BURK HOLDINGS LLC ADV 2A BROCHURE

Burk Holdings LLC d/b/a Burkholder Wealth Management, Signal Wealth Advisors, and Revive Wealth Management 5014 E 101st Street, Suite 200 Tulsa, OK 74137 Telephone: 918-727-7100 3103 Bee Caves Rd., Suite 201 Austin, TX 78746 Telephone: 512-285-8990 http://www.burkholderwm.com October 13, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Burk Holdings LLC d/b/a Burkholder Wealth Management. If you have any questions about the contents of this brochure, contact us at 918-727-7100. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Burk Holdings LLC d/b/a Burkholder Wealth Management (CRD # 305300) is available on the SEC's website at www.adviserinfo.sec.gov. Burk Holdings LLC d/b/a/ Burkholder Wealth Management is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 25, 2026, we have the following material changes to report: • • • • Items 4, 5, and 10 were updated to disclose the firm’s activities pertaining to special purpose co-investment vehicles. Item 15 was updated to disclose that our firm has custody of certain client assets as a result of standing letters of authorization for third-party transfers, and that these arrangements meet the applicable SEC staff conditions. Item 12 was updated to describe our practices for aggregating client orders in more detail, including how orders are allocated, how partially filled orders are handled, and how orders are placed across our two custodians. Items 4, 8 and 11 were updated to disclose that we may recommend private placements and special purpose vehicles to eligible clients, the risks of these investments, that our principal has invested and associated persons may invest alongside clients in these investments, and the resulting conflicts of interest and how we address them. Item 3 Table of Contents Item 2 Summary of Material Changes..................................................................................... 2 Item 3 Table of Contents ......................................................................................................... 3 Item 4 Advisory Business ........................................................................................................ 4 Item 5 Fees and Compensation .............................................................................................. 7 Item 6 Performance-Based Fees and Side-By-Side Management ...................................... 10 Item 7 Types of Clients .......................................................................................................... 10 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss.................................. 10 Item 9 Disciplinary Information .............................................................................................. 13 Item 10 Other Financial Industry Activities and Affiliations ................................................... 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................................................................................... 14 Item 12 Brokerage Practices ................................................................................................. 15 Item 13 Review of Accounts .................................................................................................. 17 Item 14 Client Referrals and Other Compensation ............................................................... 18 Item 15 Custody..................................................................................................................... 18 Item 16 Investment Discretion ............................................................................................... 19 Item 17 Voting Client Securities ............................................................................................ 19 Item 18 Financial Information ................................................................................................ 19  Item 4 Advisory Business Description of Firm Burk Holdings LLC d/b/a Burkholder Wealth Management, Signal Wealth Advisors, and Revive Wealth Management, is a registered investment adviser primarily based in Tulsa, Oklahoma. We are organized as a limited liability company ("LLC") under the laws of the State of Oklahoma. We have been providing investment advisory services since October 2019. We are owned by Eric Douglas Burkholder. Advisory services can also be conducted using Burk Holdings LLC's other d/b/a Revive Wealth Management. Currently, we offer the following investment advisory services: • Portfolio Management Services • Financial Planning Services • Retirement Plan Consulting Services The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Burkholder Wealth Management and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you focused investment advice and/or to make investments on your behalf. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. We may offer complimentary financial planning services as part of our portfolio management services. In limited circumstances and in our sole discretion, we may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. In addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions  on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Retirement Plan Consulting Services We offer retirement plan consulting services as a 3(38) discretionary fiduciary as defined by ERISA, to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as: • Diversification; • Asset allocation; • Risk tolerance; and • Time horizon Our educational seminars may include other investment-related topics specific to the particular plan. We may also provide additional types of retirement plan consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Special Purpose Co-Investment Vehicle We previously assisted in the formation of one or more special purpose vehicles, each typically structured as a limited liability company (each, an “SPV”), to facilitate client investments in private placements, and we may do so in the future. Our principal and certain qualified clients have co-  invested in the underlying investments through these SPVs. Because these opportunities are inherently limited and subject to strict regulatory eligibility requirements (e.g., Qualified Purchaser status), they are not offered to all Clients. This creates a conflict of interest as we may offer opportunities to certain clients and not others. We mitigate this conflict by allocating such opportunities based on objective suitability criteria, client investment objectives, and order of inquiry. We do not act as the manager of any SPV, do not exercise discretionary investment authority over any SPV’s ongoing operations, and do not provide continuous or regular supervisory management services to any SPV. Wrap Fee Programs We do not participate in any wrap fee program. Types of Investments We primarily offer advice on mutual funds and exchange traded funds ("ETFs"). Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Private Placements and Special Purpose Vehicles. We may recommend private placements, including unregistered pooled investment vehicles such as private equity funds and special purpose vehicles that we assist in forming, to clients who meet the applicable eligibility requirements (for example, accredited investor or qualified purchaser status) and for whom we believe the investment is suitable. These opportunities are often limited and are not offered to all clients. We do not charge advisory fees or any other fees on assets invested in these investments, and those assets are not included in our assets under management (see Item 5). Private investments involve additional risks, including limited or no liquidity, restrictions on transfer, less transparency and regulatory oversight than registered investments, difficulty in valuation, and concentration in a single investment or sponsor, and you could lose all or part of your investment. Our principal and other persons associated with our firm may invest alongside clients in these investments; see Item 11 for the conflicts of interest this creates and how we address them. Since our investment strategies and advice are based on each client’s specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. We do not engage in the purchase, sale, servicing or management of, advice relative to, or recommendation to purchase, sell, or hold any of the following investment products: 1. Structured financial products including, but not limited to, exchange-traded notes, asset-backed securities, mortgage backed securities, credit default swaps, and collateralized or securitized debt obligations ; 2. Promissory notes, real property, tangible property or tangible personal property; 3. Derivatives including, but not limited to, future contracts, warrants, forward contracts, options (with the exception of covered call strategies), swaps; 4. Cryptocurrency including, but not limited to, Bitcoin, Litecoin, Ethereum, Ripple, Dash, Zcash or Monero. Assets Under Management As of December 31, 2025, we provide continuous management services for approximately $379,869,603 client assets on a discretionary basis and $0 in client assets on a non-discretionary  basis. Item 5 Fees and Compensation Portfolio Management Services Fees Our fee for portfolio management services is based on a percentage of the assets in your account and is set forth in the following annual fee schedule: Annual Fee Schedule Assets Under Management $0 - $1,000,000 $1,000,001 - $3,000,000 $3,000,001 - $5,000,000 $5,000,001 - $10,000,000 $10,000,001 - $20,000,000 Over $20,000,000 Annual Fee* 1.00% 0.90% 0.80% 0.65% 0.50% Fee determined by complexity of planning needs *Existing clients are grandfathered in on their current fee schedule, which can be found in their portfolio management agreement. Our annual portfolio management fee is billed and payable, quarterly in arrears, based on the average daily balance. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Custodian Financial Planning Services Fees We charge an hourly fee of $250 - $500 for financial planning services, which is negotiable depending on the scope and complexity of the plan, your situation, and your financial objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. The fees are due and payable on completion of the contracted services. We also offer advice on single subject financial planning/general consulting services at the same hourly rate. We will not require prepayment of a fee more than six months in advance and in excess of $1,200. You may terminate the financial planning agreement upon written notice to our firm. If you have pre- paid financial planning fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based  on services performed prior to termination of the financial planning agreement. Retirement Plan Consulting Services Fees Our advisory fees for these customized services will be negotiated with the plan sponsor or named fiduciary on a case-by-case basis. Either party to the retirement plan consulting agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The retirement plan consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, refer to the Brokerage Practices section of this brochure. Special Purpose Co-Investment Vehicle Fees and Compensation: Exemption from Management Fees We do not charge, assess, or collect any investment management fees, performance-based fees, carried interest, or administrative fees with respect to any private placement or special purpose vehicle we recommend, including any vehicle we assist in forming, or the underlying investments. Clients invest on a fee-free basis relative to our services. We receive no compensation for assisting in the formation of any such vehicle. Our principal invests on the exact same terms as participating clients. However, a conflict of interest exists as the aggregation of client capital may assist the principal in meeting the underlying investment's minimum capital requirements or securing more favorable terms from the third-party sponsor. We mitigate this conflict by ensuring the principal receives no preferential liquidity, terms, or exit rights relative to participating clients. Assets invested in these investments are not included in our assets under management and are not subject to our advisory fees. Compensation for the Sale of Securities or Other Investment Products Persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged  performance-based fees while at the same time managing accounts that are not charged performance- based fees. Our fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We offer investment advisory services to individuals, high net worth individuals, pension plans, and charitable organizations. Portfolio Management Accounts In general, we require a $500,000 minimum dollar amount to open and maintain an advisory account, unless invested in the Program as described below. However, we may waive this minimum in our discretion. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments.  Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential loses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all. Private Placement Risk: Private placements, including interests in special purpose vehicles, are not registered with the SEC and are generally illiquid and subject to restrictions on transfer. They provide less information and regulatory oversight than registered investments, can be difficult to value, and are often concentrated in a single investment or sponsor. You may be unable to sell your interest for an extended period and could lose all or part of your investment. Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer’s securities held by a client. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client’s future interest payments and principal. Inflation also  generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. Recommendation of Particular Types of Securities We primarily recommend Mutual Funds, and ETFs. However, we may advise on other types of investments as appropriate for you since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than you expected to earn, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tends to be less than long term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a  significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF’s performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Item 9 Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Item 10 Other Financial Industry Activities and Affiliations Licensed Insurance Agent Persons providing investment advice on behalf of our firm are licensed as independent insurance agents and will earn commission-based compensation for selling insurance products to you. Insurance commissions earned by these persons are separate from our advisory fees. See the Fees and  Compensation section in this brochure for more information on the compensation received by insurance agents who are affiliated with our firm. Lawyer or Law Firm Joseph H. Hanson is an Attorney of the Law Office of Joseph Harvey Hanson, PLLC, a law firm. If you require legal services, we may recommend that you use the Law Office of Joseph Harvey Hanson, PLLC. The services provided and compensation received by Mr. Hanson for legal related activities are separate and distinct from any fees paid for advisory services provided by our firm. While we believe that the Law Office of Joseph Harvey Hanson, PLLC’s fees are competitive, such fees may be higher than those charged by other firms providing the same or similar services. You are under no obligation to use the legal services provided by Mr. Hanson. Special Purpose Co-Investment Vehicle As discussed above, we assisted in the formation of one or more SPVs to facilitate client investments in private placements. Our principal and certain qualified clients have co-invested in the underlying investments through these SPVs. To mitigate structural conflicts of interest and ensure a strict separation of operational controls, each SPV is managed exclusively by a third party that is unrelated to our firm and acts as the designated manager. The manager maintains sole operational control over the SPV, including its banking and capital accounts. Operational tax administrative duties, including the preparation and filing of each SPV’s tax returns and Schedule K-1s, are executed by an independent, third-party Certified Public Accountant (CPA). The Advisor maintains no access to, nor control over, any SPV’s financial accounts or custody of assets. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Our principal has invested, and our principal and other persons associated with our firm may in the future invest, alongside clients in private placements and special purpose vehicles that we recommend to those clients, including vehicles we assist in forming. When this occurs, the associated person has a financial interest in an investment we recommended, and client participation may help the vehicle meet the investment’s minimum capital requirements or obtain more favorable terms from the sponsor. This creates a conflict of interest. We address this conflict by (1) requiring associated persons to invest on the same terms as participating clients, with no preferential liquidity, terms, or exit rights; (2) recommending these investments only to clients for whom we believe they are suitable and who meet the applicable eligibility requirements; and (3) allocating limited opportunities among eligible clients based on objective suitability criteria, client investment objectives, and order of inquiry. Other than as described in this brochure, neither our firm nor any persons associated with our firm has any material  financial interest in client transactions. Any assets invested in private placements would not be included in our assets under management and will not be subject to any other services or fees described herein. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We recommend the brokerage and custodial services of either Fidelity Brokerage Services LLC, or Charles Schwab & CO., Inc., each of which are FINRA registered broker-dealers, members SIPC, as the qualified custodian to maintain custody of clients' assets (“Custodian”). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider various factors, including: • Capability to buy and sell securities for your account itself or to facilitate such services. • The likelihood that your trades will be executed. • Availability of investment research and tools. • Overall quality of services. • Competitiveness of price. • Reputation, financial strength, and stability. • Existing relationship with our firm and our other clients. Economic Benefits, Research and Other Soft Dollar Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision- making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Your Custody and Brokerage Costs For our clients’ accounts it maintains, the Custodian generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Custodian account. The Custodian’s commission rates and/or asset- based fees applicable to our client accounts were negotiated based on our commitment to maintain $100 million of our clients’ assets statement equity in accounts at the Custodian. This  commitment benefits you because the overall commission rates and/or asset-based fees you pay are lower than they would be if we had not made the commitment. In addition to commission rates and/or asset-based fees the Custodian charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Custodian account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have the Custodian execute most trades for your account. Schwab Adviser Services Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage trading, custody, reporting and related services, many of which are not typically available to the Custodian retail customers. The Custodian also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. The Custodian’s support services are generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us. Services that Benefit You The Custodian’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through the Custodian. include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The Custodian’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You The Custodian also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both the Custodian’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at the Custodian. In addition to investment research, the Custodian also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • • provide pricing and other market data; o facilitate payment of our fees from our clients’ accounts; and • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us The Custodian also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events; • • publications and conferences on practice management and business succession; • access to employee benefits providers, human capital consultants and insurance providers; and The Custodian may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Custodian. may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Custodian. may also provide us with other benefits  such as occasional business entertainment of our personnel. Our Interest in Custodian’s Services The availability of these services from the Custodian. benefits us because we do not have to produce or purchase them. These services may give us an incentive to recommend that you maintain your account with the Custodian based on our interest in receiving the Custodian’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of the Custodian as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of the Custodian’s services (based on the factors discussed above – see “The Custodian and Broker We Use”) and not the Custodian’s services that benefit only us. We do not believe that maintaining our client's assets at the Custodian for services presents a material conflict of interest. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage We routinely require that you direct our firm to execute transactions through the Custodian. As such, we may be unable to achieve the most favorable execution of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. Aggregated Trades We may, at times, aggregate (“block”) purchase or sale orders for the same security across multiple client accounts when we believe doing so is consistent with our duty to seek best execution. We are not required to aggregate orders. When we aggregate orders: • Before entering the order, we record which accounts are participating and the quantity each account will receive. • • Each participating account receives the average price for that block on that day and pays its proportional share of transaction costs, subject to any per-account charges imposed by your custodian. If an order is only partially filled, the shares are allocated pro rata based on the original allocation. • Accounts of our firm and its personnel may participate in a block only on the same terms as client accounts. If such an order is only partially filled, client accounts are filled first. • Because client accounts are held at both Schwab and Fidelity, we enter a separate block order at each custodian and rotate the order in which they are entered so that clients at neither custodian are consistently favored. As a result, clients at different custodians may receive different prices for the same security on the same day. Accounts that are traded individually, for example because of client instructions, account restrictions, cash flows, or tax considerations, may receive prices that differ from those of a contemporaneous block order. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When we purchase, or recommend the purchase of, mutual funds for a client, we select the share class that is deemed to be in the client’s best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, we will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual funds held in accounts that come under our management  to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. Item 13 Review of Accounts Eric D. Burkholder, Member and Chief Compliance Officer will monitor your accounts on an ongoing basis and will conduct account reviews at least annually, to ensure the advisory services provided to you are consistent with your investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals; • year-end tax planning; • market moving events; • security specific events; and/or • changes in your risk/return objectives. We will not provide you with regular written reports. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Financial Planning Reviews While reviews and updates to the financial plan are not part of the contracted services, at your request we will review your financial plan to determine if the investment advice provided is consistent with your investment needs and objectives. We will also update the financial plan at your request. At our sole discretion, reviews and updates may be subject to our then current hourly rate. If you implement the financial planning advice provided by our firm, you will receive trade confirmations and monthly or quarterly statements from relevant custodians. Item 14 Client Referrals and Other Compensation Charles Schwab & Co., Inc. - Institutional In addition, we receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 - Brokerage Practices). The availability to us of Schwab's products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. As disclosed under the Fees and Compensation section in this brochure, persons providing investment advice on behalf of our firm are licensed insurance agents. For information on the conflicts of interest this presents, and how we address these conflicts, refer to the Fees and Compensation section. We do not receive any compensation from any third party in connection with providing investment advice to you. We compensate employees for referrals as a percentage of first year’s revenue, which will not result in increased fees to clients. We maintain policies and procedures to ensure that individuals compensated for referrals remain compliant with our policies, procedures, and industry rules and regulations. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian.  Item 15 Custody As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We will also provide invoices to you reflecting the amount of the advisory fee deducted from your account. You should compare our invoice with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, contact us immediately at the telephone number on the cover page of this brochure. Standing Letters of Authorization. Some clients have authorized our firm, through a standing letter of authorization (“SLOA”) on file with their custodian, to direct transfers of funds from their accounts to third parties the client has designated. Under SEC rules, this authority gives our firm custody of those clients’ assets, and we report those assets as subject to our custody in our Form ADV. Each of these arrangements meets the conditions described below, which the SEC staff has stated allow an adviser with this authority not to obtain an annual surprise examination. Authority to transfer funds only between your own accounts (a “first-party” transfer) does not give our firm custody. You may also establish your own standing instructions with your custodian to send funds to a third party; our firm has no authority or discretion over transfers under those instructions. Custody – SLOAs On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction.  Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement and the appropriate trading authorization forms. You may grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory Business section in this brochure for more information on our discretionary management services. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities We do not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, our representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Item 18 Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. We have not filed a bankruptcy petition at any time in the past ten years.