PHFA ADV PART 2A

Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Item 1 - Cover Page FIRM BROCHURE FORM ADV PART 2A Powerhouse Financial Advisors, Inc. CRD No. 338952 SEC-Registered Investment Adviser | Investment Advisers Act of 1940 Principal Office 1674 US Hwy 395 N, Suite 208, Minden, NV 89423 (775) 266-8867 www.powerhousefinancialadvisors.com Chief Compliance Officer Steven James Smit, CFP® │ CEO │ CCO steve@powerhousefa.com IMPORTANT NOTICE: This brochure provides information about the qualifications and business practices of Powerhouse Financial Advisors, Inc. ("PHFA" or the "Firm"). If you have any questions about the contents of this brochure, please contact us at (775) 266-8867 or steve@powerhousefa.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Additional information about PHFA is available on the SEC's website at www.adviserinfo.sec.gov. Registration as an investment adviser does not imply a certain level of skill or training. Brochure Date: August 18, 2026 Item 2. Material Changes This brochure amends PHFA's previously filed brochure dated May 6, 2026. The following material changes have occurred since that prior filing: • Correction of Advisory Fee Disclosure. The fee schedule previously shown in Item 5 did not match the fee schedule set forth in PHFA's executed client advisory agreements. Item 5 has been corrected to reflect the tiered, blended fee schedule actually charged, the calculation of fees on the average daily balance of account assets, and the 0.25% annual portfolio platform fee charged on assets custodied at Charles Schwab. The portfolio platform fee was not previously disclosed in this brochure. Clients' actual fees have not changed; this amendment corrects the disclosure to match the fees charged under their advisory agreements. Firm Brochure · August 14, 2026 · Page 1 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 • SEC Registration Transition. PHFA has applied for registration with the SEC as an investment adviser. Upon SEC effectiveness, PHFA's registration with the applicable state securities authorities will be withdrawn pursuant to a partial Form ADV-W. • Howard Capital Management (HCM), CRD No. 118070 — Two Separate Arrangements. (1) PHFA-Managed SDBA Accounts: PHFA manages Self-Directed Brokerage Accounts within 401(k) plans under PHFA's own advisory agreement, using HCM's affiliated mutual funds (HCMPX, HCMDX, HCMKX) through Charles Schwab. PHFA exercises investment discretion and bills its advisory fee and the portfolio platform fee through Orion. These assets are included in PHFA's regulatory assets under management. HCM's funds carry internal management fees of 0.95% to 1.25% annually. (2) Direct HCM Referrals: PHFA has entered into a written Investment Advisory Solicitation Agreement with HCM, executed February 24–25, 2026, under Rule 206(4)-1. PHFA refers certain retirement plan participants directly to HCM as their adviser of record. Those assets are managed by HCM and are not included in PHFA's RAUM. PHFA receives a 0.75% annual referral fee from HCM's mutual fund management fees as revenue sharing. • Retirement Recommendation Documentation. PHFA has adopted a firm-wide procedure under DOL Prohibited Transaction Exemption 2020-02. A written analysis and client disclosure is completed for each covered recommendation involving retirement assets, including rollovers, transfers, account-type changes, distributions, and referrals to third-party managers. • Aspire Financial Services Added as Retirement Plan Recordkeeper. PHFA has engaged Aspire as a recordkeeper for retirement plan consulting services. Aspire's fees and the nature of any economic benefits received are disclosed in Items 5 and 10. • Jackson National Life Insurance Company — Variable Annuity Advisory Fee Arrangement. PHFA has entered into an Onboarding Agreement with Jackson National, dated April 20, 2026, authorizing PHFA to bill its advisory fee directly from variable annuity contract values via fee disbursements. PHFA does not receive commissions on these contracts. Fee disbursements reduce contract values, death benefits, and optional benefits. See Items 5.G and 10.A. • Tax Referral Business Clarified. Item 10.C has been corrected to describe Steven James Financial as a tax referral business owned by Steven Smit, which refers clients to third-party tax preparers, rather than as a tax preparation business. As a matter of firm practice, PHFA will deliver this updated brochure to all existing clients within 30 days of SEC effectiveness. Clients may request a copy at any time, without charge, by contacting PHFA at steve@powerhousefa.com or (775) 266-8867. Firm Brochure · August 14, 2026 · Page 2 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Item 3. Table of Contents Item 1. Cover Page 1 Item 2. Material Changes 2 Item 3. Table of Contents 3 Item 4. Advisory Business 4 Item 5. Fees and Compensation 5 Item 6. Performance-Based Fees and Side-By-Side Management 8 Item 7. Types of Clients 8 Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss 8 Item 9. Disciplinary Information 9 Item 10. Other Financial Industry Activities and Affiliations 10 12 Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Item 12. Brokerage Practices 12 Item 13. Review of Accounts 13 Item 14. Client Referrals and Other Compensation 13 Item 15. Custody 14 Item 16. Investment Discretion 14 Item 17. Voting Client Securities 14 Item 18. Financial Information 15 Firm Brochure · August 14, 2026 · Page 3 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Item 4. Advisory Business A. Description of the Firm Powerhouse Financial Advisors, Inc. ("PHFA" or the "Firm") is a Nevada corporation formed in August 2025. PHFA is registered with the U.S. Securities and Exchange Commission as an investment adviser under the Investment Advisers Act of 1940 ("Advisers Act"). Steven James Smit is the Chief Executive Officer, Chief Compliance Officer, and sole owner (100%) of PHFA. Mr. Smit holds the CERTIFIED FINANCIAL PLANNER™ (CFP®) designation. B. Description of Advisory Services 1. Discretionary Portfolio Management PHFA provides continuous and ongoing discretionary portfolio management services. PHFA constructs, monitors, and rebalances investment portfolios consisting of equities, fixed income securities, mutual funds, exchange-traded funds (ETFs), and other investment vehicles. PHFA tailors each portfolio to the individual client's investment objectives, risk tolerance, time horizon, and financial situation as gathered through the client intake process and ongoing reviews. 2. SEI Sub-Advised Program PHFA offers access to the SEI Private Trust Company ("SPTC") and Capital Bank & Trust ("CB&T") sub-advisory platform. Client assets are invested in SEI-managed model portfolios. SEI serves as sub-adviser and directs day-to-day investment decisions within the client's selected strategy. PHFA acts as the introducing adviser, establishes the client relationship, assists with account opening and strategy selection, and monitors the overall suitability of the SEI program. PHFA receives a referral and revenue-sharing portion of the SEI program fee. PHFA charges its standard advisory fee on SEI sub-advised accounts in addition to the SEI program fee. See Items 5 and 10. See Items 5 and 10. 3. Financial Planning Services PHFA offers comprehensive financial planning services on a fixed-fee or hourly basis, which may address retirement planning, investment planning, tax planning considerations, education funding, insurance analysis, estate planning, cash flow analysis, and debt management. Recommendations are based on information provided by the client. Implementation of financial planning recommendations through PHFA's investment advisory services may result in additional compensation to PHFA. 4. Retirement Plan Consulting PHFA provides consulting services to employer-sponsored retirement plans, including 401(k) plans, Cash Balance Pension plans, Self-Directed Brokerage Accounts (SDBA), and Personal Choice Retirement Accounts (PCRA). Services include plan design review, investment menu evaluation, investment policy statement development, participant education, and fiduciary support. PHFA manages certain SDBA accounts under its own advisory agreement using HCM's affiliated mutual funds as investment vehicles. PHFA may also refer certain retirement plan participants directly to Howard Capital Management ("HCM") as their investment adviser under a written solicitation agreement. See Items 5, 10, and 14. C. Client-Tailored Services and Investment Restrictions PHFA tailors its advisory services to the individual needs of each client. Prior to the commencement of advisory services, PHFA gathers information regarding the client's investment objectives, risk tolerance, investment time horizon, liquidity needs, and any investment restrictions. Clients may impose reasonable restrictions on the management of their accounts, including restrictions on investing in specific securities or categories of securities. PHFA will accommodate reasonable restrictions to the extent practicable; however, PHFA may decline to accept or continue an advisory relationship if the restrictions significantly limit PHFA's ability to manage the account in a suitable manner. D. Wrap Fee Programs PHFA does not sponsor or participate in a wrap fee program. E. Assets Under Management As of July 1, 2026, PHFA managed $108,231,666 in client assets on a discretionary basis and $0 in client assets on a non- discretionary basis. These amounts are calculated on the same basis as the regulatory assets under management reported Firm Brochure · August 14, 2026 · Page 4 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 in Item 5.F of Part 1A of Form ADV. Clients and prospective clients may obtain current information at www.adviserinfo.sec.gov. Item 5. Fees and Compensation A. Discretionary Portfolio Management Fees PHFA charges fees for discretionary portfolio management services based on a percentage of assets under management. The fee schedule is tiered and blended, meaning each portion of a client's assets is charged at the rate applicable to that tier. PHFA's advisory compensation consists of two components: a portfolio management fee and, for accounts custodied at Charles Schwab, a portfolio platform fee. Total Assets Under Management Annual Portfolio Management Fee $0 – $1,000,000 1.00% $1,000,001 – $3,000,000 0.80% $3,000,001 – $5,000,000 0.60% $5,000,001 and above 0.40% The schedule above is the portfolio management fee and applies to all discretionary portfolio management accounts. A separate portfolio platform fee of 0.25% annually applies only to accounts custodied at Charles Schwab, as described in paragraph B. The platform fee does not apply to accounts in the SEI Sub-Advised Program or to Jackson National variable annuity contracts. For those accounts, the portfolio management fee above is the entire advisory fee. Both fees, where charged, are advisory compensation retained by PHFA. Example. For a $2,000,000 account custodied at Schwab, PHFA charges 1.00% on the first $1,000,000 ($10,000) and 0.80% on the portion between $1,000,000 and $2,000,000 ($8,000), plus the 0.25% platform fee on the full balance ($5,000). Total annual advisory compensation to PHFA is $23,000, an effective rate of 1.15%. Advisory fees are billed quarterly in arrears. PHFA calculates fees using the average of the daily balance in the client's account throughout the billing period, after accounting for deposits and withdrawals. The applicable rate is determined by the total value of assets under PHFA's management for each client household. Fees are negotiable in PHFA's sole discretion. Discounted pricing is available to immediate household members of PHFA's adviser representatives. Because fees are negotiable, some clients may pay more or less than other clients for the same services. Lower fees for comparable services may be available from other sources. PHFA does not impose an account minimum. PHFA is not compensated on the basis of a share of capital gains or capital appreciation of client funds. B. Portfolio Platform Fee In addition to the portfolio management fee described above, PHFA charges a portfolio platform fee of 0.25% per annum on assets held in custodial accounts at Charles Schwab, including Self-Directed Brokerage Accounts and Personal Choice Retirement Accounts managed by PHFA. It is deducted quarterly and appears as a separate line item on the custodial statement. The portfolio platform fee is retained by PHFA as compensation for its advisory services. It is not paid to Charles Schwab or to any third-party technology, reporting, or platform provider, and it is not a pass-through of any cost PHFA incurs. It is a second component of PHFA's advisory compensation and is charged in addition to any fees assessed by the custodian. The platform fee does not apply to accounts in the SEI Sub-Advised Program or to variable annuity contracts held at Jackson National Life Insurance Company. C. SEI Sub-Advised Program Fees Firm Brochure · August 14, 2026 · Page 5 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Clients who participate in the SEI sub-advised program are charged a single bundled program fee ranging from approximately 0.25% to 2.00% annually, depending on the investment strategy selected, calculated on the average daily balance of assets. This fee covers SEI's sub-advisory services, custody provided by SPTC or CB&T, and an adviser revenue- sharing component paid to PHFA. PHFA charges its standard advisory fee from the tiered schedule in Item 5.A in addition to the SEI program fee. The portfolio platform fee does not apply to SEI accounts. The exact fee applicable to each client is disclosed in the SEI account documentation provided at account opening. PHFA receives both its advisory fee and a revenue-sharing portion of the SEI program fee in connection with SEI accounts. This creates a conflict of interest because PHFA has a financial incentive to recommend the SEI program and receives compensation from two sources. See Item 10. D. Financial Planning Fees • Fixed fee: $1,500 to $3,000 per engagement, depending on scope and complexity. • Hourly fee: $350 to $450 per hour. The fee and scope of services are agreed upon in writing before services commence. Financial planning fees are not based on assets under management and are not affected by investment performance. PHFA does not require or solicit prepayment of more than $1,200 in fees six or more months in advance of services rendered. Financial planning clients who also engage PHFA for discretionary portfolio management may receive a fee credit or reduction at PHFA's discretion. E. Retirement Plan Consulting Fees PHFA does not take part in retirement plan consulting. F. Howard Capital Management — Fee Arrangements Arrangement 1 — PHFA-Managed SDBA Accounts. PHFA manages Self-Directed Brokerage Accounts within 401(k) plans under PHFA's own advisory agreement with the plan participant. PHFA exercises investment discretion, selecting HCM's affiliated mutual funds — HCM Dividend Sector Plus Fund (HCMPX), HCM Tactical Growth Fund (HCMDX), and HCM Income Plus Fund (HCMKX) — as investment vehicles through Charles Schwab. PHFA's portfolio management fee and the 0.25% portfolio platform fee both apply to these accounts and are billed through Orion. These assets are included in PHFA's regulatory assets under management. Layered costs. A client in a PHFA-managed SDBA at Schwab using HCM funds bears three separate layers of cost: PHFA's portfolio management fee under the schedule in paragraph A; the 0.25% portfolio platform fee; and the internal management fee of the HCM funds, which ranges from 0.95% to 1.25% annually These costs are cumulative and, in combination, may approach or exceed 2.5% annually. Clients should review each fund's prospectus before investing. Arrangement 2 — Direct HCM Referrals. PHFA also refers certain retirement plan participants directly to HCM as their investment adviser of record, pursuant to a written Investment Advisory Solicitation Agreement executed February 24–25, 2026, under Rule 206(4)-1 of the Advisers Act. Under this arrangement, HCM manages the assets and is the adviser of record, and those assets are not included in PHFA's RAUM. PHFA receives a referral fee of 0.75% annually, paid monthly from HCM's mutual fund management fees as revenue sharing. This fee does not result in an additional charge to the referred client. PHFA has a conflict of interest because it has a financial incentive to refer clients to HCM rather than to other managers. PHFA addresses this by providing a written solicitor disclosure at the time of each referral and by completing its PTE 2020-02 documentation for each covered retirement account recommendation. G. Aspire — Retirement Plan Recordkeeping PHFA uses Aspire Financial Services as a retirement plan recordkeeper for certain retirement plan consulting clients. Aspire charges its own recordkeeping and administrative fees directly to plan accounts or plan sponsors. These fees are separate from and in addition to any fees charged by PHFA. PHFA does not receive compensation directly from Aspire in connection with plan referrals. Aspire's fees and services are disclosed in the plan's service agreement. H. Jackson National — Variable Annuity Advisory Fee Disbursements PHFA has entered into an Onboarding Agreement for Registered Investment Advisers with Jackson National Life Insurance Company ("Jackson National"), dated April 20, 2026. PHFA is authorized to administer and service variable annuity ("VA") Firm Brochure · August 14, 2026 · Page 6 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 contracts issued by Jackson National and held by PHFA advisory clients. PHFA does not receive commissions on these contracts. Instead, PHFA bills its portfolio management fee by directing fee disbursements directly from the client's contract value ("Fee Disbursements"). The portfolio platform fee described in paragraph B does not apply to Jackson National contracts. Fee Disbursements are subject to the following conditions: (i) each request must be submitted to Jackson National in good order prior to the close of the New York Stock Exchange on the day requested; (ii) Fee Disbursements in any calendar year may not exceed 1.5% of the total cash value of the contract; (iii) Fee Disbursements reduce the cash surrender value of the contract, the basic death benefit, and may reduce any optional living or death benefits elected by the client; (iv) Fee Disbursements count as withdrawals under the contract and are included in the calculation of the free withdrawal amount; and (v) Fee Disbursement withdrawals are not available if the client has elected an optional death or living benefit unless those benefits are explicitly identified as eligible in the contract or any endorsement. Jackson National VA contract values subject to PHFA's ongoing advisory services are included in PHFA's regulatory assets under management. Conflicts of interest associated with this arrangement are disclosed in Item 10.A. I. Third-Party and Custodial Fees In addition to PHFA's advisory compensation described in paragraphs A and B, clients may incur the following third-party costs, which are not paid to PHFA: • Custodial fees. Transaction commissions, account maintenance fees, and other charges assessed by custodians (Charles Schwab, SEI Private Trust Company, Capital Bank & Trust, or Aspire), as disclosed in the custodian's fee schedule. • Mutual fund and ETF expenses. Internal management fees and operating expenses reflected in a fund's expense ratio. • HCM mutual fund internal fees. HCM's affiliated mutual funds held in PHFA-managed SDBA accounts carry internal management fees of 0.95% to 1.25% annually. These are in addition to PHFA's advisory compensation. For accounts referred directly to HCM, HCM's own fee applies. • Annuity contract charges. Mortality and expense charges, administrative fees, rider charges, and surrender charges applicable to variable annuity contracts. The total combined fees charged by PHFA and any third-party money managers (including SEI program fees) will not exceed 3.00% per annum of assets under management. This cap does not include fund-level internal expenses such as HCM mutual fund management fees or variable annuity contract charges. Clients should review all custodial and third- party statements and fee disclosures. Clients will generally pay a higher total cost when multiple service providers are involved. For information on custodian selection and brokerage practices, see Item 12. J. Fee Billing and Account Deduction Advisory fees are billed quarterly in arrears and calculated on the average daily balance of assets in the client's account during the billing period. Clients authorize PHFA in their advisory agreement to instruct the custodian to deduct the portfolio management fee and, where applicable, the portfolio platform fee directly from the client's account. The custodian sends account statements to clients, at least quarterly, showing all amounts disbursed from the account, including both fee components. Clients should review these statements carefully and contact PHFA with any questions or discrepancies. PHFA maintains a Billing Error Log and reviews billing calculations for accuracy at least annually. K. Termination and Refunds Either party may terminate the advisory agreement upon 30 days' prior written notice. A client may terminate within five business days of signing the agreement without penalty or fee. Because fees are billed in arrears, upon termination PHFA prorates fees for the portion of the quarter during which services were rendered and invoices for any fees earned but not yet collected. No refund of prepaid fees is applicable because PHFA does not bill in advance. PHFA does not charge early termination fees or penalties. Item 6. Performance-Based Fees and Side-By-Side Management Firm Brochure · August 14, 2026 · Page 7 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 PHFA does not charge performance-based fees, meaning fees based on a share of capital gains or capital appreciation of client assets. PHFA does not engage in side-by-side management of accounts charged performance-based fees. Item 7. Types of Clients • Individuals, including high net worth individuals • Joint accounts and family accounts • Trusts, estates, and charitable organizations • Corporations and business entities • Employer-sponsored retirement plans (401(k) plans, Cash Balance Pension plans) and plan participants PHFA has no minimum account size requirement. Minimum account sizes may be established for specific services, programs, or strategies at PHFA's discretion. PHFA reserves the right to decline advisory relationships based on the nature of services requested, account size, suitability considerations, or other factors at its reasonable discretion. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Fundamental analysis. PHFA evaluates the intrinsic value of securities by examining financial statements, management quality, earnings growth, competitive positioning, industry trends, and macroeconomic factors, primarily in evaluating individual equity and fixed income securities and fund managers. Technical analysis. PHFA may use technical analysis, including review of price trends, momentum indicators, and charting patterns, to assist in timing investment decisions or identifying entry and exit points. Asset allocation and modern portfolio theory. PHFA constructs diversified portfolios based on principles of asset allocation and modern portfolio theory, seeking to optimize the expected risk-return profile consistent with the client's objectives and risk tolerance. Third-party research and sub-adviser analysis. PHFA may utilize research and analysis provided by third parties, including Howard Capital Management, SEI, and other investment managers. In the SEI program, SEI's proprietary research and portfolio management process govern investment decisions within the selected strategy. Risk assessment. PHFA conducts ongoing risk assessment of client portfolios, including monitoring for concentration risk, liquidity risk, interest rate sensitivity, and changes in client circumstances. Clients are encouraged to notify PHFA of any material change in their financial situation, objectives, or risk tolerance. B. Investment Strategies • Long-term buy-and-hold strategies using diversified portfolios of mutual funds and ETFs • Asset allocation strategies tailored to individual client objectives and risk profiles • Income-oriented strategies using fixed income securities, dividend-paying equities, and income-focused funds • Growth-oriented strategies emphasizing equities and equity funds • Conservative strategies emphasizing capital preservation with limited equity exposure • Retirement income strategies that may include annuity and insurance products offered through the separate insurance activities of PHFA's principal — see Item 10 • SDBA accounts managed by PHFA using HCM's affiliated mutual funds through Charles Schwab C. Risk of Loss Firm Brochure · August 14, 2026 · Page 8 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 All investing involves the risk of loss, including possible loss of principal. PHFA does not guarantee any specific investment outcome. Material risks include: • Market risk. The value of investments may decline due to general market conditions, economic factors, political events, or investor sentiment. • Interest rate risk. Rising interest rates typically cause bond prices to decline. • Credit risk. An issuer may default on its obligations, resulting in loss of principal. • Inflation risk. Inflation may erode the purchasing power of investment returns over time. • Concentration risk. Portfolios concentrated in specific sectors, geographies, or individual securities may experience greater volatility. • Liquidity risk. Certain investments may not be readily sold at a fair price in a timely manner. • Manager risk. In the SEI program, results depend in part on SEI's decisions as sub-adviser. In PHFA-managed SDBA accounts, results depend in part on the performance of the HCM funds selected by PHFA. For accounts referred directly to HCM, results depend on HCM's management decisions. • Cost layering risk. Where multiple fee layers apply — PHFA's advisory compensation, a platform fee, and fund-level expenses — the cumulative cost reduces net return more than any single component suggests. • Retirement plan risk. Investments held in retirement plans are subject to ERISA requirements and early withdrawal penalties. Participants should consult their tax and legal advisers. • Model portfolio risk. Clients in model-based strategies are invested in the same portfolio as other clients; individual circumstances may not be fully reflected. • Annuity risk. Variable annuity contracts carry mortality and expense charges, administrative fees, and surrender charges. Guarantees are subject to the claims-paying ability of the issuing insurance company. Past performance of any investment strategy is not indicative of future results. Item 9. Disciplinary Information Registered investment advisers are required to disclose all material facts regarding legal or disciplinary events that would be material to a client's or prospective client's evaluation of the firm or the integrity of its management. PHFA and Steven James Smit (CRD No. 5849990) have no disciplinary history. There are no legal or disciplinary events required to be disclosed under this Item. Firm Brochure · August 14, 2026 · Page 9 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Item 10. Other Financial Industry Activities and Affiliations Neither PHFA nor any of its management persons is registered, or has an application pending, as a broker-dealer, registered representative, futures commission merchant, commodity pool operator, or commodity trading advisor. A. Insurance Activities — BackNine Insurance and Jackson National Steven James Smit is an independent licensed insurance agent appointed through BackNine Insurance. BackNine is not affiliated with PHFA. In this capacity, Mr. Smit may recommend and sell fixed insurance and life insurance products to PHFA advisory clients and will receive commissions or other compensation from the insurance carrier. This creates a conflict of interest because Mr. Smit has a financial incentive to recommend insurance products, and the compensation received may vary depending on the product recommended. Separately, PHFA has entered into an Onboarding Agreement with Jackson National Life Insurance Company, dated April 20, 2026, authorizing PHFA to administer and service Jackson National variable annuity contracts held by PHFA advisory clients. This is a distinct arrangement from the BackNine relationship. PHFA does not receive commissions on Jackson National VA contracts; instead PHFA bills its portfolio management fee through fee disbursements from contract value. This creates the following conflicts: • Fee disbursements reduce the cash surrender value of the contract, the basic death benefit, and may reduce optional living and death benefits. They count against the contract's annual free withdrawal amount and are capped by Jackson National at 1.5% of contract value per calendar year. • Because PHFA earns its ongoing advisory fee from the contract value, PHFA has a financial incentive to recommend that clients maintain assets in Jackson National contracts rather than move them elsewhere, even where an alternative might better serve the client. PHFA addresses both conflicts by recommending insurance and annuity products only where PHFA believes they are suitable and in the client's best interest, and by disclosing the compensation received. Clients are never required to purchase any insurance or annuity product, and doing so is not a condition of the advisory relationship. Insurance products recommended may also be available from other providers on more favorable terms. B. SEI Revenue Sharing Arrangement As described in Item 5, PHFA charges its standard advisory fee on SEI sub-advised accounts and also receives a revenue- sharing component from the SEI program fee. SEI clients therefore pay two separate fees. This creates a conflict of interest because PHFA has a financial incentive to recommend the SEI program and receives compensation from two sources. PHFA mitigates this conflict by recommending the SEI program only where PHFA believes it is suitable and consistent with the client’s objectives. C. Tax Referral Business — Steven James Financial Steven Smit owns Steven James Financial, a separate business that refers individuals to third-party tax preparation professionals. Steven James Financial does not itself prepare tax returns and is not an accounting firm. Mr. Smit may refer PHFA advisory clients to Steven James Financial and receives referral compensation when a referred client engages a tax professional through that business. This creates a conflict of interest because Mr. Smit has a financial incentive to make the referral. Clients are not required to use Steven James Financial or any tax professional it recommends, and may use any tax preparer they choose. The referral is not a condition of any advisory service. PHFA does not provide tax advice and does not supervise the services of any tax preparer. D. Custodian Economic Benefits PHFA and its principal do receive economic benefits from custodians, including Charles Schwab Institutional, SEI Private Trust Company, Capital Bank & Trust, and Aspire. These benefits may include access to technology platforms, compliance tools, practice management resources, research materials, client reporting systems, and other services that benefit PHFA's business. PHFA does not pay for these benefits in cash. They create a conflict of interest because PHFA has an incentive to recommend these custodians and to maintain client accounts there in order to continue receiving them. Firm Brochure · August 14, 2026 · Page 10 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 PHFA addresses this conflict by selecting custodians based on service quality, execution capability, client benefit, and overall suitability, and by documenting the basis for its selections. E. Howard Capital Management — Two Separate Arrangements PHFA has two distinct arrangements with Howard Capital Management ("HCM"), CRD No. 118070. HCM is a registered investment adviser and is not affiliated with PHFA. Arrangement 1 — PHFA-Managed SDBA Accounts. PHFA manages SDBA accounts at Charles Schwab under its own advisory agreement, exercising discretion and selecting HCM's affiliated mutual funds as investment vehicles. PHFA's portfolio management fee and the portfolio platform fee apply. HCM's funds carry internal management fees of 0.95% to 1.25% annually, which are in addition to PHFA's advisory compensation. See the layered-cost disclosure in Item 5.F. Arrangement 2 — Direct HCM Referrals. PHFA refers certain retirement plan participants directly to HCM as their investment adviser of record, pursuant to a written Investment Advisory Solicitation Agreement executed February 24–25, 2026, under Rule 206(4)-1. HCM manages the assets and is the adviser of record; those assets are not included in PHFA's RAUM. PHFA receives a referral fee of 0.75% annually, paid monthly from HCM's mutual fund management fees as revenue sharing, and does not charge the referred client an additional fee. Because PHFA receives ongoing compensation tied to referred assets, PHFA has a material conflict of interest and a financial incentive to refer participants to HCM rather than to other managers. Applicable to both arrangements. • HCM performance results and track records belong to HCM and are attributed to HCM, not PHFA, in any marketing or client communication. PHFA uses only marketing materials supplied or approved in writing by HCM in connection with its solicitation activities. • At the time of each referral, PHFA provides the participant with a written disclosure describing the referral arrangement, the compensation PHFA receives, and the material conflicts of interest. • PHFA completes its written PTE 2020-02 analysis and client disclosure for each covered recommendation involving retirement assets under either arrangement. • Plan sponsors whose participants may be referred to HCM receive written notice of the arrangement and of PHFA's direct and indirect compensation. ERISA fiduciary obligations apply to retirement account recommendations. F. Aspire Financial Services PHFA uses Aspire Financial Services as a retirement plan recordkeeper for certain retirement plan consulting clients. Aspire provides recordkeeping, plan administration, and participant services. PHFA's engagement of Aspire is based on service quality and suitability for client needs. PHFA does not receive direct compensation from Aspire in connection with plan referrals. Aspire charges its own fees to plans and plan sponsors, as disclosed in the applicable service agreement. Firm Brochure · August 14, 2026 · Page 11 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics PHFA has adopted a Code of Ethics pursuant to Rule 204A-1 under the Advisers Act. The Code establishes standards of conduct expected of all personnel, including the duty to act consistently with PHFA's fiduciary obligations. The Code addresses the duty to put client interests first, personal trading policies and pre-clearance requirements, the prohibition on insider trading and misuse of material nonpublic information, gifts and entertainment, reporting obligations for access persons, and the confidentiality of client information. Clients and prospective clients may obtain a copy upon request by contacting steve@powerhousefa.com. B. Participation or Interest in Client Transactions PHFA and its associated persons do not buy or sell securities for their own accounts in transactions in which PHFA simultaneously buys or sells the same securities for client accounts in a manner that would disadvantage clients. PHFA's Code of Ethics requires that client interests take priority. PHFA may invest its own assets, or the assets of its principal, in the same securities recommended to clients. Such transactions may create conflicts of interest; PHFA's Code of Ethics and personal trading policies are designed to detect and prevent them. C. Personal Trading PHFA's Code of Ethics requires access persons to report personal securities transactions and holdings on at least an annual basis, with quarterly transaction reporting, and to obtain pre-clearance for trades in certain securities. PHFA reviews personal trading records to identify and address conflicts of interest or violations of the Code. Item 12. Brokerage Practices A. Custodian Selection PHFA recommends that clients establish custodial accounts at Charles Schwab Institutional, SEI Private Trust Company (for SEI sub-advised accounts), Capital Bank & Trust (for certain SEI program accounts), or Aspire (for retirement plan accounts). PHFA is not affiliated with any of these custodians. PHFA recommends them based on the quality and breadth of services offered, execution capabilities, technology platforms, client reporting, and overall value to clients. Clients are not required to use a recommended custodian; however, if a client chooses a different custodian, PHFA may not be able to provide all advisory services or implement strategies as efficiently. Conflict relating to Charles Schwab. PHFA charges a 0.25% annual portfolio platform fee on assets custodied at Charles Schwab, which it does not charge on assets held elsewhere. This creates a financial incentive for PHFA to recommend Schwab over another custodian. PHFA also receives economic benefits from Schwab as described in Item 10.D. PHFA addresses these conflicts by evaluating custodians on execution quality, service, technology, and overall client benefit, and by documenting the basis for its recommendations. B. Soft Dollars PHFA does not maintain a soft dollar program and does not direct client brokerage in exchange for research or other products or services. To the extent PHFA were to enter into any such arrangement in the future, it would do so only within the safe harbor of Section 28(e) of the Securities Exchange Act of 1934 and would amend this brochure accordingly. PHFA does receive technology, research tools, and practice management resources from Schwab and other custodians as described in Item 10.D; those benefits are an economic benefit of the custodial relationship rather than a soft dollar arrangement. C. Brokerage for Client Referrals PHFA does not direct client brokerage based on the referral of clients by custodians or other third parties. Firm Brochure · August 14, 2026 · Page 12 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 D. Directed Brokerage PHFA exercises discretion over the selection of brokers and dealers for client transactions in discretionary accounts, subject to the client's best interest. Clients may direct PHFA to use a specific broker or dealer in limited circumstances; directed brokerage may result in less favorable execution prices or increased transaction costs. E. Trade Aggregation PHFA may aggregate or batch trades across multiple client accounts to obtain more efficient execution. When trades are aggregated, execution prices and transaction costs are allocated equitably among participating accounts. Item 13. Review of Accounts PHFA reviews client accounts on an ongoing basis and conducts a formal review of each client account at least annually. Reviews address portfolio performance, asset allocation, changes in client circumstances, and continued suitability of the investment strategy. Steven James Smit, CFP®, CEO and CCO, is responsible for account reviews. Additional reviews may be triggered by significant changes in the client's financial situation, objectives, or risk tolerance; material changes in market conditions; significant deposits or withdrawals; client request; or changes in strategy or applicable regulatory requirements. Clients receive account statements directly from their custodians, typically monthly or quarterly. PHFA may also provide performance reports and portfolio summaries at the client's request. Clients are encouraged to review all account statements carefully and notify PHFA promptly of any discrepancies. Item 14. Client Referrals and Other Compensation A. Compensation Received by PHFA • Howard Capital Management. PHFA receives a referral fee of 0.75% annually pursuant to a written Investment Advisory Solicitation Agreement dated February 24–25, 2026, under Rule 206(4)-1. The fee is paid monthly from HCM's mutual fund management fees as revenue sharing and does not result in an additional charge to referred clients. At the time of each referral, PHFA provides a written solicitor disclosure describing the referral relationship, the compensation received, and the associated conflicts. The client also receives HCM's Form ADV Part 2A, Client Relationship Summary, and privacy notice prior to engagement. • Steven James Financial. Steven Smit receives referral compensation when PHFA clients are referred to tax professionals through Steven James Financial, a business he owns. See Item 10.C. • SEI revenue sharing. PHFA receives a portion of the SEI program fee as described in Items 5 and 10. B. Compensation Paid for Client Referrals to PHFA PHFA does not currently pay cash or non-cash compensation to any person for the referral of clients to PHFA. If PHFA enters into any promoter or endorsement arrangement in the future, it will comply with Rule 206(4)-1, including the requirement for a written agreement, disclosure at the time of the endorsement, and an ineligibility determination. C. Economic Benefits from Custodians As described in Item 10.D, PHFA may receive economic benefits from custodians, including practice management support, technology access, compliance tools, and educational resources. These benefits are not tied to specific client referrals and do not result in direct payments to PHFA. Item 15. Custody Under Rule 206(4)-2 of the Advisers Act, an investment adviser is deemed to have custody of client assets if it holds, directly or indirectly, client funds or securities or has authority to obtain possession of them. PHFA is deemed to have Firm Brochure · August 14, 2026 · Page 13 of 14  Powerhouse Financial Advisors, Inc. · Form ADV Part 2A · CRD No. 338952 limited custody because it has authority to instruct custodians to deduct advisory fees, including the portfolio platform fee, directly from client accounts. PHFA addresses this by: • Maintaining client assets with qualified custodians (Charles Schwab Institutional, SEI Private Trust Company, Capital Bank & Trust). Note: Aspire Financial Services serves as a retirement plan recordkeeper and is not a qualified custodian under Rule 206(4)-2; • Ensuring that custodians send account statements directly to clients at least quarterly, showing all amounts disbursed including both fee components; • Encouraging clients to review all custodial statements and compare them against any report received from PHFA; • Limiting fee deductions to the amounts agreed in the advisory agreement. Clients who do not receive account statements directly from their custodian should contact PHFA or the custodian immediately. PHFA does not maintain physical custody of client assets. Item 16. Investment Discretion PHFA accepts discretionary authority to manage client accounts pursuant to written advisory agreements. With discretionary authority, PHFA is authorized to buy, sell, and manage securities in client accounts without obtaining client approval for individual transactions. That authority is subject to the investment objectives, risk tolerance, and guidelines established with the client; any reasonable written restrictions imposed by the client; and PHFA's fiduciary duty. In the SEI sub-advised program, discretion over day-to-day portfolio management is delegated to SEI, and PHFA retains discretion over strategy selection and overall program suitability. For PHFA-managed SDBA accounts using HCM mutual funds, PHFA retains full investment discretion and selects the fund holdings. For accounts referred directly to HCM, HCM exercises investment discretion as the adviser of record. Item 17. Voting Client Securities PHFA does not vote proxies on behalf of clients. Clients retain the right and responsibility to vote proxies for securities held in their accounts and will receive proxy materials directly from the custodian or issuer. Clients who have questions about a particular proxy may contact PHFA for general guidance; the voting decision rests with the client. PHFA does not take action with respect to class action lawsuits, bankruptcies, or other legal proceedings affecting client securities. Clients should consult their own legal counsel regarding participation in any such proceedings. Item 18. Financial Information PHFA does not require or solicit prepayment of more than $1,200 in fees, six or more months in advance of services rendered. Accordingly, PHFA is not required to include a balance sheet for its most recent fiscal year in this brochure. PHFA does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. PHFA has not been the subject of a bankruptcy petition at any time. Firm Brochure · August 14, 2026 · Page 14 of 14