ROCKPORT WRAP FEE BROCHURE

ROCKPORT WEALTH, LLC doing business as “Rockport Wealth Advisors” FORM ADV 2A, APPENDIX 1 WRAP FEE PROGRAM BROCHURE This wrap fee program Brochure provides information about the qualifications and business practices of Rockport Wealth, LLC (doing business as “Rockport Wealth Advisors”). If you have any questions about the contents of this Brochure, please contact us (216) 226-4560 or via email to compliance@rockportwealth.com. The information in this Brochure has not been approved or verified by or the United States Securities and Exchange Commission (“SEC”) or any state securities regulator. Registration does not imply a certain level of skill or training. Additional information about Rockport Wealth is available on the SEC’s Advisor Search website at www.adviserinfo.sec.gov. Rockport Wealth’s CRD number is: 297122 22730 Fairview Center Dr Suite# 150 Fairview Park, OH 44126 (216) 226-4560 7227 Glenwood Ave Youngstown, OH 44512 Phone: (330) 965-9890 compliance@rockportwealth.com https://www.rockportwealth.com June 1, 2026 Item 1: Cover page 1  ITEM 2: MATERIAL CHANGES Rockport Wealth, LLC, dba “Rockport Wealth Advisors” (hereinafter referred to as the “Advisor”) has the following material changes to report since its last annual amendment to this Brochure filed March 23, 2026: Item 4: Services, Fees, and Compensation Under the Fees and Termination of Services sections, we removed references to legacy contract fees and billing arrangements as all accounts are in the process of being moved to monthly, advanced billing utilizing the fee schedule as stated in this section. Item 6: Portfolio Manager Selection and Evaluation Under the Voting Client Securities (Proxies) section, we removed any references to our proxy voting procedures as the firm no longer votes proxies on behalf of clients. The following amendments have additionally been made within the past year: Item 4: Services, Fees, and Compensation The following information was added to the Services section regarding the purchase of J Arnold Wealth Management: In February of 2024, RWA purchased another registered investment advisor firm, J Arnold Wealth Management (“JAWM”). As of that date, the owner of JAWM, Jon Arnold, had no ownership role in RWA. A conflict of interest existed because a portion of the compensation paid to Mr. Arnold for the sale of his firm was dependent upon whether a significant number of the assets under management by JAWM transferring to RWA as part of the purchase. Mr. Arnold was to continue to work with RWA as an Investment Advisor Representative under RWA’s supervision and as a consultant with RWA, participating in the Investment Committee alongside Joseph Kovach and Adam Stalnaker. Later, it was discovered that JAWM’s Form ADV Part 2A and Investment Management Agreement stated that fees would be charged according to total assets under management by household rather than by account. As part of our standard onboarding and account transition process, we may review certain historical account records relating to advisory services previously provided by another investment adviser. Based solely on the documentation made available to us, the fee calculations reflected in those records may not correspond in all respects with the billing methodology described in the applicable written advisory agreement between the client and the prior adviser. Our firm was not involved in the prior adviser’s fee calculation or billing processes and did not supervise or oversee such activities. Our review is limited in scope and is not conducted as an audit, verification, or comprehensive analysis of the prior adviser’s records or practices. Accordingly, we make no representation regarding the accuracy, completeness, or appropriateness of any prior fee calculations. 2  Clients with questions regarding historical advisory fees should contact the prior investment adviser directly for clarification regarding the billing methodology applied. This disclosure is provided for informational and transparency purposes only. Mr. Arnold is no longer an Investment Advisor Representative of RWA, but he does currently act as a promoter of the firm. Also, as Jon Arnold is no longer affiliated as an Investment Advisor Representative of Rockport Wealth Advisors, all references to J Arnold Wealth Management and Jon Arnold have been removed from this Brochure. The following clarification was also added to the Services section regarding the treatment of billing and fees incurred for private placements not recommended by Rockport Wealth Advisors: RWA will not hold outside private placements not recommended by the firm; RWA will assist in the facilitation of redemptions of these assets as needed and upon client request. For any legacy private placements not recommended by the Advisor but being held by RWA, these assets are not included in the wrap program. The Advisor will not bill the client on these assets, and the client is responsible for the alternative asset maintenance fee. The following information regarding RWA’s Strategic Models was added to the Services section: Strategic Models Certain RWA investment management services, referred to as the Strategic Models, provide for an alternative management style. The designed strategy utilized may involve certain investments being held for short terms. This approach is similar to a short-term market timing strategy and is not appropriate for every type of investor It is also unlike a typical “style-box” strategy that remains fully invested in all market environments regardless of the risk/reward potential. The asset allocation model determines the percentage of assets that are appropriate to invest in equities, exchange traded funds (“ETFs”), bonds and cash and/or fixed income at any given time. From time to time, these management strategies may result in over-weighted positions in particular market sectors and/or industries, which can be more volatile and/or underperform relative to the market as a whole. Please refer to Item 8.A of this Brochure for further investment strategy information. The strategy of the Strategic Models is limited to the types of investments noted in the previous page. While the firm attempts to accommodate certain reasonable investment restrictions such as amounts invested in the types of investments, the other investment strategies available through RWA may be more appropriate for investors who would prefer an alternative to a more active risk on - risk off strategy with limited classes of investments. Performance results for this investment style are best analyzed over a market cycle due to the fact that the strategies may not correlate to the broader market. As with most investment strategies, it may be possible that the value of a managed account may depreciate in value over periods of time when the overall market may (be up) (appreciate in value). The strategies seek to obtain consistent returns in a bull or bear market. There is no assurance that a model’s goal will be realized. Obviously long-term or choppy markets can persist. As at Item 8 of this Brochure, no investment strategy can guarantee profits, and all investors must be prepared for an investment loss. 3  Investors should not expect to be fully invested at all times, as these strategies maintain the ability to move into money market or defensive positions either partially or fully (such as fixed income or money market funds). When in a money market, the investor loses the potential for market appreciation within the account. Further, after the application of advisory fees, the account will lose value. If during the engagement a client directs the Advisor to move all or a portion of assets into a money market fund, the Advisor takes no responsibility on timing the move out or back into the designed investment strategy as the client is electing to self-direct the account during that time. Frequent trading may impact investment performance and tax implications. Investors should consult with their personal tax adviser in connection with securities transactions and/or any particular investment(s) held in their account(s). These strategies may not be appropriate for every type of investor. The strategies may deploy short-term trading strategies in an effort to capitalize on shorter-term market moves and as a result, a higher number of transactions may occur over a relatively short period of time. More transactions could result in higher fees in individual accounts which is why the Advisor’s wrap fee program is utilized, as discussed below and at Item 5 of this Brochure. Some mutual funds / fund families impose redemption charges on funds held for less than the required minimum period, as determined by the fund (ref. prospectus). While best efforts are made to avoid these charges, clients may incur them from time. The following was updated in the Fees section, disclosing the fee schedule for all new accounts, updating information regarding how fees are charged, and clarifying agreement termination requirements. The Advisor’s Program fees are calculated as a percentage of assets under management by household and combines portfolio management, commissions, trade execution costs, custody and other standard brokerage services within a single investment management fee. The fee does not include separate administrative costs that may be charged by sponsors of mutual funds or excluded funds held in the account. The agreed upon annual fee is negotiable, based on the nature, complexity, and scope of services as well as the amount and nature of assets to be managed, pre-existing relationships, and other factors, at the discretion of the Advisor as follows: Account Value $0 - $500.000 $500,001 and above Standard Fee Schedule 1.25% 1.00% or negotiable All fees are negotiable The fees are charged based on a flat percentage using total account value (including cash and cash equivalent positions such as money market funds), as opposed to a tiered rate. The account value will be based upon the total value of all accounts attributable to the same household, so the same fee rate will be applied to each of those accounts. Different accounts within a household may have a different fee structure based on the assets involved. The agreed upon fee schedule and cadence will be established in the Advisor’s Client Agreement. For all new accounts, fees are paid monthly in advance, except for the initial month which is billed pro rata in arrears. 4  RWA has had different fee schedules in place in the past and, as stated above, our fees are negotiable at our discretion, which means that not all RWA clients are paying the same fees. Should moving to the fee schedule stated above lower your fees, we will automatically move you to the new, lower fee schedule. However, if moving to the above listed fee schedule would raise your fees, your legacy agreed upon fee will remain in place; if your fee was a negotiated fixed rate, your legacy agreed upon fee will remain in place. Please refer to your Client Agreement or reach out to RWA if you are unsure as to your agreed upon fee schedule. Your fees are paid monthly and according to the payment timing (arrears or advance) as specified in your Client Agreement. The investment management fee may be revised during the engagement, particularly if different needs and/or complexities arise, or the scope of services should change. In such cases, the Advisor will notify the client of its intention to modify the fee with at least 30 days’ written notice. Should the client decide not to accept the amended fee terms, the client is welcome to terminate services with 5 days’ written notice prior to the effective date of the fee modification. Item 5: Account Requirements and Types of Clients This section was updated to the following: The Advisor offers investment advisory services to individuals and high net worth individuals. The suggested account minimum for investment management services is $250,000 but can be negotiated based upon individual circumstances. A client seeking performance-based services, as discussed at Item 5.A of this brochure, must meet the definition of a qualified client as established by the United States Securities and Exchange Commission (assets under the Advisor’s management of at least $1,100,000, or a minimum liquid net worth of $2,200,000). Item 6: Portfolio Manager Selection and Evaluation The following risks were added to the section: Fixed Income Risk: Fixed income securities are subject to the risk of the issuer’s or a guarantor’s inability to meet principal and interest payments on its obligations and to price volatility. Fixed-income securities are generally subject to the following risks: • Interest Rate Risk. The value of investments in fixed-income securities will change based on changes in interest rates. If interest rates increase, the value of these investments generally declines. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. • Extension Risk. If interest rates rise, repayments of principal on certain fixed- income securities may occur at a slower-than-expected rate and, as a result, the expected maturity of such securities could lengthen which could cause their value to decline. • Credit Risk. Fixed income investments are subject to the risk that issuers and/or counterparties will fail to make payments when they are due or default completely. Prices of the investments may be adversely affected if any of the issuers or counterparties are subject to an actual or perceived deterioration in their credit quality. Credit spreads may increase, which may reduce the market values of fixed income securities. Credit spread risk is the risk that economic and 5  market conditions or any actual or perceived credit deterioration may lead to an increase in the credit spread (i.e., the difference in yield between two securities of similar maturity but different credit quality) and a decline in price of the issuer’s securities. • Prepayment Risk. Issuers of certain fixed income securities may be able to prepay principal due on these securities, particularly during periods of declining interest rates, and Villere may have to invest the proceeds in lower-yielding securities. Large-Sized Companies Risk: Larger, more established companies may be unable to respond quickly to new competitive challenges like changes in consumer tastes or innovative smaller competitors. In addition, large-cap companies are sometimes unable to attain the high growth rates of successful, smaller companies, especially during extended periods of economic expansion. Market Capitalization Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium-cap companies may face a greater risk of business failure, which could increase the volatility of the clients’ portfolios. Small- and Medium-Sized Companies Risk: Investing in securities of smaller companies including micro-cap, small-cap, medium-cap and less seasoned companies often involve greater volatility than investing in larger, more established companies and these securities may be less liquid than other securities. Sector/Industry Risk: In connection with Jon Arnold’s management strategy, from time to time, client portfolios may have overweighted positions in particular market sectors and/or industries, which can be more volatile and/or underperform relative to the market as a whole. Tax Considerations: The Advisor’s strategies and investments can have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Unaffiliated Money Managers: If a portion of your assets is managed by a third-party money manager (such as Betterment), we will not determine the investments to be made for your account, but we will monitor the investments in the accounts and advise you on those holdings for so long as we are providing investment management services. Delaware Statutory Trusts. These investments have a unique set of risks and are only appropriate for accredited investors. Risks may include but are not limited to: Illiquidity risk (investment must be held for an extended period of time), loss of control (no decision making over property, sponsor controls management and selling of property), regulatory risk (change in tax rules which could result in tax liabilities), execution risk (operator competence) and economic risk. There can be no assurance that a property will perform as projected and Delaware Statutory Trusts are subject to economic volatility, tenants not paying their rent as expected, and other traditional risks of owning, selling, and operating real estate. The fees and expenses of each offering should be carefully evaluated. Multiple owner offerings typically have additional expenses versus owning real estate on your own and these fees should be weighed against specific capital gains tax liability. All investors are encouraged to have their tax and legal counsel advise them on taxes including any federal and state 6  capital gains taxes, depreciation recapture and any other tax issues, which could be applicable. Covered Call Options. While this strategy can provide income, it limits your ability to participate in any increase in the price of the underlying security above the strike price. Furthermore, a covered call strategy does not eliminate the risk of market- based losses on the underlying stock. In fact, if the stock price declines, the premium received from the option may not be sufficient to offset the loss in the value of the underlying security. Additionally, the option can be exercised at any time, requiring you to sell the underlying security at the strike price, potentially below the market price. Market conditions can negatively impact option values or the ability to close positions favorably and the forced sale of shares upon assignment may trigger taxable events. Inverse ETFs. This strategy is used to hedge client portfolios against market downturns or to seek returns that are the inverse of a specific benchmark on a daily basis. They are designed to achieve their investments objectives on a daily basis. They are not intended to track the underlying index over periods longer than a single day. Due to the effect of daily compounding, performance over longer periods can differ significantly from the inverse of the underlying index. In volatile markets, an inverse ETF may lose money even if the underlying index decreases over time. Holding inverse ETFs for longer than one trading session increases risk due to the compounding of returns. As such, these investments are generally considered unsuitable for long-term holding. These products may not achieve their stated objectives. If the market rises, the inverse ETF will lose value, and you may lose a significant portion or all of your principal investment. The following update was made regarding the Advisor’s proxy voting policy: As a matter of policy and practice, RWA will not vote proxies on behalf of clients. Clients will retain voting authority and can expect to receive voting materials directly from their custodian. The Advisor is available to assist clients with questions and concerns relating to proxies. The Advisor does not engage in proxy-related discussions with non-clients and does not solicit proxies. Item 9 Additional Information The Other Financial Industry Affiliations section was updated to reflect the following: Investment Advisor Representative, Andrew Smith, is the owner of an accounting firm and receives separate and customary payment for delivering any accounting related services. Some advisory clients may also be accounting clients of Mr. Smith. This creates a conflict in that Mr. Smith has an incentive to recommend his accounting firm to RWA clients and RWA to accounting clients. Clients are under no obligation to utilize Mr. Smith for any accounting services. Item 2: Material Changes 7  ITEM 3: TABLE OF CONTENTS Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 8 Item 4: Services, Fees, and Compensation 9 Item 5: Account Requirements and Types of Clients 15 Item 6: Portfolio Manager Selection and Evaluation 15 Item 7: Client Information Provided to Portfolio Managers 22 Item 8: Client Contact with Portfolio Managers 22 Item 9: Additional Information 22 8  ITEM 4: SERVICES, FEES, AND COMPENSATION Services Rockport Wealth, LLC, dba “Rockport Wealth Advisors” (hereinafter referred to as the “Advisor”) offers The Rockport Wealth Wrap Fee Program. (the “Program”). The Program combines a portfolio management fee as well as commission and trade execution costs within a single, bundled fee. In February of 2024, RWA purchased another registered investment advisor firm, J Arnold Wealth Management (“JAWM”). As of that date, the owner of JAWM, Jon Arnold, had no ownership role in RWA. A conflict of interest existed because a portion of the compensation paid to Mr. Arnold for the sale of his firm was dependent upon whether a significant number of the assets under management by JAWM transferring to RWA as part of the purchase. Mr. Arnold was to continue to work with RWA as an Investment Advisor Representative under RWA’s supervision and as a consultant with RWA, participating in the Investment Committee alongside Joseph Kovach and Adam Stalnaker. Later, it was discovered that JAWM’s Form ADV Part 2A and Investment Management Agreement stated that fees would be charged according to total assets under management by household rather than by account. As part of our standard onboarding and account transition process, we may review certain historical account records relating to advisory services previously provided by another investment adviser. Based solely on the documentation made available to us, the fee calculations reflected in those records may not correspond in all respects with the billing methodology described in the applicable written advisory agreement between the client and the prior adviser. Our firm was not involved in the prior adviser’s fee calculation or billing processes and did not supervise or oversee such activities. Our review is limited in scope and is not conducted as an audit, verification, or comprehensive analysis of the prior adviser’s records or practices. Accordingly, we make no representation regarding the accuracy, completeness, or appropriateness of any prior fee calculations. Clients with questions regarding historical advisory fees should contact the prior investment adviser directly for clarification regarding the billing methodology applied. This disclosure is provided for informational and transparency purposes only. Mr. Arnold is no longer an Investment Advisor Representative of RWA, but he does currently act as a promoter of the firm. In addition to “Advisor”, you will see the term, “Investment Advisor Representatives” used in this Brochure. This term refers to those persons who are appropriately registered and authorized by the Advisor to deliver investment advisory services on behalf of the Advisor. The Advisor, as the Program’s manager, together with its investment adviser representatives, are responsible for research, security selection, and implementation of transaction orders in the Client's account. The Advisor receives a portion of the Program fee for its services. The transactions in the Client's account will be executed by and custodied at Charles Schwab & Co., Inc., a FINRA registered broker-dealer and Member SIPC. The Program pays Charles Schwab & Co., Inc, a portion of its fee for commissions and trade execution expenses. The Program’s investment management services are ongoing in nature, focus solely on portfolio management, and include financial planning services. This service does not include consultation services outside the scope of the managed investments. Investment management services are ongoing until terminated in writing by either party. Services are provided under this wrap fee program, which provides for portfolio management fees for all 9  assets including private placements recommended by the Advisor as well as commission, trade executions costs, custody, and other standard brokerage services within a single, bundled fee. RWA will not hold outside private placements not recommended by the firm; RWA will assist in the facilitation of redemptions of these assets as needed and upon client request. For any legacy private placements not recommended by the Advisor but being held by RWA, these assets are not included in the wrap program. The Advisor will not bill the client on these assets, and the client is responsible for the alternative asset maintenance fee. Program services begin only after the Client and Advisor formalize the relationship with a properly executed client agreement. After the formal engagement and depending upon the scope of the engagement, the Advisor and client will share in a data gathering and discovery process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client and the nature of services requested. The Advisor and its client will normally complete a risk assessment, investment policy statement (“IPS”) or similar document, depending upon the scope of services to be provided. After an analysis and data-gathering process and depending upon the nature of services requested, The Advisor may prepare reviews, analysis, asset allocation recommendations, and may recommend specific investments. The Advisor utilizes the information provided by the client to prepare portfolio recommendations or adjustments in an existing portfolio. The Advisor can tailor services as desired by the client, however where Investment Management Services or information are limited, clients must understand that comprehensive investment needs and or objectives may not be fully considered due to the client’s option not to receive limited services, the lack of information received, and/or client disclosure. As the Program’s Manager, the Advisor is responsible for the research, security selection and implementation of transactions in clients’ accounts. Recommended investments will normally include (as appropriate for each client’s stated situation): exchange traded index funds, mutual funds, other similar equity related index funds, stocks, bonds, real estate investment trusts, master limited partnerships, money market funds, U.S. treasury funds, cash sweep accounts, covered calls, inverse ETF derivatives and other liquid cash and cash-like vehicles. Please refer to Item 6 of this Brochure for additional information. Strategic Models Certain RWA investment management services, referred to as the Strategic Models, provide an alternative management style. The designed strategy utilized may involve certain investments being held for short terms. This approach is similar to a short-term market timing strategy and is not appropriate for every type of investor. It is also unlike a typical “style-box” strategy that remains fully invested in all market environments regardless of the risk/reward potential. The asset allocation model determines the percentage of assets that are appropriate to invest in equities, exchange traded funds (“ETFs”), bonds and cash and/or fixed income at any given time. From time to time, these management strategies may result in over-weighted positions in particular market sectors and/or industries, which can be more volatile and/or underperform relative to the market as a whole. Please refer to Item 8.A of this Brochure for further investment strategy information. The strategy of the Strategic Models is limited to the types of investments noted in the previous page. While the firm attempts to accommodate certain reasonable investment restrictions such as amounts invested in the types of investments, the other investment strategies available through RWA may be more appropriate for investors who would prefer an alternative to a more active risk on - risk off strategy with limited classes of investments. Performance results for this investment style are best analyzed over a market cycle due to the fact that the strategies may not correlate to the broader market. As with most investment 10  strategies, it may be possible that the value of a managed account may depreciate in value over periods of time when the overall market may (be up) (appreciate in value). The strategies seek to obtain consistent returns in a bull or bear market. There is no assurance that a model’s goal will be realized. Obviously long-term or choppy markets can persist. As at Item 8 of this Brochure, no investment strategy can guarantee profits, and all investors must be prepared for an investment loss. Investors should not expect to be fully invested at all times, as these strategies maintain the ability to move into money market or defensive positions either partially or fully (such as fixed income or money market funds). When in a money market, the investor loses the potential for market appreciation within the account. Further, after the application of advisory fees, the account will lose value. If during the engagement a client directs the Advisor to move all or a portion of assets into a money market fund, the Advisor takes no responsibility on timing the move out or back into the designed investment strategy as the client is electing to self-direct the account during that time. Frequent trading may impact investment performance and tax implications. Investors should consult with their personal tax adviser in connection with securities transactions and/or any particular investment(s) held in their account(s). These strategies may not be appropriate for every type of investor. The strategies may deploy short-term trading strategies in an effort to capitalize on shorter-term market moves and as a result, a higher number of transactions may occur over a relatively short period of time. More transactions could result in higher fees in individual accounts which is why the Advisor’s wrap fee program is utilized, as discussed below and at Item 5 of this Brochure. Some mutual funds / fund families impose redemption charges on funds held for less than the required minimum period, as determined by the fund (ref. prospectus). While best efforts are made to avoid these charges, clients may incur them from time. Limited Discretion With the client’s authorization as provided in the custodial account forms and the Advisor’s client agreement, the Advisor will maintain limited discretionary trading authority to execute securities transactions in the investor’s portfolio within investor’s designated investment objectives, to include the securities to be bought and sold, and the amount of securities to be bought and sold. The Advisor will not hold full power of attorney, nor will the Advisor ever have authority to withdraw funds or to take custody of investor funds or securities other than the ability to deduct contractually agreed advisory fees via the client’s account held at Charles Schwab & Co., Inc., with the client’s authorization. Client Tailored Services and Client Imposed Restrictions The Advisor focuses on providing individualized services. The Advisor can tailor services to focus only on certain portfolio components, depending upon the client’s wishes and/or the nature of the engagement. However, where client services or information are limited, clients must understand that comprehensive investment needs and objectives may not be fully considered due to the client’s option to receive limited services, the lack of information received, and/or client disclosure. The Advisor and the client will share in a data gathering and discovery process in an effort to determine the client’s stated needs, goals, intentions, time horizons, risk tolerance and investment objectives, based upon information provided by the client and the nature of services requested. The client and Advisor may complete a risk assessment, investment policy statement (“IPS”) or similar documentation, depending upon the nature of services to be provided. Clients may impose reasonable restrictions pertaining to certain securities or types of securities in accordance with their values or beliefs and such instructions will be agreed to in writing between the client and the Advisor. The ongoing Investment Management Services provided are based upon the client’s stated individual needs and objectives. 11  Ongoing Services Throughout its engagement, the Advisor will remain available for consultations pertaining to the managed portfolio. The Advisor will provide ongoing monitoring of the portfolio in accordance with the directives provided. The underlying portfolio assets will be reviewed internally on a frequent basis (often daily), the client’s portfolio will be internally reviewed no less than annually, but reviews may occur more frequently, depending upon the types of investments, market conditions, when the client reports (actual or potential) changes in their financial condition, at the discretion of the Advisor, and in conjunction with significant deposits or withdrawals. The review process is discussed in Item 8 of this Brochure. Clients must play an active role. The Advisor requires its client to participate in the formation of the investment plan, the development of investment advice and recommendations and the ongoing services provided. Clients may call the office during regular business hours to discuss their portfolio or ask questions, but the Advisor recommends that clients initiate a meeting with the Advisor no less than annually. However, clients are obligated to immediately inform the Advisor of any changes in their financial situation to provide the Advisor with the opportunity to review the new data to ensure it the portfolio continues to be structured to help meet the client’s stated needs and objectives. Performance Accounts and Side-by-Side Management The Advisor may enter into performance-based fee arrangements with qualified clients. The Advisor may receive incentive fees based on a share of capital gains on or capital appreciation of the assets or any portion of the assets of an advisory Client, in accordance with the investment management agreement executed between the client and Adviser, in compliance with the requirements set forth in applicable laws and regulations. The performance fees charged by the Advisor may be higher or lower than fees charged by other advisers for comparable services. Clients should be aware that a performance-based fee arrangement can create an incentive for the Advisor to recommend investments that are riskier or more speculative than those recommended under a different fee arrangement. The Advisor works to mitigate this conflict by selecting investments that we believe are appropriate for clients in accordance with the Advisor’s and the client’s investment strategies; The Advisor has established procedures designed and implemented to (i) ensure that all clients are treated fairly and equally, and (ii) prevent potential conflicts with respect to allocations of investment opportunities among clients. Other Important Program Considerations • Wrap fee programs are not suitable for all investment needs and any decision to participate in a wrap fee program should be based on your financial situation, investment objectives, tolerance for risk, and investment time horizon, among other considerations. The designed strategies and any client-imposed restrictions / guidelines may affect the composition and performance of a client’s portfolio. For these reasons, portfolio performance may vary from that of other clients. Further, based on the individualized nature of services, there may be extended periods of time when the Advisor determines that changes to a client’s portfolio are neither necessary nor producent. Notwithstanding, unless otherwise agreed in writing, the Advisor’s Program fee will continue to apply during these periods. • The investment products available within the Program can be purchased by clients outside of the wrap fee program account via unaffiliated financial services firms. When utilizing another firm, the Advisor’s ongoing management services would not be provided. • When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap [or program] fee 12  you pay after custodial, trading, and other management costs (including execution and transaction fees) have been deducted. The Advisor does not charge clients higher advisory fees based on their trading activity, but you should be aware that we have an incentive to limit our trading in your account(s) because we are charged for executed trades. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at https://www.schwab.com/aspricingguide. Fees Factors that impact the relative cost of the program include the trading activity in the managed account as discussed herein. Participation in the wrap fee program may cost clients more or less than engaging another Advisor separately (for non-wrap services). As discussed in this section, the program fees are negotiable and agreed in the Advisor’s Wrap Fee Program Agreement. The Advisor receives a portion of the wrap fee for portfolio management services and Charles Schwab & Co., Inc. receives a portion of the fee for trade execution and custodial services. 1. The Advisor’s Program fees are calculated as a percentage of assets under management by household and combines portfolio management, commissions, trade execution costs, custody and other standard brokerage services within a single investment management fee. The fee does not include separate administrative costs that may be charged by sponsors of mutual funds or excluded funds held in the account. The agreed upon annual fee is negotiable, based on the nature, complexity, and scope of services as well as the amount and nature of assets to be managed, pre-existing relationships, and other factors, at the discretion of the Advisor as follows: Account Value Standard Fee Schedule $0 - $500.000 $500,001 and above 1.25% 1.00% or negotiable All fees are negotiable The fees are charged based on a flat percentage using total account value (including cash and cash equivalent positions such as money market funds), as opposed to a tiered rate. The account value will be based upon the total value of all accounts attributable to the same household, so the same fee rate will be applied to each of those accounts. Different accounts within a household may have a different fee structure based on the assets involved. The agreed upon fee schedule will be established in the Advisor’s Client Agreement. Fees are paid monthly in advance, except for the initial month which is billed pro rata in arrears. RWA has had different fee schedules in place in the past and, as stated above, our fees are negotiable at our discretion, which means that not all RWA clients are paying the same fees. The investment management fee may be revised during the engagement, particularly if different needs and/or complexities arise, or the scope of services should change. In such cases, the Advisor will notify the client of its intention to modify the fee with at least 30 days’ written notice. Should the client decide not to accept the amended fee terms, the client is 13  welcome to terminate services with 5 days’ written notice prior to the effective date of the fee modification. While the Advisor takes the position that its fees are competitive, fees may be higher or lower than fees charged by other financial services providers for similar services. 2. Performance-Based Fee Arrangements For Qualified clients, as defined by the Securities and Exchange Commission, the Advisor may negotiate a fee based on a combination of a percentage of assets under management and a performance fee. In such cases, the Advisor charges a maximum asset management 10% of the annual gross profits for the account in performance fees. The performance fee is invoiced directly to the client and is payable annually, in arrears. No performance fee will be charged, except to the extent that the amount of the capital increase exceeds the sum of any cumulative loss in the account on a yearly basis. In the event the client makes a complete withdrawal from the account on a date other than the end of the year, fees will be due at the time of withdrawal. Annual gross profits are defined as the difference in the value of the account for the previous 4 quarters, adjusted for deposits and withdrawals made during the year. Clients are hereby advised that performance-based fees are higher than industry norm and similar (but non-performance-based) advisory services can be obtained for less. Please see important disclosures in Item 6 of this Brochure which discusses side-by-side management. Other Fees and Fees Associated with Investing The Program fee does not include mark-ups. and mark-downs, dealer spreads or other costs associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities exchange fees, charges for transactions not executed through Charles Schwab & Co., Inc., costs associated with exchanging currencies, wire transfer fees, or other fees required by law or imposed by third parties. The investor’s account will be responsible for these additional fees and expenses. All fees paid to the Advisor for advisory services are separate from the fees and expenses charged to shareholders of exchange traded funds (ETFs) or mutual fund shares offered by mutual fund companies. A complete explanation of the expenses charged by a mutual fund or ETF is contained in the respective fund prospectus. Clients are encouraged to read each prospectus and securities offering document. If a mutual fund previously purchased by or selected by a client should impose a sales charge, a client may pay an initial or deferred sales charge. The Advisor does not receive any portion of these investment- related fees. Such charges, fees and commissions are exclusive of and in addition to the Advisor’s fees. However, in their separate capacities as registered representatives of an unaffiliated broker/dealer, the investment adviser representatives of the Advisor do accept commissions for securities recommendations. Compensation Matters The Advisor’s investment adviser representatives do not receive referral-based incentives associated with recommending the Advisor’s wrap fee program. Obviously, a higher management fee has the potential to increase the Advisor’s and the investment adviser representative’s compensation and thus there exists an incentive to recommend the Program over other services. However, such compensation is impacted by the costs associated with the managed account(s) since the Program pays for various account charges as described above. The investment management fee associated with the Program may be higher or lower than non-wrap services or similar services offered by other firms. Program fees are negotiable as described in this section. Payment of Fees The Advisor’s contractually agreed fees will be deducted from clients’ custodial accounts with our client’s authorization. The Advisor adheres to the following required criteria when payment is deducted from the client’s account via a qualified custodian, as required by the SEC as 14  follows: 1) The client provides written authorization permitting the fees to be paid directly from the client’s account held by the independent qualified custodian and the authorization is limited to withdrawing contractually agreed upon investment advisor fees; (2) The client will directly receive regular account statements directly from the qualified custodian which reflect the Advisor’s fee deduction; (3) The frequency of fee withdrawal shall be specified in the written authorization/client agreement; 4) The custodian of the account shall be advised in writing of the limitation on the Advisor’s access to the account and; (5) The client shall be able to terminate the written billing authorization or agreement at any time. It is important to note that custodial firms do not verify advisory fees. Therefore, clients should review their custodial statements carefully. If a client should have any questions or concerns in connection with an advisory fee deduction, they should promptly contact the Advisor and Betterment. If at any time during the engagement, the client fails to receive the regular statements produced by the custodian or they have new address information to report, it is important for the client to promptly notify the Advisor and their custodian. Termination of Services The client may terminate services within five business days of signing the investment management agreement and without penalty or fees due if the Advisor’s Form ADV 2 Brochure (and Betterment’s Brochure, if applicable) was not delivered at least 48 hours prior to engagement. Alternatively, either party may terminate services with 5 days’ notice. As fees are charged in advance, where services are terminated prior to the end of the billing period, the Advisor will return a pro-rated refund for any unearned fees. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS The Advisor offers investment advisory services to individuals and high net worth individuals. The suggested account minimum for investment management services is $250,000 but can be negotiated based upon individual circumstances. A client seeking performance-based services, as discussed at Item 5.A of this brochure, must meet the definition of a qualified client as established by the United States Securities and Exchange Commission (assets under the Advisor’s management of at least $1,100,000, or a minimum liquid net worth of $2,200,000). Since ongoing investment management services and participation in the wrap fee program may not be appropriate for some investors, the Advisor reserves the right to decline to provide services to any person or firm and for any reason. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION The Advisor is the Wrap Fee Program’s Sponsor and Manager. The Advisor’s services and fees are discussed at Item 4 of this Program Brochure. Additional Information – Internal Reviews Investment Management Services involve frequent monitoring of portfolios. Portfolios are reviewed no less than quarterly and underlying securities are generally reviewed daily. Reviews are performed by The Advisor’s Investment Advisor Representatives. Portfolios are analyzed in relation to the client’s stated investment objectives, risk profile, tax situation and market conditions. Individual client reviews are conducted no less than annually in order to provide the client with the opportunity to review their profile data and investment strategies. Investment Advisor Representatives conduct periodic client meetings and have frequent telephonic contacts in which investment objectives, market conditions and other factors are discussed with clients. 15  Clients are welcome to initiate meetings (telephonically, electronically or in person) throughout the year. However, clients are obligated to promptly contact the Advisor when there exists a real or potential change in the clients’ financial condition or if a change in strategy may be contemplated. This prompt notification gives the Advisor the opportunity to review the clients’ new information and determine if it impacts the advice and recommendations prepared for the client. Performance-Based Accounts and Side-by-Side Management As previously disclosed in Item 5 of this Brochure, the Advisor may enter into performance- based fee arrangements with qualified clients. The Advisor may receive incentive fees based on a share of capital gains on or capital appreciation of the assets or any portion of the assets of an advisory Client, in accordance with the investment management agreement executed between the client and Adviser, in compliance with the requirements set forth in applicable laws and regulations. The performance fees charged by the Advisor may be higher or lower than fees charged by other advisers for comparable services. Clients should be aware that a performance-based fee arrangement can create an incentive for the Advisor to recommend investments that are riskier or more speculative than those recommended under a different fee arrangement. The Advisor works to mitigate this conflict by selecting investments that we believe are appropriate for clients in accordance with the Advisor’s and the client’s investment strategies; The Advisor has established procedures designed and implemented to (i) ensure that all clients are treated fairly and equally, and (ii) prevent potential conflicts with respect to allocations of investment opportunities among clients. Methods of Analysis, Investment Strategies, and Risk of Loss The Program provides personalized investment management services to its clients and portfolio advice is available for clients interested in conservative to moderately aggressive strategies; with advice designed to meet varying needs of and within the direction set forth by the investors. The Advisor seeks to design advice that is best suited to a client’s stated unique needs after clients have defined their objectives, risk tolerance, and time horizons and the selection is approved by the client. Based on information provided by the client, the Advisor seeks to evaluate an investor’s risk tolerance, time horizon, goals and objectives through an interview and data-gathering process in an effort to determine an investment strategy and portfolio design to best fit the investor’s profile. Client participation and the client’s delivery of accurate and complete information are critical to the Advisor’s process. In performing its services, the Advisor is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. The Advisor considers securities investments based on its professional judgment and the experience of its investment advisor representatives coupled with publicly available research and analysis. Asset allocation software and historical performance modeling software may also be utilized. Of course, no method of analysis can guarantee success. The Advisor’s recommended investment strategies may be based upon a number of concepts and determined by the type of investor. This process attempts to coordinate the client’s objectives for risk vs. return with the Advisor’s analysis of the macro environment. Registered funds are researched and monitored internally by the Advisor with a process that emphasizes investment philosophy, management quality, and overall expense ratios. Portfolio holdings or recommendations are generally judged by track record and performance of like-kind investments. While pure market timing strategies are generally not used, Selected Models from RWA may employ risk on strategies when indicators and market conditions warrant as well as risk reduction strategies during times of heightened market volatility. 16  Changing conditions in the client’s financial life or significant changes in market conditions may warrant a collaborative effort with the client to modify their strategic investment framework, which consequently may also trigger changes to investment holdings within the portfolio. The Advisor may recommend its Program, the services of itself as Investment Advisor, its Investment Advisor Representatives in their individual capacities as investment managers, and the services of other industry entities to implement recommendations. Any other professional referrals (i.e., accounting professionals, tax preparers, legal professionals, etc.) may be provided but solely as a courtesy and the Advisor and its personnel receive no direct or indirect compensation as a result of referrals. Clients are welcome but are never under any obligation to act upon any of the recommendations made by the Advisor or to engage the services of any recommended service firm or professional including the Advisor itself. Clients should appropriately research other service providers before engaging those services. Investors may prefer to utilize the investment management styles offered via the Strategic Models. These strategies fall within one of 3 general categories: conservative, moderate/balanced and growth. Each model generally holds the same positions but with different percentages based on the amount of risk involved. These positions may include the use of stocks, exchange traded funds, and mutual funds. The tactical nature of the strategy allows the flexibility to move away from equity positions to cash or bonds when risk is deemed high. Please reference Item 4 of this Brochure for additional information provides about these strategies. It is important to understand that investing in securities involves a risk of loss that a client should be prepared to bear. Material Risks Involved The Advisor takes the general position that investors with diverse portfolios have a better chance of making a profit because it is difficult to accurately predict the movement of the economy. However, no single strategy can be relied upon to outperform the market. The Advisor does not attempt to time the market. Frequent trading is not recommended as it can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. The Advisor does not generally recommend short sales, margin transactions and options writing as they are generally associated with greater risk. In contrast, the Strategic Models, as discussed at Items 4 and 6 of this Brochure, do seek to time investments. Please refer to these sections for important information concerning this manager’s strategies. Clients may make additions to and withdrawals from the account at any time, subject to customary securities settlement procedures and the Advisor’s right to terminate services (such as when assets dip so low as to make investment management inappropriate for the client). Asset withdrawals may impair the achievement of a client’s investment objectives. All investment strategies involve risk and may result in a loss of an investor’s original investment. Many of these risks apply equally to stocks, bonds and any other investment or security. Identified material risks associated with the Advisor’s investment strategies include: Defensive Risk: To the extent that the strategy attempts to hedge or take defensive measures such as holding a significant portion of its assets in cash or cash equivalents, the objective may not be achieved. External Events: As we know from recent events, the market can be impacted by external events such as pandemic, supply chain issues, natural disasters, terrorism, war, etc. 17  Fixed Income Risk: Fixed income securities are subject to the risk of the issuer’s or a guarantor’s inability to meet principal and interest payments on its obligations and to price volatility. Fixed-income securities are generally subject to the following risks: • Interest Rate Risk. The value of investments in fixed-income securities will change based on changes in interest rates. If interest rates increase, the value of these investments generally decline. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. • Extension Risk. If interest rates rise, repayments of principal on certain fixed-income securities may occur at a slower-than-expected rate and, as a result, the expected maturity of such securities could lengthen which could cause their value to decline. • Credit Risk. Fixed income investments are subject to the risk that issuers and/or counterparties will fail to make payments when they are due or default completely. Prices of the investments may be adversely affected if any of the issuers or counterparties are subject to an actual or perceived deterioration in their credit quality. Credit spreads may increase, which may reduce the market values of fixed income securities. Credit spread risk is the risk that economic and market conditions or any actual or perceived credit deterioration may lead to an increase in the credit spread (i.e., the difference in yield between two securities of similar maturity but different credit quality) and a decline in price of the issuer’s securities. • Prepayment Risk. Issuers of certain fixed income securities may be able to prepay principal due on these securities, particularly during periods of declining interest rates, and Villere may have to invest the proceeds in lower-yielding securities. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social, or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, and regulatory and financial reporting standards, which differ from those of the U.S. Investment Strategy Risk: This risk exists when an Advisor’s strategy may fail to produce the intended results. Large-Sized Companies Risk: Larger, more established companies may be unable to respond quickly to new competitive challenges like changes in consumer tastes or innovative smaller competitors. In addition, large-cap companies are sometimes unable to attain the high growth rates of successful, smaller companies, especially during extended periods of economic expansion. Legal or Legislative Risk: Legislative changes or court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Margin Transactions: Investors utilizing margin accounts must carefully review the margin agreement provided by the selected brokerage firm. These firms charge interest on the funds loaned to purchase securities on margin and an investor needs to understand the additional charges he or she may incur by opening a margin account. Additionally, risks associated with margin accounts include: The loss of more funds that an investor deposits into the margin which may require the investor to deposit additional funds to avoid the forced sale of securities in the account. Additionally, if the equity in the account falls below the maintenance margin requirements under the law or the firm’s higher "house" requirements, the firm can sell the 18  securities in the account to cover the margin deficiency. Investors are also responsible for any short fall in the account after such a sale. Additionally, the selected firm can sell the securities in the account without contacting the investor (although as a courtesy many firms do attempt contact). Investors are not entitled to a time extension on margin calls. While extensions are sometimes given under certain conditions, investors do not automatically have a right to time extensions. An investor does not have a right to an extension of time to meet a maintenance margin call. Market Risk: Market risk involves the possibility that an investment’s current market value will decline due to general market decline, thus reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Market Capitalization Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium-cap companies may face a greater risk of business failure, which could increase the volatility of the clients’ portfolios. Small- and Medium-Sized Companies Risk: Investing in securities of smaller companies including micro-cap, small-cap, medium-cap and less seasoned companies often involve greater volatility than investing in larger, more established companies and these securities may be less liquid than other securities. Political Risk: The chance that a change in government may affect stock prices of domestic or international stocks. Sector/Industry Risk: In connection with Jon Arnold’s management strategy, from time to time, client portfolios may have overweighted positions in particular market sectors and/or industries, which can be more volatile and/or underperform relative to the market as a whole. Style Risk: The Advisor’s strategy may consist of “value” and or “growth” investments. With respect to securities and investments considered undervalued by the Advisor, market prices may not reflect our determination that the security is undervalued, and its price may not increase to what we believe to be its full value and may even decrease in value. With respect to “growth” investments, the underlying earnings or operational growth anticipated may not occur, or the market price of the security may not increase as anticipated. Tax Considerations: The Advisor’s strategies and investments can have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Unaffiliated Money Managers: If a portion of your assets is managed by a third-party money manager (such as Betterment), we will not determine the investments to be made for your account, but we will monitor the investments in the accounts and advise you on those holdings for so long as we are providing investment management services. Other (non-securities) Annuities are retirement products for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial 19  taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Clients are hereby advised to read each offering document carefully before investing. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that all clients should be prepared to bear. Risks of Specific Securities Utilized The Advisor generally seeks investment management strategies that do not involve significant or unusual risk beyond that of the general domestic and / or international equity markets. Investing in the financial markets, including the securities The Advisor recommends to clients, involves the risk of loss—including loss of principal. While the Advisor attempts to manage risks associated with the financial markets and the securities it recommends to clients, the Advisor makes no guarantee or promise that advice given will not result in losses. Past investment performance of any investment is not a guarantee of future results. Investments in mutual funds may bear a risk of investment loss. Clients who invest should also be prepared to bear a loss of investment proceeds. While the Adviser monitors underlying fund investments, it is possible that a fund manager’s strategy will not provide desired results. Exchange traded funds (ETFs) - ETF Risks, including Net Asset Valuations and Tracking Error: ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by the Advisor plus any management fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the fund's net asset value, and therefore directly affect the fund's performance and indirectly affect a client’s portfolio performance or an index benchmark comparison. Expenses of the fund may include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Investments in individual stocks can be risky. Some risks can be controlled, and some risks can be guarded against, but no investment strategy can carry guarantees from loss. Certain market risks cannot be controlled, such as market or economic conditions. Certain strategies may be employed to adjust portfolios, or the Adviser and client may agree to hold the portfolio’s course. The Advisor designs portfolio strategies for the long-term, unless otherwise specifically requested in writing. Therefore, the Adviser does not attempt to time the market. Fixed income investments generally are utilized as a portfolio diversification element as well as for income-deriving investments outside of equity exposure. There are certain risks involved in investing in bonds: Government, Municipal, and Corporate and the following is an overview of the types of risks that one should consider: Interest rate risk; reinvestment risk; inflation risk; mark risk, selection risk, timing risk, and price risk. Additional risks for some government agency, corporate and municipal bonds may include 20  Legislative risk (a change in the tax code could affect the value of taxable/tax-exempt interest income); Call risk (some corporate, municipal and agency bonds have a “call provision” entitling their issuers to redeem them at a specified price on a date prior to maturity. Declining interest rates may accelerate the redemption of a callable bond, causing an investor’s principal to be returned sooner than expected. In that scenario, investors have to reinvest the principal at the lower interest rates. If the bond is called at or close to par value, as is usually the case, investors who paid a premium for their bond also risk a loss of principal. In reality, prices of callable bonds are unlikely to move much above the call price if lower interest rates make the bond likely to be called. Additionally, there may be a liquidity risk involved if investors have difficulty finding a buyer when they want to sell and may be forced to sell at a significant discount to market value. Liquidity risk is greater for thinly traded securities such as lower-rated bonds, bonds that were part of a small issue, bonds that have recently had their credit rating downgraded or bonds sold by an infrequent issuer. Bonds are generally the most liquid during the period right after issuance when the typical bond has the highest trading volume. Additional risks for corporate and municipal bonds may include Credit risk; default risk; event risk and duration risk. Bank obligations, including bonds and certificates of deposit, may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are highly dependent upon short-term interest rates and may be adversely affected by downturns in the U.S. and foreign economies and/or changes in regulations. Delaware Statutory Trusts. These investments have a unique set of risks and are only appropriate for accredited investors. Risks may include but are not limited to: Illiquidity risk (investment must be held for an extended period of time), loss of control (no decision making over property, sponsor controls management and selling of property), regulatory risk (change in tax rules which could result in tax liabilities), execution risk (operator competence) and economic risk. There can be no assurance that a property will perform as projected and Delaware Statutory Trusts are subject to economic volatility, tenants not paying their rent as expected, and other traditional risks of owning, selling, and operating real estate. The fees and expenses of each offering should be carefully evaluated. Multiple owner offerings typically have additional expenses versus owning real estate on your own and these fees should be weighed against specific capital gains tax liability. All investors are encouraged to have their tax and legal counsel advise them on taxes including any federal and state capital gains taxes, depreciation recapture and any other tax issues, which could be applicable. Covered Call Options. While this strategy can provide income, it limits your ability to participate in any increase in the price of the underlying security above the strike price. Furthermore, a covered call strategy does not eliminate the risk of market-based losses on the underlying stock. In fact, if the stock price declines, the premium received from the option may not be sufficient to offset the loss in the value of the underlying security. Additionally, the option can be exercised at any time, requiring you to sell the underlying security at the strike price, potentially below the market price. Market conditions can negatively impact option values or the ability to close positions favorably and the forced sale of shares upon assignment may trigger taxable events. Inverse ETFs. This strategy is used to hedge client portfolios against market downturns or to seek returns that are the inverse of a specific benchmark on a daily basis. They are designed to achieve their investments objectives on a daily basis. They are not intended to track the underlying index over periods longer than a single day. Due to the effect of daily compounding, performance over longer periods can differ significantly from the inverse of the underlying index. In volatile markets, an inverse ETF may lose money even if the underlying index decreases over time. Holding inverse ETFs for longer than one trading session increases risk due to the compounding of returns. As such, these investments are generally considered unsuitable for long-term holding. These products may not achieve their stated objectives. If the market rises, the inverse ETF will lose value, and you may lose a significant portion or all of your principal investment. 21  It is important to understand that investing in securities involves a risk of loss that a client should be prepared to bear. Voting Client Securities (Proxies) As a matter of policy and practice, RWA will not vote proxies on behalf of clients. Clients will retain voting authority and can expect to receive voting materials directly from their custodian. The Advisor is available to assist clients with questions and concerns relating to proxies. The Advisor does not engage in proxy-related discussions with non-clients and does not solicit proxies. Deviations from these policies will result in a prompt amendment of this Form ADV 2A Brochure and may require the Advisor to comply with SEC Proxy Registration Rules. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Advisor is the Program’s Sponsor and Manager and therefore, the Program does not utilize other portfolio managers. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS The Advisor is the Program’s Sponsor and Manager and therefore, as with our non-wrapped investment management services, the Advisor welcomes communications with our clients. Clients are welcome to contact the Advisor at any time during our normal office hours. Individual client reviews are conducted no less than annually in order to provide the client with the opportunity to review their profile data and investment strategies. Investment Advisor Representatives conduct periodic client meetings and have frequent telephonic contacts in which investment objectives, market conditions and other factors are discussed with clients. Clients are welcome to initiate meetings (telephonically, electronically or in person) throughout the year. However, clients are obligated to promptly contact the Advisor when there exists a real or potential change in the clients’ financial condition or if a change in strategy may be contemplated. This prompt notification gives the Advisor the opportunity to review the clients’ new information and determine if it impacts the advice and recommendations prepared for the client. ITEM 9: ADDITIONAL INFORMATION Disclosure-Disciplinary Information Registered Investment Advisors are required to disclose legal and disciplinary events that may be material to a client’s or prospective client’s evaluation of the Advisor’s practice or the integrity of its management. The Advisor has responded to each item below: A. A criminal or civil action in a domestic, foreign, or military court of competent jurisdiction in which your firm or a management person: 1.was convicted of or pled guilty or nolo contendere (“no contest”) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses. 2. is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses. 3. was found to have been involved in a violation of an investment-related statute or regulation; or 4. was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, your firm or a 22  management person from engaging in any investment- related activity, or from violating any investment-related statute, rule, or order. Neither the Advisor nor its management persons have any disclosure information to report for Item 9.A.1., Item 9.A.2, Item 9.A.3, and Item 9.A.4. B. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which your firm or a management person: 1. was found to have caused an investment-related business to lose its authorization to do business; or 2. was found to have been involved in a violation of an investment- related statute or regulation and was the subject of an order by the agency or authority (a) denying, suspending, or revoking the authorization of your firm or a management person to act in an investment-related business (b) barring or suspending your firm’s or a management person's association with an investment related business (c) otherwise significantly limiting your firm’s or a management person's investment- related activities; or (d) imposing a civil money penalty of more than $2,500 on your firm or a management person. Neither the Advisor nor its management persons have any information to report for Items 9.B.1 and 9.B 2(a-d). C. A self-regulatory organization (SRO) proceeding in which your firm or a management person: 1. was found to have caused an investment-related business to lose its authorization to do business; or 2. was found to have been involved in a violation of the SRO’s rules and was:(i) barred or suspended from membership or from association with other members or was expelled from membership; (ii) otherwise significantly limited from investment-related activities; or (iii) fined more than $2,500. Neither the Advisor nor its management persons have any information to report for Items 9.C.1 and 9.C.2. Note: Individual information about The Advisor’s management persons and investment advisor representatives is contained in their Form ADV Part 2B Brochures which are attached directly behind this firm Brochure. One investment adviser representative (Mr. Curly) has a reportable event from 1972 when he was a college student. Mr. Arnold has a reportable event from 2012. If you did not receive these Brochures, please contact the Advisor via the contact information contained on the cover page of this Brochure. Other Financial Industry Activities and Affiliations Registration as a broker/dealer or broker/dealer representative The Advisor is not registered as a broker/dealer and no such registration is pending. As disclosed in Item 10.C below, Adam Stalnaker, Joseph Kovach, and Michael Curley are separately registered as registered representatives of Private Client Services and in this capacity, they accept commissions for the sale of securities. Registration as a futures commission merchant, commodity pool operator or a commodity trading adviser Neither the Advisor nor its Investment Advisor Representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor and no such registrations are pending. 23  Registration relationships material to this advisory business and conflicts of interest Neither the Advisor nor its Investment Advisor Representatives have any registration relationships, legal affiliations or any association with the following businesses that would present a possible conflict of interest and no such relationships are pending. ❖ broker-dealer, municipal securities dealer, government securities dealer or broker ❖ investment company or other pooled investment vehicle (including a mutual fund, closed- end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) ❖ futures commission merchant, commodity pool operator or trading advisor ❖ banking or thrift institution ❖ lawyer or law firm ❖ insurance company or agency* ❖ pension consultant ❖ real estate broker or dealer ❖ sponsor or syndicator of limited partnerships. The Advisor does not operate and does not have a material relationship with a hedge fund or other type of private pooled investment vehicle. Adam Richard Stalnaker, Joseph J. Kovach and Michael A. Curley are separately engaged and dually registered as registered representatives of an unaffiliated broker/dealer (Private Client Services LLC) and receive commissions for securities transactions placed with this broker/dealer. *Adam R. Stalnaker, Joseph J. Kovach, and Michael A. Curley are separately engaged as independently licensed insurance agents and receive normal commissions paid by insurance companies when clients purchase insurance through them. Investment Advisor Representative, Andrew Smith, is the owner of an accounting firm and receives separate and customary payment for delivering any accounting related services. Some advisory clients may also be accounting clients of Mr. Smith. This creates a conflict in that Mr. Smith has an incentive to recommend his accounting firm to RWA clients and RWA to accounting clients. Clients are under no obligation to utilize Mr. Smith for any accounting services. The Advisor is a fiduciary to each of its clients. The receipt of commissions by its registrants poses a conflict of interest between the Adviser and its clients. Please refer to the important disclosure at Item 5.E of this Brochure as it addresses the conflicts of interest, The Advisor’s fiduciary duty to its clients and how the conflicts are managed. Selection of Other Advisers or Managers and How this Adviser is Compensated for Those Selections Outside of the Program and as discussed in the Adviser’s Form ADV 2A Brochure at Item 4.B, the Advisor has entered into an agreement with Betterment, LLC (“Betterment”) to utilize among other things, Betterment’s software, advice, and digital services on a sub-advisory basis. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading The Advisor takes the issues of fiduciary duty and regulatory compliance seriously and is committed to maintain compliance with state and applicable federal securities laws. The Advisor has a position of public trust, and it is our goal to maintain that trust; provide excellent service, good investment performance; and advice that is suitable. The Advisor places great value on ethical conduct. Therefore, the ultimate goal of our internal policies is to challenge our staff to live up not only to the letter of the law, but also to the ideals 24  set forth by the Advisor. Clients may be familiar with the roles fiduciaries play in various legal situations and in certain industries. As a Registered Investment Advisor, the Advisor is a fiduciary to each and every client. As fiduciaries, Registered Investment Advisors owe their clients several specific duties. In accordance with the SEC’s Regulation Best Interest, an Investment Advisor’s fiduciary duties include: • Providing advice that is suitable based on information gathered from the client • Providing full disclosure of material facts and potential conflicts of interest (such that the client has complete and accurate disclosure in order to make an informed decision about services of the Advisor and about investment recommendations) • The utmost and exclusive loyalty and good faith • Best execution of transactions under the available circumstances • The Advisor’s reasonable care to avoid ever misleading clients • Only acting in the best interests of clients. It is The Advisor’s policy to protect the interests of each of our clients and to place clients’ interests first and foremost. The Advisor will abide by honest and ethical business practices to include, but not limited to: • The Advisor will not induce trading in a client’s account that is excessive in size or frequency in view of the financial resources and character of the account. ▪ The Advisor will make investment decisions with reasonable grounds to believe that the decisions are suitable for the client on the basis of information furnished by the client and we will document suitability. ▪ The Advisor and its Investment Advisor Representatives will not borrow money from clients, nor will they lend money to clients. ▪ The Advisor will not recommend the purchase of a security without the reasonable belief that the security is registered, or the security or transaction is exempt from registration in states where we provide investment advice and based upon information the Advisor receives. ▪ The Advisor will not recommend that a client place an order to purchase or sell a security through a broker/dealer or agent, or engage the services of an unlicensed brokerage firm, based upon information available to the Advisor. ▪ The Advisor’s Member and staff (if applicable) will report all required personal securities transactions to Thomas V. David, Chief Compliance Officer as required by securities rules and regulations. Reportable trades for the Advisor include all but the following exceptions: ❖ Transactions effected pursuant to an automatic investment plan ❖ Securities held in accounts over which the access person has no direct or indirect influence or control ❖ Transactions/holdings in direct obligations of the US Government ❖ Money market instruments — bankers' acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high- quality short-term debt instruments ❖ Shares of money market funds ❖ Transactions and holdings in shares of mutual funds, since the Advisor does not have a material relationship with an investment company ❖ Transactions in units of a unit investment trust are not reportable if the UIT is invested exclusively in unaffiliated mutual funds. 25  All applicable securities rules and regulations will be strictly enforced. The Advisor will not permit and has instituted controls against insider trading. Investment Advisor Representatives and administrative personnel who do not follow the Advisor’s Code of Ethics or who in any way violate securities rules and regulations, or who fail to report known or suspected violations will be disciplined or terminated, depending upon severity. Such persons could also face action by the SEC and/or state securities regulators. Clients are welcome to request a copy of the Advisor’s Code of Ethics by contacting the Advisor’s office. Recommendations Involving Material Financial Interests The Advisor does not recommend that clients buy or sell any security in which any of The Advisor or its related persons have a material financial interest. Investing Personal Monies in the Same Securities as Clients The Advisor and/or individuals associated with the Advisor may have similar investment goals and objectives and as a result may buy or sell securities for their personal accounts that may be identical to or different from those recommended to clients. Thus, at times the interests of staff members’ accounts may coincide with the interests of clients’ accounts. However, at no time will the Advisor or its related persons receive an added benefit or advantage over clients with respect to these transactions nor will the Advisor or its staff ever place themselves in a position to have added benefit as a result of advice given to clients. The Advisor’s Chief Compliance Officer monitors access person’s personal trading activities. Trading Securities at / around the Same Time as Clients The Advisor acknowledges the Advisor’s fiduciary responsibility to place the investment needs of clients ahead of the Advisor and its staff. The interests of clients are held in the highest regard. At no time will the Advisor or its personnel receive an added benefit or advantage over clients with respect to these transactions. The Advisor and its personnel will not place itself in a position to have added benefit as a result of advice given to clients. The Advisor and its personnel will not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. The Advisor has established trading policies for its access persons. The Advisor’s Chief Compliance Officer is responsible for the monitoring of personal trading conducted by staff. Financial Information Balance sheet The Advisor does not accept fees for services that involve $1,200 or more for services to be performed six or more months in advance. The Advisor does not maintain custody of client funds and securities and therefore is not required to include a balance sheet with this Brochure. Financial conditions reasonably likely to impair the adviser’s ability to meet contractual commitments to clients Neither the Advisor nor its management have a financial condition that is reasonably likely to impair the Advisor’s ability to meet contractual commitments to clients. Bankruptcy petitions in previous ten years The Advisor, its owners and its investment adviser representatives have not been party to a bankruptcy petition during the previous 10 years. 26