ADV PART 2A OTHER THAN ANNUAL AMENDMENT OCTOBER 22, 2026

COVER PAGE FIRM BROCHURE ADV PART 2A OTHER THAN ANNUAL AMENDMENT OCTOBER 22, 2026 BLUM FINANCIAL L.P. d/b/a STRATEGIC WEALTH PLANNING 2929 NORTH CENTRAL EXPRESSWAY | SUITE 200 RICHARDSON, TX 75080 FIRM CONTACT: STEPHEN J. BLUM, PRESIDENT FIRM WEBSITE: WWW.AWEALTHPLAN.COM ITEM 1 This brochure (Brochure) provides information about the qualifications and business practices of Blum Financial L.P. d/b/a Strategic Wealth Planning. If you have any questions about the contents of this brochure, please contact us by telephone at (214) 727-6000 or email at sjblum@awealthplan.com. 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 Strategic Wealth Planning also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as an IARD/CRD number. The IARD/CRD number for Strategic Wealth Planning is 149134. Please note that the use of the term “registered investment adviser” and description of Blum Financial L.P. d/b/a Strategic Wealth Planning and/or our associates as “registered” do not imply a certain level of skill or training. You are encouraged to review this Brochure and the Brochure Supplement (ADV Part 2B) for the firm’s associate who advises you for more information on the qualifications of our firm and our associates. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 1  ITEM 2 – MATERIAL CHANGES Strategic Wealth Planning is required to advise you of any material changes to our Firm Brochure from our last annual update, identify those changes on the cover page of our Firm Brochure or on the page immediately following the cover page, or in a separate communication accompanying our Brochure. We must state clearly that we are discussing only material changes since the last annual update of our Firm Brochure. We will deliver an updated Firm Brochure annually to our advisory clients, together with a summary of material changes, within 120 days from the close of our fiscal year. The date of our last annual Firm Brochure was March 6, 2026. Material changes: This summary discusses only material changes since our last annual update. • Alternative investments. We describe how we value alternative investments for fee purposes. Because our fee is based on the value we use, we have an incentive to select a higher value. Because an illiquid investment generally cannot be sold, you may continue to pay our fee on it for as long as you hold it. We also describe how we address these conflicts (Item 5.A(v)). We describe which clients we recommend private investments to, our concentration guidelines, the disclosures each client signs and we expanded our description of the risks of these investments (Item 8). • Futures accounts. We describe our fee on futures accounts, which is charged on the Nominal Account Size (your cash and securities plus a notional funding amount) rather than the money deposited, the conflicts this creates, and how we address them (Items 5.A(v) and 8). • Third-party money managers. We no longer refer clients to third-party money managers, and we have removed this service from Items 4, 5, 10, 13 and 14. • Fees. We describe our two MAP fee schedules, that your advisory agreement states which schedule applies to you, and that clients with the same portfolio size may pay different fees (Item 5.A(ii)). • Conflicts of interest. We expanded the description of our conflicts of interest and how we address them, including: recommendations to sell or surrender investments and invest the proceeds with us or buy insurance through SWP (Item 5.C); insurance commissions and how our adviser is paid (Item 10.C); our affiliated bookkeeping and tax preparation businesses (Item 10.C); due diligence fees paid by sponsors of alternative investments (Items 11 and 12); and benefits we receive from our custodians (Item 12.A). • Mutual fund share classes. We describe how we select share classes and the related conflict in MAP accounts (Item 8). • Code of Ethics and personal trading. We describe our Code of Ethics, adopted effective October 1, 2026, and our personal trading restrictions. These include advance approval when access persons invest in alternative investments that clients own or trade futures of the types we trade for clients (Item 11). • Aggregation. We describe when we aggregate client orders, how aggregated orders are priced and allocated, and when we do not aggregate (Item 12.B). ITEM 3 – TABLE OF CONTENTS Item Page SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 2  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 9 Item 7 – Types of Clients and Account Requirements 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 9 Item 9 – Disciplinary Information 11 Item 10 – Other Financial Industry Activities and Affiliations 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 12 Item 12 – Brokerage Practices 14 Item 13 – Review of Accounts and Financial Plans 17 Item 14 – Client Referrals and Other Compensation 17 Item 15 – Custody 17 Item 16 – Investment Discretion 18 Item 17 – Voting Client Securities 18 Item 18 – Financial Information 18 SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 3  Item 4. Advisory Business A. Description of our advisory firm, including how long we have been in business and our principal owners. Blum Financial L.P. d/b/a Strategic Wealth Planning is dedicated to providing individuals, families, businesses and other types of clients with a wide array of investment advisory services. Our firm is a Texas Limited Partnership and has been in business as an investment adviser since 2009. The firm's General Partner is Blum Management Group, Inc. and our principal owner is Stephen J. Blum who holds the professional designations of CFP®, ChFC, CLU and AEP. B. Description of the types of advisory services we offer. (i) Non-Discretionary Asset Management: We offer continuous supervision for those clients who choose to open non-discretionary advisory accounts with our firm. We communicate with these clients on an as-needed basis and suggest an investment strategy and individual investments that will meet their goals and objectives. The final investment decision is made by the client. We review non-discretionary portfolios at least quarterly. We may recommend that you sell investments held in your non-discretionary account, or other assets that we do not manage. Item 5.C describes the conflicts of interest these recommendations create and how we address them. (ii) Strategic Wealth Planning Discretionary Managed Account Program: Our firm offers a discretionary Managed Account Program ("MAP") whereby we manage client accounts for a single fee that includes both management services and the transaction costs. The MAP is designed to assist our clients meet their stated investment goals and to obtain professional asset management for a convenient single "wrap" fee. We construct an individualized portfolio based on the initial and ongoing information our clients provide to us. Once we establish the initial portfolio, we review the discretionary portfolio at least monthly and rebalance the portfolio based upon a client's individual needs, stated goals and objectives and any changes in circumstances that are provided to us. We do not allow MAP clients to place restrictions on the types of investments to be held in the portfolio unless the client has an employment-related restriction. Additionally, we may make individual investment recommendations to our discretionary MAP clients for their consideration and approval. (iii) Pension Consulting: We provide pension consulting services to employer plan sponsors. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment options, plan structure and participant education. All pension consulting services are in compliance with the applicable state laws regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans ("Plan") governed by the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA, but only with respect to the provision of services described in our Advisory Agreement. (iv) Financial Planning and Consulting: Strategic Wealth Planning provides a variety of financial planning, consulting and management services to individuals, families, businesses and other clients regarding the management of their financial resources based upon an analysis of client's current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan, providing a financial consultation for clients based on the client's financial goals and objectives and/or supervision and/or management of non-publicly traded securities and other investments. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations provided to our clients may include general recommendations for a course of activity or specific actions to be taken by the clients, some of which will be effected by SWP. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, establish education or charitable giving programs and/or buy or sell non-publicly traded securities or other investments. It should also be noted that we refer clients to an accountant, attorney or other specialist, as necessary, for non-advisory related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 4  recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the client's discretion. When we recommend that you sell an investment and invest the proceeds with us or buy insurance through SWP, we have conflicts of interest, which are described in Items 5.C and 10.C. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients and whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing our firm's Managed Account Program and to those clients who choose non-discretionary investment services. Additionally, we offer general investment advice to clients utilizing the following services offered by our firm: Financial Planning and Consulting and Pension Consulting. More details about how we individualize our investment services for each client are found in Item 4B above. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: We do not allow MAP clients to impose restrictions on investing in certain securities or types of securities, due to the difficulty this would entail in managing their accounts, unless the client has an employment-related restriction. Non- discretionary clients make the final decision on each investment in their accounts. D. Participation in wrap fee programs. SWP offers a wrap fee program as described in Part 2A, Appendix 1 (the "Wrap Fee Program Brochure") to our Firm Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client's investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee accounts differently than other accounts. As further described in our Wrap Fee Program Brochure, our firm receives the wrap fee for its services. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis. As of December 31, 2025, SWP manages $208,600,000 in client assets. We manage $182,900,000 on a discretionary basis and $25,700,000 on a non-discretionary basis. Item 5. Fees and Compensation We are required to describe our brokerage, custody, fees and fund expenses so you will know how much you are charged and by whom for our advisory services. Except as described below, our fees are generally not negotiable. A. Description of how we are compensated for advisory services. (i) Non-Discretionary Asset Management: As of the date of this Brochure, our fees for Non-Discretionary Asset Management are as follows. Portfolio Size $0 - $50,000 $50,001 - $100,000 $100,001 - $250,000 $250,001 - $500,000 $500,001 - $750,000 $750,001 - $1,000,000 $1,000,001 - $2,000,000 $2,000,001 - $3,500,000 $3,500,001 - $5,000,000 $5,000,001 and up Annualized Fee 2.00% 1.85% 1.70% 1.60% 1.50% 1.35% 1.20% 1.10% 1.05% 1.00% (ii) Discretionary Managed Account Program Our firm's discretionary Managed Account Program (MAP) is detailed in Item 4 of Appendix 1 to our Firm Brochure. The following are the fees we charge for this program: SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 5  The Firm has two MAP fee schedules. Your advisory agreement states which schedule applies to you. Since 2016, most new clients have been billed under the Tiered Schedule. Our adviser may agree to the Original Schedule or a different fee for a particular client, so clients with the same portfolio size may pay different fees. Original Fee Schedule. Clients who entered the MAP before 2016 remain on the Original Schedule unless they sign a new advisory agreement, as do some later clients for whom our adviser has made an exception. Under this schedule, one annual rate, based on your total portfolio value, applies to your entire portfolio. Original Schedule Portfolio Size $0 - $50,000 $50,001 - $100,000 $100,001 - $250,000 $250,001 - $500,000 $500,001 - $750,000 $750,001 - $1,000,000 $1,000,001 - $2,000,000 $2,000,001 - $3,500,000 $3,500,001 - $5,000,000 $5,000,001 and up Annualized Fee 2.00% 1.85% 1.70% 1.60% 1.50% 1.35% 1.20% 1.10% 1.05% 1.00% Tiered Schedule (adopted 2016). Managed Account Program Tiered Fee1 Schedule implemented in 2016 for some clients: Annualized Fee Portfolio Size 1.50% First $750,000 ($0-$750,000) Next $1,250,000 ($750,000-$2,000,000) 1.00% Next $ 1,500,000 ($2,000,000 - $3,500,000) 0.98% 0.95% $3,500,000 and up (iii) Pension Consulting: We charge an annual flat fee for pension consulting services. The initial yearly fee is established at the beginning of our client relationship. The total estimated yearly fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our yearly fees range from $750.00 to $10,000.00. Planning fees may be negotiable based upon the specific services requested, including the complexity and scope of the consultation. Where the scope or complexity of services varies from the initial agreed upon services and fees, we will consult with a client before charging additional fees. (iv) Financial Planning and Consulting: We charge an annual flat fee for financial planning and consulting services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of your engagement. Our annual planning fees range from $1,500 to as high as $150,000. Planning fees may be negotiable based upon the specific services requested, including the complexity and scope of the plan, as well as your financial situation and objectives. Planning fees are usually payable in advance unless the planning engagement is complex. We establish the agreed upon fee at the beginning of our planning and consulting services. Applicable fees, fee payment arrangements, and the terms of the engagement will be clearly set forth in the client agreement executed between our firm and each client prior to providing financial services. The retainer fee will be fixed for a 12-month period; thereafter, the retainer fee may be adjusted based on the scope and complexity of the engagement. However, if additional services are required that will exceed the estimated fee, we notify the client as soon as possible to discuss additional fees associated with our services. Either party may terminate the Financial Planning Services agreement with 30-days prior written notice to the other. SWP will return unearned fees to the client. (v) Fees on Alternative Investments and Futures Accounts 1 Tiered fees are fees which 1) decline incrementally as assets increase above pre-determined breakpoints and 2) are applied on a marginal basis to assets within those tiers. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 6  Alternative Investments. An alternative investment is valued at the initial investment until the sponsor reports a value, and after that at the sponsor’s value as of the last day of the prior quarter. Where the sponsor has not updated its value, or a third party values the asset, SWP uses best efforts at least annually to confirm or update the value and may rely on secondary-market prices, tender offers or third-party research valuations. For each review SWP considers reliable sources, documents the reason for the value selected and applies the same method whether the value rises or falls. A new value applies beginning with the next billing period. Because our fee is based on the value we use, we have an incentive to select a higher value. We address this conflict through the valuation method described above. Because an illiquid investment generally cannot be sold, you may continue to pay our fee on it for as long as you hold it, even if you would prefer to sell. Fees on illiquid alternative investments are deducted from another of the client’s non-qualified accounts or paid by check within ten days of invoice. Futures Accounts. We do not market this strategy and offer it only when a client requests it. In a futures account, under an addendum to our Discretionary Investment Advisory Agreement, we manage a portfolio of futures positions sized as though the account held more than the cash and securities you deposit. Your agreement states that larger amount, the Nominal Account Size, which equals your cash and securities plus a notional funding amount, and the fee rate. Our fee is 1.00% per year of the Nominal Account Size, billed quarterly in advance. We size the futures position to the Nominal Account Size and calculate our fee on it, not on the funds you deposited. The Nominal Account Size increases or decreases with your deposits and withdrawals and with net trading gains and losses. Because our fee is charged on the Nominal Account Size, you pay a fee on an amount larger than your deposit, and the fee is a higher percentage of your deposit than the stated rate. Conflicts of interest. We charge our fee on the Nominal Account Size, not just the money you deposit, so the fee is higher than it would be on your deposit alone. We decide how many futures contracts to hold, and because net trading gains increase the Nominal Account Size, our fee also grows when we reinvest gains and when the account does well. We are paid whether the account gains or loses money, so you bear the full risk of leveraged losses while our fee rises with the size of the position. This gives us an incentive to accept clients for this strategy, to set a higher notional funding amount, to reinvest gains rather than reduce exposure and to take more risk. We address these conflicts by offering this strategy only at a client’s request under a signed agreement; by requiring the client’s written authorization and our Chief Compliance Officer’s approval before any increase in the notional funding amount other than from net trading gains; by having the Chief Compliance Officer review each fee before billing; and by reviewing the account with the client at least annually. B. Description of whether we deduct fees from clients' assets or bill clients for fees incurred. (i) Asset Management – Discretionary MAP and non-Discretionary: Fees are automatically deducted from both discretionary MAP and non-discretionary client accounts on a quarterly basis. (ii) Pension Consulting: For pension consulting, fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed Pension Consulting Agreement. The client will be invoiced directly for the fees. (iii) Financial Planning and Consulting: We generally require a retainer of fifty-percent (50%) of the financial planning or consulting fee with the remainder due upon completion of the initial services or six (6) months after the start of the planning agreement, whichever is earlier. In all cases, we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months. C. Description of any other types of fees or expenses clients may pay in connection with our advisory services, such as custodian fees or mutual fund expenses. Wrap Fee Clients. Most SWP clients participate in our wrap fee program (Managed Account Program "MAP"). Wrap fee clients will not incur transaction costs for trades. We disclose more information about this matter in our separate wrap fee program brochure. Non-Wrap Fee Clients. Non-wrap fee clients may pay transaction charges imposed by their custodian on some trades (for example, certain mutual fund purchases and individual stock and bond trades), as described in Item 12. These charges are separate from and in addition to our advisory fees, are disclosed by the custodian, and we do not receive any part of them. All Clients. All firm clients are responsible for and will pay all separately incurred expenses, which we do not receive any part of. The following list is an example of such additional charges: charges imposed directly by a mutual fund, index fund, exchange traded fund or private investment, which charges shall be disclosed in the fund's or investment's prospectus (i.e. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 7  management fees and other expenses); custodian and other fees charged by institutions to hold and/or administer accounts; custodian transfer fees (fees charged by a custodian when an investment moves from one custodian to a new custodian); bank charges for accounts with check writing privileges; wire transfer fees. Recommendations to Sell or Surrender Assets. We may recommend that you sell or surrender investments held in your non-discretionary account or investments we do not manage or do not charge a fee on, such as accounts held at other firms, employer retirement plan assets, annuities, insurance policies, private investments or securities you hold outside our model portfolios. These recommendations create conflicts of interest: • Advisory fees. If you invest the proceeds in the MAP or another account we manage, we charge our advisory fee on them, including on assets that were not previously subject to our fee. As an owner of SWP, Stephen J. Blum shares in SWP's profits, including these fees. If you move assets from a non-discretionary account into the MAP, SWP pays the trade execution costs for your account out of the MAP fee, as described in our Wrap Fee Program Brochure. • Insurance commissions. If you use the proceeds to buy insurance through Mr. Blum, SWP receives a commission, as described in Item 10.C. • Costs you bear. Selling or surrendering an investment may result in capital gains taxes, surrender charges, early withdrawal penalties, sales charges, redemption fees or transaction costs, and you may lose guaranteed benefits, riders, death benefits or lower-cost investment options. SWP does not pay these costs or reimburse you for them, and we do not receive any part of them. These conflicts give us an incentive to recommend that you sell an investment based on what we earn rather than on your needs. Before we recommend that you sell or surrender an investment, we compare the costs, tax effects and benefits you would give up with the expected benefits of the change, and we document why we believe the recommendation is in your best interest. Our Chief Compliance Officer reviews a sample of these recommendations each year. You are not required to sell any investment, to invest the proceeds with us or to buy insurance through SWP. D. Fees paid in advance and how a client may receive a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period and how the amount of the refund is determined. Advisory Fees are billed quarterly in advance, based on the total value of the Assets at the end of the previous quarter or at the time of receipt of Assets by SWP. Advisory Fees will be assessed pro rata in the event an advisory agreement is executed at any time other than the first day of a calendar quarter. We do not adjust fees for deposits or withdrawals during a quarter. Our firm requires written notification in the event a client decides to terminate our advisory services. Email notices will NOT suffice. When we receive a written notice of termination, we will stop managing your account, work with you to liquidate or transfer the assets and will process a pro-rata refund of unearned advisory fees. All advisory fees shall be prorated up to and including the date of termination which shall be the later of (i) thirty days from the date we receive a termination notice or (ii) the date all assets we manage are transferred to another adviser or custodian. E. Commissionable securities sales. In order to sell securities for a commission, our advisors must be registered with a broker-dealer. No advisor is registered with a broker-dealer. Item 6. Performance-Based Fees and Side-By-Side Management We do not charge performance fees to our clients. We make investment decisions for our clients based on their respective investment objectives, restrictions, risk profiles, tax status and other relevant considerations. As a result of client differences, we may purchase or sell securities and/or investments at the same or at different times for some clients but not for others. Item 7. Types of Clients and Account Requirements We have the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, Limited Liability Companies and other types of enterprises Our requirements for opening and maintaining accounts or otherwise engaging us: SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 8  We require a minimum initial investment of $100,000.00. However, our firm may allow accounts of members of the same household to be aggregated for purposes of determining the advisory fee and/or for meeting the minimum investment. Generally, this minimum account balance requirement is not negotiable and would be required throughout the course of the client's relationship with our firm. We may open accounts for less than the minimum investment under particular circumstances (for example, setting up a new 401k or new Simple plan). Our firm's minimum fee for written financial plans is $1500.00, which minimum may be waived in certain circumstances. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss A. Description of the methods of analysis and investment strategies we use in formulating investment advice or managing assets. Our firm uses a variety of methods of analysis and investment strategies. Our analysis may include but is not limited to, fundamental analysis of a company's financials, charting and technical analysis of market activity. Within each method of analysis, our advisers may employ a variety of timing outlooks, including long-term strategic, intermediate cyclical or short-term tactical. RISK OF LOSS: Regardless of the method of analysis and investment strategy, investing in securities and private investments involves a risk of loss that clients should be prepared to bear. All securities are subject to risk of loss, and there is no assurance that any investment program or strategy will be successful. While the stock market could increase and your private investments may enjoy a gain, it is also possible that the stock market will decrease and that private investments may not meet their expected performance, resulting in a loss to your investment account(s). It is important that you understand the risks associated with investing in the stock market and in private non-traded investments and that your investments are sufficiently diversified. We request that clients ask us any questions they may have regarding the following investment strategies. B. For each significant investment strategy or method of analysis, we must explain the material risks involved. • Equities. Equity strategies (including investing in individual companies, equity mutual funds or ETFs) involve investments in common stocks and are subject to the volatility and individual risks associated with those stocks. • Small-cap stocks. Small-cap stocks tend to be more volatile relative to the overall market. • Bonds. Bonds may guarantee return of principal if they are held to maturity but any guarantee remains subject to the credit worthiness of the guarantor and, prior to maturity, the bond remains subject to interest rate, inflation and credit risks. • Bond Funds. Bond funds of all types are subject to the various risks of the underlying fixed income instruments in the fund, and there is no fixed maturity date. • High Yield bonds expose the investor to investments in lower credit quality securities, and hence, risk of higher volatility. • Tax-Exempt bonds may or may not provide returns higher than the after-tax returns of taxable bonds, so investors should consider their tax bracket and state of residence. • Emerging Markets and International/Global/Foreign Investments. These types of securities expose the investor to currency risk and political, social and economic risks of the countries in which the securities are domiciled, in addition to the equity or debt nature of the securities involved. • Real Estate Investment Trusts. REITs are subject to risks of the specific commercial or housing market in which the assets are invested, as well as interest rate risks. REITs may be publicly traded or non-traded. Non-traded REITs are alternative investments, described below. • Private and Alternative Investments. Alternative investments are investments other than publicly traded stocks, bonds, mutual funds and ETFs. Those we recommend are generally private investments, such as non-traded REITs, limited liability companies and limited partnerships. Private investments are non-traded and illiquid (meaning there is no market where the investment can be sold). Some have a “redemption program” which may provide limited liquidity, but the sponsor may limit, suspend or end redemptions at any time. Values are generally reported by the sponsor, may be estimates, and may not reflect what you would receive in a sale. Alternative investments may pay their sponsor management or other fees from the investment’s assets, which reduce returns and are in addition to SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 9  our advisory fee. These fees are described in each offering’s documents. Many alternative investments use borrowed money. Distributions are not guaranteed and may be a return of your own capital. There is no guarantee of income or return of principal, and you could lose your entire investment. Private investments are long-term investments suitable to only a small percentage of accredited investors. We recommend private investments only to clients who meet the offering’s investor qualifications, such as accredited investor status, and for whom we determine the investment is in their best interest, considering their liquidity needs. Our guidelines are that any single illiquid investment generally should not exceed 20% of a client's investable assets and all illiquid investments generally should not exceed 30%. Before recommending a new alternative investment, we review the client's holdings against these guidelines. Each client who invests in alternative investments signs our Alternative Investment Suitability and Fee Calculation Disclosures. We have conflicts of interest when we recommend alternative investments: we charge our fee on values we select, you may pay our fee for as long as you hold an illiquid investment, some sponsors pay us due diligence fees, and our principal has invested in some of the same investments. These conflicts, and how we address them, are described in Items 5.A(v), 11.C and 12.A. • Interval Funds. The ability to invest in alternate types of assets and the ability to limit investor withdrawals allows Interval Funds to potentially pay out a higher distribution and/or earn a higher total return over time. Interval Funds may be more stable in down markets since their shares cannot be liquidated immediately. However, Interval Fund fees may be more expensive compared to traditional mutual funds and ETFs. • Options. Options are contracts (often called "Option Contracts") that give the purchaser the right, but not the obligation, to buy or sell a security, such as a stock or exchange-traded fund, at a fixed price within a specific period of time. Option contracts can help investors manage risk and are used to leverage additional exposure to equity instruments for a smaller amount of cash consideration. However, like any other securities, investing in Options involves risk of loss that clients should be prepared to bear. • Futures. Futures are derivative financial contracts that obligate parties to buy or sell an asset at a predetermined future date and price. The buyer must purchase or the seller must sell the underlying asset at the set price, regardless of the current market price at the expiration date. Underlying assets include physical commodities and financial instruments. Futures contracts detail the quantity of the underlying asset and are standardized to facilitate trading on a futures exchange. Futures can be used for hedging or trade speculation. Futures contracts were created to reduce risk for producers, consumers, and investors. However, because of the leverage used in futures trading, it is possible to sustain losses greater than one's original investment. In a futures account (Item 5.A(v)), positions are sized to a Nominal Account Size larger than the funds you have deposited, which magnifies gains and losses relative to your deposit, and losses can exceed the funds deposited. You may be required to deposit additional funds on short notice to meet margin calls. It is not possible to enumerate all risks associated with each of the asset classes listed above. Clients should discuss any concerns with their adviser. Additionally, some financial instruments are sold by prospectus such as mutual funds, REITs and/or Exchange Traded Funds (ETFs). While particular funds or investments may be selected by an adviser, it is the client's responsibility to read the prospectus carefully to fully understand the various risks, investment objectives, charges/expenses and other information about the fund or company associated with the investment. Participants in SWP's MAP do not pay additional charges based on the frequency of trading in their account. However, the client should understand that higher-frequency trading strategies may increase the likelihood that tax consequences may be short-term in nature and result in a higher tax cost and hence, lower net performance. Cash balances. We generally invest cash balances in money market funds, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client's cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees related to our asset management services, as applicable to each client. Mutual Fund Share Class Fees. Mutual fund share class fees are the different ways a fund charges you for sales commissions and ongoing expenses depending on which "letter" share class (A, B, C, R, etc.) you buy. Many mutual funds offer more than one share class. Share classes of the same fund hold the same investments but charge different fees and expenses, so a lower-cost class gives you a better return over time. When a fund offers more than one share class, we recommend the lowest-cost class available to you unless we document a reason that another class is in your best interest. In MAP accounts, SWP pays transaction charges, so we have an incentive to choose a share class that has no transaction charge even if it has higher ongoing expenses, which you bear. We address this conflict through the share class standard described above and our annual best execution review (Item 12). SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 10  Item 9. Disciplinary Information We are required to disclose whether there are legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. There are a number of specific legal and disciplinary events that we must presume are material for this Item. If our advisory firm or a management person has been involved in one of these events, we must disclose it under this Item for ten years following the date of the event, unless (1) the event was resolved in our or the management person's favor, or was reversed, suspended or vacated, or (2) the event is not material. For purposes of calculating this ten-year period, the "date" of an event is the date that the final order, judgment, or decree was entered, or the date that any rights of appeal from preliminary orders, judgments or decrees lapsed. The SEC and/or State Regulators have not provided us with an exclusive list of material disciplinary events, which need to be disclosed. If our advisory firm or a management person has been involved in a legal or disciplinary event that is not specifically required to be disclosed, but nonetheless is material to a client's or prospective client's evaluation of our advisory business or the integrity of our management, we must disclose the event. Similarly, even if more than ten years has passed since the date of the event, we must disclose the event if it is so serious that it remains currently material to a client's or prospective client's evaluation of our firm or management. Our firm and management have nothing to disclose under this item. Item 10. Other Financial Industry Activities and Affiliations A. Broker-Dealer Affiliation. Neither our firm nor our management persons are registered with a broker-dealer nor as a registered representative of a broker-dealer. B. Futures and commodity registrations. If our firm or any of our management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of the foregoing entities, disclose that fact. We have nothing to disclose under this paragraph. C. Material relationships with related persons. Description of any relationship or arrangement that is material to our advisory business or to our clients that we or any of our management persons have with any related person is listed below. We are required to identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. Our firm and/or our management persons have a material relationship with the following related persons and entities as follows: Insurance Agency. SWP is a licensed insurance agency. Our investment adviser representative, Stephen J. Blum, is a licensed insurance agent. SWP pays Mr. Blum a salary. No one at SWP is paid a percentage of the advisory fees clients pay, and his salary is not based on the fees you pay, the size of your account, whether you participate in the MAP, or the insurance you buy. When clients buy life, health, disability or long-term care insurance through him, the insurance company pays SWP a commission, in addition to the advisory fees clients pay us. As an owner of SWP, Mr. Blum shares in SWP's profits, including these commissions. This gives us an incentive to recommend insurance based on the commissions we receive rather than on your needs, including when we recommend that you sell or surrender an investment and use the proceeds to buy insurance (see Item 5.C). You are never required to buy insurance through us, and you may use any insurance agent you choose. SWP does not sell annuities. When Mr. Blum recommends insurance to an advisory client, he documents why it is in the client's best interest, and our Chief Compliance Officer reviews a sample of these recommendations at least annually. Insurance commissions are a small part of SWP's revenue. Bookkeeping Services. Blum Management Group, Inc., through its subsidiary, Strategic Bookkeeper, LLC, offers bookkeeping services to the public and to SWP advisory clients. We occasionally refer clients to Strategic Bookkeeper, LLC, and the clients we refer are informed that they are under no obligation to use its services and may use any other company offering similar services. The bookkeeping fees paid to Strategic Bookkeeper, LLC are separate and distinct from all fees paid to our firm. Because Strategic Bookkeeper, LLC is owned by our general partner, we have an incentive to SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 11  refer clients to it. We address this conflict through the disclosures above, and our Chief Compliance Officer reviews these referrals at least annually. Tax Preparation Services. Strategic CFO Solutions LLC d/b/a Strategic Tax & Family Office offers tax preparation services to the public and to SWP advisory clients. We may refer our clients to Strategic Tax & Family Office for tax preparation services. At the time of referral, clients are informed that they are under no obligation to use these tax services. The tax preparation fees paid to Strategic Tax & Family Office are separate and distinct from all fees paid to our firm. Because Strategic CFO Solutions LLC is owned by our general partner, Blum Management Group, Inc., we have an incentive to refer clients to it. We address this conflict through the disclosures above, and our Chief Compliance Officer reviews these referrals at least annually. Lawyer or Law Firm. Our firm's CCO, Jenifer Smith Blum, is an attorney licensed to practice law in the states of Texas, Missouri and Kansas. We occasionally refer clients to Ms. Blum's firm, Blum Law PLLC, for legal services. Clients are informed that they are under no obligation to use Ms. Blum for legal services and they may use any attorney they choose. Legal fees paid to Blum Law PLLC are separate and distinct from all fees paid to our firm. Because Ms. Blum is our Chief Compliance Officer, she has a financial interest in these referrals. Stephen Blum, rather than Ms. Blum, reviews these referrals at least annually. D. Other investment advisers. SWP does not recommend or select other investment advisers for its clients and does not receive compensation from other investment advisers. SWP does not use Third Party Money Managers. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics As an investment adviser, SWP is a fiduciary to each of its clients. We owe clients a duty of care and loyalty, which requires us to act in their best interest at all times and to provide full and fair disclosure of all material facts, including conflicts of interest. This fiduciary duty is the core principle of our Code of Ethics. We adopted the Code under SEC Rule 204A-1, effective October 1, 2026, and it includes our Insider Trading and Personal Securities Transactions Policies and Procedures. Our Code of Ethics applies to all of our supervised persons. It requires each of them to: • Conduct business in an honest, ethical and fair manner, and avoid any situation that might compromise, or appear to compromise, our duty of loyalty to clients • Comply with all applicable federal securities laws • Not trade on, or communicate, material nonpublic information • Report any violation of the Code of Ethics promptly to the Chief Compliance Officer Each supervised person signs an acknowledgment that he or she has received, read and agrees to comply with our Code of Ethics. This happens upon employment or affiliation, annually, and whenever the Code is materially amended. Supervised persons who have access to nonpublic information about client transactions or holdings, or who are involved in making recommendations to clients, are "access persons" under our Code. We treat all of our supervised persons as access persons. Access persons must also: • Obtain the Chief Compliance Officer’s prior approval for any personal trade in a reportable security, except trades our firm makes in a model portfolio account, exchange-traded funds and investments under an automatic investment plan. Initial public offerings, limited offerings (such as private placements) and alternative investments that we recommend to or hold for clients always require the Chief Compliance Officer’s prior written approval. Accounts managed by an unaffiliated adviser over which the access person has no direct or indirect influence or control are not subject to pre-approval or reporting. • Not trade securities on our restricted list. • Not have their personal accounts included in an aggregated client order. On any day we trade a security for clients, they may trade that security only after all client orders in it have been executed, as described in Item 11.D below. • Submit initial and annual holdings reports and quarterly transaction reports. These cover all accounts in which they have a beneficial interest, including accounts of household members and accounts managed by our firm, except accounts over which the access person has no direct or indirect influence or control. For accounts our firm manages, we use the account statements and trade confirmations in our records. The Chief Compliance Officer SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 12  reviews these reports and each quarter compares the timing of personal trades with client trades in the same securities. Stephen Blum (or, in his absence, Wesley Holloway) reviews the Chief Compliance Officer’s own reports, trades and pre-approval requests. This disclosure is provided to give all clients and prospective clients a summary of our Code of Ethics. If a client or prospective client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. B. Securities in Which We Have a Material Financial Interest Neither SWP nor any related person recommends to clients, or buys or sells for client accounts, securities in which SWP or a related person has a material financial interest. SWP does not engage in principal transactions or agency cross transactions. SWP has received due diligence fees from the sponsors of some alternative investments, as described in Item 11.C.3 and Item 12.A.1. C. Investing in the Same Securities Recommended to Clients 1. Owning the same investments as our clients creates a conflict of interest. An access person could benefit from client transactions, or could place personal interests ahead of clients' interests, for example by trading before a client's trade is executed. Stephen Blum, our President, has invested in some of the same securities and alternative investments that some of our clients own. He also has an account that our firm manages in one of our model portfolios. Other access persons also hold some of the same securities as our clients. 2. Stephen Blum's account, like every access person's account, is never included in an aggregated client order and never receives a better price or allocation than clients. When his account receives the same model portfolio trades as client accounts, those trades are placed only after all client orders have been executed. 3. Stephen Blum has invested in some of the same alternative investments that we recommend to clients. These investments are not sponsored or managed by SWP or any related person. The sponsors of some alternative investments have paid SWP a due diligence fee to compensate SWP for the time and costs of researching the investment, as described in Item 12.A.1. The fee is not contingent on whether we recommend the investment. We recommend some alternative investments whose sponsors pay no fee, and we do not recommend some investments whose sponsors pay one. Because the fee is paid by the sponsor of an investment we may recommend, it still creates a conflict of interest. We address this conflict by recommending an alternative investment only when we determine it is in the client’s best interest, regardless of whether the sponsor pays a fee. We accept a due diligence fee only with our Chief Compliance Officer’s advance written approval. Other than these due diligence fees, neither SWP nor Stephen Blum receives compensation from these investments or their sponsors. When Stephen Blum or another access person invests in an alternative investment that clients also own, he or she must invest at the same price per share or unit as clients, and the Chief Compliance Officer must approve the investment in advance. Access persons receive no priority or advantage over clients in purchases or redemptions. When redemptions are limited, they are filled pro rata, so an access person cannot redeem ahead of clients. 4. The Chief Compliance Officer reviews quarterly transaction reports, initial and annual holdings reports, and the timing of personal trades to confirm that personal trading does not disadvantage clients. At least annually, the Chief Compliance Officer also compares access persons’ alternative investment holdings and redemptions with those of clients to confirm that access persons invested at the same price and received no priority or advantage over clients, and documents the review. D. Trading at or About the Same Time as Clients When an access person trades a security at or about the same time we trade it for clients, the access person could benefit by trading ahead of clients. To address this conflict, access persons' accounts, including model portfolio accounts, are never included in an aggregated client order and never receive a better price or allocation than clients. On any day we buy or sell a security for clients, an access person's account at SWP, including a model portfolio account, may trade that security only after all client orders in it have been executed. This applies to every security, including ETFs. Trades in accounts held elsewhere require our Chief Compliance Officer's prior approval, and the Chief Compliance Officer will not approve a same-day trade in a security we are trading for clients until all client orders in it have been executed. Trades in accounts held elsewhere that do not require prior approval are not subject to this same-day restriction: ETFs, transactions under an automatic investment plan, and accounts managed by an unaffiliated adviser over which the access person has no direct or indirect influence or control. Because ETFs are diversified, an access person's trade in an ETF is unlikely to affect the price our clients receive. Each quarter, the Chief Compliance Officer compares the time of each access person trade reported to us, including trades in accounts SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 13  at SWP and trades shown on quarterly transaction reports for accounts held elsewhere, with our client trades in the same security that day, and documents the review. Accounts over which an access person has no direct or indirect influence or control are not reported or reviewed; the access person certifies this each year. Stephen Blum (or, in his absence, Wesley Holloway) reviews the Chief Compliance Officer’s trades. Stephen Blum and another access person trade the same types of index futures that we trade for clients. Their futures trades require our Chief Compliance Officer’s prior approval, are placed only after all client futures orders that day have been executed, and are included in the Chief Compliance Officer’s quarterly review. Item 12. Brokerage Practices A. Selecting and Recommending Custodians and Brokers Our custodians. We recommend that clients hold their accounts at one of the following qualified custodians: Fidelity Investments, Charles Schwab, Vantage Retirement Plans, LLC, or Interactive Brokers, LLC. None of them is affiliated with SWP. Neither SWP nor any of our employees is registered with a broker-dealer, and we do not receive any part of the transaction fees our custodians charge. The custodian you choose also executes the trades in your account. How we choose them. We look for the most favorable overall terms reasonably available for your transactions, not just the lowest cost. We consider: price, and speed and likelihood of execution; financial strength, reputation and responsiveness; custody, recordkeeping and reporting capabilities, including online account access; the range of investments available, including no-transaction-fee mutual funds; and the quality and cost of the services the custodian provides to you and to us. • • • • • At least annually we evaluate each custodian against these factors and against reasonably available alternatives, and we document our conclusions. This best execution review also covers the conflicts described below. The transaction fees our custodians charge may be higher or lower than those charged by other custodians and broker-dealers. Transaction costs in the MAP. In our Managed Account Program (MAP), SWP pays the transaction costs in your account. Every trade therefore costs us money. That gives us an incentive to trade less often than we otherwise might, to choose investments or share classes that carry no transaction fee even if they have higher ongoing expenses (which you bear), and to favor custodians whose fees are lower for us. We address this conflict as follows: Our annual best execution review specifically considers whether our costs are affecting our trading We follow the share class standard described in Item 8: we recommend the lowest-cost share class We review MAP accounts at least monthly and rebalance based on each client’s needs, not on trading • decisions, share class selection or custodian selection. • available to you unless we document why another class is in your best interest. • costs. Transaction costs outside the MAP. If your account is not in the MAP, you pay the custodian’s transaction fees directly. Examples include fees on certain no-load mutual funds and commissions on individual stocks and bonds, as described in Item 5.C. Some custodians offer many no-load funds without transaction charges, and their rates may be discounted from retail rates. Research and Other Soft Dollar Benefits 1. Platform and reporting services. The only benefits we receive from our custodians are the platform and reporting services they make available to every adviser that uses their platforms: trade execution, custody, account statements, recordkeeping, administrative support, and online access to account and reporting data. We do not receive research, software, practice management support, conference or event support, payments or any other benefit from our custodians. These services support our work for clients, but they also make it easier and less expensive for us to run our business, which gives us an incentive to recommend these custodians. We address this conflict by recommending custodians only on the factors described above and by including these services in our annual best execution review. Our Chief Compliance Officer must approve any additional product, service or benefit from a custodian before we accept it, and we would describe it in this Item before it began. Soft dollars. We have no soft dollar arrangements. We do not use client brokerage commissions to obtain research or other products or services. We do not cause clients to pay higher commissions in return for any benefit, and we do not direct client trades to any broker-dealer in return for research. Any future soft dollar arrangement would require our Chief Compliance Officer’s approval and would be disclosed in this Item before it began. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 14  • Products and services acquired with client brokerage commissions during our last fiscal year: none. • Procedures used during our last fiscal year to direct client transactions to a broker-dealer in return for soft dollar benefits: none. Due diligence fees. Some sponsors of private and alternative investments have paid SWP a due diligence fee to compensate us for the time and cost of researching their offerings. These investments are not sponsored or managed by SWP or any related person. The fee is paid to SWP, not to any individual, and is not contingent on whether we recommend the investment. We recommend some investments whose sponsors pay no fee. Because the fee comes from the sponsor of an investment we may recommend, it gives us an incentive to recommend that sponsor’s investments. We address this conflict by recommending an alternative investment only when we determine it is in your best interest, whether or not the sponsor pays a fee. Our Chief Compliance Officer must approve any due diligence fee arrangement in advance, and each fee is recorded and reviewed annually. Other than these fees, SWP receives no compensation from these investments or their sponsors. See also Item 11.C.3. Brokerage for Client Referrals 2. We do not receive client referrals from any custodian, broker-dealer or third party, and we do not consider referrals when we select or recommend a custodian. Directed Brokerage 3. We do not recommend, request or require that clients direct us to use a particular broker-dealer. If you ask us to place your trades through a broker-dealer you choose, you are responsible for negotiating its commissions and other terms, and we will not be able to seek best execution for those trades. Your directed trades will not be aggregated with other clients’ orders, so you may pay higher commissions or other transaction costs, or receive less favorable prices, than clients who do not direct brokerage. Not all advisers permit directed brokerage. ERISA plans. A retirement plan subject to ERISA may direct some or all of its trades to a particular broker-dealer to obtain goods or services for the plan, but only if they are reasonable plan expenses that the plan would otherwise pay and are for the exclusive benefit of the plan. We will ask the plan sponsor for a letter confirming this before we accept the direction. Principal and cross transactions. SWP does not buy securities from or sell securities to client accounts for its own account (principal transactions) and does not arrange trades between client accounts (cross trades or agency cross transactions). Trade errors. If we make an error in placing a trade for your account, we correct it as soon as possible. If the error causes a loss, SWP pays the cost of correcting it and puts your account in the position it would have been in had the error not occurred. If the error results in a gain, you keep it; SWP never keeps a gain from a trade error. We never use soft dollars or another client’s account to correct an error. SWP is not responsible for the acts or omissions of any custodian, broker-dealer or investment company. B. Aggregation of Client Orders When we aggregate. Because each client has an individual investment policy, we aggregate orders only in limited situations, mainly when we change or rebalance our model portfolios. We may aggregate (block) orders when we place the same trade in the same security, in the same direction, on the same day, for multiple accounts at the same custodian, and only when we believe aggregation is consistent with best execution and fair to every participating account. Aggregation can lower costs and give every participating account the same price. How aggregated orders are allocated. Before placing an aggregated order, we document how it will be allocated among the participating accounts, and we send the account allocations to the custodian by 4:30 p.m. Eastern time on the trade date. Each participating account receives the average price for the order. Transaction costs are shared pro rata; in MAP accounts, SWP pays them. Partially filled orders are allocated pro rata based on the pre-trade allocation. Allocations are never changed after the fact based on how a trade performs. Investments with limited availability, such as initial public offerings or private placements with limited capacity, are allocated pro rata or by rotation among eligible accounts, and the allocation is documented beforehand. When we do not aggregate. We do not aggregate: SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 15  trades for a single client, such as a withdrawal, a tax-loss sale, or a trade to meet one client’s restrictions; trades in non-discretionary accounts, which are placed after the client approves them; trades at different custodians, or trades placed at different times; or trades in accounts that direct brokerage. • • • • These accounts may receive a different price than an aggregated order. Outside the MAP, they may also pay separate transaction costs that an aggregated order would have shared. Employee accounts. Accounts of SWP’s supervised persons, including accounts we manage in our model portfolios, are never included in a client block. On any day we trade a security for clients, a supervised person’s account at SWP may trade that security only after all client orders in it have been executed. Accounts we manage in our model portfolios receive the same changes as client accounts in that model, placed after all client orders, and may receive a different price. Supervised persons’ trades in accounts held elsewhere generally require our Chief Compliance Officer’s prior approval under our Code of Ethics, and the Chief Compliance Officer will not approve a same-day trade in a security we are trading for clients until all client orders in it have been executed. Exceptions to pre-approval include ETFs, transactions under an automatic investment plan, and accounts managed by an unaffiliated adviser over which the supervised person has no influence or control. Trades under these exceptions are not subject to the same-day restriction. Each quarter, our Chief Compliance Officer reviews the timing of supervised persons’ trades against client trades in the same securities (see Item 11.D). Review. At least quarterly, a sample of aggregated trades is reviewed to confirm that allocations followed the pre-trade allocation and that no account was favored. Short sales. We do not sell securities short in MAP client accounts or take short futures positions in futures accounts. Item 13. Review of Accounts and Financial Plans A. Review of client accounts or financial plans, along with a description of the frequency and nature of our review, and the titles of our employees who conduct the review. For our clients subscribing to our discretionary "Wrap"/Managed Account Program ("MAP") we review each account on at least a monthly basis. The nature of these reviews is to ascertain whether clients' accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. MAP clients receive written reviews on at least a quarterly basis. We review the accounts of our non-discretionary clients at least quarterly, and the accounts of our pension consulting clients at least yearly. We also meet with these clients on request, or as we determine, to discuss changes in their plans or circumstances. The nature of our review is to learn whether these client accounts are in line with investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. For the firm's financial planning clients, we review their plan according to the terms of their planning agreement, and we are available to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Only our Financial Advisors or Portfolio Specialists will conduct the above reviews. B. Review of client accounts on other than a periodic basis, along with a description of the factors that trigger a review. We may review client accounts more frequently than described in Item 13A. Among the factors which may trigger a review are major market or economic events, the client's life events, requests by the client, etc. C. Description of the content and indication of the frequency of written or verbal regular reports we provide to clients regarding their accounts. Our firm or our clients' custodians provide written reports at least quarterly to our MAP clients. In addition, we provide written or verbal reports annually when we meet with clients who use our Financial Planning and Asset Management services. We are always available to discuss any report or account on request, in person, by phone or by videoconference. We do not provide pension clients with written or verbal updated reports unless they choose to contract with us for Pension Consulting services. Pension client account reports are prepared and provided by the plan's recordkeeper or custodian. Financial planning clients receive an initial written report and updated written or verbal reports regarding their financial plans as set forth in their agreement with us. Item 14. Client Referrals and Other Compensation SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 16  A. Economic benefits from non-clients. Other than the custodian platform services and the due diligence fees described in Item 12.A, no one who is not a client gives us an economic benefit for providing advisory services to our clients. B. Compensation for client referrals. We do not directly or indirectly compensate any person for client referrals. Item 15. Custody A. Custody of client funds or securities. SWP is deemed to have custody of client funds and securities because we deduct our advisory fees directly from client accounts. We do not accept standing letters of authorization or other authority to transfer client funds to third parties. All client funds and securities are held by qualified custodians in accounts in the client's name, except certain privately offered securities held directly by clients as permitted by SEC Rule 206(4)-2. When we open an account with a qualified custodian for you, we notify you in writing of the custodian's name and address and how your assets are held. We deduct fees only as you have authorized in writing. B. Account statements. You will receive account statements at least quarterly directly from your qualified custodian, by mail or electronically on the custodian’s website, listing your account balances, transactions and any fees deducted. Please review the statements carefully and compare them with any reports we send you. We encourage you to raise any questions with us about the custody, safety or security of your assets. C. Approved custodians. As of the date of this Brochure, our firm has approved the following account custodians: Fidelity Investments, Vantage Retirement Plans, LLC, Charles Schwab and Interactive Brokers, LLC. Item 16. Investment Discretion We accept discretionary authority to manage securities accounts only for clients who sign a discretionary investment advisory agreement with our firm, which grants us that authority before we begin managing the account. Discretionary authority applies to accounts in our Managed Account Program and any other assets the agreement places under our discretion, and it may not cover all of a client’s assets. We do not allow clients to place restrictions on our discretionary authority unless the client has an employment-related restriction, which we document and apply to the account. Assets not covered by a discretionary investment advisory agreement are managed on a non-discretionary basis, and the client makes the final decision on each investment. Item 17. Voting Client Securities If we have, or will accept, proxy authority to vote client securities, we must briefly describe our voting policies and procedures, including those adopted pursuant to SEC Rule 206(4)-6. We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. You may call, write or email us to discuss questions you may have about particular proxy votes or other solicitations. We do not file class action claims for clients. Item 18. Financial Information A. Prepayment of fees. If we require or solicit prepayment of more than $1,200.00 in fees per client, six months or more in advance, we must include a balance sheet for our most recent fiscal year. We do not require nor do we solicit prepayment of more than $1,200.00 in fees per client, six months or more in advance. Therefore we have not included a balance sheet for our most recent fiscal year. B. Financial condition. If we are an SEC-registered adviser and have discretionary authority or custody of client funds or securities, or we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we must disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 17  We have nothing to disclose in this regard. C. Bankruptcy. If we have been the subject of a bankruptcy petition at any time during the past ten years, we must disclose this fact, the date the petition was first brought, and the current status. We have nothing to disclose in this regard. SWP ADV Part 2A Firm Brochure Other than Annual Supplement| October 22, 2026 | page 18