BRYANT WOODS INVESTMENT ADVISORS, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure March 2025 2410 North Forest Road, Suite 101 Getzville, NY 14068 www.landmarkfirm.com Firm Contact: Emillie Camilleri Chief Compliance Officer This brochure provides information about the qualifications and business practices of Bryant Woods Investment Advisors, LLC doing business as Landmark Wealth Management. If clients have any questions about the contents of this brochure, please contact us at (716) 810-9594 or email info@landmarkfirm.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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #109379. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Landmark Wealth Management is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. Since the last annual amendment filed on 01/18/2024, the following changes have been made: Our firm has designated Emillie Camilleri as the firm contact and Chief Compliance Officer. Our firm has updated our contact number to (716) 810-9594. ADV Part 2A – Firm Brochure Page 2 Landmark Wealth Management  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................................. 1 Item 2: Material Changes ...................................................................................................................................................... 2 Item 3: Table of Contents ..................................................................................................................................................... 3 Item 4: Advisory Business.................................................................................................................................................... 4 Item 5: Fees & Compensation ............................................................................................................................................. 5 Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7 Item 7: Types of Clients & Account Requirements .................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 7 Item 9: Disciplinary Information..................................................................................................................................... 11 Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 11 Item 11: Code of Ethics, Participation or Interest in ............................................................................................... 11 Client Transactions & Personal Trading ...................................................................................................................... 11 Item 12: Brokerage Practices ........................................................................................................................................... 12 Item 13: Review of Accounts or Financial Plans ....................................................................................................... 15 Item 14: Client Referrals & Other Compensation ..................................................................................................... 16 Item 15: Custody .................................................................................................................................................................... 17 Item 16: Investment Discretion ....................................................................................................................................... 17 Item 17: Voting Client Securities ..................................................................................................................................... 18 Item 18: Financial Information ........................................................................................................................................ 18 ADV Part 2A – Firm Brochure Page 3 Landmark Wealth Management  Item 4: Advisory Business We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed in the State of New York and has been in business as an investment adviser since 2005. The following individuals own 5% or more of our firm: Chiampou, Travis, Besaw & Kershner, LLP, Brian K. Laible (vicariously through Landmark Wealth Advisors, LLC), and Mark P. Collard (vicariously through Odyssey Advisors Inc.). Our firm provides asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Employer-Sponsored ERISA Plan Consulting: We provide consulting services to employer plan sponsors on an ongoing basis. Generally, such pension consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure and participant education. All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide ADV Part 2A – Firm Brochure Page 4 Landmark Wealth Management  our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of the aforementioned services). Tailoring of Advisory Services Our firm offers individualized investment advice to our Comprehensive Portfolio Management clients. General investment advice will be offered to our Employer-Sponsored ERISA Plan Consulting clients. Each Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Comprehensive Portfolio Management. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management Our firm manages $517,728,000 on a discretionary basis and $98,177,000 on a non-discretionary basis as of 12/31/2024. Item 5: Fees & Compensation Compensation for Our Advisory Services Comprehensive Portfolio Management: Landmark provides investment management services for an annual fee based upon a percentage of the market value of the assets being managed by Landmark. Landmark’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. Landmark does not, however, receive any portion of these commissions, fees, and costs. The maximum annual fee charged for this service will not exceed 1.00%. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Our firm bills on cash or cash equivalents, unless otherwise discussed with the client. Annualized fees are billed on a pro-rata basis quarterly in advance based on the market value of the account(s) being managed by Landmark on the last day of the previous quarter. Landmark, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc. and will be deducted from client account(s). Our firm does not make adjustments for routine deposits or withdrawals except in cases of significant deposits, new client’s relationships, or client terminations. In rare cases, our firm will agree to directly invoice. As part of this process, Clients understand the following: ADV Part 2A – Firm Brochure Page 5 Landmark Wealth Management  a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Advice on other matters—Landmark provides financial advice upon client request and/or as the situation requires. There is no additional fee charged for this type of service. Up to 20% of Landmark’s time is spent on these matters. Employer-Sponsored ERISA Plan Consulting: We charge a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee that we charge the client, is based on the scope and complexity of our engagement. Fees based on a percentage of managed Plan assets will not exceed 1.00%. Fees are prorated and charged either monthly or quarterly in advance based upon the market value of the Plan’s Account(s) on the last day of the previous month or quarter. The Adviser's fees will be debited directly from the Plan's Account(s) and the Client authorizes the custodian for the Plan assets, which may be upon instruction from the Plan's administrator, to deduct Adviser’s fees directly from the Plan's Account(s). Client shall have the responsibility to verify the accuracy of the fee calculation. Other Types of Fees & Expenses Landmark’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, check overnighting and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Landmark’s fee, and Landmark shall not receive any portion of these commissions, fees, and costs. Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. Termination & Refunds Either party may terminate the advisory agreement signed with our firm for Comprehensive Portfolio Management service in writing at any time. Upon notice of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance at the beginning of the quarter. ADV Part 2A – Firm Brochure Page 6 Landmark Wealth Management  Either party to an Employer-Sponsored ERISA Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Commissionable Securities Sales Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: • Individuals and High Net Worth Individuals; • Corporate Pension and Profit Sharing Plans; • Charitable Institutions, Foundations, Endowments, and Private Investment Funds • Corporations, Limited Liability Companies and/or Other Business Entities • State and/or Municipal Government Entities Our requirements for opening accounts or otherwise engaging us: • Our firm requires a minimum initial account balance of $500,000 for our Comprehensive Portfolio Management service. The minimum initial account balance requirement is negotiable, and does not apply to existing clients or clients who fall below this threshold during the course of management. • Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: ADV Part 2A – Firm Brochure Page 7 Landmark Wealth Management  Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. Landmark’s primary method of analysis is based upon Modern Portfolio Theory. Modern Portfolio Theory is a theory on how risk-averse investors can construct portfolios to optimize or maximize expected return based on a given level of market risk, emphasizing that risk is an inherent part of higher reward. Modern Portfolio Theory seeks to construct an optimal portfolio by considering the relationship between risk and return, especially as measured by such industry- recognized measures of risk such as alpha, beta, and R-squared. Landmark utilizes multiple sources of information and research, including but not limited to proprietary investment research firms, Dimensional Fund Advisors, Fidelity Management & Research (hereafter Fidelity) research services, Morningstar Direct, Style Advisor, Federal Reserve economic databases, financial newspapers and magazines, research materials prepared by others, corporate rating services, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategies We Use Through our process of fact gathering we come to understand each client’s current financial situation, federal & state tax bracket, investment knowledge, risk tolerance, investment objectives and time horizon for the invested assets and desired investment strategy. This information becomes the basis for the strategic asset allocation plan which we believe will best meet the client's stated long term, personal financial goals and objectives. We regularly communicate with our clients and review their situation and circumstances. Clients may contact us with changes at any time. The investment advice which we provide is based upon long-term investment strategies which incorporate the principles of Modern Portfolio Theory. In developing client portfolios, Landmark primarily uses mutual funds to invest in asset classes rather than purchasing individual securities. Primarily, Landmark recommends clients invest in a well-diversified set of mutual funds, incorporating large cap, mid cap, and small cap companies. These mutual funds may include both domestic and international securities. Landmark may also use some less traditional mutual funds, including but not limited to REIT funds, commodity funds, emerging market debt funds, high yield and multi-sector bond funds, and alternative strategy mutual funds. Client portfolios may also include exchange-traded funds (ETFs) or private equity and credit strategies. The utilization of several different asset classes as part of an investor’s portfolio is emphasized, as this has been shown to usually effect a reduction in portfolio volatility over long periods of time. We diversify our client’s assets among various asset classes and then among individual investments, following the guidelines agreed to by the client. Our investment approach is firmly rooted in the belief that markets are somewhat efficient, and that investors’ returns are determined principally by asset allocation decisions. We utilize no-load, low- cost, passive/active, tax-efficient, well diversified stock and bond mutual funds, Exchange traded funds, CD’s and other similar investments to develop globally diversified portfolios. If desired, client portfolios from time to time may also include some individual stock securities or individual bonds, options, warrants, rights, corporate, municipal or government bonds, and notes or bills. ADV Part 2A – Firm Brochure Page 8 Landmark Wealth Management  If advised to do so by our clients, our firm has the ability to purchase stocks, mutual funds, and/or other securities for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash, and allows us to purchase stock without selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; and (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Please Note: Investing in securities involves risk of loss that clients should be prepared to bear. While the financial markets and value of the securities your portfolio is invested in may increase and your account(s) could enjoy a gain, it is also possible that the financial markets and the value of the securities your portfolio is invested in may decrease and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the financial markets, that the risks are appropriately diversified in your investments, and that you ask us any questions you may have. Risk of Loss All investments have certain risks that are borne by the investor. Our investment approach is to educate clients of these risks and select only those risks that they can tolerate in exchange for potential return. Investors face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Business’ Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. ADV Part 2A – Firm Brochure Page 9 Landmark Wealth Management  • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Small Company Risk: Securities of small companies are often less liquid than those of large companies and this could make it difficult to sell a small company security at a desired time or price. As a result, small company stocks may fluctuate relatively more in price. In general, smaller capitalization companies are also more vulnerable than larger companies to adverse business or economic developments and they may have more limited resources. • Mutual Funds and Exchange Traded Funds (ETFs): An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. • Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. • Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. • Investing in market and private securities involves the risk of loss. Clients should be prepared to bear such loss. Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk ADV Part 2A – Firm Brochure Page 10 Landmark Wealth Management  conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Comprehensive Portfolio Management services, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Representatives of our firm are Certified Public Accountants for Landmark Tax Advisors, LLC. In such capacity, they also provide income tax preparation or accounting services. These services are independent of our financial planning and investment advisory services and are governed under a separate engagement agreement. Clients have the option of engaging our firm for tax preparation or accounting services, however, they are under no obligation to do so. Representatives of our firm are Certified Public Accountants. In such capacity, they may also provide income tax preparation or accounting services. These services are independent of our financial planning and investment advisory services and are governed under a separate engagement agreement. The fees for these services are billed hourly and are in addition to the client’s Landmark’s fees. The hourly rate varies depending on the complexity of the work conducted. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Landmark has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Landmark must acknowledge the terms of the Code of Ethics annually, or as amended. Landmark anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Landmark has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Landmark, its affiliates and/or clients, directly or indirectly, have a position of interest. Landmark’s employees and persons associated with Landmark are required to follow Landmark’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Landmark and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Landmark’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Landmark will not ADV Part 2A – Firm Brochure Page 11 Landmark Wealth Management  interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Landmark’s clients. It is also the express policy of LWM that no person employed by LWM may purchase or sell any individual security on the same day as a transaction(s) being implemented for an advisory account, preventing such Supervised Person from benefiting from transactions placed on behalf of advisory accounts. LWM may utilize batched orders to carry out this policy. In addition, the Code requires pre- clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Landmark and its clients. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with Landmark’s obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. Landmark will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Landmark’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting info@landmarkfirm.com on our company’s website. It is Landmark’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. Landmark will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Landmark is not registered as a broker-dealer nor has an affiliated broker-dealer, this disclosure is not applicable to Landmark. Item 12: Brokerage Practices Selecting a Brokerage Firm Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • Timeliness of execution ADV Part 2A – Firm Brochure Page 12 Landmark Wealth Management  • Timeliness and accuracy of trade confirmations • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation • Quality of services With this in consideration, our firm has an arrangement with Fidelity Institutional Wealth Services (“Fidelity”), a qualified custodian from whom our firm is independently owned and operated. Fidelity offers services to independent investment advisers which includes custody of securities, trade execution, clearance and settlement of transactions. Fidelity enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity does not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settle into the client’s custodial account. Transaction fees are negotiated with Fidelity and are generally discounted from customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Fidelity may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by Fidelity may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. Fidelity does not make client brokerage commissions generated by client transactions available for our firm’s use. The aforementioned research and brokerage services are used by our firm to manage accounts for which our firm has investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend Fidelity and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Our clients may pay a transaction fee or commission to Fidelity that is higher than another qualified broker dealer might charge to effect the same transaction where our firm determines in good faith ADV Part 2A – Firm Brochure Page 13 Landmark Wealth Management  that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. However, Fidelity eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Our firm may receive research products or services that fall within the “safe harbor” established by Section 28(e) of the Securities Exchange Act of 1934, in connection with its allocation of portfolio brokerage. Research products or services within the scope of Section 28(e) typically include research reports, market data, discussions with research analysts, meetings with corporate executives, software that provides for analysis of securities, and publications (excluding mass-marketed publications) as further described in Item 12 above. Client Brokerage Commissions Fidelity does not make client brokerage commissions generated by client transactions available for our firm’s use. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Our firm recommends the use of Fidelity. Each client will be required to establish their account(s) with Fidelity if not already done. Please note that not all advisers have this requirement. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such ADV Part 2A – Firm Brochure Page 14 Landmark Wealth Management  direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Client-Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans Periodic Reviews: Periodic Portfolio Reviews are undertaken by advisors of Landmark to ascertain if the values in any asset class have strayed beyond their target minimums or maximums and/or for purposes of meeting a client’s cash flow needs. Even if one or more asset classes fall outside their target minimums or maximums, we may determine not to rebalance the asset class for various reasons, such as avoidance of short-term capital gains, deferring long-term capital gains realization, minimization of transaction costs, or their view on whether the asset class is undervalued or overvalued relative to historic norms. Additional Portfolio Reviews are undertaken upon request by the client, such as when special cash needs arise or when additional cash or securities are added to the investment portfolio. We will respond to such requests within a reasonable period of time. We may also recommend sales and purchases to effect tax loss harvesting in addition to rebalancing actions. Review Triggers: Other conditions that may trigger a review are changes in the tax laws, new investment information and changes in a client's own situation, etc. ADV Part 2A – Firm Brochure Page 15 Landmark Wealth Management  Regular Reports: Landmark advisors make best efforts to meet with investment clients on an annual basis at a minimum. Quarterly Reports: Many investment clients receive quarterly updates from Landmark. The updates include account performance reports, and investment newsletter. Monthly Statements are additionally sent to the client directly from the independent, account custodian (specifically, Fidelity). These statements reflect the assets in the custodian’s custody, together with confirmations of each transaction executed in the account(s) if desired by the client. Clients may elect to receive these statements by e-mail rather than U.S. mail. Clients may also directly access account information at the custodian with which the accounts are held online (specifically, Fidelity) each and every business day via their secure website at www.fidelity.com. Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom Landmark provides investment advisory services will also receive a report from Landmark that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance on a quarterly basis. Clients should compare the account statements they receive from their custodian with those they receive from Landmark. Employer-Sponsored ERISA Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. Item 14: Client Referrals & Other Compensation Fidelity Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional arrangements to disclose. Referral Fees Landmark typically receives non-paid referrals from current clients, estate planning attorneys, and accountants. LWM compensates employees of Chiampou, Travis, Besaw & Kershner LLP (“CTBK”), an affiliate of LWM, for referrals. Clients who are referred will receive a disclosure acknowledgement form which discloses the fee-paying arrangements between LWM and the applicable employee of CTBK. While CTBK refers Clients to LWM, Clients are under no obligation to receive services from our firm. In order to mitigate this conflict of interest, our firm will act in the Client’s best interest. ADV Part 2A – Firm Brochure Page 16 Landmark Wealth Management  In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Item 15: Custody Representatives of our firm maintain full power of attorney over certain client accounts as well as access to client’s outside accounts through a record of their login information. As such, our firm is deemed to have custody. The client funds and securities of which our firm has custody are verified by actual examination at least once during each calendar year by an independent public accountant (“IPA”) registered with the Public Company Accounting Oversight Board (“PCAOB”), at a time that is chosen by the accountant without prior notice or announcement to our firm and that is irregular from year to year. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguarding procedures in conjunction with our custodian, Fidelity: • Fidelity’s forms, used to establish a standing letter of authorization, include the name and account number on the receiving account and must be signed by the client. • Fidelity’s SLOA forms currently require client’s signature. • Fidelity performs verification on all SLOA forms and sends a transfer of notice to the client promptly following the transaction. • Clients always have the ability to terminate (or amend) a SLOA in writing. • Our firm has no authority, or ability, to amend the third party designated on a standing instruction. • Our firm maintains records showing the third party is not a related party of our firm or located at our firm. • Fidelity notifies the client in writing when a new standing instruction is set up. Clients also receive an annual mailing reconfirming the existence of the standing instruction Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. However, Landmark usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. In all cases, however, any discretion given to ADV Part 2A – Firm Brochure Page 17 Landmark Wealth Management  our firm is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Landmark observes the investment policies, limitations and restrictions of the clients for which it advises. For registered investment companies, Landmark’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Investment guidelines and restrictions must be provided to Landmark in writing. Item 17: Voting Client Securities As a matter of firm policy and practice, Landmark does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Landmark may provide advice to clients regarding the clients’ voting of proxies. Item 18: Financial Information Inclusion of a Balance Sheet Our firm does not require nor is prepayment solicited for more than $1,200 in fees per client, 6 months or more in advance. Therefore our firm has not included a balance sheet for our most recent fiscal year. Disclosure of Financial Condition Our firm has nothing to disclose in this regard. Bankruptcy Petition Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 18 Landmark Wealth Management