WEATHERSTONE/FOCUS PARTNERS ADVISOR SOLUTIONS PART 2A

FOCUS ADVISOR SOLUTIONS, LLC Firm Brochure for DBA (“doing business as”) WEATHERSTONE CAPITAL MANAGEMENT 190 Carondelet Plaza, Suite 600 St. Louis Missouri, 63105 www.weatherstone.com Phone: (800) 366-7266 This brochure provides information about the qualifications and business practices of Focus Advisor Solutions, LLC, specifically “doing business as” Weatherstone Capital Management. If you have any questions about the contents of this brochure, please contact us at (800) 366-7266 or via email directly to FAScompliance@focuspartners.com. The Information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about our firm is also available on the SEC’s web site at www.adviserinfo.sec.gov. Focus Partners Advisor Solutions, LLC is registered as a Registered Investment Adviser with the Securities and Exchange Commission (“SEC”). Registration does not imply a certain level of skill or training. Website: www.weatherstone.com July 31, 2026 1  Item 2 Material Changes Our most recent annual updating amendment was filed on March 31, 2026. This Item discusses only the material changes that have occurred since Focus Advisor Solutions, LLC (“FAS”) last Annual Amendment Update filed on March 31, 2026. This Item of the Brochure will discuss only specific material changes that are made to the Brochure and provide clients with a summary of such changes. The most recent update of our Brochure was March 31, 2026 during an annual amendment, and had the following material changes since our last annual updating amendment: On July 1, 2026, Focus Partners Advisor Solutions, LLC, d/b/a Weatherstone Capital Management, legally changed its name to Focus Advisor Solutions, LLC. It will operate under this new legal name as well as continue to do business as Focus Partners Advisor Solutions, LLC and Weatherstone Capital Management. • We amend this brochure at least annually. To receive a copy of our most recent brochure at any point during the year, please call the Compliance Department toll-free at (800) 366-7266 or email FAScompliance@focuspartners.com and a copy will be sent to you without charge. We will provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Item 3 Table of Contents Item 2 Material Changes ..................................................................................................................................................... 2 Item 4 Advisory Business..................................................................................................................................................... 4 Item 5 Fees and Compensation........................................................................................................................................... 6 2  Item 6 Performance-Based Fees and Side-by-Side Management ...................................................................................... 9 Item 7 Types of Clients ........................................................................................................................................................ 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................. 9 Item 9 Disciplinary Information ........................................................................................................................................ 14 Item 10 Other Financial Industry Activities and Affiliations ............................................................................................... 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................... 17 Item 12 Brokerage Practices ............................................................................................................................................... 17 Item 13 Review of Accounts ................................................................................................................................................ 19 Item 14 Client Referrals and Other Compensation ............................................................................................................. 19 Item 15 Custody .................................................................................................................................................................. 19 Item 16 Investment Discretion ............................................................................................................................................ 20 Item 17 Voting Client Securities .......................................................................................................................................... 20 Item 18 Financial Information ............................................................................................................................................. 20 3  Item 4 Advisory Business About the Firm Weatherstone Capital Management was acquired by Transform Wealth, LLC (“Transform Wealth”) on April 1, 2019. Transform Wealth, LLC was then acquired by Kovitz Investment Group Partners, LLC (“Kovitz”) on April 1, 2025. Kovitz merged with Focus Partners Wealth, LLC except for the Weatherstone division of Kovitz which merged into Focus Partners Advisor Solutions, LLC (“FAS”) both on January 1, 2026. As of January 1, 2026 Weatherstone Capital Management operates as a D/B/A for FAS. For detailed information on FAS please see FAS’ ADV Part 2A. This ADV Part 2A is focused on the Weatherstone Capital Management division. Weatherstone’s Wealth Management Services include investment supervisory services to our clients. FAS, dba Weatherstone Capital Management (hereinafter referred to as “Weatherstone”), is fiduciary advisor, meaning we are required to act in your best interest and not place our own interests ahead of yours. Our commitment is to: • Meet a professional and prudent standard of care when making investment recommendations; • A duty of loyalty to never put our financial interests ahead of yours when making recommendations; • Follow policies and procedures designed to ensure that we give you advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under federal and state securities laws or as a waiver of any un-waivable rights you possess. FOCUS FINANCIAL PARTNERS FAS is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, FAS is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority- owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because FAS is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of FAS. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Investment Supervisory Services Weatherstone offers wealth management services, defined as providing continuous advice to a client or making investments for a client's individual needs. The assets managed by Weatherstone utilize tactical and strategic asset allocation strategies. Weatherstone provides these services as follows: 1) As a Co-Advisor with other investment advisers, where our Co-Advisor provides an assessment, asset allocation advice and client communication services, and we provide portfolio management services; and 4  2) As a sub-advisor for various broker/dealers or registered investment advisory firms on their respective platforms (whose accounts are referred to as wrap fee accounts). Direct client investment supervisory services are available through our affiliate, Focus Partners Wealth, LLC. Your Financial Advisor interviews you and collects data through an investment profile at the opening of the account as to your investment experience, liquidity requirements, and tolerance for risk, as well as for general financial information. The Investment Strategy or Strategies, selected by your Financial Advisor, and guided by your chosen Account Objectives then guides the placement and investments for your managed accounts. You can instruct your Financial Advisor to notify us to exclude certain investments on an individual basis or to impose reasonable restrictions on your accounts. You can also vote, pledge, or hypothecate the investments in your account. In order for us to provide ongoing services, you are responsible to advise your Financial Advisor, who is responsible to notify Weatherstone, in writing of any material changes in your financial status, modifications to your Account Objective, specific investment restrictions if applicable, special reports required if any, and material changes, such as a change of address, marital status, or any other relevant circumstance which may change how you wish your account to be managed. We cannot manage your account if you have no risk tolerance. We are a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. We are also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, we are subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). External Managers When we allocate client assets to External Managers, the referring, client-facing adviser, is responsible for assessing the client’s needs, communicating with the client, allocating (or recommending the allocation of) the client’s assets and conducting due diligence and monitoring of the client’s investments. The External Manager is responsible for managing certain of the client’s assets that we allocate to them in a manner consistent with the manager’s stated investment strategies and in accordance with the guidelines we provide. UPTIQ Treasury & Credit Solutions We offer to third-party unaffiliated investment advisors and their clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Held Away Accounts We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). FOCUS RISK SOLUTIONS, LLC (“FRS”) We make available to investment advisors and their clients the option of obtaining certain insurance solutions from unaffiliated, third-party insurance brokers by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a 5  wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Assets Under Management As of June 30, 2026, FAS had $23.21 billion of discretionary regulatory assets under management and $18.27 billion of non-discretionary regulatory assets under management. In addition, FAS provides administrative, back-office and retirement plan services to $10.70 billion of assets managed or advised by the independent firms that hire FAS for its services. In the aggregate, the total number of assets under management or administration was $52.18 billion. Item 5 Fees and Compensation Fees for Investment Supervisory Services For Weatherstone’s investment supervisory services, Weatherstone collects an investment advisory fee (Management Fee) on a quarterly basis. Our fee schedule is listed below. Our fees are negotiable at our discretion. 1.95%* Bond & Equity Programs at Variable Annuities $1,000,000 and under 2.00% $1,000,001 and over Negotiable Tactical Programs at Axos & Schwab $1,000,000 and under $1,000,001 and over Negotiable *Short-Term Bond 1.00% Strategic-Active & Tactical Foundation Programs at Strategic-Passive Programs at 1.75% Axos & Schwab $1,000,000 and under $1,000,001 and over Negotiable Axos & Schwab $1,000,000 and under 1.30% $1,000,001 and over Negotiable Custom Programs at all custodians up to 2.50% The above fees include and presume fees to Referring Advisors of 1.00% with the exception of .70% for Tactical Short-Term Bond. Referring Advisors determine the rates of their fees, which will not exceed 1.00%. Management fees are based on assets under management and are calculated as a percentage based on the value of all assets in the account, including cash, accrued interest, accrued dividends and securities purchased on margin. Management Fees are due at the beginning of each calendar quarter, in advance, based on the account valuation on the last business day of the prior calendar quarter. An account that is opened mid-quarter is charged an initial Management Fee that includes a portion of the fee that is pro-rated for the number of days that the account is open in the first quarter. In addition, an account that is terminated mid-quarter is charged a Management Fee that is calculated on a pro-rated basis for the number of days the account is open in the quarter. If the termination occurs prior to the end of a billing period, fees paid in advance for the final billing period are considered to be earned through the effective date of the termination date. Any unearned portion of the fee paid in advance will be refunded to the client. If an account changes strategies mid-quarter and the fees for the new strategies, in aggregate are at a higher or lower fee than they were prior to the change, the adjustment to the billing will occur at the next quarter. Fees will vary for legacy clients and in some instances are waived for family and friends of the firm. For certain clients, we charge an advisory fee for services provided to the held-away accounts mentioned above in Item 4, just as we do with client accounts held at our primary custodians. The specific fee schedule charged by us is provided in the client’s investment advisory agreement with us. We do not recommend the use of margin by Clients but we may accommodate Client requests for use of margin by agreement between the Client and the Custodian. To the extent that a Client authorizes the use of margin, and margin is thereafter employed, the market value of the Client’s account and corresponding fee payable by the Client to us will be 6  increased. As a result, in addition to understanding and assuming the additional principal risks associated with the use of margin, Clients authorizing margin are advised of the potential conflict of interest whereby the Client’s decision to employ margin will correspondingly increase the management fee payable to us. Accordingly, the decision to employ margin is left to the sole discretion of the Client. Clients employing margin are advised that the margin balance is not deducted when calculating the advisory fee. Other Information about Advisory Fees The fees charged can be higher or lower than fees charged in the industry for like services. Tactical investment strategies will typically be more expensive than strategic strategies due to the amount of time and infrastructure needed to frequently review and analyze investments, market conditions, and other risk factors, and then to update and trade investment portfolios as needed. Most of the Weatherstone strategies are evaluated weekly as well as at the beginning of each month. Changes are made as needed. Exceptions or any other modifications to the fee schedule or minimum account sizes require our approval. In some instances, the primary custodian receives 12b-1 fees from investment companies. These fees offset client custodial fees and administrative costs. The client assets will be subject to additional fees and expenses as set forth in the prospectuses of those funds and variable annuities. The custodian of the assets will typically charge fees for custodial services or trading charges. These fees and expenses are ultimately borne by the client. Clients Are Responsible for Fees Associated with Investing Clients are responsible for the payment of all third party fees and expenses associated with investing, such as transaction charges and brokerage commissions to their broker/dealer or other service providers (“Financial Institutions”) as well as any fees associated with their particular accounts (e.g., account opening, maintenance, transfer, termination, wire transfer, retirement plan, trust fees, and all such applicable third party fees, deferred sales charges, odd lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions). Third-party fees and expenses that clients are responsible for include the fees and expenses of third-party investment managers. Our fees are separate and distinct from the fees of third-party managers of separately managed accounts and fees and expenses charged to shareholders of ETFs or mutual funds. Such charges, fees and commissions are exclusive of and in addition to the Adviser’s fees. The fees charged by third-party managers of separately managed accounts are described in the Form ADV 2A brochure of that investment manager, and the fees and expenses charged by a mutual fund or ETF are described in the prospectus for the relevant fund. We do not receive any portion of these investment- related commissions and/or fees. Clients are encouraged to read each prospectus and securities offering document. Portfolio additions may be in cash or securities provided that Weatherstone reserves the right to liquidate any transferred securities, or decline to accept particular securities into a client’s account. Weatherstone may consult with its clients about the options and ramifications of transferring securities. However, clients are hereby advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. FOCUS RISK SOLUTIONS, LLC (“FRS”) We make available to investment advisors and their clients the option of obtaining certain insurance solutions offered by our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. FRS assists these investment advisors’ clients with regulated insurance sales activity by advising such clients on insurance matters and placing insurance matters and placing insurance products for them and/or referring such clients to third-party licensed insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS, place insurance products for them. If FRS places an insurance product or refers one of these investment advisors’ clients to an insurance broker and there is a purchase of insurance through the broker, then 7  FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS will vary over time in response to market conditions and negotiations and will also differ based on the type of insurance product sold and which broker placed the policy. Investment advisors and their clients who use FRS’s services will receive product-specific disclosure from the brokers and insurance carriers and other unaffiliated third-party intermediaries that provide such services. Such fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not directly share in such revenue, although certain revenue is “passed through” FAS to reach FRS but FAS does not receive any “passed through” revenue. FRS also indirectly benefits from the investment advisors and their clients’ use of the services insofar as such use of incentives the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. UPTIQ TREASURY & CREDIT SOLUTIONS We make available to investment advisors and their clients the option of obtaining certain credit and cash management financial solutions from unaffiliated third-party financial institutions with the assistance of UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus, LLC is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients, which benefits UPTIQ, Inc.’s investors, including Focus, LLC. Investment advisors and their clients who use UPTIQ’s or Flourish’s services will receive product-specific disclosure from the unaffiliated third-party financial institutions and other unaffiliated third-party intermediaries that provide such services. Item 6 Performance-Based Fees and Side-by-Side Management We do not have any performance-based fee clients. Item 7 Types of Clients We provide investment advice to independent registered investment advisors, end individuals (which may include individuals, trusts, estates, ERISA plans, corporations or other business entities) and registered investment companies. We also provide retirement solutions services to qualified retirement plans. We have a minimum account value of $25,000 and a program minimum of $12,500. At our discretion, we may accept smaller accounts and programs. Note, if your account is of a smaller size and the program you have selected invests in stocks, we may have to substitute other investments, such as mutual funds with similar objectives, due to the limitations of purchasing stocks with small dollar amounts. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We offer the Investment Programs listed below. Each investment strategy has different objectives and ways of adjusting to changing investment climates. Most programs seek to manage risk based upon various measures that have been useful historically. While we expect that they will be useful in the future, market dynamics can and do change, and as a result it is not unusual to see the methods of risk measurement and analysis change over time as well. While risk management strategies can be quite effective when market changes are due to the impact of factors such as rising interest rates or economic cycles, they have little ability to protect against unexpected events such as terrorist attacks, major earthquakes, pandemics, etc. which are unpredictable. If we experience one of these types of situations, our goal is to determine if the financial markets have overreacted to the intermediate and long-term impact of the event and adjust the asset allocations accordingly. Each investment strategy is best suited for investors who can hold the portfolio over a full market cycle of both a bull and bear market, because there are some market environments where programs may outperform their benchmarks, and others where they will lag behind. A full market cycle will typically give you some of each. You should review each program 8  description to ensure that you are comfortable with the style of management and types of investments used by each program that you select under your investment advisory agreement. Please consult with your financial advisor for a current listing of custodians on which the investment management programs are made available. The programs will often have different holdings and may trade differently from one custodian to another based upon factors such as investment options available and transaction fees and trading cutoff times. Each program listed below has corresponding risks associated with the investment. Our program sheets also show performance for the programs. This data is given for performance at the primary custodian. We do not provide program sheets by individual custodians. MANAGED HIGH YIELD - The Managed High Yield strategy is designed to generate income and growth through a portfolio primarily composed of non-investment grade corporate bond mutual funds. This program is designed to hold corporate bond mutual funds when various risk measurement models show that the funds have the potential to produce a higher return than a money market fund over an intermediate-term time frame. Mutual funds are used to provide greater diversification and liquidity than in a portfolio of individual bonds. During periods that show above average risk, the money is typically moved into a money market fund, or government bond fund. ASSET ENHANCEMENT - The goal of the program is to provide clients with the ability and opportunity to participate in various financial markets and to provide that participation with a focus on reducing risk. The program is based on a foundation of dynamic asset allocation/modeling. The primary trading model is trend following in nature and based on technical indicators. Short-term, intermediate, and long-term trends are taken into consideration. A series of secondary models may be used when the primary model is less than 100% invested or in a defensive mode. The secondary models are designed to invest in bonds and equity income asset classes, as well as market index funds. The primary model is mostly mechanical and allows for some manager discretion. This component allows for flexibility during unusual events. The secondary models are driven by a variety of factors, as well as by manager discretion. Equity, bond, domestic and international funds are all options to be used within this program. Position size will vary accordingly, with money market positions taken as a defensive stance. The two main goals of the program are capital preservation and consistent returns over time. INCOME PLUS - The Income Plus program is designed for income-oriented and moderate growth investors who wish to grow their assets through bonds and other equity income type investments. The portfolio will primarily concentrate its assets in the high yield corporate bond asset class when that sector is favorable, and will also use other bond asset classes and other income-oriented asset classes if the manager determines that they could have a favorable impact on the portfolio. During time periods when market conditions are determined to be generally unfavorable to bonds, then money market funds and inverse rising rate bond funds, and other defensive mutual funds designed to preserve purchasing power may be used. STRATEGIC INCOME - The Strategic Income program is a tactically managed investment strategy designed to generate income and growth by investing in fixed income mutual funds and ETFs. The portfolio can invest across the full spectrum of fixed income securities without minimum or maximum weightings to any specific area within the fixed- income universe. During periods where the portfolio manager does not find attractive opportunities in fixed income securities, money market funds, other cash equivalent instruments and inverse rising rate bond funds may be used. TAX-AWARE FIXED INCOME - The Tax-Aware Fixed Income program is a tactically managed investment strategy designed to primarily utilize tax-free municipal bonds, but will also include taxable bonds in the portfolio when the portfolio 9  manager determines that they have income or capital appreciation potential that is more attractive than current opportunities in tax-free municipal bonds. The portfolio may move from being fully invested in tax-free municipal bonds to being fully invested in taxable bonds. During periods where the portfolio manager does not find attractive opportunities in fixed income securities, money market funds, other cash equivalent instruments and inverse rising rate bond funds may be used. BALANCED GROWTH - The goal of the Balanced Growth program is to provide long-term growth of capital from a portfolio of stock and bond exchange-traded and traditional mutual funds that is diversified across several different tactical investment strategies where each directs a portion of the investment allocation, and determines the allocation between stocks, bonds and cash. The program is typically weighted 70% equities and 30% bonds. During periods when the various investment models indicate that there is little or no potential for gain over the intermediate-term in their respective categories, the asset allocation for that model will typically be moved to money markets or inverse positions to hedge long positions, or allocated to another model. DIVERSIFIED GROWTH - The Diversified Growth program is designed for investors seeking long-term growth of their capital over time. The program will typically be invested in stock exchange-traded and traditional mutual funds when conditions for a rising stock market exist. The program adds additional diversification by including tactical mutual funds, which typically provide additional managers who have the ability to utilize innovative strategies that can adapt to changing market environments. During periods when the various investment models indicate that there is little or no potential for gain over the intermediate-term in their respective categories, the asset allocation for that model will typically be moved to money markets or inverse positions to hedge long positions, or allocated to another model. STRATEGIC DIVIDEND – The Strategic Dividend strategy seeks to deliver long-term growth of capital by investing primarily in high quality, individual large cap value U.S. companies. With an emphasis on stability and strong fundamentals, this strategy controls sector and attribute exposures based on the investment team’s perceived state of the market cycle and thematic catalysts believed to offer upside opportunity. The portfolio seeks to achieve these results by maintaining holdings concentrated in 35-50 companies with strong financial condition, strong relative earnings power, astute management, and a company culture of returning earnings to shareholders through dividends. HIGH QUALITY GROWTH - The High-Quality Growth program is an actively-managed strategic portfolio with a disciplined approach to investing in a concentrated portfolio of 20 to 30 mid-to-large capitalization stocks and international ADRs, growing at above average rates and generate positive cash flow. The managers use a proprietary screening of company fundamentals for the equity decision process, and target stocks that they view as high quality that can be purchased at favorable price/earnings ratios based on fundamental valuation methods. They believe that holding a focused portfolio of quality stocks over a long-term horizon and not striving to match the sector weightings of a market index improves the probability of outperforming the market over time. TACTICAL SHORT-TERM BOND - This program strives to maximize total return while minimizing overall risk by investing in short-duration and floating-rate investments. The program seeks to achieve this by employing active management strategies that leverage analysis of economic data, technical indicators, and relative performance trends. Through the combination of these insights, the portfolio can be dynamically adjusted to navigate changing market conditions. In practice, the Tactical Short-Term Bond program focuses on short-term duration or floating-rate bonds, while also maintaining flexibility to allocate across the full fixed income universe. Additionally, it can tactically move into cash or more conservative assets when market conditions are unfavorable. Typically, the portfolio will invest in corporate bonds when economic conditions support taking on credit risk. During periods of economic uncertainty or when taking on 10  additional credit risk is less desirable, the strategy can shift toward government bonds or money market funds to preserve capital and minimize exposure. In summary, by monitoring economic trends, market signals, and asset performance. CUSTOM PROGRAMS - Custom programs have the ability to utilize customized strategies and investment options that will not normally be used in a standard portfolio. In addition, custom portfolios may also be used on platforms not typically utilized because of their difficulty in managing larger number of accounts at a particular custodian. These accounts may trade in a delayed status (Tier II) compared to the regular strategies; generally, a one-day delay if operationally necessary. The ability to utilize a custom strategy requires the prior written approval of applicant. Mutual Funds and Exchange-Traded Funds (ETFs) Mutual fund and ETF portfolios are comprised of individual equity and debt securities with their own unique company risks. Shareholders are liable for taxes on any capital gains, as these issuers are required by law to distribute capital gains to underlying shareholders. Open-end mutual fund shares are calculated at the end of each business day where all shareholders receive the same closing price. ETF’s generally trade intra-day where the net asset value (NAV) can fluctuate throughout the business day. As a result, ETF investors may receive different prices when trades are executed on the same day. PROGRAM RISKS The investment programs listed above may not be appropriate for all investors. There is no assurance that the Program's separate objectives will be achieved. Because most investment positions will be held less than one year, our investment strategies are best suited for tax-deferred accounts. The items listed below are additional risks associated with our programs. Investing in securities involves risk of loss that clients should be prepared to bear. It is important that clients understand these risks and they proactively address any concerns with their Advisor. Investment returns and the value of your investment will fluctuate and may lose money. (1) Some of our Programs can invest in small/mid-cap and micro-cap stocks. The risks associated with investments in smaller companies include less experienced management, limited product lines and financial resources, shorter operating histories, less publicly available information, which may have more limited marketability and may be subject to more abrupt or erratic market movements than large-cap stocks. This may result in greater share price volatility. (2) Some of our Programs can invest in fixed income securities. Fixed income securities are subject to credit risk, interest rate risk and liquidity risk. Generally, the value of fixed-income securities rises when prevailing interest rates fall and falls when interest rates rise. High-yield bonds, also known as "junk" bonds are subject to greater credit risks and market risks, and are subject to adverse changes in general market conditions and in the industries in which the issuers are engaged, and to changes in the financial conditions of the issuers. (3) Some Programs may also invest in "short" or "inverse" mutual funds which are designed to profit from declining securities prices, which involve certain risks that may include increased volatility due to the funds possible use of short sales of securities and derivatives such as options and futures. Short funds are typically used to offset the risk of "long" positions that may continue to be held in the portfolio. (4) Some strategies may use leveraged mutual funds. The more a fund invests in leveraged instruments, the more the leverage will magnify any gains or losses on those investments. Leveraged mutual funds are typically used for short or intermediate-term trades and enable us to achieve market exposure without selling positions such as bonds or holdings that may move from being taxed as short-term capital gains to being taxed as long-term capital gains. We do not typically use leveraged funds in order to increase the stock market exposure to more than 100% 11  invested. As an example, a 50% allocation in an index fund that is leveraged 2-1 would be expected to provide 100% of the return of an index. The impact of compounding often makes it difficult to achieve a perfect correlation with an index. (5) Money market funds are not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. typically associated with investment in domestic corporations. Funds allocated (6) International funds that invest in the securities of foreign companies involve considerations and potential risks in an not international/global/emerging markets investment could be subject to risks associated with changes in currency values, economic, political, social conditions and local regulatory environments. (7) The securities markets of many of the emerging markets in which the strategies may invest are substantially smaller, less developed, less liquid and more volatile than the securities markets of the United States. (8) Sector specific funds invest in a single sector mutual fund which involves greater risk and potential reward than investing in a more diversified mutual fund. Additional information regarding the risks associated with the investments that may be owned are more fully explained in the prospectus provided by the investment companies. Please read the prospectus for more information. (9) Concentrated portfolios. The program will invest its assets in less than 50 positions, this will expose the portfolio to greater volatility and risk from company specific events than a broadly diversified portfolio would. Concentrated holdings may offer the potential for higher gain, but also offer the potential for higher loss. Market Volatility At various times in the past, volatile market conditions have had a dramatic effect on the value of private investments. In addition, terrorist attacks, other acts of violence or war, health epidemics or pandemics, natural hazards, and/or force majeure may affect the operations and profitability of a Fund’s portfolio companies. Such events also could cause consumer confidence and spending to decrease or result in increased volatility in the U.S. and worldwide financial markets and economy. Any of these occurrences could have a significant impact on the operating results and revenues of a Fund’s portfolio companies and, in turn, on the return of a Fund’s investments. Cybersecurity The computer systems, networks and devices used by our firm and service providers to our firm and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by our firm and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. 12  Limited Partnership / Private Real Estate Investment Trust Risks We offer access to limited partnerships (public and private) and private real estate investment trusts to investors when such investments are consistent with client objectives, risk tolerance, and regulatory eligibility. Private investments are subject to various risks which are set forth in applicable offering documents for each investment. These risks include but are not limited to the risk of loss of principal; liquidity risk; lack of transparency or limitations on communications from the issuer or third parties regarding operations; challenges in obtaining or evaluating comparable pricing information or comparable information on which to evaluate the businesses; limited or no secondary market availability; risks associated with inconsistent dividends and/or distributions; and high internal and operating expenses. Private investments are subject to pricing and liquidity risks as they do not have regular daily pricing. Real Estate Income Trust Risks Investments in non-listed or non-traded real estate investment trusts (REITs) are subject to additional risks including but not limited to: (1) Liquidity risk, as non-traded REITs generally cannot be sold until listed on an exchange or the trust’s assets are liquidated. Early redemptions may be subject to limitations including notice requirements, termination of redemption provisions, and discounted redemption values. (2) Non-traded REITs can include high upfront fees which are generally designed to cover offering and organizational costs. These early, high fees reduce the value of the principal invested and results in less return on investment. In addition, non-traded REITs can involve significant transaction costs including fees to acquire properties and asset management fees. (3) Distributions from non-traded REITs, particularly initial distributions, may be derived from investment principal rather than operations. This practice reduces the value of the shares and reduces the cash available to the REIT to purchase real estate assets. (4) Lack of available share price for non-traded REITs, which may limit or eliminate the ability to assess the value or performance of the investment for significant time periods. (5) Conflicts of interest risks, including external managers that may receive significant transaction fees by the REIT for services that do not align with shareholder interests, such as fees based on the amount of property acquisitions and assets under management. Credit Risk Investments in credit funds are subject to the credit risk of the underlying instruments. Where such investments are below investment grade and speculative, the risks increase that economic downturns will negatively impact the ability to repurchase shares. Additional risks include lack of a secondary market, liquidity risk, redemption risk (including the risk of discounted returns upon early redemptions and other redemption risks associated with shares not listed on an exchange) and risks associated with distributions being funded from unlimited amounts of offering proceeds or borrowings (which reduces the amount of capital available to invest). Item 9 Disciplinary Information Neither the Firm nor any of our management persons have been involved in any event that are material to a client’s or prospective client’s evaluation of the Firm or the integrity of its management. 13  Item 10 Other Financial Industry Activities and Affiliations Focus Financial Partners As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because FAS is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of FAS. Additional information about Focus can be found at www.focusfinancialpartners.com.Our parent company is Focus Financial Partners, LLC (“Focus, LLC” or “Focus”). From time to time, Focus, LLC holds partnership meetings and other industry and best-practices conferences, which typically include FAS, other Focus Partners firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus firms, including FAS. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus Partners firms, including FAS. Although the participation of Focus partner firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause FAS to focus on those conference sponsors in the course of its duties. Focus, LLC attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including FAS. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset Recommendation of Other Advisers Weatherstone Capital Management manages some of the tactical programs with in-house staff while other programs are managed by sub-advisors who provide us with trading instructions. If we use sub-advisors, they are paid for their services. We receive more income for programs managed in-house and it can be considered a conflict of interest to recommend our own investment programs over those of a sub-advisor. Code of Ethics, Participation or Interest in Client Transactions and Item 11 Personal Trading We have adopted a Code of Ethics for all supervised persons expressing the firm’s commitment to ethical conduct. Our Code of Ethics describes its standard of business conduct and fiduciary duty to Clients and sets forth our practice of supervising the personal securities transactions of associates with access to Client information. All supervised persons receive a copy of the Code of Ethics at the time of hiring and must acknowledge the terms of the Code of Ethics annually or more frequently if amended. Subject to satisfying the Code of Ethics and applicable laws, supervised persons and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for our Clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the supervised persons will not interfere with making decisions in the best interest of Clients or allowing employees to invest for their own accounts. It is our expressed policy that no person employed by the firm shall prefer their own interest to that of an advisory Client. It is our policy that its supervised persons shall place the interests of Clients first. Under the Code of Ethics, 14  certain transactions have been designated as exempt transactions, based upon a determination that such transactions would not materially interfere with the best interests of Clients. For a subset of supervised persons called access persons, trading is monitored for compliance with the Code of Ethics, and to reasonably prevent conflicts of interest between us and our Clients. We anticipate that we will generally recommend the purchase or sale of securities to current or prospective Clients in which we, our affiliates, and/or other Clients, directly or indirectly, have a position or interest. All personal securities transactions of such access persons shall be conducted in a manner as to avoid any actual or potential conflicts of interest or any abuse of a position of trust and responsibility or operate as a deceit. To supervise compliance with its Code of Ethics, we require access persons to provide annual securities holding reports and quarterly transaction reports to the firm's Compliance department. We also require such access persons to receive approval from the Compliance department prior to investing in any initial public offerings or private placements. Our Code of Ethics further includes the firm's policy prohibiting the misuse of material non-public information and protecting the confidentiality of client information. We require that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to discipline. Current or prospective Clients may obtain a copy of our Code of Ethics without charge by calling (800) 366-7266 and asking for the Compliance Department. Item 12 Brokerage Practices Investment advisors work with their clients to select a custodian. Many investment advisors use Axos Advisor Services (Axos) for their Clients’ custodial needs when they wish to use multiple strategies in a single account. They have no minimum commission or trading fee and can trade in fractional shares, but there are certain asset-based fees. If we do use a mutual fund that pays a 12b-1 fee to Axos, they use up to 25 basis points of the shareholder servicing fees they receive from the mutual fund used in the account to offset the custodial service fee charged to your account. This offset is only available to customers at Axos, and not to our Clients with other custodians. Many advisors also use Charles Schwab & Company for smaller accounts, and for accounts that do not mind having a separate account for each investment strategy, and because of their customer service, technology, trade execution and low expenses to clients. They have relatively low transaction fees, low custodial fees, and provide many client services free of charge. In many cases, there is also an asset-based fee option for clients. The pricing and execution a Client will receive will vary between Charles Schwab and Axos. There is no guarantee that one will offer better execution than the other will. Choosing one over the other could cost you more money or could result in less favorable execution. We receive referrals from representatives associated with broker-dealers. These broker-dealers may place limitations on the custodial platforms they permit, and have an incentive to recommend a particular custodian because of additional compensation or reduced clearing fees they may pay for other services. We do not receive any research, products or services from broker/dealers or third parties, other than what is necessary for the execution of Client securities transactions. We do not receive any “formal soft dollar” benefits. 15  We do not offer directed brokerage services. Aggregated Trading Weatherstone engages in aggregated, block trading to avoid the time and expense of simultaneously entering similar orders for many individual client accounts that are managed similarly at the same custodian, with a goal to receive the same execution price and minimize any difference in performance. Weatherstone has established procedures to comply with its obligations associated with aggregated, block orders. Other Information about Trading We place trades using your selected custodian, and in some instances, we send our trade instructions to platform sponsors, who in turn execute the trades. Because of the multiple platforms through which we are directing trades, not all trades will be done at the same time. We anticipate that they will generally be done within one business day of each other, but cannot guarantee that result. This means that you may receive better or worse pricing than other individuals in the same program. Trade Error Policy On rare occasions, trade errors c a n occur. To resolve trade errors, we will place a correcting trade with the client’s broker/dealer. At Schwab, we are responsible for any losses exceeding $100 when it is determined we are responsible for the error. To minimize administrative costs, Schwab will absorb any losses less than $100. When investment gains result from a trade error, the gain will be retained by the Client unless it is determined to be not permissible, or the Client elects not to accept the gain for tax purposes or other reasons. Any gains not retained by Clients are donated by Schwab to a charity of its choice. At Axos, we are responsible for reimbursing clients for all losses due to trade errors made by us in client accounts. Any gains resulting from trade corrections are not kept by Axos or paid to the Client, they are instead donated by Axos to a charity of its choice. Item 13 Review of Accounts Accounts are under the supervision by a review team responsible for verifying that each strategy has been reviewed after rebalances or model trades. Model review is to consist of an audit of sample of client accounts or models after adjustments are made to asset allocations for the purpose of determining if transactions were processed properly. Because of the nature of the managed account strategies, all accounts in those strategies are under regular review. Accounts in custom programs are reviewed at least semi-annually. We provide optional quarterly performance statements to some clients. Clients with these types of accounts may view their account information and run reports by going to the client section of our website at www.weatherstone.com. Item 14 Client Referrals and Other Compensation FAS, through its Weatherstone division, continues to pay Solicitors for client referrals that were made in the past but has terminated some of these agreements. FAS’s parent company is Focus Financial Partners, LLC (“Focus” or “Focus, LLC”). From time to time, Focus holds partnership meetings and other industry and best-practices conferences, which typically include FAS, other Focus firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of 16  Focus firms, including FAS. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including FAS. Although the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause FAS to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including FAS. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from between January 1, 2025 to and February 1, 2026: o Addepar, Inc. o AQR Capital Management, LLC o Bigelow LLC o BlackRock, Inc. o BOWS Administrator LLC (Brookfield Oaktree Wealth Solutions) o Capital Integration Systems LLC (CAIS) o Charles Schwab & Co., Inc. o Cliffwater LLC o Dimensional Fund Advisors LP o Dinsmore Compliance Services, LLC (DCS) o Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) o Edgewood Partners Insurance Center (EPIC) (includes Vanbridge) o Fidelity Brokerage Services LLC(includes FIAM and Wealthscape) o Flourish Financial LLC o Franklin Templeton Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) Jackson National Life Distributors LLC o o K&L Gates LLP o Lord, Abbett & Co. LLC o Nuveen Securities, LLC o Orion Advisor Solutions, Inc. o Pacific Investment Management Company LLC (PIMCO) o Pinnacle Insurance & Financial Services, LLC o Practifi, Inc. o Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct Equity Active Long Short)) o RedBlack Software, LLC (includes intelliflo) o SmartAsset Advisors LLC o Stone Ridge Asset Management LLC o The Vanguard Marketing Corporation, Inc. o T. Rowe Price Investment Services, Inc. 17  o TriState Capital Bank o VRGL Inc. o You can access updates to the list of conference sponsors on Focus’ website through the following link: https://www.focusfinancialpartners.com/conference-sponsors For a detailed list of other compensation arrangements that FAS receives outside of its operation as Weatherstone Capital Management can be found FAS’ ADV Part 2A. Item 15 Custody We typically deduct advisory fees from client accounts held at an independent custodian, as allowed under the safe harbor provisions of the SEC’s Custody rule. The qualified custodian of client assets sends account statements directly to Clients. You will receive account statements from the broker-dealer or other qualified custodian at least quarterly. You should carefully review those statements because they are the independent custodian who holds your investments. An independent custodian is an important safeguard to protect your account. We provide some of our clients with portfolio reports. If you receive these types of reports, we urge you to compare their contents with the statements you receive from your custodian. In the event of a valuation discrepancy, the custodial statement will serve as the official statement. Item 16 Investment Discretion We ask you to provide us with investment discretion with respect to securities to be bought and sold and amount of securities to be bought and sold. You grant us this authority by signing a discretionary asset management agreement. We use this investment discretion to be able to adjust our asset allocation across our investment models as market conditions and investment opportunities change. This allows us to make the adjustment for individual client accounts, and as a group with others invested in the same strategy. We may also use this discretion to select different sub-advisers to use to help us manage our programs. Item 17 Voting Client Securities We do not vote proxies on behalf of our Clients. Clients will receive proxies or other solicitations directly from their custodian and can contact the custodian with questions about any particular solicitation. Also, we do not participate in any class action lawsuits on behalf of our Clients. Item 18 Financial Information We do not require or solicit prepayment of investment advisory fees of more than $1,200, six months or more in advance. We are unaware of any financial condition that is likely to impair our ability to meet our contractual commitments to our clients and we have not been the subject of a bankruptcy petition. 18