ADV PART 2A SUPPLEMENT WRAP BROCHURE OCTOBER 22, 2026

COVER PAGE WRAP FEE PROGRAM BROCHURE FORM ADV PART 2A APPENDIX 1 OTHER THAN ANNUAL AMENDMENT October 22, 2026 Program Sponsored by: Blum Financial, L.P. d/b/a Strategic Wealth Planning 2929 North Central Expressway | Suite 200 Richardson, Texas 75080 (214) 727-6000 Firm Contact: Stephen J. Blum, President Firm Website: www.awealthplan.com ITEM 1 This wrap fee program 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 at 214.727.6000 or 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 Blum Financial, L.P. d/b/a Strategic Wealth Planning 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. Registration as an investment adviser does not imply a certain level of skill or training. You are encouraged to review our Firm Brochure (Form ADV Part 2A), this Wrap Fee Program Brochure and the brochure supplement (Form ADV Part 2B) for the adviser who advises you for more information about our qualifications. SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 1  Item 2 – Material Changes This summary discusses only the material changes to this Wrap Fee Program Brochure ("Wrap Brochure") since our last Wrap Fee Program Brochure dated March 6, 2026. • Alternative investments (Items 4.A and 6.C). 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. We describe which clients we recommend private investments to, our concentration limits, and the disclosures each client signs. We also expanded our description of the risks of these investments. • Futures accounts (Items 4.A and 6.C). 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. • Third-party managers (Items 4, 6, 7, 8 and 9). SWP does not use third-party portfolio managers. Our investment adviser representative is the portfolio manager for all MAP accounts. • MAP fee schedules (Item 4.A). 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. • Mutual fund share classes (Item 4.C). We describe how we select share classes and the conflict created because SWP pays transaction charges in the MAP. • Adviser compensation and conflicts (Item 4.D). We describe how our investment adviser representative is paid; the conflicts created by SWP paying transaction costs in the MAP; and the conflicts when we recommend that you sell or surrender an investment and invest the proceeds in the MAP. • Insurance and related persons (Item 9.A). We describe the commission SWP receives when you buy insurance through our investment adviser representative, our referrals to related businesses, and the conflicts these create. • Code of Ethics and personal trading (Item 9.B). 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. • Custodial benefits and due diligence fees (Item 9.B). We describe the platform services we receive from custodians and the due diligence fees paid by sponsors of some alternative investments. SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 2  Item 3 – Table of Contents Item Page Item 1 – Cover Page 1 Item 2 – Material Changes 2 Item 3 – Table of Contents 3 Item 4 – Services, Fees and Compensation 4 Item 5 – Account Requirements and Types of Clients 7 Item 6 – Portfolio Manager Selection and Evaluation 7 Item 7 – Client Information Provided to Portfolio Managers 10 Item 8 – Client Contact with Portfolio Managers 10 Item 9 – Additional Information 10 SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 3  Item 4 – Services, Fees and Compensation A. The Managed Account Program Strategic Wealth Planning ("SWP" or the "Firm") offers a Managed Account Program ("MAP"), in which SWP manages client accounts on a discretionary basis for a single fee that covers both SWP's management services and the transaction costs in your account. The MAP is designed to help clients meet their investment needs through professional asset management for a single "wrap" fee. MAP accounts are managed on an individualized basis according to each client's objectives, financial goals and risk tolerance. MAP accounts are the accounts a client places in the MAP under a discretionary advisory agreement. Accounts we manage on a non-discretionary basis are not part of the MAP. We provide continuous and regular account supervision. As part of our asset management services, we create portfolios that may include individual stocks or bonds, exchange-traded funds ("ETFs"), options, mutual funds, and other public and private securities and investments. Each client's strategy is tailored to the client's needs. Once the portfolio has been determined, we review it at least monthly and rebalance it based on the client's individual needs, goals and objectives. We do not allow MAP clients to restrict the types of investments held in the portfolio unless the client has an employment-related restriction. SWP does not use third-party portfolio managers for MAP accounts. Fees and Expenses of the MAP The MAP fee is billed quarterly in advance, based on the total value of your MAP accounts at the end of the previous calendar quarter or at the time we receive your assets. If the MAP agreement begins on a day other than the first day of a calendar quarter, the fee for that quarter is prorated. We do not adjust fees for deposits or withdrawals during a quarter. Fees are deducted from your account. SWP charges MAP clients under one of two fee schedules. Your advisory agreement states which schedule applies to you. Our adviser may agree to bill a client under the Original Schedule or at a different fee. As a result, clients with the same portfolio size may pay different fees for the same services. Depending on portfolio size, the Tiered Schedule may cost more or less than the Original Schedule. For many portfolios above $750,000, it costs more. You may ask us which schedule would cost you less. 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% SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 4  Tiered Schedule (adopted 2016). Managed Account Program Tiered Fee1 Schedule implemented in 2016 for some clients: Portfolio Size First $750,000 ($0-$750,000) Annualized Fee 1.50% 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 Fees on Alternative Investments and Futures Accounts 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. Comparing the Cost of the MAP The MAP fee covers investment advisory services, including portfolio management, and the costs of executing transactions in your account. The fee is not based on the number of transactions in your account, and we do not charge higher fees based on trading activity. Depending on how often your account is traded, you may pay more or less in the MAP than you would in a non-wrap program, where a lower advisory fee may be charged but transaction costs are passed directly to you. The relative cost also depends on the MAP fee you pay and the value of the services you receive. 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 Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 5  C. Other Fees and Expenses Mutual Fund Charges. The MAP fee is separate from the fees and expenses that mutual funds charge their shareholders, which are described in each fund's prospectus. These generally include a management fee, other fund expenses and, in some cases, a distribution fee. If a fund imposes a sales charge, you may pay an initial or deferred sales charge. Mutual Fund Share Classes. Many mutual funds offer more than one share class, with different sales charges and ongoing expenses. When a fund offers more than one share class, we recommend or buy the lowest-cost class available to you, unless we document a reason that another class is in your best interest (for example, the lower-cost class is not available on your custodian's platform or requires a minimum investment you do not meet). A higher- cost share class reduces your return. Because SWP pays transaction charges in the MAP, 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. Other Fees. Other costs not included in the MAP fee may include custodian fees, national securities exchange fees, charges for transactions not executed through the custodian, currency exchange costs, custodian transfer fees, wire transfer fees, and other fees required by law. We do not receive any part of these costs. D. Compensation of the Person Recommending the MAP SWP pays our investment adviser representative a salary. No one at SWP is paid a percentage of the advisory fees clients pay. Our adviser's 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. However, as an owner of SWP, our adviser shares in SWP's profits, which include the MAP fees and the insurance commissions SWP receives. This gives our adviser an incentive to recommend that you participate in the MAP, place more assets with us, and buy insurance through SWP. In the MAP, SWP pays the transaction costs in your account. In a traditional non-wrap program, you would pay those costs separately. Because we pay those costs in the MAP, we earn more when your account is not actively traded. This gives us an incentive to recommend the MAP over a non-wrap program. We recommend the MAP only when we believe it is in your best interest, considering your expected trading activity, and we review this at least annually. Paying transaction costs also gives us an incentive to trade less often than we otherwise might, to choose investments or mutual fund 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 these conflicts by reviewing MAP accounts at least monthly and rebalancing based on your needs, not on trading costs; by recommending the lowest-cost share class available to you unless we document why another class is in your best interest; and through our annual best execution review, which considers whether our costs affect our trading or custodian decisions. Recommendations to Sell or Surrender Assets. We may recommend that you sell or surrender investments held in a 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, and invest the proceeds in the MAP. These recommendations create conflicts of interest: • • Advisory fees. If you invest the proceeds in the MAP, we charge the MAP 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. SWP also pays the transaction costs in your MAP account, so we earn more when the proceeds are invested in the MAP and not actively traded. Insurance commissions. If you use the proceeds to buy insurance through Mr. Blum, SWP receives a commission, as described in Item 9.A of this Wrap Brochure. • 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. SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 6  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. Item 5 – Account Requirements and Types of Clients A. Account Requirements. SWP requires a minimum initial investment of $100,000. We may combine the accounts of members of the same household to determine the advisory fee or to meet the minimum. Generally, the minimum is not negotiable and applies throughout the client relationship. We may open accounts below the minimum in particular circumstances (for example, a new 401(k) or SIMPLE plan). B. Types of Clients. We provide services to individuals and high net worth individuals; trusts, estates and charitable organizations; pension and profit-sharing plans; and corporations, limited liability companies and other business entities. Item 6 – Portfolio Manager Selection and Evaluation A. Selection and Review of Portfolio Managers SWP does not use third-party portfolio managers. Our investment adviser representative, Stephen J. Blum, is the portfolio manager for all MAP accounts and creates an individualized investment strategy for each client according to the client's goals and objectives. B. Related Person Portfolio Managers Because SWP sponsors the MAP and our investment adviser representative is its portfolio manager, SWP receives the entire MAP fee, and our portfolio manager is not selected or reviewed as an outside manager would be. Other investment advisers may charge the same or lower fees for similar services. We address these conflicts by reviewing each MAP account at least monthly, reviewing at least annually whether the MAP remains in each client's best interest, and through our Code of Ethics, which is summarized in Item 9.B of this Wrap Brochure. C. Advisory Business and Other Information from Our Firm Brochure Because SWP acts as the portfolio manager for the MAP, the following information from our Firm Brochure also applies. Firm Brochure Item 4.B – Types of Advisory Services (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 4.D of this Wrap Brochure 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 SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 7  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. If we accept appointments to provide our services to a plan governed by the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), 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 the client's current situation, goals and objectives. Generally, such financial planning services will involve preparing a financial plan, providing a financial consultation 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, and business and personal financial planning. Our written financial plans or financial consultations 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. 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 recommendations. For financial consulting engagements, we usually do not provide a written summary, as the process is less formal than our planning service. Plans or consultations are typically completed within six months of the client signing a contract with us, assuming that all the information and documents we request are provided to us promptly. Implementation of the recommendations is 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 4.D and 9.A of this Wrap Brochure. Firm Brochure Item 4.C – Tailoring and Client Restrictions (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 our Financial Planning and Consulting and Pension Consulting services. (ii) Ability of Clients to Impose Restrictions. 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. Firm Brochure Item 4.D – Participation in Wrap Fee Programs SWP sponsors the MAP, which is described in this Wrap Brochure. Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the client's investment objectives, financial goals and risk tolerance. MAP accounts are managed on a discretionary basis and may be included in aggregated orders; non- discretionary accounts are not. SWP receives the wrap fee for its services and pays the transaction costs in MAP accounts. SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 8  Firm Brochure 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. Firm Brochure Item 8.A – Methods of Analysis, Investment Strategies and Risk of Loss 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. Please ask us any questions you may have about our investment strategies. 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 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 4.A and 9.B of this Wrap Brochure. Futures Accounts. Futures are leveraged contracts, and it is possible to lose more than the funds you deposit. In a futures account (Item 4.A), positions are sized to a Nominal Account Size larger than the funds you have deposited, which magnifies gains and losses relative to your deposit. You may be required to deposit additional funds on short notice to meet margin calls. Firm Brochure Item 17 – Voting Client Securities 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 to you and ask the party who sent them to mail them directly to you in the future. You may call, write SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 9  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 7 – Client Information Provided to Portfolio Managers Because our investment adviser representative is both your adviser and your portfolio manager, the information you give us about your financial situation, objectives, risk tolerance and any restrictions is available directly to your portfolio manager. We update this information at least annually and whenever you tell us about a change. Item 8 – Client Contact with Portfolio Managers You may contact your portfolio manager, Stephen J. Blum, at any time with questions about your investments or any other matter. Item 9 – Additional Information Item 9.A – Disciplinary Information and Other Financial Industry Activities Firm Brochure Item 9 – Disciplinary Information Our firm and management have no legal or disciplinary events to disclose. Firm Brochure Item 10 – Other Financial Industry Activities and Affiliations 10.A Broker-Dealer Affiliation. Neither our firm nor our management persons are registered with a broker-dealer or as a registered representative of a broker-dealer. 10.B Futures and Commodity Registrations. Neither our firm nor 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 any of them. 10.C Material Relationships with Related Persons. 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 4.D of this Wrap Brochure). 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 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 SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 10  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. 10.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. Item 9.B – Code of Ethics, Review of Accounts, Client Referrals and Financial Information Firm Brochure Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11.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 control. For accounts our SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 11  firm manages, we use the account statements and trade confirmations in our records. The Chief Compliance Officer 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. 11.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 below. 11.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. 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. 11.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 SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 12  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 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. Firm Brochure Item 13 – Review of Accounts 13.A Periodic Reviews. We review each MAP account at least monthly. 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. At least annually, we also review whether the MAP remains in the client's best interest. We review the accounts of our non-discretionary clients at least quarterly, and the plans of our ongoing pension consulting clients at least annually. For financial planning clients, we review their plan according to the terms of their planning agreement. Only our Financial Advisors or Portfolio Specialists conduct these reviews. 13.B Other Reviews. We may review client accounts more frequently than described above. Among the factors that may trigger a review are major market or economic events, the client's life events and requests by the client. 13.C Reports. 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 video conference. 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. Firm Brochure Item 14 – Client Referrals and Other Compensation 14.A Economic Benefits from Non-Clients. Our custodians provide us with the same platform 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. These services 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 including the services in our annual best execution review, and our Chief Compliance Officer must approve any additional benefit before we accept it. Some sponsors of alternative investments have paid SWP due diligence fees, as described in Item 11.C.3 above. Other than these custodian platform services and due diligence fees, no one who is not a client gives us an economic benefit for providing advisory services to our clients. 14.B Compensation for Client Referrals. We do not directly or indirectly compensate any person for client referrals. Firm Brochure Item 18 – Financial Information We do not require or solicit prepayment of more than $1,200 in fees per client six or more months in advance, so we have not included a balance sheet. We have no financial condition that is reasonably likely to impair our ability to meet our contractual commitments to clients, and we have not been the subject of a bankruptcy petition during the past ten years. SWP Form ADV 2A Wrap Fee Brochure Supplement – Other than Annual Amendment | October 22, 2026 | page 13