PROTOCOL WEALTH FORM ADV 2A OCT 2026

Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 PROTOCOL WEALTH, LLC Firm Brochure — Form ADV Part 2A Item 1 – Cover Page Protocol Wealth, LLC 201 Milwaukee Street, Suite 200 Denver, CO 80206 720-383-4550 info@protocolwealthllc.com protocolwealthllc.com October 9, 2026 This brochure provides information about the qualifications and business practices of Protocol Wealth, LLC. If you have any questions about its contents, please contact us at 720-383-4550 or info@protocolwealthllc.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. Protocol Wealth, LLC is a Delaware limited liability company and an investment adviser registered with the SEC. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about Protocol Wealth, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Our CRD number is 335298. Page 1 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Item 2 – Material Changes This brochure has been rewritten and replaces our brochure dated September 2026. The material changes since our last annual updating amendment brochure, dated January 13, 2026, are summarized below. This edition also corrects the identity of the broker-dealer named in the September 2026 edition. Broker-dealer registration and how we are compensated Jason Leupold and Nicholas Rygiel have become registered representatives of Finalis Securities LLC (CRD #305908), an unaffiliated broker-dealer and member of FINRA and SIPC. Finalis Securities supports private capital raising and merger and acquisition transactions. In that capacity Jason Leupold and Nicholas Rygiel may act on capital raising or transaction engagements and receive transaction-based compensation, including success fees, which must flow through Finalis Securities. Those engagements may involve persons or companies that are also our advisory clients, or in which our advisory clients invest. Our brochure filed October 1, 2026 named a different broker-dealer in error; this edition corrects that. Protocol Wealth itself is compensated only by the fees its clients pay, and receives no commissions, no revenue sharing and no third-party compensation. Because two of our principals may receive transaction-based compensation, we no longer describe the firm as fee-only. See Items 5, 10 and 14. Sub-advisers and vault strategies We now engage sub-advisers to manage a portion of certain clients’ digital assets, including firms located outside the United States that are not registered with the SEC or any state. Assets allocated to a sub-adviser are transferred into a smart contract vault, and the client’s wallet receives a token representing the interest in that vault. Sub-advisers charge their own management and, in some cases, performance fees, which are taken from the assets in the vault and are in addition to our advisory fee. See Items 4, 5, 6, 8, 10, 14 and 16. Fees Our fee schedule has been revised. Our asset-based fee ranges from 0.25% to 2.00% annually: 1.00% to 2.00% for onchain digital asset management, 0.25% to 0.50% for passive custody sleeves, and 0.50% to 2.00% for traditional portfolio management. Monthly retainers range from $250 to $15,000 or more. We no longer charge a minimum fee; the $600 per month onchain minimum stated in the January 2026 brochure and the $300 per month firm minimum stated in the brochure filed October 1, 2026 no longer apply. See Item 5. Ownership, management and organization Effective December 31, 2025, ownership of the firm is held by three limited liability companies, each holding a one-third interest: Forbidden Fruit Consulting, LLC, Leupold Capital Management, LLC and Rygiel Holdings, LLC. Adam Blumberg, Jason Leupold and Nicholas Rygiel each serve as a Managing Partner and Manager. A former principal is no longer associated with the firm. Effective January 5, 2026, the firm converted from a Wyoming to a Delaware limited liability company. The January 2026 brochure gave the effective date as January 1, 2026. Offices In addition to our principal office in Denver, Colorado, we maintain an office in Havertown, Pennsylvania. Private fund We serve as a sub-adviser to LA-0512 Fund I, a series of Ironclad-Financial-Investments, LP, a private fund whose investment adviser is Platform Advisor, LLC. The fund was organized under the name of Ironclad Financial, an advisory firm Nicholas Rygiel owned before joining Protocol Wealth. We receive no management fee from the fund, but we may receive carried interest, a share of its profits, which is a performance-based fee. Our prior brochures did not describe this relationship. See Items 4, 5, 6, 7, 8, 10 and 11. Artificial intelligence Our client portal includes an AI assistant that answers clients’ questions about their own accounts. Its answers are not reviewed by an adviser before the client sees them. We have added a description of how we use artificial intelligence (AI) tools, including that assistant and AI that reads values from documents clients provide, a feature we are introducing. See Items 4, 8 and 11. Page 2 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Self-custodial wallets Selected clients may hold digital assets in a self-custodial wallet within PW Portal, which only the client can sign for and which is not a qualified custodian. See Items 12 and 15. Retirement plans We have added pension and profit-sharing plans, including small-business and individual 401(k) plans, to the clients we serve. See Items 4 and 7. Contact information Our telephone number is 720-383-4550. Earlier filings gave a different number in error. Custody and reporting Our description of custody has been revised to explain how our multi-party computation wallet arrangement works, to state our position on the application of the custody rule, and to describe the assets held in vaults. We do not accept standing letters of authorization. Our client platform is PW Portal, and we generally make a report of digital asset holdings available monthly through the portal. See Items 13 and 15. Services no longer offered We are not currently providing institutional consulting services, and those services have been removed from this brochure. Our role as sub-adviser to the private fund described above continues; see Items 4 and 6. That fund is our only sub-advisory engagement; we are not providing sub-advisory services to any other adviser or fund. Our description of the outside business activities of our personnel has been updated; see Item 10. Assets under management As of October 7, 2026, we managed approximately $153 million in client assets and provided advisory services to 50 clients, compared with approximately $125 million reported in the January 2026 brochure. Merger with Ironclad Financial The merger with Ironclad Financial, effective June 1, 2025, is complete. Ironclad’s clients signed new Protocol Wealth advisory agreements and Ironclad has withdrawn its registrations. Item 3 – Table of Contents • • • • • • • • • • • • • • • • Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Business Item 5 – Fees and Compensation Item 6 – Performance-Based Fees and Side-by-Side Management Item 7 – Types of Clients Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Item 12 – Brokerage Practices Item 13 – Review of Accounts Item 14 – Client Referrals and Other Compensation Item 15 – Custody Item 16 – Investment Discretion Page 3 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 • • Item 17 – Voting Client Securities Item 18 – Financial Information Item 4 – Advisory Business A. Firm Description and Ownership Protocol Wealth, LLC ("Protocol Wealth," "we," "our" or "the firm") is an investment adviser registered with the U.S. Securities and Exchange Commission, with its principal office in Denver, Colorado and an additional office in Havertown, Pennsylvania. Registration does not imply a certain level of skill or training. The firm was organized in Wyoming in 2025 under a different name and changed its name to Protocol Wealth, LLC later that year. Effective January 5, 2026, the firm converted to a Delaware limited liability company. The conversion did not change the firm’s ownership, management or operations. The firm is owned in equal shares by three limited liability companies: • Forbidden Fruit Consulting, LLC (member: Adam Blumberg) — 33.33% • Leupold Capital Management, LLC (member: Jason Leupold) — 33.33% • Rygiel Holdings, LLC (member: Nicholas Rygiel) — 33.33% The firm is managed by Adam Blumberg, Jason Leupold and Nicholas Rygiel, each a Manager. Their roles are: • Adam Blumberg — Managing Partner and Chief Compliance Officer • Jason Leupold — Managing Partner and Chief Investment Officer • Nicholas Rygiel — Managing Partner, Chief Technology Officer and Chief Information Security Officer On June 1, 2025, the firm merged with Ironclad Financial, an investment adviser founded by Nicholas Rygiel and registered in Pennsylvania, Florida, New Jersey and California. Protocol Wealth was the surviving firm. Ironclad’s clients and advisory operations became part of Protocol Wealth, Mr. Rygiel became an owner of the firm, and Ironclad withdrew its registrations. B. Advisory Services Investment portfolio management. We manage portfolios on a discretionary and non-discretionary basis. Portfolios may hold traditional securities such as equities, ETFs and fixed income, and digital assets such as cryptocurrencies and tokens. Strategies are built around each client’s objectives, time horizon and tolerance for risk. Depending on the client, we may also use staking, liquidity provision on decentralized exchanges, yield strategies on decentralized protocols, and derivatives for hedging or income. These strategies carry the risks described in Item 8. Financial planning and consulting. We provide financial planning either alongside investment management or on its own. This includes retirement, tax, estate, insurance and cash flow planning, with particular attention to digital asset taxation, concentrated token positions, lock-up schedules and liquidity events. Engagements may be ongoing under a monthly retainer, project-based for a fixed fee, or included as part of discretionary asset management at no separate charge. Digital asset advisory. For clients who hold digital assets onchain or outside traditional brokerage accounts, we advise on wallet structure, custody options, protocol selection, yield opportunities and risk management. In these engagements we may advise without managing the assets directly. Private fund. We serve as a sub-adviser to LA-0512 Fund I, a series of Ironclad-Financial-Investments, LP, a private fund for which we manage approximately $300,000. The fund was organized on the AngelList platform under the name of Ironclad Financial, an advisory firm Mr. Rygiel owned before joining Protocol Wealth. Platform Advisor, LLC, an AngelList affiliate not affiliated with us, is the fund’s investment adviser of record, and AngelList/Belltower entities provide its administration and custody. Platform Advisor, LLC (SEC file number 802-78135) reports the fund in its own Form ADV. We provide investment advice to the fund only as its sub-adviser, and we do not administer the fund or hold its assets. We receive no management fee from the fund, but we may receive carried interest, a share of its profits, as described in Items 5 and 6. Only qualified clients may invest in the fund. The risks of investing in a private fund are described in Item 8. Page 4 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Retirement plans. For business-owner clients, we may help evaluate and coordinate their company’s retirement plan offered through a third-party provider. Where that provider serves as the plan’s investment manager, we are not a fiduciary to the plan and do not select or monitor its investments. We also advise individual (solo) 401(k) plans, which generally are not subject to the Employee Retirement Income Security Act because they cover no employees. C. Sub-Advisers For certain digital asset strategies, particularly yield strategies on decentralized protocols, we engage sub-advisers to manage a portion of a client’s assets. Protocol Wealth enters into a written agreement with each sub-adviser; clients do not sign a separate agreement with them. We obtain the client’s permission before allocating assets to a sub-adviser and before moving an allocation from one sub-adviser to another. How an allocation works. Assets are transferred from the client’s wallet into a smart contract vault operated or curated by the sub-adviser, and the client’s wallet receives a token representing the client’s interest in that vault. Other investors may participate in the same vault. The sub-adviser decides how the assets in the vault are deployed. Assets held in a vault are not held by a qualified custodian, and a vault is not a bank, broker-dealer or trust company. A client’s ability to withdraw depends on the terms of the vault and on conditions in the market and in the underlying protocols. We maintain a list of approved sub-advisers and complete written due diligence before adding one, covering the sub-adviser’s registration status, personnel and track record, the strategies it uses, its security and key management practices, the protocols it uses, its operational controls and the design of the vaults through which it manages assets. We review approved sub-advisers at least annually and may remove one at any time. Sub-advisers we use include firms located outside the United States that are not registered with the SEC or any state securities regulator. The risks of these arrangements are described in Item 8. D. Technology and Artificial Intelligence Clients access reporting and documents through PW Portal, our client platform. There is no separate charge for it. We use software tools that rely on artificial intelligence (AI), including large language models, in our work. Our advisers use AI tools to help with research, analysis, drafting, and the internal software we build and use, and we use AI in sorting email sent to us. An adviser is responsible for every recommendation and every communication we send you, and reviews AI-assisted work before it is used in advice to you. Other AI-assisted work, such as internal software and drafts, is checked by sampling and other controls, not item by item. AI tools do not make investment decisions for you, do not trade, and do not move money. Our systems cannot place, stage, route or change trades, and all trades are entered by our personnel. In two limited cases, AI output reaches you without an adviser reviewing each item first. Client portal AI assistant. Our client portal at pwportal.app offers an AI assistant. It is a limited beta. It is off unless you or your adviser turn it on, and either of you can turn it off at any time. It answers questions about your own account information and gives general educational information. It can also do illustrative calculations with figures from your accounts, which are not projections of returns, and can send a note to your adviser when you ask. It does not give investment advice or recommendations. An adviser does not review each answer before you see it, and an answer can be wrong. We keep a record of every conversation with the assistant. Since October 9, 2026, a principal of the firm reviews a sample of the assistant’s conversations each week, and each review is recorded. The first review covered every week since the beta began in which the assistant was used. Your adviser can see your conversations with the assistant, and we keep each message as you wrote it. The replacement of identifiers described below applies only to what we send to the AI provider. If an answer matters to a decision, please confirm it with your adviser. Values read from your documents. We are introducing a feature in which, when a statement or Schedule K-1 for an investment we do not manage is placed in the document folder we set up with you for that purpose, AI reads values from it, such as the investment’s name, type, value, and as-of date. These values may appear in your portal before an adviser reviews them. Each one is labeled “Unverified” until an adviser confirms or corrects it. If an estimated total includes unverified values, the unverified amount is shown beneath it. For each investment we use the most recent statement we have. A K-1 figure is used only when we have no statement for that investment, and a statement is used instead of a K-1 even when the K-1 is more recent. A K-1 figure is labeled “K-1 capital account (tax basis)” with its as-of date and is never shown as a market value. We do not calculate returns or Page 5 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 performance from these values, and no advice comes with them. You can choose whether these values appear in your view. That choice changes only what you see. It does not change your fees or your statements. How your information is handled. Our client portal assistant and our document reading use Anthropic’s Claude models under zero data retention terms, meaning Anthropic does not store the content after it responds, except where the law requires it or Anthropic’s automated safety systems flag a conversation, in which case Anthropic may keep it for up to two years. Advisers can also choose xAI’s Grok in our internal advisory chat, under xAI’s zero data retention terms. Before document text is sent to a model, our software replaces account numbers, tax identification numbers, addresses, and phone numbers where it recognizes them. Names printed on a document are not replaced. Before a message you type to the portal assistant is sent to a model, our software replaces some identifiers it can detect by pattern, such as email addresses, U.S. phone numbers, and Social Security numbers. This detection is not complete, and names are not replaced, so please avoid typing account numbers or full names. To make documents that advisers add to our internal advisory chat searchable, we send passages of those documents, which can include client information, to Google’s Gemini service. Google’s terms bar it from using that data to train its models. They are not zero data retention terms. We also use Gemini to generate images. Our List of Subprocessors names these providers: https://protocolwealthllc.com/subprocessors/. Our AI & Technology Use Disclosure, at https://protocolwealthllc.com/ai-technology/, gives more detail. If you have questions about how we use AI, contact us at compliance@protocolwealthllc.com or 720-383-4550. E. Tailoring and Client Restrictions We tailor our advice to each client. We begin each relationship with a discussion of the client’s goals, financial circumstances and tolerance for risk, and we document our understanding of them. We also make available a risk-tolerance questionnaire, which some clients complete; for most relationships, risk tolerance is established through discussion with the client rather than through the questionnaire. We are working to put a written risk profile in place for every advisory relationship. Clients may impose reasonable restrictions, such as excluding a particular asset or sector, and we follow restrictions provided to us in writing. F. Assets Under Management As of October 7, 2026, Protocol Wealth managed approximately $153 million in client assets and provided advisory services to 50 clients. Approximately $85 million is managed on a discretionary basis and approximately $68 million on a non-discretionary basis. These figures fluctuate with market conditions. Item 5 – Fees and Compensation A. Advisory Fees All fees are set out in each client’s advisory agreement. Fees are negotiable, and the schedule below is our general pricing. Asset-based fees. Our annual asset-based fee ranges from 0.25% to 2.00% of assets under management, depending on the services provided, the complexity of the relationship and the size of the account. Asset-based fees are billed monthly in arrears, based on the average daily balance of the account during the month: • Onchain digital asset management — 1.00% to 2.00% annually. • Passive custody sleeves — 0.25% to 0.50% annually for assets held in a passive custody arrangement with limited ongoing management. • Traditional portfolio management — 0.50% to 2.00% annually, with lower rates generally applying to larger relationships. We do not require a minimum account size and we do not charge a minimum fee. Fixed fees. Clients may instead pay a fixed fee: • Monthly retainer for ongoing planning and advisory services, ranging from $250 to $15,000 or more per month depending on the complexity of the engagement. • Project fees for limited-scope engagements, agreed in advance and varying with scope. Page 6 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Hybrid arrangements combining a reduced asset-based fee with a fixed planning fee are available where they better reflect the work involved. Carried interest. We receive no management fee from the private fund we sub-advise, described in Item 4, but we may receive carried interest, a share of the fund’s profits, typically 10% and up to 20%. Carried interest is a performance-based fee and reduces the returns of the fund’s investors. Only qualified clients may invest in the fund. See Item 6. B. Payment of Fees Where a client authorizes it, advisory fees are deducted directly from the client’s account by the custodian and paid to us. Clients may instead be invoiced and pay by ACH through Mercury or by card through Stripe. One client pays fees in digital assets; in that case the fee is calculated in U.S. dollars in the same way as any other fee and settled in the dollar equivalent of a digital asset. Fees are billed after services are rendered. We do not require prepayment of more than $1,200 in fees per client six months or more in advance. C. Other Fees and Expenses Our advisory fee covers advisory services only. Clients also bear costs charged by third parties, of which we receive no part: Internal expenses of funds and ETFs held in the account. • Brokerage commissions, transaction and ticket charges, and the costs of derivative transactions. • Digital asset trading costs, including exchange fees, spreads and blockchain network (gas) fees. • • Custodial fees, including digital asset custody fees, wire and transfer fees. Sub-adviser fees. A sub-adviser charges its own fee for managing the assets allocated to it. Depending on the sub-adviser and the strategy, that fee may be a management fee based on assets, a performance fee based on returns, or both. Those fees are taken from the assets in the vault rather than billed to the client separately, which means they reduce the value of the client’s interest in the vault. They are in addition to the advisory fee the client pays Protocol Wealth, because our asset-based fee applies to all assets under our management, including assets a sub-adviser manages. A client therefore pays two levels of fees on those assets, and our fee does not decrease when a sub-adviser manages them. We disclose the applicable fee structure to the client before an allocation is made. Protocol Wealth receives no part of any sub-adviser’s fee. Clients who pay a flat monthly retainer rather than an asset-based fee are not charged an additional Protocol Wealth fee on assets allocated to a sub-adviser. Smart contract cover. Where a client elects smart contract cover for a strategy, the client pays the cost of that cover. We disclose the cost when we offer the option. Cover of this kind is not insurance issued by a regulated insurer; see Item 8. D. Negotiability Fees are negotiable. We may group related accounts for pricing and may charge less than the schedule above, for example for long-standing relationships or early clients of a new service. Each client’s arrangement is set out in that client’s agreement. E. Termination and Refunds Either party may terminate the advisory agreement at any time, without penalty. Because fees are billed in arrears, we calculate the final fee through the termination date. Any fees paid in advance and not earned are refunded on a pro rata basis. Transferring assets on termination may involve custodian fees, which are the client’s cost. F. Compensation for the Sale of Securities Jason Leupold and Nicholas Rygiel are registered representatives of Finalis Securities LLC (CRD #305908), a broker-dealer and member of FINRA and SIPC that is not affiliated with Protocol Wealth. Finalis Securities supports private capital raising and merger and acquisition transactions. Acting as registered representatives, Jason Leupold and Nicholas Rygiel may work on capital raising or transaction engagements and receive transaction-based compensation, including success fees, which must flow through Finalis Securities. This compensation is separate from Protocol Wealth’s advisory fees, and Protocol Wealth receives no part of it. Page 7 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 This is a conflict of interest, and our clients make it a significant one. Many of our clients are founders of digital asset projects, protocol treasuries and companies that raise capital or pursue transactions. Transaction-based compensation creates a financial incentive to pursue, recommend or encourage a capital raise, sale or other transaction that pays a success fee, rather than advice that pays none, and to recommend that advisory clients invest in an offering on which a success fee is earned. We address the conflict as follows: • Protocol Wealth does not recommend that an advisory client invest in an offering or transaction on which any of our personnel is earning or may earn transaction-based compensation, unless the conflict is disclosed to the client in writing before the client commits. • Any engagement in which a person who is also an advisory client is the issuer, the seller or the buyer is disclosed to that client in writing before the engagement proceeds. • Advice given to advisory clients must be in the client’s best interest, is given under Protocol Wealth’s compliance program, and is supervised by the Chief Compliance Officer. • Protocol Wealth receives no part of any transaction-based compensation, and advisory fees are not reduced or offset by it. • No client is required to engage Finalis Securities or any other broker-dealer, and clients may use any firm they choose. • These activities are also subject to Finalis Securities’ own supervision and FINRA requirements, including its pre-approval process for engagements. Item 6 – Performance-Based Fees and Side-by-Side Management Protocol Wealth does not charge performance-based fees on the separately managed accounts of its advisory clients. Our advisory fee for those accounts is the asset-based or fixed fee described in Item 5 and does not depend on investment performance. Carried interest. We serve as a sub-adviser to the private fund described in Item 4. We receive no management fee from the fund, but we may receive carried interest, which is a share of the fund’s profits, typically 10% and up to 20%. Carried interest is a performance-based fee. Every investor in the fund must be a qualified client under Rule 205-3 under the Investment Advisers Act, and AngelList confirms each investor’s eligibility. If we are engaged to sub-advise other private funds or special purpose vehicles on similar terms, we will update this brochure before doing so. Because we may receive carried interest from the fund while we charge asset-based or fixed fees to other accounts, we manage accounts with different fee arrangements side by side. This creates conflicts of interest. Carried interest is a share of the fund’s net profits, so we share in gains but not in losses on the capital invested, which gives us an incentive to make riskier or more speculative investments for the fund than we would otherwise make. It also gives us an incentive to favor the fund over accounts that pay an asset-based fee, for example in how we allocate investment opportunities and our time, and to recommend that clients invest in it. We address these conflicts as follows. We act as a fiduciary to each client. We base investment decisions for each account on that account’s objectives, circumstances and restrictions. We do not steer any client into the fund in order to earn carried interest. A client invests in the fund only after receiving its offering documents, and only once AngelList has confirmed that the client is a qualified client. Certain sub-advisers we use do charge performance fees on the assets they manage, as described in Item 5. Protocol Wealth receives no part of those fees. A performance fee gives the sub-adviser an incentive to pursue higher returns through higher risk than it might otherwise take, because it shares in gains but not in losses. We consider a sub-adviser’s fee structure as part of our due diligence and in deciding whether an allocation is appropriate for a client. Success fees earned by our personnel through Finalis Securities, described in Item 5.F, are compensation for transaction services rather than for investment performance, and are not paid by advisory clients as part of our advisory fee. Item 7 – Types of Clients Protocol Wealth advises: Page 8 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 • Individuals, including high net worth individuals, many of whom hold a significant part of their wealth in digital assets. • Founders and early holders of digital asset projects, who often hold concentrated, volatile or restricted positions. • Employees of technology companies with equity compensation. • Decentralized autonomous organizations, foundations and protocol treasuries, where our client is the entity and we work with its board or authorized signatories. • Businesses and other entities that hold digital assets on their balance sheets. • Trusts and estates, including those holding digital assets. • Pension and profit-sharing plans, including small-business 401(k) plans and individual (solo) 401(k) plans. • A pooled investment vehicle, specifically the private fund described in Item 4, to which we are a sub-adviser. We do not require a minimum account size and we do not charge a minimum fee. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Traditional securities. We use fundamental analysis of the issuer or fund, together with macroeconomic analysis, and we build diversified allocations using individual securities, ETFs and fixed income. Our orientation is long term. We do not engage in high-frequency or short-term trading. Digital assets. We analyze digital assets using onchain data such as network activity, staking participation and liquidity depth; the economics of the token, including supply schedule and distribution; the development team and the state of the protocol; the degree of decentralization and how governance works; the security history of the protocol and its audits; and its regulatory position, including whether the asset may be treated as a security. We supplement our own work with third-party research and analytics. We also use artificial intelligence tools to gather and summarize research and data. Their output is reviewed by our personnel and is not the basis of a recommendation on its own. B. Investment Strategies Which strategies apply depends on the client’s objectives, circumstances and instructions, and on whether the client’s assets are held with a custodian or onchain. • Long-term allocation across traditional assets and digital assets, rebalanced periodically. • Diversification and risk reduction for concentrated positions, including planning around lock-up and vesting schedules. • Staking of digital assets to earn network rewards. • Stablecoin strategies, which hold digital assets designed to maintain a fixed value against a currency such as the U.S. dollar and deploy them to earn yield on lending markets and other decentralized protocols. • Providing liquidity to decentralized exchanges. • Yield strategies on decentralized protocols, generally implemented through the sub-advisers described in Item 4. Those strategies do not use leverage or margin. • Derivatives, including futures and options, used to hedge exposure or generate income. Airdrops and forks. Clients may receive digital assets through airdrops or network forks. Where those assets are held in an account we advise on, we treat them as part of the portfolio and advise on whether to hold, sell or convert them. Smart contract cover. Where cover against smart contract failure is available from a provider such as Nexus Mutual or OpenCover, we offer the client the option to purchase it, explain what it does and does not cover, and document the client’s decision. C. Material Risks Page 9 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Investing involves the risk of loss, including loss of the entire amount invested, and clients should be prepared to bear that risk. The risks below are the ones we consider material to our strategies. They are not a complete list. Market risk. Markets fall, sometimes sharply and for extended periods. Diversification reduces but does not eliminate this risk. Liquidity risk. Some assets cannot be sold quickly at a fair price. This applies to smaller digital assets that trade on few venues, to positions held in protocols with withdrawal delays, and to any asset during stressed markets. Concentration risk. Clients who hold a large position in a single asset, often a token or employer equity, carry risk tied to that one holding. We may recommend diversification or hedging, but the decision belongs to the client. Volatility of digital assets. Digital assets routinely move more in a day than traditional assets move in a year. Clients should expect large swings in value and should not invest amounts they cannot afford to lose. Regulatory risk. The legal treatment of digital assets is unsettled and changing. A token may be treated as a security, a platform may be restricted or shut down, tax treatment may change, and any of these can affect an asset’s value, its liquidity or our ability to manage it. Regulators have not issued guidance addressing several of the arrangements described in this brochure, including multi-party computation wallets and smart contract vaults. Our practices reflect our own interpretation of rules written for traditional assets, and a regulator could take a different view, which could require changes to how client assets are held or managed. Technology and smart contract risk. Digital assets depend on software. Protocols can contain flaws that are exploited, and funds taken that way are usually unrecoverable. Blockchain transactions are generally irreversible, so an error in a transfer cannot be undone. Key and access risk. Access to digital assets depends on cryptographic keys. Loss of key material, including a client’s backup, can mean permanent loss of the assets. The arrangements described in Item 15 reduce this risk but do not eliminate it. Custody and counterparty risk. Custodians, exchanges and trading desks can fail, halt withdrawals or become insolvent. Protections that apply to bank deposits and brokerage accounts, such as FDIC or SIPC coverage, do not apply to digital assets. Insurance offered by digital asset custodians is limited and may not cover a given loss. Valuation risk. Digital assets trade across many venues at different prices, and thinly traded or locked assets may have no reliable price. Valuations used for reporting and for calculating our fee are based on third-party market and blockchain data and may differ from the price realized on a sale. Governance risk. Holders of governance tokens are subject to decisions made by other holders, which can change a protocol’s economics or its rules. A holder with a small position has little influence, and a party that accumulates enough voting power can force changes that harm other holders. We generally do not vote on governance proposals for clients; see Item 17. Stablecoin risk. A stablecoin can lose its peg and trade below its stated value, temporarily or permanently. Its stability depends on the reserves backing it, the issuer’s solvency and disclosure practices, and in some cases on an algorithm rather than on reserves. An issuer can freeze balances, and a stablecoin can be affected by regulatory action. Yield earned on stablecoins comes from lending or protocol activity and carries the counterparty and smart contract risks described here; it is not interest on a deposit and is not insured. Staking. Staked assets may be locked for a period and unavailable to sell, including during a sharp decline. Networks can impose penalties, including slashing, for validator failures or misbehavior, which reduces the amount staked. Rewards are not guaranteed and can change. Where staking is done through a third party, that party’s failure can affect the assets. Liquidity provision. Providing liquidity to a decentralized exchange exposes the client to impermanent loss, meaning the position can be worth less than simply holding the assets would have been. It also carries smart contract risk, and fees earned may not compensate for either. Vault structure. Assets allocated to a sub-adviser are held in a smart contract vault together with other investors’ assets, and the client holds a token representing an interest in the vault rather than the underlying assets themselves. A flaw or exploit in the vault contract, or in a protocol the vault uses, can cause loss of the assets in it, and losses are shared by everyone in the vault. Many vaults can be upgraded or reconfigured by their operator or by governance, which introduces the risk that the terms on which a client’s assets are held change after the allocation is made. Page 10 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Withdrawal and liquidity of vault interests. The ability to redeem a vault interest depends on the vault’s terms and on the liquidity of the assets inside it. Withdrawals may be delayed, queued, suspended or filled in kind, particularly in stressed markets, and a client may be unable to exit at the moment it would most want to. The value of a vault interest is derived from the assets inside the vault and from pricing data that may be incomplete or delayed, and reported values may differ from what a client would realize on redemption. Use of sub-advisers. Where a sub-adviser manages part of a client’s assets, that sub-adviser makes the investment decisions for those assets. Our due diligence cannot eliminate the risk that a sub-adviser performs poorly, departs from its stated strategy, suffers a security failure or ceases operations. We do not control a sub-adviser’s systems, key management or choice of protocols, and our monitoring depends in part on the information the sub-adviser provides. Sub-advisers outside the United States. Some sub-advisers we use are located outside the United States and are not registered with the SEC or any state securities regulator. They are not subject to the Investment Advisers Act, to SEC examination, or to the compliance and recordkeeping requirements that apply to Protocol Wealth. Information about them is more limited than it is for a registered firm. If a dispute arises, a client’s practical remedies against a firm located abroad may be limited, and enforcing a judgment may be difficult or impossible. Derivatives. Futures and options involve leverage, which can magnify losses beyond the amount committed, and depend on the exchange or counterparty performing. A hedge may not move as expected against the position it is meant to protect. We use derivatives only where the client’s circumstances and the account documentation support them. Smart contract cover. Cover offered by providers such as Nexus Mutual or OpenCover is not insurance issued by a regulated insurer, and it is not available for every protocol or strategy. Cover pays only on the terms of the specific product, may exclude the cause of a given loss, and depends on the provider having the funds to pay claims. A client who declines cover bears the full risk of a covered event; a client who purchases it may still suffer a loss that cover does not reach. Airdrops and forked assets. Assets received through an airdrop or fork may have little or no liquidity, may be difficult to value, may be subject to lock-ups or claim deadlines, and may create a tax liability at the time of receipt. Claiming an airdrop can also require interacting with a contract that carries its own risks. Private fund interests. An interest in a private fund is illiquid. It generally cannot be sold or redeemed on demand, and a holder’s rights are set by the fund’s governing documents, which may permit changes the holder does not control. The fund’s investments may be difficult to value and may be concentrated in a small number of positions, and reporting on them is less frequent and less detailed than for publicly traded investments. As a sub-adviser, we do not control the fund’s administration, custody or valuation, which are handled by the fund’s adviser and its service providers. Operational and technology risk at the firm. We depend on systems and third-party providers. A failure, outage or cybersecurity incident could interrupt our ability to manage or report on accounts. The risks of the artificial intelligence tools we use are described below. Artificial intelligence. Our advisers use AI tools in research and analysis that inform our advice, as described in Item 4. Using AI involves risks, including the following. AI errors. AI tools can produce output that is wrong, incomplete, out of date, or made up while sounding confident (sometimes called “hallucination”). We address this by having an adviser review AI-assisted work before it is used in advice to you. An adviser’s review reduces this risk but does not remove it. The portal assistant. Because an adviser does not review each answer from the portal assistant first, an answer you receive can be wrong or incomplete. The assistant does not give investment advice, and you should not act on an answer without confirming it with your adviser. An illustrative calculation from the assistant can also be wrong, is not a projection of returns, and should be confirmed with your adviser before you rely on it. Values read from documents. AI can misread a document, for example by taking the wrong figure, date, or investment name. A value labeled “Unverified” has not been checked by an adviser. A K-1 capital account figure is a tax-basis amount and is not a market value. Your information. Sending information to an AI provider adds a party that handles it. Our replacement of identifiers works by recognizing patterns, so it can miss some identifiers, and it does not replace names. A provider’s systems could be breached or its terms could change. Page 11 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Reliance on AI providers. We depend on outside AI providers. A provider can be unavailable, change how a model behaves, or end a service, which could delay or change the tools we use. AI tools do not remove the investment risks described elsewhere in this brochure. Investing in securities involves risk of loss that you should be prepared to bear. Tax complexity. Digital asset transactions, including staking rewards, protocol activity, forks and airdrops, can create tax consequences that are complicated and in some cases unsettled. We are not accountants, and clients should consult their tax advisers. Item 9 – Disciplinary Information Registered investment advisers must disclose legal or disciplinary events that are material to a client’s evaluation of the firm or its management persons. Protocol Wealth has no such events to report. Clients and prospective clients can review the background of the firm and its personnel at adviserinfo.sec.gov. Item 10 – Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration Neither Protocol Wealth nor its management persons is registered as a broker-dealer, and the firm has no application pending. Jason Leupold and Nicholas Rygiel are registered representatives of Finalis Securities LLC (CRD #305908), a broker-dealer and member of FINRA and SIPC that is not affiliated with Protocol Wealth. Finalis Securities supports private capital raising and merger and acquisition transactions, and transaction-based compensation earned on those engagements, including success fees, must flow through it. This is a conflict of interest, because transaction-based compensation creates an incentive to pursue or encourage transactions that pay a success fee. Our client base makes the conflict more significant than it would be at many advisers, because many of our clients are the founders, companies and treasuries that undertake such transactions. Protocol Wealth addresses the conflict through the measures described in Item 5.F. No client is required to engage Finalis Securities, and Protocol Wealth receives no part of any transaction-based compensation. B. Futures and Commodities Registration Neither Protocol Wealth nor its management persons is registered, or has an application pending, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of any of those. Where client strategies use derivatives, including digital asset derivatives, we act under our investment adviser registration. C. Related Persons Protocol Wealth is owned by three limited liability companies: Forbidden Fruit Consulting, LLC, Leupold Capital Management, LLC and Rygiel Holdings, LLC. None of them conducts advisory, brokerage or other financial services business. Forbidden Fruit Consulting and Leupold Capital Management are personal holding companies for their members. Rygiel Holdings is the holding company for Mr. Rygiel’s interest in Protocol Wealth and is also the vehicle for his personal projects and the technology consulting described in Item 10.E. Protocol Wealth has no affiliated broker-dealer, bank, insurance company or other adviser. We serve as a sub-adviser to LA-0512 Fund I, the private fund described in Item 4. The fund was organized on the AngelList platform under the name of Ironclad Financial, an advisory firm Mr. Rygiel owned before joining Protocol Wealth. Platform Advisor, LLC, an AngelList affiliate not affiliated with us, is the fund’s investment adviser of record, and AngelList/Belltower entities provide its administration and custody. Ironclad Financial has since been combined into Protocol Wealth and no longer exists, and neither it nor Mr. Rygiel holds any role in the fund or its general partner. We may receive carried interest from the fund, as described in Item 6. D. Selection of Other Advisers We select and allocate client assets to sub-advisers for certain digital asset strategies, as described in Item 4. We maintain a list of approved sub-advisers and complete written due diligence before adding one. Some are located Page 12 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 outside the United States and are not registered with the SEC or any state. Protocol Wealth has no ownership interest in, and is not affiliated with, any sub-adviser, and receives no part of any sub-adviser’s fee. Protocol Wealth’s own advisory fee continues to apply to assets a sub-adviser manages, as described in Item 5. Referrals from sub-advisers. Sub-advisers sometimes refer prospective clients to Protocol Wealth, typically investors who want exposure to a strategy and also want a fiduciary adviser. We pay nothing for those referrals, and a referred client pays no more than any other client. The arrangement is a conflict of interest: a sub-adviser that refers clients to us has an interest in remaining on our approved list, and we have an interest in continuing to receive referrals from firms we allocate to. We apply the same due diligence and ongoing review to every sub-adviser whether or not it has referred clients to us, and allocation decisions are made on the basis of the client’s circumstances. Where a client needs specialized help from another professional, such as an attorney or accountant, we may suggest professionals we consider qualified. We receive no compensation for those introductions. E. Outside Business Activities of Management Persons Our management persons have the following outside business activities: • Adam Blumberg is co-founder and chief executive officer of Interaxis, which provides education on digital assets to financial professionals. The role is inactive: he has spent no time on it and received no compensation from it in more than a year. • Jason Leupold provides investment-banking services, such as sourcing transactions and capital, through Silicon Valley Highpoint Capital LLC, on which he spends about 10 hours a month, and is a registered representative of Finalis Securities LLC, through which any securities transactions in that work are effected. • Nicholas Rygiel provides investment-banking services, such as sourcing transactions and capital, through Silicon Valley Highpoint Capital LLC (SVH Capital), and is a registered representative of Finalis Securities LLC, through which any securities transactions in that work are effected. He spends about 10 hours a month on this activity. • Mr. Rygiel is the sole member of Rygiel Holdings LLC, a single-member holding company through which he holds his ownership interest in Protocol Wealth, LLC. Rygiel Holdings is also the vehicle for Mr. Rygiel’s personal, family and hobbyist projects, including software research and development, and through it he may provide technology, software and AI consulting to small businesses. This consulting is unrelated to investment advice and to Protocol Wealth’s business; Mr. Rygiel does not solicit Protocol Wealth clients for it or use Protocol Wealth’s information or resources in it. He spends about 12 hours a month on this activity. These activities take time that would otherwise be available for our clients. Where an activity involves a client or a security we recommend, it is a conflict of interest, and it is subject to our code of ethics and the review described in Item 11. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading A. Code of Ethics Protocol Wealth has adopted a code of ethics under Rule 204A-1. It requires our personnel to put client interests first, to comply with securities laws, to protect client information, to report violations, and to follow the personal trading and information barrier requirements summarized below. A copy is available to any client or prospective client on request. The code also governs our use of technology. Personnel may use only firm-approved artificial intelligence tools for firm business, client confidential information may not be entered into public AI systems, AI-generated content must be reviewed by qualified personnel before it is used with clients, except for the client portal features described in Item 4.D, which operate under the limits and the sample review described there, and statements about our technology must be accurate. B. Material Nonpublic Information Page 13 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 Our clients include founders and early holders of digital asset projects, protocol treasuries and employees of technology companies. Through those relationships our personnel may come into possession of material nonpublic information about a company, a token or a protocol. Our personnel may also receive material nonpublic information through capital raising and transaction engagements conducted through Finalis Securities. Our code prohibits trading on that information or passing it to others, requires personnel to report to the Chief Compliance Officer when they may have received it, and provides for the affected asset to be placed on a restricted list. Information received in connection with a Finalis Securities engagement is also subject to that firm’s own information barrier and supervisory requirements. C. Participation or Interest in Client Transactions Protocol Wealth does not act as principal in transactions with clients and does not act as broker for a client. We serve as a sub-adviser to the private fund described in Item 4, whose investment adviser is Platform Advisor, LLC. We receive no management fee from the fund, but we may receive carried interest from it, which gives us an incentive to recommend that clients invest in it. We do not steer clients into the fund to earn carried interest, a client may invest only as a qualified client and after receiving the fund’s offering documents, and Item 6 describes how we address this conflict. We receive no compensation from any issuer or token project for recommending its asset. As described in Items 5.F, 10 and 14, two of our management persons may receive transaction-based compensation through an unaffiliated broker-dealer. D. Personal Trading Our personnel may buy and sell the same assets we recommend to clients, and given our focus, they are likely to hold some of the same digital assets. This creates a conflict: personnel could benefit by trading ahead of client transactions or in a way that disadvantages clients. We address it as follows: • Client transactions take priority. Personal transactions in an asset being bought or sold for clients are restricted until client activity is complete, or are included in an aggregated order at the same average price. • Personnel must pre-clear participation in initial public offerings and limited offerings, including private token sales and private placements on which the firm’s personnel are engaged through Finalis Securities. • Assets subject to material nonpublic information or significant client activity are placed on a restricted list. • Personnel report their holdings when they join and annually, and report their transactions quarterly. The Chief Compliance Officer reviews those reports. • Violations are subject to discipline, up to termination. Most digital assets are not reportable securities under Rule 204A-1. As a matter of firm policy, our code requires personnel to report digital asset holdings and transactions on the same basis as securities. Item 12 – Brokerage Practices A. Selection of Brokers and Custodians For traditional securities, we generally recommend that clients custody assets at Charles Schwab, Altruist or Interactive Brokers. In selecting and reviewing them we consider execution quality, costs, available investments, technology and integration, cybersecurity, reporting, service and financial stability. Clients are free to choose a different custodian, though we may be unable to manage assets held at institutions where we have no platform access. For digital assets, we use Anchorage Digital Bank as a qualified custodian and the Fordefi platform for assets held onchain, as described in Item 15. Anchorage Digital Bank does not provide trade execution. Digital asset transactions are executed through over-the-counter desks, centralized exchanges and decentralized exchanges, and, for assets managed by a sub-adviser, by the sub-adviser within its strategy. In selecting a venue we consider price and spread, liquidity, settlement risk, the counterparty’s regulatory standing and security practices, and network costs. We do not receive commissions or compensation from any broker, custodian or trading venue. B. Research and Soft Dollars Protocol Wealth does not enter into soft dollar arrangements. We pay for our own research and tools. Page 14 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 C. Brokerage for Client Referrals We do not select or recommend brokers or custodians in exchange for client referrals. D. Directed Brokerage A client may direct us to use a particular broker or custodian. Directed brokerage may prevent us from aggregating that client’s orders with others and may result in less favorable execution or higher costs. Certain supervised persons are registered representatives of Finalis Securities LLC, as described in Items 5.F and 10. Finalis Securities does not execute portfolio transactions for our advisory clients, and no client is asked to direct brokerage there. E. Aggregation and Allocation Where we decide to buy or sell the same asset for more than one account, we may aggregate the orders. Each participating account receives the average price and its share of transaction costs. Partial fills are allocated pro rata among participating accounts, subject to rounding and minimum trade sizes. We do not favor any account over another, including accounts in which our personnel have an interest. F. Trade Errors If we make a trading error, we correct it promptly and the client is made whole. Losses from our errors are borne by the firm. For digital asset transactions, which are generally irreversible and cannot be reversed through a custodian error account, we correct an error by making the client whole at the firm’s expense. Gains resulting from an error are not retained by Protocol Wealth. G. Technology and Trade Execution Our systems do not place, stage, route or modify orders. Every order is entered by our personnel. Artificial intelligence tools are used for research, analysis and reporting only, and have no trading authority. Transfers from a self-custodial wallet in PW Portal are initiated and signed by the client; our systems transmit a transfer the client has signed and do not originate it. Item 13 – Review of Accounts A. Reviews Accounts under our management are reviewed internally at least semi-annually. Reviews cover the account’s allocation, holdings, performance and consistency with the client’s objectives and any restrictions. Accounts with significant digital asset exposure are monitored more frequently. We meet with clients to review their accounts at least annually, and more often at the client’s request. Reviews may also be triggered by a significant move in the portfolio’s value, news affecting a material holding, a change in the client’s circumstances, a client request, or a drift from the agreed allocation. Where a client’s assets are managed by a sub-adviser, our review includes the sub-adviser’s performance, its adherence to the agreed strategy, and any change in its personnel, security practices or operations. B. Reviewers Reviews are conducted by Jason Leupold, Chief Investment Officer, who leads portfolio review, and Nicholas Rygiel for accounts with significant onchain holdings. Adam Blumberg, Chief Compliance Officer, oversees that reviews are conducted as scheduled and documented. C. Reports to Clients Clients receive account statements directly from their qualified custodians. For traditional accounts, those custodians are Altruist, Interactive Brokers or Charles Schwab. Custodian statements are the official record of a client’s holdings and transactions. As a courtesy, we generally make a written report available each month through the client portal covering the digital asset holdings we manage or monitor for the client, including assets held in wallets for which the client holds the backup key. Our reports supplement custodian statements and do not replace them, and we may change their content or frequency. Values in our reports come from third-party market and blockchain data and Page 15 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 may differ from the values a custodian reports. Clients should compare our reports with their custodian statements. Item 14 – Client Referrals and Other Compensation A. Economic Benefits from Non-Clients Protocol Wealth does not receive economic benefits from anyone other than clients for providing investment advice. We have no revenue sharing and no arrangement under which a custodian, vendor or product sponsor compensates us. B. Compensation to Promoters Protocol Wealth has agreements with two promoters who may refer clients to the firm. A promoter who refers a client receives 10% of the ongoing advisory fee paid by that client for as long as the arrangement remains in place. Each arrangement is governed by a written agreement, and any client introduced by a promoter receives disclosure of the arrangement and the compensation at the time of the referral. A promoter has a financial incentive to recommend Protocol Wealth, and that recommendation should not be understood as an objective assessment of our services. Referral compensation is paid by Protocol Wealth out of the advisory fee and does not increase the fee the client pays. C. Compensation from the Broker-Dealer Relationship As described in Items 5.F and 10, Jason Leupold and Nicholas Rygiel may receive transaction-based compensation, including success fees on capital raising and merger and acquisition engagements, through Finalis Securities LLC in their capacity as registered representatives. That compensation is separate from Protocol Wealth’s advisory fees and is not shared with the firm. D. Referrals from Sub-Advisers and Others Sub-advisers we use sometimes refer prospective clients to us. We pay no compensation for those referrals, and a referred client pays no more than any other client. The conflict this creates, and how we address it, is described in Item 10. We also receive referrals from existing clients and from professionals such as attorneys and accountants, and we do not compensate anyone for those referrals. Item 15 – Custody Custody means holding client funds or securities, or having authority to obtain possession of them. The rule that applies to advisers with custody is Rule 206(4)-2 under the Investment Advisers Act. A. Fee Deduction Protocol Wealth is deemed to have custody of client assets because we are authorized to deduct our advisory fees from many client accounts. Client authorization for deduction is given in the advisory agreement. The qualified custodian holding the account sends account statements directly to the client at least quarterly, showing all transactions including our fee. We urge clients to review those statements, which are the official record of their holdings, and to compare them with any report they receive from us. B. Custodians Client assets are held at qualified custodians in accounts in the client’s name: Charles Schwab, Altruist and Interactive Brokers for traditional securities, and Anchorage Digital Bank, a federally chartered digital asset bank, for digital assets held in custody. We are authorized to trade in these accounts. We are not authorized to move assets out of them to third parties. C. Onchain Assets Held Through Multi-Party Computation Wallets Some clients hold digital assets onchain rather than with a custodian. For those assets we use the Fordefi multi-party computation (MPC) wallet platform. Fordefi is not a qualified custodian. The arrangement works as follows: Page 16 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 • Instead of a single private key, signing authority is divided into cryptographic shards. Fordefi holds one shard and Protocol Wealth holds one shard. • The client holds the ultimate backup, secured either through Coincover or through a recovery phrase held by the client. Protocol Wealth does not hold the backup and cannot recover the wallet on its own. • Transactions are governed by a policy engine. The client approves the strategies that may be used and the destination addresses that may receive assets. We can transact only within those approvals, and assets can be sent only to addresses the client has approved. • Protocol Wealth and Coincover, acting together, cannot move client assets without the client. • Wallet activity is visible onchain, and clients have access to their wallet activity through PW Portal. Because Protocol Wealth cannot send client assets to any destination the client has not approved, and cannot recover or reconstitute a wallet without the client, we do not believe this arrangement gives the firm custody of those assets within the meaning of Rule 206(4)-2. Clients retain the ability to recover and control their digital assets at all times. Regulators have not issued guidance addressing multi-party computation wallet arrangements of this kind. The position described above is our own interpretation of a rule written for traditional assets. A regulator could reach a different conclusion, in which case additional requirements, including the use of a qualified custodian and an annual surprise examination by an independent public accountant, could apply to these assets. D. Assets Allocated to Sub-Advisers Where assets are allocated to a sub-adviser, they are transferred to a smart contract vault and the client’s wallet holds a token representing the interest in that vault. Assets held in a vault are not held by a qualified custodian. Protocol Wealth does not hold or receive those assets, and a sub-adviser’s fees are taken from the vault rather than paid by or to us. The same interpretive uncertainty described above applies to these arrangements. E. Self-Custodial Wallets in the Client Portal Some clients hold digital assets in a self-custodial wallet within PW Portal. The client holds the credential that authorizes transactions, and every transfer is signed by the client. Protocol Wealth cannot initiate, sign or approve a transfer from that wallet and cannot move those assets. The wallet is made available through a third-party technology provider and is not a qualified custodian, and assets held in it are not covered by FDIC or SIPC protection. Loss of the client’s credential can mean permanent loss of the assets. The wallet is offered only to clients we enable for it, and the transfers available in it may be limited; we describe the current capability to each client when the wallet is enabled. F. Standing Letters of Authorization Protocol Wealth does not accept standing letters of authorization to transfer client assets to third parties. Item 16 – Investment Discretion Most of our portfolio management relationships are discretionary. A client grants discretion in the advisory agreement and in the trading authorization signed with the custodian. Discretionary authority allows us to decide which assets to buy or sell, in what amount, when, and through which venue or counterparty, without contacting the client before each transaction. Our discretion is limited by: • Written restrictions and guidelines the client gives us, such as excluding an asset or sector. • The strategy documented for the account. We discuss a change with the client rather than moving into a materially different strategy on our own. • For digital assets held onchain, the client’s approvals in the Fordefi policy engine. We can transact only in the strategies the client has approved, and assets can be sent only to addresses the client has approved. • Legal and regulatory limits, including restrictions that apply to clients who are insiders of a public company or subject to lock-up or vesting terms. Assets allocated to a sub-adviser are managed at that sub-adviser’s discretion, within the strategy agreed with us. We obtain the client’s permission before allocating assets to a sub-adviser and before moving an allocation from Page 17 of 18  Protocol Wealth, LLC — Form ADV Part 2A — October 9, 2026 one sub-adviser to another. We do not exercise investment discretion over the individual transactions a sub-adviser makes. Discretionary authority does not allow us to withdraw assets from a client’s account, other than the advisory fee the client has authorized us to deduct. Clients may also engage us on a non-discretionary basis, in which case we obtain the client’s approval before each transaction. Non-discretionary management can delay execution if we cannot reach the client. A client may revoke discretionary authority at any time by written notice. Investment discretion is exercised only by our advisory personnel. Artificial intelligence tools have no discretionary authority and cannot make or execute investment decisions. Item 17 – Voting Client Securities Protocol Wealth does not accept authority to vote proxies. Clients receive proxy materials directly from their custodian or the issuer and vote their own securities. We will discuss a particular proxy with a client who asks, but the client casts the vote. The same applies to onchain governance. Some digital assets carry the right to vote on protocol proposals. We do not vote those tokens for clients as a matter of course. Where a client asks us to participate in a specific vote, we will do so only on the client’s written instruction and where we have the technical ability to submit the vote. We may analyze a proposal and give our view at any time. We do not file claims in class action settlements on behalf of clients. We will provide records a client needs to file a claim. Item 18 – Financial Information Protocol Wealth does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance, and is therefore not required to include a balance sheet in this brochure. We are not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to clients. Neither the firm nor its management persons has been the subject of a bankruptcy petition. Page 18 of 18