Capital Financial Advisors (UCFA). UCFA is registered as an investment advisor with the SEC and provides financial planning, investment management, and related advisory services. UCFA is headquartered in Irving, TX and UCFA has investment advisor representatives that are dually registered representatives with Integrity Alliance, LLC an unaffiliated broker-dealer registered with the SEC and a member of the Financial Industry Regulatory Authority (FINRA). The services provided by UCFA are similar but in some instances differ from those provided by Baseline. Specific services provided by UCFA include but are not limited to (1) financial planning, (2) investment management (3) private fund investments, (4) fixed and variable insurance and annuities, (5) securities- based loans and margin, (6) brokerage activity through Integrity, (7) referrals to affiliates and other third parties. Please refer to United Capital Financial Advisors Form ADV 2A Brochure for more information regarding their services. There is a conflict of interest when Baseline recommends services of UCFA. Clients are never obligated to use the services of UCFA and are free to select any broker-dealer or investment advisor of their choice. If engaged, clients pay fees and expenses to UCFA separate from and in addition to the fees charged by Baseline. Because both are related entities, it presents a conflict of interest as both firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. SageView Advisory Group, LLC Baseline is affiliated with SageView Advisory Group (SageView). SageView is registered as an investment advisor with the SEC and provides investment management, and related advisory services. SageView is headquartered in Newport Beach, CA and SageView has investment advisor representatives that are dually registered investment adviser representatives with Creative Planning. The services provided by SageView are similar but in some instances differ from those provided by Baseline. Specific services provided by SageView include but are not limited to (1) retirement plan consulting, (2) investment management (3) integrity pooled solutions, (4) plan participant services, (7) referrals to affiliates and other third parties. Please refer to SageView Advisory Group Form ADV 2A Brochure for more information regarding their services. There is a conflict of interest when Baseline recommends the services of SageView. Clients are never obligated to use the services of SageView and are free to select any broker-dealer or investment advisor of their choice. If engaged, clients pay fees and expenses to SageView separate from and in addition to the fees charged by Baseline. Because both are related entities, it presents a conflict of interest as both firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. Pension Consulting – SageView Retirement Plan Consultants, LLC SageView Retirement Plan Consultants, LLC (SVRPC) provides third-party administrator (TPA) services related to payroll and benefits. Clients of Baseline may be referred to SVRPC for this service. Because Baseline and SVRPC are related entities, it presents a conflict of interest as both Firms have an economic incentive to refer clients to each other instead of referring clients to other like firms. If Baseline recommends you use the services of SVRPC, you are not obligated or required to use them. There are other firms that provide services like those offered by SVRPC and may provide such services for less expensive rates. You are encouraged to consider other firms whenever we recommend SVRPC. The services of Baseline and SVRPC are separate and distinct from one another, each with a separate compensation arrangement typical for the services rendered. 14  Form ADV Part 2A: Firm Brochure March 31, 2026 XI. Code of Ethics, Participant or Interest in Client Transaction and Personal Trading Baseline believes that its fee-based advisory business model significantly reduces its potential for conflicts of interest between Baseline and its clients. Baseline seeks to minimize such conflicts of interest and resolve those conflicts of interests in favor of the client to the extent it determines reasonable and necessary in accordance with its Code of Ethics. Code of Ethics Baseline has adopted a Code of Ethics (the “Code”) governing personal securities transactions by Baseline and its personnel. The Code also provides guidance and instruction to Baseline and its personnel on their ethical obligations in fulfilling its duties of loyalty, fairness and good faith towards the clients. The overriding principle of Baseline’s Code of Ethics is that all employees of Baseline owe a fiduciary duty to clients for whom Baseline acts as investment adviser.. Accordingly, employees of Baseline are responsible for conducting personal trading activities in a manner that does not interfere with a client’s portfolio transactions or take improper advantage of a relationship with any client. The Code contains provisions designed to try to: (i) prevent, among other things, improper trading by Baseline’s employees; (ii) identify conflicts of interest; and (iii) provide a means to resolve any actual or potential conflicts of interest in favor of the clients. The Code attempts to accomplish these objectives by, among other things, (i) implementing blackout periods where employees are prohibited from trading in certain securities; (ii) restricting trading in certain securities that may cause a conflict of interest, as well as (iii) periodic reporting regarding transactions and holdings of employees. The Code contains sections including, but not limited to, the following key areas: (i) restrictions on personal investing activities; (ii) gifts and business entertainment; and (iii) outside business activities. The fundamental position of Baseline is that, in effecting personal securities transactions, personnel of Baseline must place at all times the interests of clients ahead of their own pecuniary interests. All personal securities transactions by these persons must be conducted in accordance with the Code of Ethics and in a manner to avoid any actual or potential conflict of interest or any abuse of any person’s position of trust and responsibility. Further, these persons should not take inappropriate advantage of their positions with or on behalf of a client. Baseline will provide a copy of the Code to any client upon request. Participation or Interest in Client Transactions From time to time, Baseline and its associated persons invest in the same securities as the firm’s clients, both to align the interest of the firm and personnel and the firm’s clients and as an expression of confidence in our portfolio management efforts. In order to ensure that Baseline personnel do not put their interests ahead of their clients, the firm has implemented a blackout period, i.e. trading in positions for officer and employee account occurs after the analogous trades are executed for client accounts. Firm personnel communicate freely and frequently among themselves in order to ensure the application of these fundamental restrictions. Recommendations to Proprietary Strategies When implementing the recommended investment strategies for a client, Baseline may select from a wide range of investment options available including proprietary and nonproprietary strategies and services to construct a suitable portfolio for a client. Baseline may recommend its proprietary strategies over other non-proprietary strategies in the same asset class. Accounts are formally reviewed on a continual basis to determine if the account’s allocations are in line with the investment objectives established for the account and if the account is being managed in accordance with Baseline’s strategies and applicable policies and procedures. 15  Form ADV Part 2A: Firm Brochure March 31, 2026 XII. Brokerage Practices Baseline determines which securities are to be purchased or sold and the total amount of securities that are to be purchased or sold. However, Baseline does not select the broker or dealer through which the securities are to be purchased or sold and does not determine the commission rates of third parties, if any, at which transactions are to be affected. Each of Baseline’s clients maintains custody of his/her/their assets at one or more custodians (usually Swiss based banks); Baseline does not have custody or possession of client assets. Each of these custodians maintains relationships with designated broker-dealers (including, sometimes and for certain securities, an affiliate of the custodian). Baseline transmits security orders to the custodian bank or the broker or dealer designated by the custodian bank selected by the client. Baseline does not guarantee best execution or the best commissions because Baseline does not control these factors. Therefore, clients should be aware of the following: • Baseline does not negotiate commission rates with broker-dealers with whom orders are placed either directly or via the custodian as the broker-dealer is dictated by the custodian. The applicable commissions are agreed upon by the client. • Commission charges will vary among clients and best execution may not be guaranteed by Baseline. Because each client selects the custodian and thereby the broker-dealer to be used for securities transactions involving his account, a client may pay an executing broker a higher commission for a securities transaction than might be charged by another broker-dealer for the same transaction or than the commission charged by the broker-dealer executing a similar transaction for another client of Baseline in the same proprietary investment strategy. It also is possible that the broker-dealer used for transactions may not be a registered broker-dealer under the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”). In making the decision as to which securities are to be purchased or sold and the amounts thereof, Baseline is guided by the general guidelines of each investment strategy, in addition to those guidelines set up at the inception of the adviser-client relationship in cooperation with the client and a periodic review of the asset allocation. These general guidelines cover such matters as the relative proportion of debt and equity securities to be held in the portfolio, the degree of risk that the client wishes to assume and the types and amounts of securities to be held in the portfolio. The Adviser’s authority may be further limited by specific instructions from the client that may restrict or prohibit transactions in certain securities. Baseline may manage numerous accounts with similar or identical investment objectives or may manage accounts with different objectives that may trade in the same securities. Despite such similarities, portfolio decisions relating to client investments and the performance resulting from such decisions may differ from client to client. Baseline will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible clients, particularly if different clients have materially different amounts of assets under management with Baseline or different amounts of investable cash available or have their assets in custody with different custodians. In certain instances, such as purchases of less liquid publicly traded securities (as some small cap securities frequently are) or oversubscribed public offerings, it may not be possible or feasible to allocate a transaction pro-rata to all eligible clients, especially if clients have materially different sized portfolios and such portfolios are with different custodians. Therefore, not all clients will necessarily participate in the same investment opportunities or participate on the same basis even if they are invested in the same investment strategy. Use of Soft Dollars Baseline does not presently have any soft dollar arrangements. However, to the extent it may in the future, it will enter into such arrangements only in accordance with the conditions of the safe harbor provided by Section 28(e) of the Exchange Act. Section 28(e) is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and 16  Form ADV Part 2A: Firm Brochure March 31, 2026 appropriate assistance in the investment decision-making process. Baseline will limit the use of “soft dollars” to obtain research and brokerage services which constitute research and brokerage within the meaning of Section 28(e). XIII. Review of Accounts All managed accounts are reviewed on a continuous basis by Baseline's portfolio managers in an effort to ensure that they remain aligned with the client’s investment objectives and are positioned appropriately given current market conditions as part of Baseline’s general investment process. The stocks owned by our clients are reviewed whenever earnings or significant news are announced. Significant changes in stock prices may also trigger a review. Various other circumstances may also result in review of accounts. When necessary, accounts may be rebalanced based on Baseline’s tactical asset allocations, while striving to minimize potential tax implications. On an ongoing basis, portfolio managers monitor market developments, reinvest matured fixed income securities, and ensure that the portfolio's asset allocation remains within agreed parameters and that no investment restrictions are breached. Baseline also monitors portfolio concentration levels to ensure that no single security exceeds 10% of the portfolio and that no single issuer represents more than 20% of the portfolio, consistent with applicable regulatory requirements. At least once per year, Baseline will meet with each client, or otherwise provide the client with a portfolio statement reflecting account performance, to conduct a formal review of the client's account. During this review, Baseline will assess whether the client's investment strategy remains appropriate and will inquire whether there have been any material changes in the client's circumstances — such as retirement, changes in financial situation, or shifts in investment objectives — that may warrant a reassessment of the client's risk profile, time horizon, or overall investment strategy. Baseline may provide performance information to advisory clients about the client’s account performance, which may also include a reference to a relevant market index or benchmark. Baseline may provide reports analyzing the sources of each account’s performance, including customary performance attribution and risk measurement statistics such as standard deviations, Sharpe ratios, deviations from benchmark returns, and investments that had the largest positive and negative impacts on performance. Clients are provided with quarterly performance and account statements from the custodian bank. Clients are urged to compare the reports and statements provided by us against the custodian bank statement. XIV. Client Referrals and Other Compensation Baseline may receive economic benefits from third parties for providing investment advice or other advisory services to its clients but such benefit will be disclosed upfront to the client and agreed upon prior to Baseline engaging in such third-party agreements. When a client is introduced to us by an affiliated person or company, we pay the referring party a portion of the client’s total investment management fee in accordance with the requirements of applicable U.S federal and state rules. For example, employees of the Firm or one of our affiliates may refer clients to us. In these cases, we compensate the referring individual by paying a percentage of the total fee charged by the Firm to the client. Affiliates and employees of Baseline that refer clients and receive compensation from our Firm must disclose the nature of their relationship with Baseline to prospective clients at the time of the referral. Employees receive referral fees for clients referred to other affiliates, so a conflict of interest exists to the extent that an employee of affiliate recommends the services of the other, and the recommendation could be made because of the benefit received by the employee rather than the client’s best interest. Clients are under no obligation to engage either party for the recommended services. Any referral fees paid or received by employees of either affiliate will not increase the amount of fees you pay. 17  Form ADV Part 2A: Firm Brochure March 31, 2026 XV. Custody Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. Baseline is deemed to have custody of client funds and securities whenever the Firm is given the authority to have fees deducted directly from client accounts. We have the ability to deduct our advisory fee from the client’s custodial account. Clients are provided with quarterly performance and account statements from the custodian bank. Generally, these reports include a listing of all asset valuations and a listing of all transactions occurring during the period, including the deduction of advisory fees, along with information concerning the allocation of the assets in the client account among various asset classes and the investment performance of the client account during the quarter. The custodian also provides clients with all required year-end tax information. To the extent that we provide clients with periodic account statements or reports, the client is urged to compare any statement or report provided by us with the account statements received from the account custodian. The account custodian does not verify the accuracy of our advisory fee calculation. XVI. Investment Discretion Baseline accepts discretionary authority to manage client accounts as described above. Clients rarely restrict the authority by which the advisers may act; however, each client has the opportunity to communicate any form of limitation in writing. Clients that choose a discretionary mandate, open new individual or company accounts at the custody bank selected by the client. Baseline is in no instance a beneficial owner of the assets in the account. Each client signs a limited power of attorney authorizing Baseline to access the account and place trades. At no time is Baseline authorized to withdraw funds apart from the advisory fee. For clients with existing accounts at certain banks Baseline has relationships with, the client immediately benefits from the fees negotiated by Baseline when Baseline becomes the adviser on the account. XVII. Voting Client Securities Baseline does not have the authority to vote client proxies, as disclosed in its standard Asset Management Agreement. Generally, Baseline’s clients will receive their proxies directly from their selected custodian. If the Baseline personnel inadvertently receive any proxy materials on behalf of a client, they will promptly forward such materials to the client. XVIII. Financial Information Baseline does not require or solicit prepayment of fees from any client, six months or more in advance. There are no financial conditions that are likely to impair our ability to meet contractual commitments to all of our clients. To that end, Baseline has not been the subject of bankruptcy petition at any time during the past ten years. 18