BELLWETHER ADVISORS, LLC

Bellwether Advisors, LLC dba Bellwether Wealth 140 North 8th Street, Suite 210 Lincoln, Nebraska 68058 Phone: (402) 476-8844 Website: www.bellwetherwealth.com March 29, 2025 Item 1: Cover Page This brochure provides information about the qualifications and business practices of Bellwether Advisors, LLC dba Bellwether Wealth (“Bellwether Wealth”). If you have any questions about the contents of this brochure, please contact us at (402) 476-8844 or by email at info@bellww.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 Bellwether Wealth also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Bellwether Wealth’s CRD number is 300012.  ITEM 2 – SUMMARY OF MATERIAL CHANGES This Disclosure Brochure is our Annual Amendment Brochure. It contains information regarding Bellwether’s qualifications, business practices, nature of the advisory services we provide, as well as a description of potential conflicts of interest relating to our advisory business that could affect a client’s account with us. You should rely on the information contained in this document or other information we have referred you to. We have not authorized anyone to provide you with information that is different. We encourage all current and prospective clients to read this Disclosure Brochure and discuss any questions you have with your advisor. Should you have any additional questions regarding our Firm or the contents of this Firm Brochure, please contact us at (402) 476-8844. Material Changes Since the Last Update Since our last Annual Amendment filing on March 23, 2023, we have made the following material changes: • Leila Shaver became the Chief Compliance Officer effective February 1, 2025. • Item 4 has been updated to include more information about our services and our use of third party asset managers. Item 7 has been updated to include information about minimum fees. • • Item 8 has been updated to include additional risk factors investors should consider when investing with our Firm. • Item 17 has been updated to disclose that we have engaged Egan-Jones to vote proxies on our behalf. Future Changes Sometimes, we may amend this Disclosure Brochure to reflect changes in our business practices, regulations, and routine annual updates as required by the Securities and Exchange Commission. Either this complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Bellwether Advisors, LLC. At any time, you may view the current Disclosure Brochure online at the SEC's Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 300012. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (402) 476- 8844. 2  ITEM 3: TABLE OF CONTENTS Item 1: Cover Page ................................................................................................................. 1 Item 2 – Summary of Material Changes ................................................................................. 2 Item 3: Table of Contents ....................................................................................................... 3 Item 4 – Advisory Business ..................................................................................................... 4 Item 5 – Fees and Compensation ............................................................................................ 6 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................... 8 Item 7 – Types of Clients ........................................................................................................ 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................... 8 Item 9 – Disciplinary Information ......................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations ............................................. 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................ 15 Item 12 – Brokerage Practices .............................................................................................. 15 Item 13 – Review of Accounts ............................................................................................... 18 Item 14 – Client Referrals and Other Compensation ............................................................ 19 Item 15 – Custody ................................................................................................................. 19 Item 16 – Investment Discretion ........................................................................................... 20 Item 17 – Voting Client Securities ......................................................................................... 21 Item 18 – Financial Information ........................................................................................... 21 Privacy Policy and Procedures for Protecting Client Information ....................................... 23 3  ITEM 4 – ADVISORY BUSINESS A. ADVISORY BUSINESS Bellwether Advisors, LLC dba Bellwether Wealth (“Bellwether” or the “Firm”) was incorporated in November 2019 and has been registered as an investment advisory firm with the Securities and Exchange Commission (“SEC”) since January 2019. Bellwether Wealth’s majority owner is Clark Bellin. We provide investment advice to individuals, retirement plans, trusts, estates, charitable organizations, corporations and other business entities. We also provide advice to clients on financial planning, retirement planning, estate planning, tax planning and on matters that include, but are not limited to, life insurance, long-term care insurance, 529 plans and other similar financial matters. We are a fiduciary and are required to always act in a client’s best interest. B. ADVISORY SERVICES OFFERED Investment Management The Firm offers ongoing investment management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. The Firm creates an investment policy statement for each client, which outlines the client’s current situation (including income, tax levels, and risk tolerance levels). Investment management services include, but are not limited to, the following: Investment strategy • • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Bellwether performs its services on a discretionary basis, meaning that client will grant the Firm the authority to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the investment policy statement, which is given to each client. Trading discretion requires the Firm to seek best execution for trades executed in the account. For more information about Bellwether's trading practices and policies, see below and Item 12, Brokerage Practices. We use a time-tested, disciplined approach to investing. We are a “total portfolio” manager using active and passive, diversified investment approaches. We believe that a portfolio should be diversified, and excess returns can be achieved by overweighting undervalued asset classes and investment styles. Typically, we use model portfolios that meet the individual needs and risk tolerances of our clients. If you desire, you may impose restrictions on the securities or types of securities you would like us to invest in. We may, from time to time and based upon information received from the client, invest client assets according to one or more model portfolios developed by a third-party asset manager (TPAM) 4  pursuant to a sub-advisory agreement. In these situations, we offer consulting and advisory services in overseeing such TPAM model portfolios. We make recommendations regarding the use of a third-party model portfolio and its investment style based on, but not limited to, the client’s financial needs, long-term goals, and investment objectives. TPAMs selected by us offer multiple strategies including the use of model portfolios developed by us. Once a TPAM is selected, we continue to monitor the chosen firm to ensure that it adheres to the philosophy and investment style for which it was selected and to ensure that its performance, portfolio strategies, and management remain aligned with the client’s overall investment goals and objectives. We will retain discretionary authority to hire and fire TPAMs and reallocate the client’s assets to other TPAMs, where such action is deemed in the best interest of the client. Our review includes assessment of the TPAMs disclosure brochure, performance information, materials, personnel turnover, and regulatory events. Financial Planning Sound financial planning services can help clients identify the strengths and weaknesses of their long-term financial health. We have years of experience in this area and sophisticated software tools available to assist our clients in developing comprehensive financial plans that guide them toward the accomplishment of their goals. Retirement Planning Retirement planning and financial planning are not one and the same. We have worked with many clients through their earning years and into the distribution phase of their lives. We assist clients with the management of their portfolios to ensure longevity through retirement while at the same time providing needed income. We have experience working with clients on a range of retirement planning issues, including rollover of 401(k) plans, level of income needed for retirement and tax-efficient distribution of after-tax and before-tax assets. Estate Planning Good estate planning advice can save a client thousands of dollars in probate fees and estate taxes. We provide a full range of estate planning services, all of which are designed to help clients achieve their personal and financial goals. These services generally include, but are not limited to, advice regarding the accumulation, retention and transfer of assets. Consideration also is given to the income, gift and estate tax consequences of a situation. Please note, we are not attorneys and do not provide legal advice or prepare legal documents. Tax Planning Whether it’s the sale of a security, the exercise of a stock option, the transfer of real estate or the gifting of appreciated securities, advanced planning regarding the tax impact of a transaction is critical. Our team has many years of experience in assisting clients with tax issues. Our goal is to help our clients minimize their lifetime tax liability so they can hold onto the hard- earned dollars they work their entire careers to amass. 5  As part of our investment strategy, we may recommend allocating portions of a client’s assets to mutual funds, Exchange Traded Funds, or publicly traded REITs. We annually conduct due diligence and monitor the performance on an ongoing basis of the investment vehicles. Please note, we are not tax attorneys or CPAs and not provide tax advice. C. TAILORED SERVICES The goals and objectives for each client are documented before any investment. Clients may impose restrictions on investing in certain securities or types of securities. D. WRAP PROGRAM Bellwether does not sponsor a wrap program. This section is not applicable. E. CLIENT ASSETS MANAGED As of December 31, 2024, Bellwether manages $663,293,175 in client assets on a discretionary basis and no assets on a non-discretionary basis. ITEM 5 – FEES AND COMPENSATION We are a fee-based advisor. This means we get paid a fee for our investment management services based on the average daily market value of your assets under management in the preceding month. We typically bill for our fees monthly, payable in advance. Our minimum account size and fees are negotiable in certain circumstances. Fees can be paid by having them deducted directly from your account or by check. The choice is yours. In either case, we provide you with a fee statement. Our annual fee schedule is as follows: Assets Under Management Annual Fee* Up to $500,000 1.25% $500,001 to $1,000,000 1.00% $1,000,001- $2,500,000 0.90% $2,500,000- $5,000,0000 0.825% $5,000,001-$10,000,000 0.750% 0.625% $10,000,001-$25,000,000 0.500% $25,000,001-$50,000,000 0.375% $50,000,001 and up *Our minimum fee is $3,125 based on assets, but we may also negotiate additional fixed fees for planning/projects for smaller accounts and we, in our 6  sole discretion, may negotiate to reduce any fee. AUM excludes any non- managed assets held in a managed account. A non-managed asset includes any asset that you have directed us to hold and not trade. Asset Management Fee Calculation Example A client with $3,000,000 in Assets Under Management would annually be billed as follows: The first $500,000 is billed at a 1.25% annual rate (Tier 1), the next $500,000 is billed at a 1.00% annual rate (Tier 2), the next $1,500,000 is billed at a 0.90% annual rate (Tier 3), and the next $500,000 is billed at a 0.825% annual rate (Tier 4). The chart below further illustrates the manner in which the fee is calculated: AUM Annual Fee % Annual Fee $ Tier 1 $ 500,000 1.25% $ 6,250 Tier 2 $ 500,000 1.00% $ 5,000 Tier 3 $ 1,500,000 0.90% $13,500 Tier 4 $ 500,000 0.825% $ 4,125 Total $3,000,000 0.96% $28,875 Our minimum account size is $250,000 We do not currently charge a fee to an investment client for a financial plan. For non- investment clients, we charge a fee of $3,000 for a financial plan billed at the completion of the plan. We will also bill an hourly rate of $300 per hour for certain projects. An estimate of the project completion time will be discussed with the client. In investing your portfolio, we will likely use one or more mutual funds. If we do, you will incur mutual fund fees and expenses that are in addition to the fees we charge you. Mutual funds pass these fees and expenses on to investors directly - they are not charged nor billed by us. We use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer and member of the Securities Investor Protection Corporation, as our custodian. Through our use of Schwab’s services, you will incur certain trading costs in addition to our fees. These costs are further explained in Item 12 below. Other Compensation Certain of the Firm’s investment adviser representatives, in their individual capacities, are also independent licensed insurance agents. Although the Firm itself does not sell such insurance products to our investment advisory clients, we do permit investment adviser representatives, in their individual capacities as licensed insurance agents (and on a fully-disclosed commission basis), to sell insurance products to our investment advisory clients. A conflict of interest exists to the extent that an advisory representative recommends the purchase of insurance products where 7  they also receive insurance commissions or other additional compensation in their role as an independent insurance agent. Clients are under no obligation to purchase insurance products through any person affiliated with our firm. Termination and Refund of Fees The Discretionary Investment Management Agreement may be terminated at any time upon receipt of notice to terminate by either party to the other. If you terminate the Agreement after the commencement of a calendar billing period, the unearned portion of the Management Fee will be promptly refunded. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees nor do we engage in side-by-side management. ITEM 7 – TYPES OF CLIENTS We provide investment advice to individuals, retirement plans, trusts, estates, charitable organizations, corporations and other business entities. Minimum account size is $250,000, but we reserve the right to manage smaller accounts. Our minimum fee is $3,125 based on assets, but we may also negotiate additional fixed fees for planning/projects for smaller accounts and we, in our sole discretion, may negotiate to reduce any fee. Certain TPAMs may require a minimum account size and can vary from Manager to Manager. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Please remember that any time you invest in securities of any type, there is risk of loss of principal that you should be prepared to bear. Methods of Analysis Our disciplined, diversified investment approach is designed to achieve excess returns by overweighting undervalued asset classes and investment styles. Our approach incorporates a number of different methods of analysis. In order to determine undervalued asset classes, we use fundamental, technical and cyclical analysis. Fundamental analysis is a method of evaluating a company that has issued a security by attempting to measure the value of its underlying assets. It entails studying overall economic and industry conditions as well as the financial condition and the quality of the company’s management. Earnings, expenses, assets, and liabilities are all important in determining the value of a company. The value is then compared to the current price of the issuing company’s security to determine whether to purchase, sell, or hold the security. 8  Cyclical analysis is a form of fundamental analysis that involves the process of making investment decisions based on the different stages of an industry at a given point in time. Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume movements. Technical analysts do not attempt to measure a security’s intrinsic value, but instead, use charts and other tools to identify patterns that can suggest future activity. We use fundamental, technical and cyclical analysis and a proprietary model to assist in the determination of which investment styles to overweight. Our proprietary model is based on the concept of reversion to the mean – this means that investment styles that are overvalued will fall in value and undervalued styles will rise in value to revert to the mean performance over time. Our investment committee uses these methods to determine the appropriate weightings for asset classes, investment styles and appropriate investment vehicles. To perform its portfolio management services, we use an industry agnostic, third party artificial intelligence (AI) platform. We regularly review which feature sets (data) to use and obtain the data from third party vendors such as FactSet®. Using predictive analysis, Bellwether Wealth ranks the publicly traded stocks within individual sectors of the S&P 500 by which are believed to have the best opportunity to perform well compared to the overall sector. Analysts at Bellwether Wealth review the selections prior to them being put into models. There is a risk of loss of principal due to the fact that these methods may not prove successful at times, especially during unexpected market events or catastrophic events. Risk Disclosures Related to the Use of Artificial Intelligence and Predictive Analysis 1. Reliance on Third-Party AI Technology Our firm utilizes a third-party artificial intelligence ("AI") platform to develop model portfolios and execute rebalancing decisions. The AI platform employs predictive analysis and algorithmic modeling to assess market trends and construct investment strategies. While this technology is designed to enhance efficiency and data-driven decision-making, clients should be aware that the AI platform is not infallible, and its predictions may be inaccurate or fail to anticipate market events. 2. Model Risk and Limitations of Predictive Analysis The AI platform relies on historical data, machine learning models, and statistical techniques to forecast future market movements. However, past performance does not guarantee future results, and the models may be impacted by incorrect assumptions, incomplete data, or unforeseen economic events. As a result, the investment recommendations generated by the AI platform may not always align with actual market conditions, potentially leading to losses. 3. Lack of Human Judgment in Decision-Making While our firm reviews and oversees the AI-driven portfolio construction and rebalancing process, there may be instances where investment decisions are made with limited human intervention. This could result in suboptimal portfolio adjustments if the AI platform fails to account for qualitative 9  factors, macroeconomic shifts, or unexpected regulatory changes that a human adviser might consider. 4. Technology and Systemic Risks The AI platform is dependent on continuous access to accurate market data, reliable connectivity, and robust cybersecurity measures. Technical failures, system malfunctions, data breaches, or disruptions in service could delay or impair the platform’s ability to process transactions, rebalance portfolios, or provide accurate recommendations. Clients should recognize that reliance on such technology introduces risks beyond traditional investment considerations. 5. Market Liquidity and Execution Risks The AI platform may automatically rebalance portfolios based on algorithmic triggers. In periods of market volatility or illiquidity, automated rebalancing could result in transactions being executed at unfavorable prices, increased transaction costs, or unexpected tax consequences. 6. Potential Conflicts of Interest Our firm does not own or control the third-party AI platform but may have a contractual relationship with the provider. In some cases, the AI provider may receive compensation based on asset levels, trade volume, or other economic incentives that could influence portfolio construction methodologies. Clients should review our firm’s Fees and Compensation disclosure for details on any arrangements with the AI provider. 7. Regulatory and Compliance Risks AI-driven investment strategies are subject to evolving regulatory scrutiny. Changes in laws, regulations, or compliance requirements may impact the firm’s ability to use the AI platform as intended. Clients should be aware that regulatory developments may necessitate adjustments to investment strategies or technology usage, potentially affecting portfolio performance. 8. Data Privacy and Security Risks The AI platform processes client data as part of its predictive analysis and portfolio construction. While we implement appropriate cybersecurity measures, the use of third-party technology introduces potential risks related to data breaches, unauthorized access, or misuse of personal and financial information. Clients should review our Privacy Policy for further details on data security practices. Investment Strategies We use several investment strategies for our clients’ portfolios depending on the risk tolerance and return objectives for each of our clients. Bellwether Wealth’s investment committee determines the appropriate asset class allocation, investment vehicles and appropriate risk levels for each investment strategy. Bellwether Wealth’s core investment strategies are: aggressive growth, growth, growth and income and conservative. Each of these core strategies may invest in mutual funds, exchange traded funds, individual equities, fixed income, alternatives and/or cash. The level of equities in a clients’ portfolio will be highest for someone invested in our aggressive growth strategy and lowest for someone invested in our conservative strategy. 10  Fixed Income Strategy: We have a few clients that have a portfolio invested solely in fixed income investments. Bellwether Wealth’s approach in these situations is to overweight styles and maturity lengths we believe will outperform the market going forward. This approach is based primarily on our cyclical analysis. We may use both mutual funds and individual bonds depending on client goals as outlined in their respective investment policy statements. Our fixed income strategy is subject to risk of loss of principal through rising interest rates, bond market dislocation, lack of liquidity in the bond market and security downgrades. We also use high yield bond mutual funds which are subject to a higher default rate than traditional bonds. Third Party Asset Manager Selection and Evaluation Bellwether examines the experience, expertise, investment philosophies, and past performance of independent Managers to determine if that Manager has demonstrated an ability to invest over a period and in different economic conditions. Bellwether monitors the Manager’s underlying holdings, strategies, concentrations, and leverage as part of Bellwether’s overall periodic risk assessment. Additionally, as part of Bellwether’s due-diligence process, Bellwether surveys the Manager’s compliance and business enterprise risks. A risk of investing with a Manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as Bellwether does not control the underlying investments in a Manager’s portfolio, there is also a risk that the Manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as Bellwether does not control the Manager’s daily business and compliance operations, Bellwether may be unaware of the lack of internal controls necessary to prevent business, regulatory, or reputational deficiencies. Risk of Loss You are advised and are expected to understand that Bellwether’s past performance is not a guarantee of future results and that certain market and economic risks exist and may adversely affect an account’s performance which could result in capital losses in your account. Investing in securities involves risk of loss which you should be prepared to bear. There are principal and material risks involved which may adversely affect the account value and total return. There are other circumstances (including additional risks that are not described here) which could prevent your portfolio from achieving its investment objectives. It is important to read all of the disclosure information provided and to understand that you may lose money by investing in the any of our strategies. You should be aware that your account may be subject to the following risks: • Alternative Investments: Alternative investments are illiquid investments and do not trade on a national securities exchange. Alternative investments typically include investments in direct participation program securities (partnerships, limited liability companies, business development companies or real estate investment trusts), commodity pools, private equity, private debt, and hedge funds. Alternative investments are subject to various risks, such as illiquidity and property devaluation based on adverse economic and real estate market conditions. Alternative investments are not suitable for all investors. Investors considering 11  an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature and may involve a high degree of risk, particularly if concentrating investments in one or few alternative investments. These risks are potentially greater and substantially different than those associated with traditional equity or fixed income investments. You will find additional information regarding these risks in the product’s prospectus. You can request a copy of a prospectus from your IAR. You should read the prospectus carefully before investing in an alternative investment. • Capitalization: Small-capitalization and mid-capitalization companies may be hindered as a result of limited resources or less diverse products or services, and their stocks have historically been more volatile than the stocks of larger, more established companies. • Cash and Cash Equivalents: A portion of your assets may be invested in cash or cash equivalents to achieve your objective, provide ongoing distributions and/or take a defensive position. Cash holdings may result in a loss of market exposure. • Concentration: A large holding in any security, sector, or industry presents the risk of amplified losses. Concentrated positions can magnify volatility within a portfolio. Portfolios that are concentrated risk sudden losses that can significantly impact a portfolio’s performance. • Credit: Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or repay principal when due. A downgrade of an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value and, thus, impact the fund’s performance. • Cryptocurrencies: Cryptocurrencies are a relatively new innovation and the market for cryptocurrency is subject to rapid price swings, changes and uncertainty. The slowing, stopping, or reversing of the development of a cryptocurrency or the acceptance of said cryptocurrency may adversely affect the price of it. Cryptocurrencies are subject to the risks of fraud, theft, manipulation or security failures, operational or other problems that impact cryptocurrency trading venues. Unlike the exchanges for more traditional assets such as equity securities and futures contracts, cryptocurrencies and their trading venues are largely unregulated. As a result of the lack of regulation, individuals or groups may engage in fraud or market manipulation (including using social media to promote a cryptocurrency in a way that artificially increases the price of it). Investors may be more exposed to the risk of theft, fraud and market manipulation than when investing in more traditional asset classes. Over the past several years, a number of cryptocurrency trading venues have been closed due to fraud, failure or security breaches. Investors in cryptocurrencies may have little or no recourse should such theft, fraud or manipulation occur and could suffer significant losses. Legal or regulatory changes may negatively impact the operation of a cryptocurrency or restrict the use of it all together. The realization of any of these risks could result in a decline in the acceptance of any cryptocurrency and consequently a reduction in the value of it. Finally, the creation of a “fork” (a split within a cryptocurrency resulting in two distinct cryptocurrencies) or a substantial giveaway of a cryptocurrency (sometimes referred to as an “air drop”) may result in significant and unexpected declines in the value of a cryptocurrency. • Derivative: Derivatives are securities, such as futures contracts, whose value is derived from that of other securities or indices. Derivatives can be used for hedging (attempting to reduce risk by offsetting one investment position with another) or non-hedging purposes. Hedging 12  with derivatives may increase expenses, and there is no guarantee that a hedging strategy will achieve the desired results. • Equity Securities: In general, prices of equity securities are more volatile than those of fixed income securities. The prices of equity securities will rise and fall in response to several different factors, including events that affect issuers as well as events that affect entire financial markets or industries. Small and mid-capitalization stocks may have greater price volatility, lower trading volume, and less liquidity than large capitalization stocks. • Exchange-Traded Funds (“ETFs”): ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its net asset value. Update. • Fixed Income Securities: The return and principal value of bonds fluctuate with changes in market conditions. Fixed income securities have interest rate risk and credit risk. As interest rates rise, existing bond prices fall and can cause the value of an investment to decline. Changes in interest rates generally have a greater effect on bonds with longer maturities than those with shorter maturities. If bonds are not held to maturity, they can be worth more or less than their original value. Credit risk refers to the possibility that the issuer of a bond will not be able to make principal and/or interest payments. High yield bonds, also known as “junk bonds”, carry higher risk of loss of principal and income than higher rated investment grade bonds. • • Foreign Securities and Currency: Investments in international and emerging-market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, the potential for illiquid markets, political instability, and to the possibility of the complete loss of the underlying value of the security and/or currency. Interest Rate: In a rising rate environment, the value of fixed-income securities generally declines, and the value of equity securities may be adversely affected. • Market: Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money, and your investment may be worth less upon liquidation. • Mutual Funds: Mutual funds may invest in different types of securities, such as value or growth stocks, real estate investment trusts, corporate bonds, or U.S. government bonds. There are risks associated with each asset class. An investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although money market funds seek to preserve the value of your investment, it is possible to lose money by investing in the fund. Redemption is at the current net asset value, which may be less than the original cost. Aggressive growth funds are most suitable for investors willing to accept price per share volatility since many companies that demonstrate high growth potential can also be high risk. Income from tax-free mutual funds may be subject to local, state and/or the alternative minimum tax. Because each mutual fund owns different types of investments, performance will be affected by a variety of factors. The value of your investment in a mutual fund will vary from day to day as the values of the underlying investments in a fund vary. Such variations generally reflect changes in interest rates, market conditions, and other company and economic news. Their risks may become magnified 13  depending on how much a fund invests or uses certain strategies. You will find additional information regarding these risks in the prospectus for each individual mutual fund held in your account. You can request a copy of a prospectus from your IAR or by contacting the investment company directly. • Options: Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • Performance of Underlying Managers: Bellwether selects the mutual funds and ETFs in the asset allocation models. However, Bellwether depends on the Manager of such funds to select individual investments in accordance with their stated investment strategy. • Securities Lending: Securities lending involves the risk that the fund loses money because the borrower fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. • Special Purpose Acquisition Company (SPAC): SPAC IPOs and de-SPAC transactions can be used as a means for private companies to enter the public markets. Given the complexity of these transactions, they carry a range of risks that investors should carefully consider such as, SPACs typically have no operating history, which means investors lack insight into their past performance and management track record, the timeline for a SPAC to identify and acquire a target company can be uncertain, potentially leading to prolonged periods of illiquidity for investors, and the success of a SPAC investment hinges heavily on the ability of its management team to identify and execute a successful merger or acquisition, which may not always materialize as expected. There’s also the risk of dilution for early investors if additional capital needs to be raised to support the acquisition. Finally, regulatory changes and market volatility can impact the value of SPAC investments, adding another layer of risk to consider. Overall, while SPACs offer potential opportunities, investors should carefully weigh these risks against the potential rewards before investing. ITEM 9 – DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We do not have information to disclose in this item. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Broker Dealer Affiliation We are not affiliated with a broker dealer. Futures/Commodities Firm Affiliation We are not affiliated with a futures or commodities broker. 14  Other Industry Affiliations Some of our advisers are licensed independent insurance agents. They may recommend these services to our clients. These services pay fees or commissions separate from those outlined in Item 5 above. This is a conflict of interest because these additional fees or commissions create a financial incentive to recommend the service. We, however, attempt to mitigate any conflicts of interest to the best of our ability by placing the client’s interests ahead of our own and through the implementation of policies and procedures that address the conflicts. Additionally, the client is informed that they always have the right to choose whether to act on the recommendation and to purchase recommended services through any unaffiliated licensed agent or investment adviser representative. Recommendation of Third-Party Investment Adviser We recommend the services of TPAMs as outlined in Item 4. We will ensure that TPAMs are properly registered or exempt from registration in the client’s state of residence before making any recommendation. Depending on the TAMP, we may receive a portion of its management fee, which creates a financial incentive to recommend certain TAMPs that pay a higher percentage of the management fee. We will provide the client with a disclosure statement that details our portion of the TAMP’s fee when we receive it. We attempt to mitigate the conflict of interest to the best of our ability by placing the client’s interest ahead of our own, through our fiduciary duty and by following our Code of Ethics that establishes ideals for ethical conduct. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We have adopted a Code of Ethics, the full text of which is available to clients upon request. We have several goals in adopting this Code. First, we desire to comply with all applicable laws and regulations governing its practice, and our management has determined to set forth guidelines for professional standards, under which all our associated persons are to conduct themselves. We have set high standards, the intention of which is to always protect client interests and to demonstrate its commitment to its fiduciary duties of honesty, good faith and fair dealing with Clients. All associated persons are expected to adhere strictly to these guidelines, as well as the procedures for approval and reporting established in the Code of Ethics primarily related to personal securities transactions, and violations of the Code. In addition, we maintain and enforce written policies reasonably designed to prevent the misuse of material non- public information by us or any person associated with us. Please contact our Chief Compliance Officer at compliance@myrialawyer.com to obtain a complete copy of our Code of Ethics. ITEM 12 – BROKERAGE PRACTICES We do not maintain physical custody of the assets we manage on your behalf. Your assets must be maintained in an account at a “qualified custodian,” generally defined as a broker-dealer or bank. We typically recommend that our clients use Charles Schwab & Co. (“Schwab” or Custodian”) as our qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab holds your assets in a brokerage account and buys and sells securities when we instruct them to. You will open your account with Schwab by entering into an account agreement 15  directly with them. We do not open the account for you, although we usually assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below. How We Select Brokers/Custodians We seek to use a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services • Capability to execute, clear and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.). • Reputation, financial strength and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab”) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Schwab also receives a portion of the management fees charged by any mutual fund we invest your assets in. Schwab’s commission rates applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. This commitment benefits you because the overall commission rates you pay are lower than they would be otherwise. In lieu of commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker- dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s division that serves independent investment advisory firms like us. They provide us and you with access to its institutional brokerage services- trading, custody, reporting and other related services - many of which are not typically available to 16  Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer your accounts, while others help us manage and grow our business. Schwab’s support services are available to us on an unsolicited basis and at no charge to us as long as our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. Following is a more detailed description of Schwab’s support services: Services That Benefit You 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 we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you. Services That May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you. These products and services assist us in managing and administering your accounts. They include investment research, both from Schwab and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts. In addition to investment research, Schwab also makes available software, including Schwablink and Portfolio Center, and other technology that: • Provides access to client account data (such as duplicate trade confirmations and account statements) • Facilitates trade execution and allocates aggregated trade orders for multiple client accounts • Provides pricing and other market data • Facilitates payment of our fees from our clients’ accounts • Assists with back-office functions, recordkeeping and client reporting Services That Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business. These services include: • Educational conferences and events • Consulting on technology, compliance, legal and business needs • Publications and conferences on practice management and business succession • Access to employee benefit providers, human capital consultants and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab, or other third party vendors, may also provide us with other benefits, such as occasional business entertainment of our personnel or clients. 17  Our Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as our clients collectively keep a total of at least $10 million of their assets in accounts at Schwab. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The $10 million minimum gives us an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of you, our client. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. We do not believe that recommending our clients to collectively maintain at least $10 million of assets at Schwab in order to avoid paying Schwab quarterly service fees of $1,200 presents a material conflict of interest. We do not refer clients to broker-dealers in exchange for client referrals from those broker- dealers. We do not recommend or require that clients direct their brokerage business to any broker- dealer. On occasions when the Firm deems the purchase and sale of a security to be in the best interests of more than one of its clients, the Firm may aggregate multiple contemporaneous client purchase or sell orders into a block order for execution. Executed orders are allocated among participating accounts according to each account's pre-determined participation in the transaction. Clients' accounts for which orders are aggregated receive the average price of such transaction, which could be higher or lower than the price that would otherwise be paid by a client absent the aggregation. Any transaction costs incurred in the transaction will be assessed to each client based on each client's level of participation in the transaction. If we make a trade error that results in a loss to a client, we will make the client whole. If we make a trade error that results in a gain to a client, and the gain can be attributed to a client, the client is entitled to keep the gain. If Bellwether Wealth makes a trade error that results in a gain to a client and the gain cannot be attributable to a particular client, Schwab, and not Bellwether Wealth, keeps the gain. In that case, if the gain is more than $100, Schwab will donate the gain to charity. If the gain is less than $100, Schwab will keep the gain to minimize and offset its administrative time and expense. ITEM 13 – REVIEW OF ACCOUNTS Your accounts are under continuous review by our investment professionals. Portfolio reviews are conducted frequently to judge the appropriateness of securities held in your account. Accounts are reviewed if there is an extraordinary event such as abnormal performance of a mutual fund or individual equity, if there is a change in a mutual fund manager or if there is a significant market swing. Individual advisers review accounts and are assigned accounts under management. In addition to the at least quarterly written statements that our clients receive from their custodian through the mail or via email, our clients receive quarterly, semiannual or annual reviews that 18  include, but are not limited to, evaluation and review of securities currently held in an account, performance review and review of activity in the account since the last review. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above in Item 12. The availability to us of Schwab’s products and services is not based on us giving particular investment advice to you, our client. For accounts of our clients maintained in custody at Schwab, Schwab will not charge the client separately for custody but will receive compensation from our clients in the form of commissions or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. Thus, we have an incentive to cause trades to be executed through Schwab rather than another broker-dealer. We, nevertheless, acknowledge our duty to seek best execution of trades in clients’ accounts. Trades for client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for our other clients. We have entered into a promoter agreement with Brian Beaulieu (“Brian”), an individual. We have agreed to pay Brian a portion of the advisory fee that we receive under the investment management agreement entered into by us and each client referred to us by Brian. We have also agreed not to charge costs greater than the fees or costs we charge our advisory clients who were not introduced to us by Brian, and who have similar portfolios under management with us. We have entered into a promoter agreement with Alan Beaulieu (“Alan”), an individual. We have agreed to pay Alan a portion of the advisory fee that we receive under the investment management agreement entered into by us and each client referred to us by Alan. We have also agreed not to charge costs greater than the fees or costs we charge our advisory clients who were not introduced to us by Alan, and who have similar portfolios under management with us. In addition, we have agreed that if a client is generally referred by Institute for Trend Research (ITR) Economics, meaning that the client mentions that they have read ITR Economics’ book, Prosperity in the Age of Decline, that Brian and Alan will receive a portion of the advisory fee that we receive under the investment management agreement entered into by us and each client referred to us in this method. ITEM 15 – CUSTODY All client funds, securities and accounts are held by a qualified custodian. However, we have limited custody over some client assets. We ask the client to authorize us with the ability to instruct the custodian to deduct our management fee directly from the client’s account. This 19  authorization will apply to our management fee only. The client may terminate this authorization at any time. The client will receive at least quarterly statements from the qualified custodian that holds and maintains the client’s assets. We urge each client to carefully review such statements. We are also deemed to have custody of clients’ funds or securities when clients have standing authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers with the custodian. When your money is transferred between accounts with different titles, this is considered a limited form of custody. In 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). We and your custodian follow the safeguards outlined in the letter. These safeguards include: • 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 adviser, 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. • 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 can terminate or change the instruction with their qualified custodian. • The investment adviser 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 adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instructions. The Firm complies with SEC Rule 206(4)-2 regarding requirements to ensure third-party verification of such client assets on an annual basis. ITEM 16 – INVESTMENT DISCRETION We offer discretionary investment management services. The client will sign an investment management agreement to grant us discretionary power over his or her account. Our investment management agreement contains a limited power of attorney that allows us to select the security, the amount, and the time of the purchase or sale in the client’s account. It also allows us to place each such trade without the client’s prior approval. Finally, it allows us to hire and fire independent investment advisors to implement model portfolios on the account. In addition to our investment 20  management agreement, the client’s custodian may request the client to sign the custodian’s limited power of attorney. This varies with each custodian. We discuss all limited powers of attorney with the client prior to their execution. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the client account, and any other investment policies, limitations, or restrictions. ITEM 17 – VOTING CLIENT SECURITIES Because we buy and sell individual securities, we sometimes receive a high volume of proxy voting information on behalf of clients. We have elected to utilize the services of Egan- Jones. In order to identify conflicts of interest (both general systematic conflicts and unusual or one-time event type conflicts) and ensure the objectivity of its proxy research and vote recommendations, Egan-Jones has established a Conflicts Committee consisting of the Director of Proxy Services, General Counsel and Designated Compliance Officer. The committee meets periodically to evaluate, review, and consider interests, transactions and relationships which may result in an actual or potential conflict of interest and to consider the effectiveness of the mitigation of any such conflicts of interest. The committee is also responsible for ensuring prominent interest. disclosure is made of relevant information relating to any conflict of A copy of Egan-Jones' “Policies and Procedures for Managing and Disclosing Conflicts of Interest” may be located at www.ejproxy.com/disclosures. Egan-Jones does not currently engage in proxy voting consulting with issuers. We have adopted and implemented proxy voting policies and guidelines to ensure that we, as fiduciary, by and through Egan-Jones, vote any proxy or other beneficial interest in an equity security or mutual fund prudently and solely in the best interest of advisory clients and their beneficiaries considering all relevant factors and without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. If the client requests information regarding the voting of proxies or wants a copy of the proxy voting policy and guidelines, the client should contact us by telephone at 402-476-8844. Class Action Lawsuits From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. We have no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. We also have no duty to evaluate a client's eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, we have no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct or negligence by corporate management of issuers whose securities are held by clients. ITEM 18 – FINANCIAL INFORMATION Balance Sheet 21  We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to provide a balance sheet. Financial Condition We are required in this Item to provide you with certain financial information or disclosures about our financial condition if we have a financial commitment that impairs our ability to service you. We do not have a financial commitment that impairs our ability to service our clients. Bankruptcy We have not been the subject of a bankruptcy proceeding. 22  PRIVACY POLICY AND PROCEDURES FOR PROTECTING CLIENT INFORMATION March 2025 STATEMENT OF POLICY The Adviser is committed to protecting the confidentiality and security of consumer, customer, and former customer information that it collects and will disclose such information only in accordance with Regulation S-P, any other applicable law, rules and regulations and this Privacy Policy. Background I. Regulation S-P limits the circumstances under which an adviser may disclose nonpublic personal information about a client to other persons and requires an adviser to disclose to all its clients the adviser’s privacy policies. The Adviser has implemented the following Privacy Policy (“Privacy Policy”) and Program for Protecting Client Information (the “Program”) to comply with Regulation S-P. Summary of Regulation S-P II. Regulation S-P has four key features: • An adviser must provide notice to its clients about its privacy policies; • An adviser may only disclose nonpublic personal information about clients to a nonaffiliated third party if it provides an initial privacy notice and a notice giving the client the opportunity to “opt- out” from the adviser’s disclosure of the information; • A client may request that their nonpublic personal information not be disclosed to nonaffiliated third parties (although certain information required for processing transactions is still permitted to be disclosed); and • An adviser must adopt a program reasonably designed to (i) ensure the security and confidentiality of client records and information; (ii) protect against any anticipated threats or hazards to the security or integrity of client records and information; and (iii) protect against unauthorized access to or use of client records or information that could result in substantial harm or inconvenience to any client. Privacy Policy Scope III. The Adviser has adopted this Privacy Policy, which applies to the Adviser. The Adviser conducts its business affairs primarily through its employees, to whom this Privacy Policy applies. To the extent that service providers are utilized in servicing accounts, confidentiality agreements that comply with Regulation S-P will be put into place. Service Providers A. 23  The Adviser will obtain a representation from each service provider that the service provider will not disclose client and former client information of the Adviser other than to carry out the purposes for which the client and former client information was provided to the service provider. The Adviser will seek to obtain this representation from all third-party service providers in the contract for services. To the extent the Adviser has not previously obtained this representation from the service provider in the contract for services, the Adviser will seek to obtain such representation in substantially the form as set forth in Attachment A. Privacy Notices B. Under Regulation S-P, the Adviser must provide an initial privacy notice to its customers at the time the advisory relationship is established and annually thereafter and provide an initial privacy notice to its “consumers” before it discloses nonpublic personal information. Consumers. A “consumer” is an individual who obtains from an adviser, financial products that are to be used primarily for personal, family or household purposes, such as one-time investment advice. The Adviser must provide an initial privacy notice to its consumers before the Adviser discloses the consumers’ nonpublic personal information to a nonaffiliated third party (other than as necessary to process consumer transactions). The Adviser is not required to send a privacy notice to consumers if the Adviser discloses nonpublic information about its consumers to third parties only pursuant to certain exceptions. The Adviser may satisfy the initial notice requirement by sending a “short form” notice that explains how the consumer may obtain the adviser’s privacy notice. Customers. A “customer” is a consumer who uses the product or service of the Adviser on an on-going basis (such as receiving continuous investment advice). The Adviser must provide an initial privacy notice when the Adviser establishes the customer relationship (such as when an investor enters into an advisory contract) and annually thereafter. Content of Customer Privacy Notices C. The initial and annual privacy notices must contain the following information: • categories of nonpublic personal information collected by the Adviser; • categories of nonpublic personal information disclosed by the Adviser; • categories of affiliates and nonaffiliates to whom the Adviser discloses the nonpublic personal information; • categories of nonpublic personal information about former customers disclosed by the Adviser and the categories of affiliates and nonaffiliates to whom it is disclosed; • if nonpublic personal information is disclosed to third parties, an explanation of the right to “opt- out” of such disclosure; and • a general description of the Adviser’s policies and practices with respect to protecting the confidentiality and security of nonpublic personal information. 24  The initial privacy notice will be delivered with Part 2 of the Adviser’s Form ADV, the investment advisory agreement for separate accounts or subscription agreement for private investment vehicle investors that is given to customers at the start of the advisory or investment relationship. The annual notice will be electronically delivered to each customer, generally accompanying the annual Part 2 delivery requirements. The Chief Compliance Officer or the delegee will review and update the privacy notice at least annually. Opt-Out Notice D. If the Adviser plans to disclose nonpublic personal information (other than pursuant to certain exceptions), the Adviser will provide consumers and customers a reasonable means to “opt- out” of the disclosure of that information, in compliance with Regulation S-P. Once a consumer elects to opt-out, the Adviser must honor the election as soon as reasonably practicable. The opt- out election remains in effect until the consumer revokes it. Document Destruction Policy E. The Adviser is required to take reasonable measures to guard against access to information derived from credit reports or other customer information when disposing of it, such as shredding such information, entering into a contract with a company that is in the business of disposing of consumer information in a manner consistent with Regulation S-P, destroying or erasing electronic documents that contain consumer information, and monitoring employee compliance with disposal and destruction procedures. IV. Administration of Privacy Policy Designation of Responsibility The Chief Compliance Officer or the delegee shall be responsible for implementing this Privacy Policy and all questions regarding this Policy should be directed to the Chief Compliance Officer or the delegee. Amendment of the Privacy Policy A. The Privacy Policy may be amended only by action of the Chief Compliance Officer or the delegee. Non-Compliance B. An employee will report to the Chief Compliance Officer or the delegee any material breach of this Privacy Policy of which the employee has become aware. Upon being informed of any such breach, the Chief Compliance Officer or the delegee is authorized to take any such action they deem necessary or appropriate to enforce this Privacy Policy and otherwise comply with Regulation S-P. Program for Protecting Customer Information V. The Chief Compliance Officer or the delegee are responsible for implementing and maintaining the Program. Identifying Internal and External Risks A. 25  The Program is designed to identify foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such customer information. An assessment and evaluation will be made of the likelihood, and potential damage of these threats, the sufficiency of any safeguards in place to control such risks and, where appropriate, the Program will be revised to address such risks (the “Risk Assessment”). At a minimum, the Risk Assessment will include a consideration of the risks in each of the Adviser's areas of operation, including: • Employee training and management, including instructing and periodically reminding employees of the Adviser’s legal requirement and policy to keep customer information secure and confidential; • Information systems, including network and software design, as well as information processing, storage, transmission, retrieval, and disposal; and • Detecting, preventing, and responding to attacks, intrusions, or other system failures. Design and Implementation of Safeguards B. Information safeguards will be designed and implemented to control the risks identified through the Risk Assessment, and the effectiveness of the safeguards’ key controls, systems and procedures will be regularly tested or otherwise monitored. Overseeing Service Providers C. Reasonable steps will be taken to determine that the service providers1 who have been selected and retained by the Adviser, at a minimum, maintain sufficient customer information safeguard procedures to detect and respond to security breaches. Moreover, reasonable procedures will be implemented to discover and respond to widely known security failures by service providers. Finally, all contracts with service providers must contain assurances that such service providers have implemented and will maintain such safeguards. Evaluation and Maintenance of the Program D. The Program will be periodically adjusted, as necessary or appropriate, based on: (i) results of testing and monitoring pursuant to the Program; (ii) any material changes to the business and operation of the Adviser; and (iii) any other circumstances that may have a material impact on the Adviser’s information security system. 26