Bright Wealth Management, LLC

Item 1 – Cover Page Bright Wealth Management, LLC 4400 State Highway 121 Suite 400 Lewisville, Texas 75056 Phone: (972) 410-6623 Fax: (972) 410-5768 www.brightwealthmanagement.com June 17, 2026 Form ADV Part 2A Brochure Bright Wealth Management, LLC is a registered investment adviser. An "investment adviser" means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Bright Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (972) 410-6623. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Bright Wealth Management, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Bright Wealth Management, LLC is 169771.  Bright Wealth Management, LLC Form ADV Part 2A Page 2 Item 2 – Material Changes The purpose of this page is to inform you of any material changes since the previous annual updating amendment submitted to regulators. On February 10, 2026, we submitted our annual updating amendment for the firm’s fiscal year ending December 31, 2025. There were no material changes. Subsequently, on June 17, 2026, we made the following updates: • Item 4 was updated regarding the firm’s use of proprietary and investment adviser representative customized model portfolios. Item 5 was updated regarding clarifications of the firm’s management fee schedule. Item 8 was updated with clarifications regarding risks associated with the use of model portfolios. Item 12 was updated with clarifications regarding trade aggregation across multiple accounts. Item 13 was updated with clarifications regarding account reviews. • • • • We encourage you to carefully review our entire brochure. If you have any questions or if you would like to receive a copy of our full brochure at any time, free of charge, please contact us at (972) 410-6623.  Bright Wealth Management, LLC Form ADV Part 2A Page 3 Item 3 - Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 - Table of Contents ........................................................................................................................ 3 Item 4 - Advisory Business ........................................................................................................................ 4 Item 5 - Fees and Compensation .............................................................................................................. 5 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 ............................................................................................................ 16 Item 10 - Other Financial Industry Activities or Affiliations .................................................................... 17 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 18 Item 12 - Brokerage Practices ................................................................................................................. 18 Item 13 - Review of Accounts ................................................................................................................. 21 Item 14 - Client Referrals and Other Compensation .............................................................................. 21 Item 15 - Custody .................................................................................................................................... 22 Item 16 - Investment Discretion ............................................................................................................. 22 Item 17 - Voting Client Securities ........................................................................................................... 23 Item 18 - Financial Information .............................................................................................................. 23  Bright Wealth Management, LLC Form ADV Part 2A Page 4 Item 4 - Advisory Business Bright Wealth Management, LLC (hereinafter “BWM”) is a registered investment advisor based in Lewisville, Texas. We are a limited liability company, organized under the laws of the State of Delaware. We have been providing investment advisory services since 2014. Bright Capital Group, LLC is the sole owner of BWM. Bright Capital Group, LLC is wholly owned by Bright Industries, LLC, which is owned by two family trusts established by Christopher Roberts Bright and Clay Van Ness Bright. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such individuals are properly registered as investment adviser representatives. Our firm offers continuous discretionary and, in limited cases, non-discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions are made based on your stated investment objectives. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Non- discretionary portfolio management service means that we must obtain your approval before making any transactions in your account. Our investment advice is tailored to meet your needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. BWM generally uses equity securities, exchange traded funds, mutual funds, U.S. government securities, Securities Issued by Pooled Investment Vehicles, and options strategies in its portfolio management programs. Asset allocation models diversified among investment styles and/or asset classes are developed and managed by us based on our internal research. Some of our investment adviser representatives use customized portfolio models developed by them. Once the client portfolio is constructed, we provide continuous supervision of the portfolio as changes in the market conditions and client circumstances may require. Investments and allocations are determined based on the clients’ predefined objectives, risk tolerance, time horizons, financial needs and circumstances, and other suitability factors. Further restrictions and guidelines imposed by clients may affect the composition and performance of a client’s portfolio. As such, different clients of our firm may have significant differences in their asset allocations. Therefore, the performance of one client’s portfolio might not be identical to that of another client’s even if both clients have similar risk parameters. We review the clients’ financial circumstances and investment objectives regularly and make adjustments to clients’ portfolios or allocation models as may be necessary in an effort to achieve the desired results. At all times, our firm requires each investment adviser representative to uphold their fiduciary duty by providing advice that, in our judgement, is in the client’s best interest. As part of its overall portfolio management services, BWM may also recommend that clients invest in BE-FS Fund I, LLC and/or BE-PC FUND I, LLC, private placement offerings managed by Bright Equities, LLC, an exempt reporting adviser affiliated with BWM through common control and ownership. Investments in these offerings are offered and sold only to eligible investors who are both “accredited investors” within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act of 1933, as amended, and are also “qualified purchasers” under Section 3(c)(7) of the Investment Company Act of 1940, as amended. BWM may also recommend that clients invest in Bright Capital Advisors-ATX Venture, LLC, an affiliated private placement offering. Investments  Bright Wealth Management, LLC Form ADV Part 2A Page 5 in this offering are offered and sold only to “accredited investors” as that term is defined in Rule 501(a) of Regulation D promulgated under the Securities Act. Further disclosures about these offerings and the conflicts of interest associated with these investments are provided in Item 10 below. However, when we construct your investment portfolio, we will monitor your portfolio’s performance on a continuous basis and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. investment program. Factors that we take Selection or Recommendation of Other Advisers As part of our investment advisory services, we may engage or recommend that you engage the services of or specific programs, or portfolio models offered through an unaffiliated third-party investment adviser to manage your entire investment portfolio or a portion of your investment portfolio. After gathering information about your financial situation and objectives, we will select or recommend that you engage a specific third-party investment adviser or into consideration when making our selection(s)/recommendation(s) include, but are not limited to, the following: the third-party investment adviser's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the third-party investment adviser’s performance to ensure that the management and investment style remain aligned with your investment goals and objectives. The third-party investment adviser(s) will actively manage your portfolio and will assume discretionary investment authority over your account, or we will assume discretionary authority to hire and fire third-party investment adviser(s) and/or reallocate your assets to other third-party investment adviser(s)/programs where we deem such action to be appropriate. Neither our firm nor individuals associated with our firm serve as officers, directors, or employees of any third-party investment adviser. In some cases, you will be required to sign an agreement directly with the recommended third-party investment adviser(s). You may terminate your advisory relationship with the third-party investment adviser according to the terms of your agreement with the third-party investment adviser. You should review each third-party investment adviser's brochure for specific information on how you may terminate your advisory relationship with the third- party investment adviser and how you may receive a refund, if applicable. You should contact the third-party investment adviser directly for questions regarding your advisory agreement with the third-party investment adviser. Wrap Fee Programs Generally, a wrap fee program combines portfolio management, advisory services, and trade execution for a single fee. BWM does not manage or sponsor any wrap fee programs. Assets Under Management As of December 31, 2025, we managed approximately $264,973,479 in client assets on a discretionary basis and $0 in assets on a non-discretionary basis. Item 5 - Fees and Compensation BWM utilizes a fee-only structure, which means that we are compensated through fees paid by our clients for the services we provide in managing their investment portfolios. BWM fees are typically expressed as a percentage of the assets under management (the value of the client’s portfolio) in accordance with the following breakpoints and the contractual agreement entered into by the client with BWM.  Bright Wealth Management, LLC Form ADV Part 2A Page 6 Annual Percentage 1.50% 1.25% 1.00% 0.75% Negotiable Account Value Under $1,000,000 $1,000,001 to $5,000,000 $5,000,001 to $7,500,000 $7,500,001 to $10,000,000 Over $10,000,000 BWM charges a maximum negotiable fee of 1.50% of assets under management, excluding accounts that contain only fixed-income investments. Fixed income portfolios are subject to a 0.75% fee. Management fees are billed quarterly in arrears pursuant to the client agreement. Fees for the initial quarter are prorated based on the number of days actually invested in that initial quarter. Subsequent fees are calculated quarterly based on the average daily balance and billed at the end of each quarter. The billing statement will provide the average daily balance, the method of calculation, and the amount to be paid. Managed accounts are aggregated by household to qualify for the tiers above. Clients are responsible for transaction charges. Portfolio management fees are negotiable depending on factors such as the amount of assets under management, the range of investments, and the complexity of your financial circumstances, among others. Since this fee is negotiable, the exact fee paid by you will be clearly stated in the advisory agreement signed by BWM and the client. If you provide written authorization to us, the advisory fee will be deducted from your account held with a non- affiliated qualified custodian. The qualified custodian will provide you with an account statement at least quarterly. This statement will detail all account activity, including the advisory fees deducted from your account(s). Our fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other related costs and expenses. You are responsible for brokerage costs incurred. However, BWM will not receive any portion of the commissions, fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction costs. The management agreement between you and BWM will continue in effect until either party terminates the management agreement in accordance with the terms of the management agreement. Refunds are not applicable since fees are paid in arrears. Other Adviser Fees Third-party investment advisers/programs charge separate fees in addition to our above-referenced management fees. The advisory fee you pay to the third-party investment adviser is established and payable in accordance with the brochure provided by each third-party investment adviser to which you are referred. These fees may or may not be negotiable. You should carefully review the recommended third-party investment adviser’s brochure and consider the third party’s fees, program fees, and our fees to determine the total amount of fees you will pay. The total fees paid to us and the third-party investment adviser will not exceed 3.00% of the assets under management. Lower fees may be available from firms that do not utilize or recommend third-party investment advisers/programs. You are not required to use the services of any third party or program we recommend. In some cases, our fee may be calculated by the third-party investment adviser based on the agreed-upon amount set forth in the agreement(s) you sign with us and/or the third-party investment adviser(s). All fees paid to us and the third-party investment adviser will be deducted from the designated account(s) by the account custodian(s) as authorized by you in the agreement(s) you sign with us and/or the third-party investment adviser(s). The  Bright Wealth Management, LLC Form ADV Part 2A Page 7 statements you receive from the qualified custodian(s) holding your account(s) will show the amount of advisory fees paid. You should carefully review account statements for accuracy. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. Additional Fees and Expenses All fees paid to BWM for investment advisory services are separate and distinct from the fees and expenses charged to shareholders by pooled investment vehicles, mutual funds, or exchange traded funds. These fees and expenses are described in each fund's subscription document or prospectus. These fees generally include a management fee, carried interest, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, you will pay an initial or deferred sales charge. You could invest in a mutual fund or an exchange traded fund directly, without the services of BWM. In this case, you would not receive the services provided by BWM, which are designed, among other things, to assist you in determining which mutual fund or funds are most appropriate to your financial condition and objectives. Accordingly, you should review both the fees charged by the funds and the fees charged by BWM to fully understand the total amount of fees to be paid by you to evaluate the advisory services being provided. General Information on Advisory Services and Fees We do not represent, warrant, or imply that the services or methods of analysis employed by us can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person servicing your account may charge more or less for the same service than another Associated Person of our firm. Further, our annual investment management fee may be higher than that charged by other investment advisors offering similar services/programs. Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash-equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there is no guarantee that such anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s).  Bright Wealth Management, LLC Form ADV Part 2A Page 8 Apart from constructive custody triggered as a result of our fee deduction authority, we will not have custody of client funds or securities, as the services of a qualified and independent custodian will be used. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given us written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. Item 6 - Performance-Based Fees and Side-By-Side Management Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Our firm and Associated Persons do not accept performance-based fees. Item 7 - Types of Clients We generally offer investment advisory services to individuals, including pension and profit sharing plan participants, trusts, estates, charitable organizations, corporations, and other business entities. We require a minimum of $100,000 to establish an advisory relationship. At our sole discretion, we may waive this requirement. This requirement can be met by combining two or more accounts owned by you or related family members. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss The following are different methods of analysis that we may use when providing you with investment advice: BWM uses a financial planning process to make appropriate investment recommendations. When managing portfolios, the firm will invest more aggressively during expansionary economic environments and more defensively during contracting economic environments. Investing in securities involves a risk of loss that you should be prepared to bear. In addition, there is no guarantee that BWM will accurately allocate funds across the business cycle. Thus, it may be possible that the firm allocates more aggressively during a downturn, exposing clients to more downside risk than their benchmark; or, similarly, the firm may allocate less aggressively during an expansion, returning less than the client’s benchmark. BWM rebalances and reallocates portfolios quarterly. This trading activity may generate short-term taxable gains and losses. BWM primarily utilizes exchange-traded funds (ETFs) and mutual funds to execute its investment strategy. Because mutual funds may be actively managed, there is no assurance they perform as expected—especially in extreme market environments. ETFs are passively managed to mirror a benchmark; however, there is no assurance that they will deliver the benchmark’s performance, as market liquidity is known to shrink during stressed markets. Additionally, from time to time, BWM utilizes structured products. Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically  Bright Wealth Management, LLC Form ADV Part 2A Page 9 consist of a debt security that is structured to make interest and principal payments based on various assets, rates, or formulas. Many structured products include an embedded derivative component. Structured products may be structured in the form of a security, in which case these products may receive benefits provided under federal securities law, or they may be cast as derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation. Investing in structured products includes significant risks, including valuation, lack of liquidity, price, credit, and market risks. There is a relative lack of liquidity due to the highly customized nature of the investment. Moreover, the full extent of returns from the complex performance features is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment decision rather than a means of getting in and out of a position with speed and efficiency. Structured products are complex and are not suitable for all investors (see additional information below regarding risks associated with investing in structured products). We may use one or more of the following investment strategies when advising you on investments: • • • Long-Term Purchases – securities held for over a year. Short-Term Purchases – securities held for less than a year. Covered Options – a covered option is a strategy in which an investor writes an option contract while at the same time owning an equivalent number of shares of the underlying stock. The investment advice provided along with the strategies suggested by BWM will vary depending on your specific financial situation and goals, as well as the investment adviser representative assigned to your account. The section does not disclose all of the risks and other significant aspects of investing in financial markets. In light of the risks, you should fully understand the nature of the contractual relationship(s) into which you are entering and the extent of your risk exposure. Certain investing strategies may not be suitable for everyone. You should carefully consider whether the strategies employed would be appropriate for you in light of your experience, objectives, financial resources, and other relevant circumstances. General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks, including the possibility of the complete loss of principal plus other losses, and may not be suitable for everyone. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk, and you should familiarize yourself with the risks involved in the particular market instruments in which you intend to invest. Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives, and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise, and investors may not recoup the original amount invested. Investments may also be affected by any changes in exchange control regulations, tax laws, withholding taxes, international, political, and economic developments, and government, economic, or monetary policies. Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes. Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower-quality debt securities are more susceptible to these problems, and their value may be more volatile.  Bright Wealth Management, LLC Form ADV Part 2A Page 10 Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control regulations or changes in exchange rates. Changes in currency exchange rates may influence the share value, the dividends or interest earned, and the gains and losses realized. Exchange rates between currencies are determined by supply and demand in the currency exchange markets, the international balance of payments, governmental intervention, speculation, and other economic and political conditions. If the currency in which a security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a decline in the exchange rate of the currency would adversely affect the value of the security. Margin Risk: When you purchase securities, you may pay for the securities in full, or you may borrow part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account, you will be required to open a margin account, which will be carried by the broker-dealer of your account. The securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a brokerage firm is required to take action, such as issuing a margin call and/or selling securities or other assets in your accounts, in order to maintain a necessary level of equity in the account. It is important that you fully understand the risks involved in trading securities on margin, which apply to any margin account that you may maintain, including any margin account that may be established as a part of our Investment Management Services and held by your broker-dealer. These risks include the following: • • • • • You can lose more funds than you deposit in your margin account. The broker-dealer can force the sale of securities or other assets in your account. The broker-dealer can sell your securities or other assets without contacting you. You may not be able to choose which securities or other assets in your margin account are liquidated or sold to meet a margin call. The broker-dealer may move securities held in your cash account to your margin account and pledge the transferred securities. You may not be entitled to an extension of time on a margin call. Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small market movement will have a proportionately larger impact, which may work for or against the investor. Placing certain orders, which are intended to limit losses to certain amounts, may not be effective because market conditions may make it impossible to execute such orders. Selling an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option, and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. Risks Associated with Investing in Equities: Investing in equities generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value, and the investment may incur a loss. Risks Associated with Investing in Exchange Traded Funds (ETFs): Investing in stocks & ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these securities are not guaranteed or insured by the FDIC or any other government agency.  Bright Wealth Management, LLC Form ADV Part 2A Page 11 Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track. Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will recommend leveraged and/or inverse funds, which may amplify gains and losses. Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly) basis and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund for periods longer than a single day will be the result of each day's returns compounded over the period. Due to the effect of this mathematical compounding, their performance over longer periods can differ significantly from the performance (or inverse performance) of their underlying index or benchmark during the same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage. Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for significant losses. Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF is designed to offer downside protection for a specified period of time. These ETFs are modeled after options- based structured notes, but are generally cheaper and offer more liquidity. Buffer ETFs are designed to safeguard against market downturns by employing complex options strategies. Buffer ETFs typically charge higher management fees that are considerably higher than those of the index funds whose performance they attempt to track. Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features of these complex products. Risks Associated with Alternative Investments: Non-traded REITs, business development companies, limited partnerships, and direct alternatives are subject to various risks, such as liquidity and property devaluation based on adverse economic and real estate market conditions, and may not be suitable for all investors. A prospectus that discloses all risks, fees, and expenses may be obtained from your investment adviser representative. Read the prospectus carefully before investing. This is not a solicitation or offering that can only be made in conjunction with a copy of the prospectus. Investors considering an investment strategy utilizing alternative investments should understand that alternative investments are generally considered speculative in nature and that such investments involve a high degree of risk, particularly if concentrating investments in one or a few alternative investments. Risks Associated with Investing in Structured Products: Structured products are complex and are not suitable for all investors. Structured notes are not bank deposits and are not insured by the Federal Deposit Insurance Corporation or any other governmental agency. The terms and risks of each structured note vary materially  Bright Wealth Management, LLC Form ADV Part 2A Page 12 depending on the nature and volatility of the referenced asset, the creditworthiness of the issuer, and the maturity of the instrument, among other factors. The general risks associated with this type of investment include, but are not limited to, non-payment risk (payment of interest and return of principal may be reduced, in whole or in part, due to underperformance of the referenced asset); counter-party risk (for reasons such as bankruptcy, the issuer of the structured note may fail to pay all or a portion of the principal and interest due on the structured note); underperformance risk (depending on market conditions, the structured note may underperform alternative allocations to traditional bonds, the referenced asset, or a combination of such investments). Structured notes are significantly riskier than conventional debt instruments. There is a risk of loss of some or all of the principal at maturity. Another risk with structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the products themselves are legally considered the issuing financial institution's liabilities. The vast majority of structured products are from high-investment-grade issuers only. In addition, there is a lack of pricing transparency. There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of alternative structured product offerings than it is, for instance, to compare the net expense ratios of different mutual funds or commissions among broker-dealers. Structured Notes: Below are some specific risks related to the structured notes recommended by our firm: • Complexity: Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied by the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and/or fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk, and potential for growth through the term of the structured note. Determining the performance of each note can be complex, and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse- leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with our firm. • • • Market risk. Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some or all of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the notes to investors because issuers include the costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be resold on a daily basis and thus may be difficult to value given their complexity. Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In  Bright Wealth Management, LLC Form ADV Part 2A Page 13 • addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk selling the note at a discount to its value at the time of sale. Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some or all of the principal amount they invested in the structured notes, as well as any other payments that may be due on the structured notes. Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or trade securities. Depending on your objectives, we can help you apply for an SBLOC. This can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business opportunity, or a personal goal, any of which could trigger capital gain taxes. While we do not receive a fee for arranging these loans, our assistance in this process presents a conflict of interest, as we have an incentive for you to maintain these assets in your account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for managing your account. To address this conflict, we only make recommendations to obtain such loans when we believe obtaining an SBLOC is in the best interests of clients. Clients should note that they retain the ultimate decision to obtain such loans. The following are some of the primary risks associated with obtaining an SBLOC: • • • • • Interest rate payments on the principal balance of the loan are not fixed and may increase; If the value of the securities pledged as collateral decreases, you will be liable for any deficiency; The lender can force the sale or liquidation of securities held as collateral without contacting you in advance to meet collateral requirements, and you are not entitled to choose which securities are liquidated or sold; You are only entitled to draw on the line to the extent there is credit availability; and There may be additional risks when money funds or similar investments produce less interest income or other yield than the interest you are paying on the loan. We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or non- purpose loan. While we can assist in the application process, we are not involved in the approval process. Risks Associated with Preferred Securities: Preferred Securities have similar characteristics to bonds in that preferred securities are designed to make fixed payments based on a percentage of their par value and are senior to common stock. Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors, whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and bondholders generally have protections that preferred stockholders do not have, such as indentures that are designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the benefit of bondholders. In contrast, preferred stocks generally pay dividends, not interest payments, which can be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference is that preferred dividends are paid from the issuer’s after-tax profits, while bond interest is paid before taxes. Risks Associated with Concentrated Positions: Certain Associated Persons may recommend that clients concentrate account assets in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated positions in  Bright Wealth Management, LLC Form ADV Part 2A Page 14 specific securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a more diversified portfolio. Investments in issuers within an industry or economic sector that experiences adverse economic, business, political conditions, or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio that holds more diversified investments. Risks Associated with Cybersecurity: Our firm and our service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value, or impeding or sabotaging trading. Clients may also incur substantial costs as a result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of the unauthorized use of their personal information. While our firm has established a business continuity plan and systems designed to prevent cyber- attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cybersecurity risks are also present for issuers of securities, investment companies, and other investment advisers, which could result in material adverse consequences for such entities and may cause a client's investments to lose value. Risks Associated with Pandemics: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors, including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies, and macroeconomic factors could negatively impact investment returns. Political Risk: Each administration presents its own set of policy risks that could impact investors. One of the policy tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope, implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could further impact industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and add to inflation, which can lead to rising interest rates. Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI Tools are also used to record and transcribe client meetings. Clients should note that AI Tools are highly complex and may be flawed. Some are known to hallucinate, reflect biases included in the data on which such tools are trained, are of poor quality, or otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving and could require changes in the  Bright Wealth Management, LLC Form ADV Part 2A Page 15 firm’s implementation of AI Tools, which may increase compliance costs and the risk of non-compliance. Further, the firm may rely on AI Tools developed by third parties, and the firm has limited control over the accuracy and completeness of such AI Tools. Clients who do not want us to record their meetings have the option to opt out at the time of the meeting. Risks Associated with Cryptocurrency: Cryptocurrency (e.g., Bitcoin and Ether), often referred to as “virtual currency,” “digital currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset class. There are thousands of cryptocurrencies, the most well-known of which is Bitcoin. Certain of the firm’s clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly, through an investment such as an ETF or other investment vehicles. Cryptocurrency operates without a central authority or banks and is not backed by any government. Cryptocurrencies may experience very high volatility, and related investment vehicles may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also trade at a significant premium or discount to NAV. Cryptocurrency is also not a legal tender. Federal, state, or foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. The market price of many cryptocurrencies, including bitcoin, has been subject to extreme fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience losses if the value of the client’s investments declines. Similar to fiat currencies (i.e., currencies that are backed by a central bank or a national, supra-national, or quasi-national organization), cryptocurrencies are susceptible to theft, loss, and destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade are relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure than established, regulated exchanges for securities, derivatives, and other currencies. The SEC has issued a public report stating that U.S. federal securities laws require treating some digital assets as securities. Cryptocurrency exchanges may stop operating or be permanently shut down due to fraud, technical glitches, hackers, or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history, making it difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible, such that an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the original sender. Digital assets are highly dependent on their developers, and there is no guarantee that development will continue or that developers will not abandon a project with little or no notice. Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including cryptocurrencies and their source code. Any threatened action that reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies. Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain, and a cryptocurrency investment may produce income that is not treated as qualifying income for purposes of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to the underlying investors. Recommendation of Particular Types of Securities As disclosed under the Advisory Business section in this brochure, we recommend all types of securities, and we do not necessarily recommend one particular type of security over another since each client has different needs and a different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with that investment.  Bright Wealth Management, LLC Form ADV Part 2A Page 16 Material Risks Associated with Investments in BE-FS Fund I, LLC, BE-PC FUND I, LLC, and Bright Capital Advisors- ATX Venture, LLC, are listed in the funds’ offering documents. ‑ ‑ Model Portfolio Risk: Certain products and investment strategies rely on signals and data from various analytical models, tools, or software, which sometimes will be proprietary or from third parties. These models, tools, and software can be adversely impacted by human or system errors in the mathematical foundations of the models, programming, quality of data, and other factors. Accounts that follow model portfolios are subject to risks related to implementation and operational processes. Changes to a model portfolio may be implemented in underlying accounts at different times due to platform processing schedules, account level restrictions, cash availability, minimum investment thresholds, or other operational considerations. As a result, performance among accounts following the same model may vary and may differ from the performance of other accounts advised by BWM. In addition, transitions into or out of a model portfolio, including situations where certain investment options are available only within a model, may give rise to transaction timing, allocation, or market impact risks. Some client portfolios deviate from our model portfolios due to client preferences, restrictions, tax considerations, or other factors. Such deviations may result in different performance outcomes than the model and among different clients. Additionally, investment strategies and customized models among our investment adviser representatives can differ. For clients who work with Thomas Underwood as their assigned representative, please carefully review the ADV Part 2B for Mr. Underwood for information regarding his specific management strategy, process, and customized models used to manage your portfolio. Selection or Recommendation of Other Advisers In the event we select or recommend a third-party investment adviser to manage all or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on investment model portfolios and strategies developed by third-party investment advisers and their portfolio managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or benchmark, we may change models (or recommend changing models), or we may replace (or recommend replacing) a third-party investment adviser. The primary risk associated with investing with a third party is that while a particular third party may have demonstrated a certain level of success in the past, it may not be able to replicate that success in future markets. In addition, as we do not control the underlying investments in third-party model portfolios, there is also a risk that a third party may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a consistent level of performance and success over time. A third party’s past performance is not a guarantee of future results, and certain market and economic risks exist that may adversely affect an account’s performance and could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment strategies, methods of analysis, and associated risks. Item 9 - Disciplinary Information Registered investment advisers are required to disclose all reportable material facts regarding any legal or disciplinary events that would be material to your evaluation of us or of the integrity of our management. Neither BWM nor its management persons have a history of reportable, material legal or disciplinary events that are required to be reported in this section.  Bright Wealth Management, LLC Form ADV Part 2A Page 17 Item 10 - Other Financial Industry Activities or Affiliations Bright Wealth Management, LLC (“BWM”) is affiliated through common control and ownership with the following entities: Bright Equities, LLC is an exempt reporting adviser affiliated with BWM through common control and ownership. Bright Equities serves as the General Partner and Investment Manager to BE-FS Fund I, LLC and BE-PC FUND I, LLC, private placements offered and sold only to eligible investors who are both “accredited investors” within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act of 1933, as amended and are also “qualified purchasers” under Section 3(c)(7) of the Investment Company Act of 1940, as amended. Bright Capital Advisors, LLC is the Managing Member of Bright Capital Advisors-ATX Venture, LLC, a private placement offered and sold only to “accredited investors” as that term is defined in Rule 501(a) of Regulation D promulgated under the Securities Act. Neither BWM nor Bright Equities serves as the Investment Manager to the Bright Capital Advisors-ATX Venture, LLC fund. Investors to whom these private placement offerings are offered will receive a private placement memorandum and other offering documents. As part of its overall portfolio management services, BWM will recommend that some clients invest in BE-FS Fund I, LLC, BE-PC FUND I, LLC, and/or Bright Capital Advisors-ATX Venture, LLC (“funds”). This situation presents a conflict of interest because BWM and its Associated Persons have an incentive to recommend related funds that generate compensation for affiliated entities over unaffiliated funds that do not generate any compensation for the firm’s affiliates. BWM will uphold its fiduciary duty by placing the interests of clients first, by acting in the utmost good faith, and by recommending investments that are suitable to the client’s needs. Please refer to the offering documents for a complete description of the fees, conflicts of interest, investment objectives, risks, and other important information associated with investing in the funds. Bright Insurance Services, LLC (“Bright Insurance”) is a full-service general insurance agency licensed by the Texas Department of Insurance. At this time, this entity is inactive. Bright Realty, LLC (“Bright Realty”) is a full-service real estate company offering real estate development, funding, land brokerage, customized property management and accounting, leasing advisory services, owner and tenant representation, project management and consulting, construction services, and asset disposition. Bright Realty’s main focus is on the development, funding, management, and leasing of residential, office, multi-family, mixed- use, and retail projects. In addition to developing its own real estate projects, Bright Realty has worked with developers to be the equity or lender partner for hundreds of properties. In general, BWM expects to conduct its activities in a manner that is separate and independent from the activities of Bright Realty and its affiliated entities. In light of Bright Realty’s focus on real estate investments, BWM does not expect that its investment activities will conflict with the transactions and strategies employed by BWM in managing client accounts. Selection or Recommendation of Other Advisers As disclosed above in this brochure, we may engage or recommend that you engage a third-party investment adviser or program as part of our asset allocation and investment strategy. We continually monitor client assets managed by third-party investment advisers that we select or recommend. If a selected or recommended third- party investment adviser is not meeting the standards that we believe meet your needs, we will seek other third- party investment advisers/models that we believe will better fit your specific management needs. Please see Items 4, 5, and 8 of this brochure for additional information regarding this topic.  Bright Wealth Management, LLC Form ADV Part 2A Page 18 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics BWM has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes BWM’s policies and procedures developed to protect clients’ interests in relation to the following topics: • • • • The duty at all times to place the interests of clients first; The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the code of ethics; The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s position of trust and responsibility; The fiduciary principle that information concerning the identity of security holdings and the financial circumstances of clients is confidential; and • Having a reasonable and adequate basis, supported by appropriate research and investigation, for any investment analysis, recommendation, or action; and The principle that independence in the investment decision-making process is paramount. • A copy of BWM’s Code of Ethics is available upon request to Paul Thibodeaux, Chief Compliance Officer, at (972) 410-6623. Participation or Interest in Client Transactions As disclosed above in Item 10, BWM recommends that some clients invest in BE-FS Fund I, LLC, BE-PC FUND I, LLC, and/or Bright Capital Advisors-ATX Venture, LLC (“funds”). This situation presents a conflict of interest because BWM and its Associated Persons have an incentive to recommend related funds that generate compensation for affiliated entities over unaffiliated funds that do not generate any compensation for the firm’s affiliates. BWM will uphold its fiduciary duty by placing the interests of clients first, by acting in the utmost good faith, and by recommending investments that are suitable to the client’s needs. Personal Trading Practices Our firm and Associated Persons of our firm buy or sell some of the same securities that we recommend to clients or securities in which clients are already invested. A conflict of interest exists because we could trade ahead of client accounts and potentially receive more favorable prices. However, neither our firm nor our Associated Persons shall have priority over client accounts in the purchase or sale of securities. Item 12 - Brokerage Practices BWM does not maintain custody of your assets; however, we are deemed to have constructive custody of your assets when clients give us authority to withdraw advisory fees from their account (see Item 15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Schwab Advisor Services BWM has established an institutional custodial relationship with Charles Schwab & Co., Inc. (Schwab), a FINRA- registered broker-dealer, member SIPC. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. We are independently owned and operated, and we are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and will buy and sell securities in your account(s) upon our instructions. While we recommend that you use Schwab as  Bright Wealth Management, LLC Form ADV Part 2A Page 19 custodian/broker, you will decide whether to do so, and you will open your account with Schwab by entering into an account agreement directly with them. Your Custody and Brokerage Costs Schwab generally does not charge you separately for custody services, but it is compensated by charging commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges 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 (settled) into your Schwab account. Research and Other Benefits Although not considered “soft dollar” compensation, BWM may receive some economic benefits from Schwab Advisor Services in the form of access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we do not have to request them) and at no charge to us. Below is a 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 that we might not otherwise have access to, or that would require a significantly higher minimum initial investment from our clients. Schwab’s services described in this paragraph generally benefit you and your account. 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 or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist 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 enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants, and insurance providers. • • • • Schwab may provide some of these services itself. In other cases, 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 part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment for our personnel.  Bright Wealth Management, LLC Form ADV Part 2A Page 20 General Information Regarding Recommended Custodians BWM understands its duty for best execution and considers all factors in making recommendations to clients. These research services may be useful in servicing all BWM clients and may not be used in connection with any particular account that may have paid compensation to the firm providing such services. While BWM may not always obtain the lowest commission rate, BWM believes the rate is reasonable in relation to the value of the brokerage and research services provided. Before BWM approves a custodian for recommendation to clients, and annually thereafter, BWM will review, as applicable, the custodian’s operational, financial, and regulatory status, as well as their technological offerings, research capabilities, and execution capabilities, among other factors. Transaction charges, commissions, and fees may be higher or lower than clients would pay at other firms. BWM believes the pricing and services provided by Schwab are competitive with those of other firms offering similar services. It is important to note that some products, securities, and/or money managers may not transition from the client’s previous advisory firm to BWM. Such positions would subsequently be required to be liquidated, resulting in potential transaction fees, as well as other changes to the account(s). Brokerage for Client Referrals We do not receive client referrals from broker-dealers and custodians with whom we have an institutional advisory arrangement. In addition, we do not receive other benefits from a broker-dealer in exchange for client referrals. Directed Brokerage We routinely recommend that you direct our firm to execute transactions through one or more broker-dealers with which we have a business relationship. As such, we may be unable to achieve the most favorable execution of your transactions, and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. Trade Aggregation (Block Trading) When rebalancing our model portfolios, BWM generally aggregates transactions in equity and fixed income securities across client accounts for an average share price. Accounts owned by our firm or our Associated Persons may participate in block trading with client accounts; however, they will not be given preferential treatment. Detailed records of each block trade executed by the firm and the allocation of shares are maintained by BWM. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you, and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. We are not able to combine orders for non- discretionary accounts, as we may not be able to obtain prior client consent in a timely manner in order for non- discretionary accounts to participate in time-sensitive block trades. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts for transactions in the same securities. Additionally, client accounts managed by Thomas Underwood do not participate in block trades. Therefore, they may pay different costs than other accounts managed by Mr. Underwood or other BWM client accounts managed by other BWM representatives for transactions in the same securities. Please see the Part 2B Brochure Supplement for Mr. Underwood for additional information regarding his investment strategy and process.  Bright Wealth Management, LLC Form ADV Part 2A Page 21 Item 13 - Review of Accounts Portfolio Management Account Reviews Client accounts and holdings are monitored on a continuous basis. Formal account reviews with the client are recommended to the client at least annually. Internal account reviews are conducted at least quarterly by the investment adviser representative assigned to the account and/or the Chief Compliance Officer. Generally, we review the underlying portfolio assets, current market conditions, investment results, asset allocation, etc., to ensure investment strategy and expectations remain aligned with the client’s stated goals and objectives. Our investment committee meets at least quarterly, where we review portfolio model performance, an economic chartbook, and discuss proposed changes to our portfolio model allocations. Generally, portfolios are rebalanced to the approved allocations accordingly. We perform due diligence on the investments in our portfolios at least annually regarding performance, volatility, and competitive costs. Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation or investment objectives, or upon client request. Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. BWM also provides performance reports quarterly. Item 14 - Client Referrals and Other Compensation Client Referrals BWM and its related persons do not compensate, directly or indirectly, any entity or person who is not a supervised person of our firm for client referrals. In addition to their regular salary, investment adviser representatives of the firm may be eligible for an annual discretionary bonus, which may be determined, at least in part, based on the number of clients or amount of client assets they refer to the firm. Such arrangements do not cause clients to pay additional or higher advisory fees. Selection or Recommendation of Other Advisers We may select third-party investment advisers, models, or programs, or we may recommend that you use a third- party investment adviser or program as part of our asset allocation and investment strategy. BWM typically shares in the compensation received by the third-party investment adviser. The compensation arrangement presents a conflict of interest due to a financial incentive to recommend the services of a third-party investment adviser. Since our compensation may differ depending upon our individual agreement with each third-party adviser, we have an incentive to recommend one third-party adviser over another third-party adviser with whom we have less favorable compensation arrangements or with whom we have no compensation arrangements. At all times, BWM and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. You are not required to use the services of any recommended third-party investment adviser. Other Compensation BWM has brokerage and clearing arrangements with Schwab, and the firm may receive additional benefits from these firms in the form of electronic delivery of client information, electronic trading platforms, institutional trading support, proprietary and/or third-party research, continuing education, practice management advice, and other services provided by custodians for the benefit of investment advisory clients. Please refer to item 12 above for more information about the receipt of additional benefits from broker-dealers/account custodians.  Bright Wealth Management, LLC Form ADV Part 2A Page 22 Item 15 - Custody BWM does not act as custodian for client assets. BWM maintains client assets with a qualified custodian as defined in Rule 206(4)-2 of the Advisers Act. However, under Rule 206(4)-2 under the Advisers Act, BWM is deemed to have custody of client assets in cases where it debits advisory fees from the clients’ accounts held by a qualified custodian, such as Schwab, or it accepts standing letters of authorization to transfer client assets from a client’s account to a third party. In all cases, the firm follows regulatory requirements for safeguarding client assets. Clients should receive account statements monthly or quarterly from the broker-dealer, bank, or other qualified custodian that holds and maintains the client’s portfolio of investment assets. BWM urges clients to carefully review such statements and compare such official custodial records to the account statements that BWM may provide. BWM’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. See Item 13 – Review of Accounts of this Brochure for more information about BWM’s account statements. Since BWM does not act as a custodian for client assets, each client must select a custodian and may be required to pay custodian fees. In addition, clients will incur brokerage and other transaction costs in the course of BWM’s management of their accounts. Clients will receive account statements from one or more qualified custodians covering the assets and securities in their account(s). Under SEC Rule 206(4)-2, an affiliate of BWM, Bright Capital Advisors, may be viewed as having custody of certain client assets due to Bright Capital Advisors’ role as the managing member of Bright Capital Advisors-ATX Venture, LLC. BWM does not consider the assets of any BWM client that may be invested in this fund as assets of BWM. BWM does not collect a fee on these assets, nor recommends this investment to a client. BWM also does not report any investment a client may have in this fund on any statement provided by BWM. BWM encourages each client to review the report received directly from Bright Capital Advisors-ATX Venture, LLC. BWM also encourages any client to contact Bright Capital Advisors directly should they have any questions regarding their investment. Item 16 - Investment Discretion BWM offers Portfolio Management Services on a discretionary basis. Clients must grant discretionary authority in the management agreement. Discretionary authority extends to the types and amounts of securities to be bought and sold in client accounts. Apart from the ability to withdraw management fees, BWM does not have the ability to withdraw funds or securities from the client’s account. The client provides BWM discretionary authority via a limited power of attorney in the management agreement and the contract between the client and the custodian. If you wish, you may limit our discretionary authority, for example, by setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer to the “Advisory Business” section in this Brochure for more information on our discretionary management services. If you have engaged us for non-discretionary portfolio management services, BWM will obtain your approval before executing all transactions in your account(s).  Bright Wealth Management, LLC Form ADV Part 2A Page 23 Item 17 - Voting Client Securities BWM will not vote proxies on behalf of client accounts. However, at the client’s request, BWM may offer clients advice regarding corporate actions and the exercise of proxy voting rights and/or materials. Questions about proxies may be made via the contact information on the cover page. Item 18 - Financial Information We are required in this Item to provide you with certain financial information or disclosures about BWM’s financial condition. BWM does not require prepayment of over $1,200, six or more months in advance. Additionally, BWM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and it has not been the subject of a bankruptcy proceeding.