Overview

Assets Under Management: $653 million
Headquarters: LAKE MARY, FL
High-Net-Worth Clients: 175
Average Client Assets: $1.9 million

Frequently Asked Questions

COLLABORATIVE WEALTH is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #142106), COLLABORATIVE WEALTH is subject to fiduciary duty under federal law.

COLLABORATIVE WEALTH is headquartered in LAKE MARY, FL.

COLLABORATIVE WEALTH serves 175 high-net-worth clients according to their SEC filing dated March 18, 2026. View client details ↓

According to their SEC Form ADV, COLLABORATIVE WEALTH offers financial planning, portfolio management for individuals, and selection of other advisors. View all service details ↓

COLLABORATIVE WEALTH manages $653 million in client assets according to their SEC filing dated March 18, 2026.

According to their SEC Form ADV, COLLABORATIVE WEALTH serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Clients

Number of High-Net-Worth Clients: 175
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 51.60%
Average Client Assets: $1.9 million
Total Client Accounts: 1,948
Discretionary Accounts: 1,898
Non-Discretionary Accounts: 50

Regulatory Filings

CRD Number: 142106
Filing ID: 2038778
Last Filing Date: 2026-03-18 12:30:51

Form ADV Documents

Primary Brochure: COLLABORATIVE WEALTH ADV PART 2A (2026-03-18)

View Document Text
CW ADV Part 2A—3 Investment Adviser Brochure Part 2A March 2026 Collaborative Wealth Management, Inc. 972 International Parkway Lake Mary, FL 32746 Phone: (407) 792-3336 www.collaborativewealth.com Item 1 – Cover Page & Introduction This brochure provides information about the qualifications and business practices of Collaborative Wealth Management, Inc. If you have any questions about the contents of this brochure, please contact us at (407) 792-3336. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Additional information about Collaborative Wealth Management, Inc. also is available on the SEC’s website at www.adiserinfo.sec.gov. The use of the term registered investment adviser does not imply a certain level of skill or training. Item 2 – Material Changes There have been no material changes to this brochure since the last annual amendment was submitted. Investment Advisory and Financial Planning Services offered through CollaborativeWEALTH®—An SEC Registered Investment Advisor Securities offered through LPL Financial - Member FINRA/SIPC and separate business entity. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—4 Item 3 - Table of Contents Item 1 – Cover Page & Introduction .................................................................................................................................................3 Item 2 – Material Changes ...............................................................................................................................................................3 Item 3 - Table of Contents ................................................................................................................................................................4 Item 4 – Advisory Business ...............................................................................................................................................................5 Item 5 – Fees and Compensation ....................................................................................................................................................7 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................................................9 Item 7 – Types of Clients ..................................................................................................................................................................9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..........................................................................................10 Item 8.A – Frequent Trading of Securities .........................................................................................................................12 Item 8.B – Material Risks of Particular Securities................................................................................................................12 Partnership interests ......................................................................................................................................................................12 Private Real Estate Partnership Interests ........................................................................................................................................13 Item 9 – Disciplinary Information ....................................................................................................................................................13 Item 9.A – Criminal or Civil Actions ...................................................................................................................................13 Item 9.B – Administrative Proceedings ..............................................................................................................................13 Item 9.C – Self-Regulatory Organization (“SRO”) Proceedings .........................................................................................13 Item 10 – Other Financial Industry Activities and Affiliations .........................................................................................................14 Item 10.A – Broker-Dealer Registration .............................................................................................................................14 Item 10.B – Futures Commission Merchant/Commodities ................................................................................................14 Item 10.C – Relationships with Related Persons ................................................................................................................14 Item 10.D – Relationships with Other Advisers ..................................................................................................................15 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................15 Item 11.A – Code of Ethics ................................................................................................................................................15 Item 11.B – Participation or Interest in Client Transactions ...............................................................................................15 Item 11.C – Personal Trading by Associated Persons ........................................................................................................17 Item 11.D – Conflicts of Interest with Personal Trading by Associated Persons ................................................................17 Item 12 – Brokerage Practices ........................................................................................................................................................17 Item 12.A – Factors in Selecting or Recommending Broker-Dealers .................................................................................17 Item 12.A1 – Research and Other Soft Dollar Benefits ......................................................................................................18 Item 12.A2 – Brokerage for Client Referrals ......................................................................................................................18 Item 12.A3 – Directed Brokerage ......................................................................................................................................18 Item 12.B – Trade Aggregation..........................................................................................................................................20 Item 13 – Review of Accounts ............................................................................................................................................20 Item 14 – Client Referrals and Other Compensation .....................................................................................................................20 Item 15 – Custody .........................................................................................................................................................................21 Item 16 – Investment Discretion .....................................................................................................................................................21 Item 17 – Voting Client Securities ..................................................................................................................................................21 Item 18 – Financial Information ......................................................................................................................................................21 An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—5 Item 4 – Advisory Business Collaborative Wealth Management, Inc. (“the Adviser”) has been in business since 2007. Chad Justice is the principal owner. Planning & Consulting Services The Adviser provides planning and consulting services consistent with a client’s goals, objectives, time horizon, tax status, and risk tolerance. The Adviser works with a client to develop a plan to address their tax concerns, life insurance, retirement, investment, and budgetary needs. This involves gathering enough data to perform an analysis of a client’s cash flow, and cash management needs; in addition to the investment, tax, retirement income, estate/legacy planning requirements. Wealth Planning Services are offered to clients with the most comprehensive and complex planning needs, often multi- generational. Their holdings will often consist of more diverse assets with some alternative and illiquid investments. These may include but are not limited to real estate, family businesses, employer granted stock options, and private investments. Wealth planning clients typically have a net worth starting at $3,000,000. Comprehensive Planning Services are offered to clients with comprehensive but less complex planning needs. Their holdings will primarily consist of conventional assets. Limited Planning Services are offered to a client that needs or wants a specialized plan, which is limited to specific areas as agreed upon by the client and Adviser. Consulting Services are offered to clients that don’t want or need a formal plan and the scope and areas addressed are as requested by the client. Planning Conflicts of Interest A conflict of interest is created whenever the Adviser or an associated person of the Adviser recommends products or services to a client for which the Adviser or an associated person receives compensation. However, planning clients are under no obligation to act upon any recommendations of the Adviser or to execute any transactions through the Adviser or an associated person if they decide to follow the recommendations. Investment Management Services The Adviser provides investment management services to its clients on a discretionary and non-discretionary basis. When the Adviser manages client assets on a discretionary basis, the Adviser executes securities transactions for clients without having to obtain specific client consent prior to each transaction. Discretionary authority is limited to investments within a client’s managed accounts. When the Adviser manages client assets on a non-discretionary basis, the Adviser notifies the client and obtains permission prior to the sale or purchase of each security within the managed account. Clients may decide not to invest in certain securities or types of securities and may refuse to approve securities transactions. The Adviser provides investment management services that include, among other things, advice regarding asset allocation and the selection of investments, portfolio design, investment plan implementation and ongoing investment monitoring. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—6 The Adviser relies on the stated objectives of the client and considers the client’s risk profile and financial status prior to making any recommendations. Advisory Referral Services The Adviser maintains referral agreements with third-party asset managers (other independent investment advisers). The Adviser gathers information about a client’s financial and tax status and investment objectives to determine the client’s risk profile. Based on this analysis the Adviser assists the client in allocating assets among various third-party asset management programs. The Adviser receives compensation for introducing clients to these third-party asset managers and for certain ongoing services provided to clients. Whenever this occurs, a conflict will exist because the Adviser will have an incentive to refer a client to these third-party asset managers. All third-party asset managers to whom the Adviser refers a client are licensed as investment advisers by their resident states and any applicable jurisdictions or by the Securities and Exchange Commission. Assets Under Management As of December 31, 2025, the Adviser manages $593,995,275 in client assets on a discretionary basis and $59,287,020 on a non-discretionary basis for a total of $653,282,295. Private Fund Services The Adviser provides the following services to Collaborative Dynamic REIT, LP (the “Fund”), a private real estate limited partnership formed to acquire and manage income-producing multifamily and mixed-use properties: 1. General Partner / Sponsor Role — CollaborativeWEALTH® is one of the Primary General Partners of the Fund, serving in the capacity of Sponsor within the General Partnership. In this role, the Adviser assists in strategic direction, investor relations, acquisition sourcing, and overall fund governance alongside other General Partner entities. 2. Fund Adviser Role — CollaborativeWEALTH also acts as the Fund Advisor to the Collaborative Dynamic REIT, providing ongoing portfolio management, financial oversight, underwriting support, and reporting functions under a separate Fund Advisory Agreement Custody The Adviser will not maintain physical possession of any currency of the Fund. The Funds will enter into a custodial agreement a qualified custodian. Pursuant to each such custodial agreement, the Adviser will be restricted from making payments from any account maintained by the custodian on behalf of the Fund unless certain requirements are met. The Adviser will acknowledge and agree in writing to the terms of each Custodial Agreement. In addition, the Fund will be audited at least annually and will distribute audited financial statements within 120 days of the end of each fiscal year. Statements will be prepared in accordance with generally accepted accounting principles. Account statements will be distributed to all limited partners, other beneficial owners, or their independent representatives. The Adviser will provide clients with a written notice that contains the qualified custodian’s name, address, and the manner in which the currency is maintained promptly upon opening an account and following any changes to this information. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—7 Generally, withdrawals will be permitted with 30 days written notice and will be effective the last business day of any fiscal quarter. The Adviser may, at its sole discretion, waive or modify the conditions of withdrawal or suspend the Limited Partners’ withdrawal rights when it believes it is in the best interest of the Partnership. The Adviser may voluntarily withdraw all or any portion of its Capital Account at any time without giving notice to the Limited Partners. Item 5 – Fees and Compensation Planning & Consulting Fees The Adviser charges clients an hourly fee for consulting services. Clients are billed at the rate of $200 - $400 an hour. Clients are charged a two-hour minimum for hourly services, which is due and payable upon signing an agreement. Additional fees are payable as services that exceed two hours are performed or when services are completed. This is determined by the scope of the project. The Adviser will regularly invoice clients for fees that are due and payable. Fees for wealth planning services range from $1,000 to $10,000 dependent on the range and complexity of the services provided. The Adviser provides planning clients with an estimate of the amount of time a plan will take, and upon signing an agreement the applicable fees are due. The Adviser anticipates that the plan produced will be delivered within six months or sooner of the date of the agreement. The Adviser considers fees for planning or a consulting project to be earned as progress is realized toward creation of the plan or completion of the service. Clients will have a period of five (5) business days from the date of signing an agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the agreement prior to delivery of the plan with written notice. Upon termination, the Adviser will prorate fees to the date of termination and will refund any unearned portion of the fee. Investment Management Fees The Adviser is compensated for investment management services based on a client’s assets under management. The maximum advisory fee is 2.50% and fees will typically range from 0.25% to 2.50% and are negotiable based on the amount of assets being managed, family relationships, professionals servicing the accounts, and range of services being provided. Fees are paid monthly or quarterly in arrears or advance. Fees are due on the first day of the calendar month or quarter, and are based on the account’s asset value as of the last business day of the prior calendar month or quarter. Fees are prorated for accounts opened during the month or quarter. The Adviser deducts fees directly from client accounts. The compensation an associated person receives varies based on the management, implementation, trading, and rebalancing responsibilities among other factors. A conflict will exist because the associated person will have an incentive to recommend an investment strategy and alter client fees based on the compensation to be received rather than on the client’s needs. The Adviser monitors trading practices and regularly reviews client securities transactions in order to protect clients against these conflicts of interest. Annualized Fees The account custodian may charge fees, which are in addition to and separate from advisory fees. Accounts may incur An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—8 transaction costs, retirement plan administration fees, mutual fund annual expenses and other fees. Clients should note that fees for comparable services vary and lower or higher fees may be charged by different providers for similar services. Clients will have a period of five (5) business days from the date of signing an advisory agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the advisory agreement with 30 days written notice. Upon termination, fees will be prorated to the date of termination and the unearned portion will be refunded. Advisory Referral Fees The compensation the Adviser receives from Third-party managers is disclosed in separate disclosure documents. Compensation is typically equal to a percentage of the investment management fee charged by the third-party asset manager or a fixed fee. The disclosure document provided by the Adviser will clearly state the fees payable to the Adviser and whether the payment of the Adviser’s fee will increase the total fees the client must pay to the third-party manager. Since the compensation the Adviser receives may differ depending on the agreement with each third-party manager, the Adviser has an incentive to recommend one third-party manager over another. Fees paid by clients to independent third-party managers are established and payable in accordance with the ADV Part 2A brochure or other equivalent disclosure document of each independent third-party manager to whom the Adviser refers its clients and may or may not be negotiable. The facts and circumstances of negotiability are contained in the disclosure documents of each third-party manager. Clients who are referred to third-party investment managers will receive a Part 2A brochure providing details of services rendered and fees to be charged. Clients will receive copies of the Adviser’s and third-party investment managers’ Parts 2A at the time of the referral. In addition, if the Adviser recommends a wrap fee program, the client will also receive a wrap fee brochure provided by the sponsor of the program. The Adviser will provide to each client all appropriate disclosure statements, including disclosure of solicitation fees paid to the Adviser and its advisory associates. Private Fund Fees The Adviser charges the Fund a 1% annual Fund Advisor fee payable quarterly in advance. The Fund Advisor fee is based on calculated on the total fund asset value of the Fund. Limited Partners should note that lower or higher fees for comparable services may be available from other sources. The Fund will mortgage the properties obtained with Fund asset. The value of the liquid assets will be NAV of funds as starting point netting cashflows. The Adviser fees are payable from these assets. 8% annual simple accrued, quartlery distribution; it is a hurdle rate with 60%/40% split; In addition, the General Partners collectively participate in the Fund’s profit distribution structure, which provides: • An 8% preferred annual return distributed quarterly to Limited Partners, and • After the 8% return, a 60/40 profit split (60% to investors / 40% to the General Partners) as set forth in the Fund’s Limited Partnership Agreement and Private Placement Memorandum. The Fund, rather than the Adviser, bears all other organizational and operating expenses, including accounting, audit, legal, An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—9 property management, custody, and compliance system costs. The Adviser may waive or reduce its fees at its discretion. Receipt of Additional Compensation Investment adviser representatives receive brokerage or mutual fund trail commissions from the sale of securities, in their capacity as registered persons through LPL Financial, a registered broker-dealer, member of the Financial Industry Regulatory Authority, Inc. (“FINRA”), the Securities Investor Protection Corporation (“SIPC”), and a registered investment adviser. The practice presents a conflict of interest whenever this occurs because it provides an incentive to recommend investment products based on the compensation to be received rather than on the client’s needs. The Adviser monitors trading practices and regularly reviews client securities transactions in order to protect clients against this conflict of interest. Clients are advised that they are not required to purchase or sell securities through the investment adviser representatives acting in the capacity of registered persons through LPL Financial and may purchase the same securities or products from an unaffiliated broker-dealer. Item 6 – Performance-Based Fees and Side-By-Side Management The Adviser does not charge or receive, directly or indirectly, any performance-based fees. Item 7 – Types of Clients The Adviser provides advisory services to: • Individuals—Trusts, estates, 401(k) plans and IRAs of a household count as one individual. • High net worth individuals—An individual who is a “qualified client” under rule 205-3 of the Advisers Act of 1940 or is a “qualified purchaser”. • Pension and profit sharing plans • Foundations and charities • Business entities including sole proprietorships Account Minimums The Adviser provides services to individual and institutional investors through separately managed accounts. The Adviser has an established household minimum of $100,000 but certain exceptions may be provided by the Investment Advisor Representative. The Adviser provides services a private real estate fund, Collaborative Dynamic REIT, LP. The minimum investment in the Fund is $10,000 payable upon subscription, unless waived by the General Partner. The Fund is offered privately to accredited investors and is not registered under the Investment Company Act of 1940 or the Securities Act of 1933. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Method of Analysis The Adviser’s main sources of financial information are prospectuses, research materials prepared by others, corporate rating services, annual reports and company press releases. The Adviser may utilize official statements, continuing disclosures, and other information available through the MSRB’s Electronic Municipal Market Access system (EMMA) when analyzing municipal securities. Fundamental Analysis The Adviser uses fundamental analysis. Fundamental analysis involves predicting the price movement of an asset based on measures that are related to the underlying business. This method is used to judge the performance of management. (Although it is important to note that things outside of management’s control can impact performance.) Comparing the margins of the company and its relative performance to that of two or three of its peers will give an idea of whether the performance is potentially outside of management’s control. Technical Analysis Technical analysis involves predicting the price movement of an asset based on factors unrelated to the underlying business (price, volume, and open interest, among other factors, to detect and interpret patterns to predict the movement of individual securities, an industry or the broad market). Charting is a sub-sector of technical analysis and also focuses on predicting price movements of assets based on patterns that are formed by the price movements. The Adviser may recommend one or a combination of assets and investment strategies as follows: Mutual & Exchange Traded Funds The Adviser recommends index and actively managed, mutual and exchange traded funds when designing client portfolios. The Adviser considers index funds based on how closely the funds’ characteristics mirror the indices they track. The Adviser analyzes actively managed funds by comparing funds that target the same market sector and have the same investment style using prospectuses and other sources of information. • 5 Yr Return (Typically over a five year period, the economy experiences a complete cycle. However, the way in which a manager operates in various economic environments reflects the manager’s ability to make adjustments or stay the course.) The Adviser reviews the following prior to recommending funds to clients: • Rank in Category over various periods • Return Rating • Risk Rating • YTD Return (Outsize swings in comparisons to peers can be a sign of risky practices such as placing large bets on certain sectors of the market.) • 1 Yr Return • 3 Yr Return • Loads • Total Expense Ratios • Net Assets • Turnover • Median Market Capitalization An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—11 The Adviser also takes the manager or management team tenure under consideration to determine who was responsible for generating the performance numbers. Public Equity A corporation may issue stock to the general public after registration. Stock represents an ownership interest in a company. The Adviser uses valuation measures and financial information, evaluates the regulatory environment, analyzes products or services that are available or under development and the factors that can impact them to predict the price movement of a company’s stock. The Adviser also makes comparisons to the company’s peers and to the broader market. Corporate Debt & Municipal Securities The Adviser generally analyzes the current yield, yield to maturity, yield to call, call and default risks, and interest coverage. Debt is issued by federal, state and foreign governments and corporations to finance their operations. Debt represents their promise to repay the borrowed amount with interest according to the terms and conditions of the debt instrument. Debt obligations offer limited participation in the upside of a business. In exchange holders receive interest and a position that is generally senior to equity in a bankruptcy. Private Securities Some securities are acquired in unregistered, private sales from the issuer or from an affiliate of the issuer typically through Regulation D or other private placement offerings or employee stock benefit plans as compensation for professional services, or in exchange for providing start-up capital. The Adviser reviews the applicable offering documents. The Adviser may analyze: • Allocation of profits, losses and taxes • Custody of securities and cash • Lock-up period or any limitations towards the redemption of interest • Exemptions from registration and types of investors • Investment strategy, objective and the use of leverage • Conflicts and potential conflicts of interest • Performance information Gross or net and how calculated • Valuation particularly of illiquid securities and hard assets • Management structure • Backgrounds of management personnel • Management and director compensation • Financial statements • Regulatory environment • Competitors • Products and services differentiators • Threats to a company’s ability to execute its business plan In the case of pooled investments the Adviser may also analyze: Investment Strategies The Adviser works with each client to design an appropriate investment strategy based on their financial and tax status, risk tolerance and investment objectives. The Adviser usually recommends investment strategies for the long-term, but may occasionally recommend short-term investment and hedging strategies. The Adviser generally recommends a target asset mix with periodic rebalancing. Risk of Loss Clients are advised that investing in securities involves the risk of loss of the entire principal amount invested including any gains. Clients should not invest unless they are able to bear this risk. Any of the above investment strategies may lead to a loss on investments. Even hedging strategies may fail if markets move against the hedged investments. In addition, investing carries with it An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—12 opportunity risk. It is impossible to accurately predict the sectors of the market or asset classes that will have more favorable returns for a given period. Item 8.A – Frequent Trading of Securities The Adviser is not involved in the frequent trading of securities. Item 8.B – Material Risks of Particular Securities The Adviser doesn’t recommend any type of security that involves significant or unusual risks except for the following which may present material risks to investors: Municipal securities Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project (like a toll road or parking garage) for which the securities were issued. The latter type of securities could quickly lose value or even become virtually worthless if the expected project revenue does not meet expectations. Real Estate Investment Trusts (“REITs”) An REIT is a tax designation for a corporation investing in real estate that reduces or eliminates corporate income taxes. A REIT is a corporation, business trust, or association managed by one or more trustees or directors who pool the resources of individual investors for passive investment in real estate. In return, REITs are required to distribute 90% of their income to investors so they have the potential to be good for investors that seek a steady income from their investments. REITs typically receive special tax considerations and offer investors high yields. Individuals can invest by purchasing shares directly on an open exchange or by investing in a mutual fund that specializes in public real estate; so REITs can be highly liquid. REIT investing is not without risk. Real estate construction projects have a long time-line which can result overbuilding of types of properties owned by REITs. Higher interest rates may increase borrowing costs for construction, financing of the purchase of REIT owned properties and operating costs for existing REIT owned business properties. Any of these events may cause a substantial decline in the value of REIT investments. Clients should consult the Adviser if they have questions concerning the basic characteristics of these or other investment products or about the risks and potential rewards of investing. Partnership interests Investment partnerships are typically composed of a limited number of partners and at least one general partner. The liability of the limited partners is restricted to the amount of each partner’s investment. The liability of the general partner is theoretically unlimited and extends beyond the amount invested to personal or corporate assets. Because of this increased exposure, the general partner manages the partnership, makes the investment decisions and receives management fees and a higher portion of the return on partnership investments. Because of the nature of the limited partnership structure partnership investments should be considered long term and illiquid. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—13 There are typically no secondary markets in which these types of investments trade. Therefore, if the value of the underlying assets should decline, the value of partnership shares would also decline and unlike other types of securities, an investor may find it hard to quickly sell shares in an illiquid market. Private Real Estate Partnership Interests Investments in the Fund are illiquid, long-term, and speculative. There is no public market for partnership interests. Transfers or redemptions are limited and subject to General Partner approval. Risks include, but are not limited to: • Real estate market and interest-rate volatility; • Property-level operational and financing risk; • Leverage exposure, which may amplify losses; • Reliance on third-party managers and contractors; • Limited liquidity and valuation uncertainty; • Cybersecurity and digital custody risks associated with blockchain-based reporting; and • Potential loss of all or part of invested capital. The Fund’s target investment horizon is ten years, and participation is limited to investors able to bear these risks. Item 9 – Disciplinary Information The Adviser does not have any disciplinary information to disclose. Item 9.A – Criminal or Civil Actions Neither the Adviser nor any management person has been found guilty of or has any criminal or civil actions pending in a domestic, foreign or military court. Item 9.B – Administrative Proceedings Neither the Adviser nor any management person has any administrative proceedings pending before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. Item 9.C – Self-Regulatory Organization (“SRO”) Proceedings Neither the Adviser nor any management person has been found by any SRO to have caused an investment-related business to lose its authorization to do business, or to have been involved in a violation of the SRO’s rules, or been barred or suspended from membership or from association with other members, or expelled from membership, otherwise significantly limited from investment-related activities, or fined. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—14 Item 10 – Other Financial Industry Activities and Affiliations Item 10.A – Broker-Dealer Registration Certain associated persons of the Adviser are registered persons through LPL Financial. In these capacities, associated persons recommend securities or other products and receive normal transaction fees, commissions or other compensation. A conflict of interest is created whenever associated persons of the Adviser recommend products or services to a client for which the associated person receives compensation. Clients are under no obligation to act upon any recommendations of associated persons or affect any transactions through associated persons if they decide to follow their recommendations. Item 10.B – Futures Commission Merchant/Commodities Neither the Adviser nor any management person is a commodity broker/futures commission merchant, a commodity pool operator, commodity trading advisor or an associated person for the foregoing entities; nor do they have any registration applications pending. Item 10.C – Relationships with Related Persons In addition, to being registered persons of LPL Financial, certain associated persons are insurance agents appointed with various insurance companies. Associated persons are owners and officers of a private company. In these capacities associated persons of the Adviser recommend securities, insurance, advisory services, other products, or privacy company investments, and receive commissions, other compensation or benefit if products are purchased through any firms with which any associated persons are affiliated, control, or own. A conflict of interest is created whenever associated persons of the Adviser recommend products, services or securities to a client for which the associated person receives compensation or other benefits. However, clients are under no obligation to act upon any of their recommendations or execute any transactions through them if they decide to follow their recommendations. SmartAsset is a registered investment adviser. SmartAsset isn’t a current client or investor of the Adviser. SmartAsset refers clients to an associated person in exchange for a referral fee. The referral fee is paid even if the referred person doesn’t become a client of the Adviser. This doesn’t create a conflict of interest for the Adviser. Affiliated General Partner and Fund Advisor The Adviser (and its principal, Chad Justice) holds ownership and management interests in Collaborative Dynamic REIT GP, LLC, the General Partner of the Fund. Through this relationship, the Adviser serves both as a Sponsor-level General Partner and as the Fund Advisor to the same entity. This dual role creates potential conflicts of interest, as the Adviser participates in management fees and profit distributions from the Fund while also providing advisory services. To address these conflicts: • All investors receive a Private Placement Memorandum, Limited Partnership Agreement, and Fund Advisory Agreement An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—15 clearly outlining roles, fees, and conflicts; • The Fund undergoes annual independent PCAOB-audited financial statements distributed within 120 days of fiscal year-end; • All assets are held by qualified custodians under dual-control procedures; and The Adviser adheres to fiduciary obligations under the Investment Advisers Act of 1940, including conflict monitoring, documentation, and compliance reviews. Item 10.D – Relationships with Other Advisers Associated persons of the Adviser may invest personally in the Fund on the same terms as other investors. The Adviser’s Code of Ethics requires pre-clearance, ongoing reporting, and supervisory review to ensure equitable treatment and to prevent misuse of confidential information. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11.A – Code of Ethics The Adviser has adopted a Code of Ethics that sets forth standards of conduct expected of advisory personnel and to address conflicts that arise from personal trading by advisory personnel. Advisory personnel are obligated to adhere to the Code of Ethics, and applicable securities and other laws. The Code covers a range of topics that may include: general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code, review and enforcement processes, amendments to Form ADV and supervisory procedures. The Adviser will provide a copy of the Code to any client or prospective client upon request. Item 11.B – Participation or Interest in Client Transactions Principal Trading Associated persons are owners and officers of a private company. Associated persons acting as principals, may buy shares in the private company from or sells shares to clients. Associated persons may recommend clients invest in the private company. A conflict of interest is created whenever an associated person of the Adviser recommends a client invest in an entity owned and controlled by an associated person. An associated person benefits from client investments and has an incentive to recommend clients invest. The associated person is acting in a manner that might conflict with the duty of loyalty and care. Personal Trading of Associates Affiliated with a Brokerage Firm In their capacity as registered persons through LPL Financial, associated persons of the Adviser may receive payments from certain mutual funds distributed pursuant to a 12b-1 distribution plan, or other such plans, as compensation for administrative services, representing a separate financial interest. A conflict of interest is created whenever associated persons of the Adviser recommend products or services to a client for which the associated person receives compensation. In all cases, recommendations are made in the best interests of the client. The Adviser does not permit insider trading and has implemented procedures to ensure that its policy regarding insider trading is being observed by associated persons. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—16 Additional Conflicts The Adviser (or associated persons of the Adviser) receive the following additional compensation: • Securities Sales Commissions • Commissions on the sale of insurance or other products • Marketing-support payments from a mutual fund’s investment adviser • Payments from a broker-dealer to help defray costs of dually registered persons transitioning The Adviser (or associated persons or the Adviser) receive payments related to a relationship with a custodian in the following circumstances: • Payments from a custodian based on net new assets maintained at that custodian • Limitations on share class availability based on custodian agreements with investment companies • An associated person secured loans from LPL for the purpose of acquiring investment advisory business. In addition, the loans have a lien clause in the agreement where it grants LPL an interest in non-qualified brokerage and investment advisory accounts where the associated person has an interest. This financial obligation creates a conflict of interest. The Adviser is subject to the following circumstances related to investment limitations imposed by the Adviser or third parties: • Limitations on share class availability due to Adviser business or service providers used • Limitations imposed by a fund, clearing broker or custodian (i.e. platform limits certain share classes, fund or platform imposes minimum investment requirements) The Adviser considers the following factors when making recommendations to clients regarding share classes with different fee structures: • Whether the Adviser would bear the cost of a transaction fee versus no cost to the Adviser • A share class with a 12b-1 fee but no transaction fee and a share class of the same fund with a transaction fee but no 12b-1 fee • The availability of different share classes of the same fund that represent the same underlying investments but generate different compensation • The impact on investment return over time of different sales charges, transaction fees and ongoing fees Any of the above situations will result in a conflict of interest by creating an incentive for the adviser or associated persons to recommend a particular investment product or service. The Adviser will compare investment product selections to ensure that expense ratios are a consideration and eventual selections are in the best interest of clients. In regards to the selection of certain share classes of investments with higher expense ratios, documentation will be required to demonstrate the benefit to the client over less expensive options. Should the Adviser find instances of inappropriate selections, the additional expense incurred will be rebated to the client. The Adviser offsets or rebates any client costs when limitations are imposed regarding the availability of certain share classes based on custodian agreements with investment companies or service provider limitations. Additionally, the Adviser informs clients that they are under no obligation to act upon any recommendations or execute any transactions and may elect to do business with other advisers or broker-dealers at any time. Agency-Cross Action Transactions Neither the Adviser nor any associated person recommends that clients buy from or sell securities to other clients. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—17 Item 11.C – Personal Trading by Associated Persons The Adviser recommends that clients invest in various types of assets. The Adviser and its associated persons may invest in the same types of assets. Permitted investments for associated persons are all asset classes. See Item 11.D for conflicts of interest. Item 11.D – Conflicts of Interest with Personal Trading by Associated Persons Associated persons may own an interest in or buy or sell for their own accounts the same securities, which may be recommended to advisory clients. Associated persons seek to ensure that they do not personally benefit from the short-term market effects of their recommendations to clients and their personal transactions are regularly monitored. Associated persons are aware of the rules regarding material non-public information and insider trading. Associated persons may also buy or sell a specific security for their own account based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Associated persons are owners and officers of a private company and may offer clients an opportunity to invest in the company. Each offeree will be given with a copy of the offering documents, which disclose the relationship between the associated persons, and the private company. When this occurs, it creates conflicts of interest because an associated person benefits and has an incentive to recommend a client invests. An associated person is acting in a manner that might conflict with the duty of loyalty and care. Clients are under no obligation to act upon any recommendations of an associated person. Item 12 – Brokerage Practices Item 12.A – Factors in Selecting or Recommending Broker-Dealers Associated persons in their capacity as registered persons through LPL Financial may suggest that clients implement recommendations through LPL Financial. If the client so elects, associated persons would receive normal and customary commissions in their capacities as registered persons of LPL Financial presenting associated persons with a conflict of interest. Additionally, Transition Assistance payments and other benefits are provided to associated persons of the Adviser in their capacity as registered representatives of LPL Financial. The receipt of Transition Assistance creates a conflict of interest in that an associated person has a financial incentive to recommend that a client open and maintain an account with the IAR and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are not available through LPL, in order to receive the Transition Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. Associated persons attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by any particular associated person. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to an associated person, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the associated person. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—18 Associated persons receive indirect compensation from LPL Financial to include paid conference admission, airfare, lodging and transportation costs. The Adviser attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL Financial’s services based on the benefits that such services provide to our clients, rather than the Transition Assistance earned by any particular Dually Registered Person. The Adviser recommends other broker-dealers. The Adviser’s recommendation are subject to various considerations, client holdings, efficiency of execution and error resolution, block trading and block positioning capabilities, special execution capabilities, willingness to execute related or unrelated difficult transactions, on-line access to computerized data regarding client accounts, the competitiveness of commission rates in comparison to other brokers satisfying the Adviser’s other selection criteria and other matters involved in the receipt of brokerage services when recommending or requiring that clients maintain accounts with LPL Financial. However, clients should be aware of this conflict and take it into consideration in making a decision whether to custody their assets in a brokerage account at LPL Financial. Clients may pay commissions or fees that are higher or lower than those that may be obtained elsewhere for similar services. Clients are advised that they are under no obligation to implement recommendations through the associated persons or use LPL Financial as their custodian. The Adviser does not maintain custody of Fund assets. All Fund and property-level accounts are maintained with qualified custodians and are subject to annual audit verification. The Fund operates under a Hybrid Treasury Model, integrating: • Traditional cash reserves (FDIC-insured banking and U.S. Treasury money market holdings); • A Bitcoin Treasury Reserve held through institutional-grade custody with multi-signature protection and proof-of-reserve attestations; and • Hybrid credit facilities secured by a blend of real estate equity and digital assets. Custodial oversight is performed by a Treasury and Custody Committee consisting of representatives from the General Partner, an independent fund administrator, and the external auditor. The Fund qualifies for the Annual Audit Exception under Rule 206(4)-2, with audited statements distributed annually. Item 12.A1 – Research and Other Soft Dollar Benefits The Adviser does not receive soft dollars generated by the securities transactions of its clients. The term “soft dollars” refers to funds which are generated by client trades being used by the Adviser to purchase products or services (such as research and enhanced brokerage services) from or through the broker-dealers whom the Adviser engages to execute securities transactions. Item 12.A2 – Brokerage for Client Referrals The Adviser does not refer clients to particular broker-dealers in exchange for client referrals from those broker-dealers. Item 12.A3 – Directed Brokerage The Adviser does not recommend or require that clients direct their brokerage business to any particular broker-dealer. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—19 Benefits of Using LPL as Custodian The Adviser receives support services and/or products from LPL Financial, many of which assist the Adviser to better monitor and service program accounts maintained at LPL Financial; however, some of the services and products benefit the Adviser and not client accounts. These support services and/or products may be received without cost, at a discount, and/or at a negotiated rate. Such compensation provided to the Adviser includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to the Adviser, and, may include the following: • Payments based on production; • Equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of • either restricted stock units or stock options to purchase stock, in each case subject to • satisfaction of vesting and other conditions; • Reimbursement or credit of fees that The Adviser pays to LPL for items such as administrative • services or technology fees; • Free or reduced-cost marketing materials; • Payments in connection with the transition of association from another broker-dealer or • investment advisor firm to LPL; • Payments in the form of repayable or forgivable loans; • Advances of advisory fees; and/or • Attendance at LPL conferences and events. LPL Financial may provide these services and products directly or may arrange for third party vendors to provide the services or products to Advisor. In the case of third-party vendors, LPL Financial may pay for some or all of the third party’s fees. These support services are provided to the Adviser based on the overall relationship between the Adviser and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements with LPL Financial that involves the execution of client transactions as a condition to the receipt of services. The Adviser will continue to receive the services regardless of the volume of client transactions executed with LPL Financial. Clients do not pay more for services as a result of this arrangement. There is no corresponding commitment made by the Adviser to LPL or any other entity to invest any specific amount or percentage of client assets in any specific securities as a result of the arrangement. However, because the Adviser receives these benefits from LPL Financial, there is a potential conflict of interest. The receipt of these products and services presents a financial incentive for the Adviser to recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s platform. For a further listing of potential conflicts, please refer to LPL Financial’s Brokerage Compensation and Conflicts Disclosure, available at Ipl.com/disclosures.html. Use of External Custodians As discussed previously, certain associated persons of the Adviser are registered representatives of LPL Financial. As a result of this relationship, LPL Financial may have access to certain confidential information (e.g., financial information, investment objectives, transactions, and holdings) about [Advisor’s] clients in order to supervise certain activities of the Adviser, even if client does not establish any account through LPL. If you would like a copy of the LPL Financial privacy policy, please contact the branch office at (407) 792-3336. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—20 Item 12.B – Trade Aggregation The Adviser primarily recommends and invests client assets in open-end mutual funds and ETFs. The Adviser’s investment strategies do not present an opportunity to aggregate trades. Item 13 – Review of Accounts Mr. Justice and advisory associates perform reviews of all investment advisory accounts no less than annually but as frequently as quarterly depending on the client’s needs and situation. They review accounts for consistency with the investment strategy and performance chosen by clients (among other things). Reviews may be triggered by changes in an account holder’s personal, tax or financial status. Macroeconomic and company specific events may also trigger reviews. There is currently no limit on the number of accounts that can be reviewed by an associate or Mr. Justice. Advisory account statements are generated no less than quarterly. These statements are sent directly to the account owner from their broker-dealer, product sponsors, custodian or retirement plan administrators. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction. Account Reviews Private Fund Fund assets, valuations, and performance are reviewed continuously by the Adviser through its internal systems and UnderwriteAI™, an agentic underwriting framework with human-in-the-loop verification. Investors receive: • Quarterly fund performance and treasury reports, • Annual audited financial statements, and • Schedule K-1 tax forms. REALBLOCK® provides immutable, blockchain-anchored transparency for reporting and custody verification. Item 14 – Client Referrals and Other Compensation The Adviser may also employ/engage solicitors to whom it will pay cash or a portion of the fees paid by clients referred by those solicitors. All solicitors who refer clients will be in compliance with the requirements of the jurisdiction where they operate. When applicable the solicitors will be licensed as investment advisers or notice filed in the appropriate jurisdictions. Whenever the Adviser compensates solicitors for referrals, the effected clients will receive a disclosure document discussing the referral fees paid and informing the client about whether the client or the Adviser pays the fee. See Item 4 for information about referral arrangements. The Adviser has engaged a solicitor to whom it will pay a referral fee. The Adviser pays the fee. The Adviser may engage third-party solicitors or placement agents in connection with the offering of the Fund. All arrangements will comply with Rule 206(4)-3, and full written disclosures of compensation and relationships will be provided to investors. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026 CW ADV Part 2A—21 Item 15 – Custody Client assets are held by qualified custodians. The Adviser maintains custody of client funds and/or securities by virtue of having one or more Standing Letters of Instruction (“SLOA”) from clients of the Adviser. SLOAs provide investment advisers with the authority to disburse client funds to one or more third parties as specifically designated by the client. Clients instruct account custodians to accept the Adviser’s instructions (on the client’s behalf) to move money to third parties designated by the client in the SLOA. The Adviser’s authority is strictly limited by the terms of that instruction and the client retains full power to change or revoke the arrangement at any time. The SEC has determined that under these circumstances, the Adviser retains custody of client assets. The Adviser will periodically review fund transfer authorizations from client accounts and wire transfer destination information to ensure that transfers conform to the authority granted in the SLOAs. Item 16 – Investment Discretion The Adviser will have discretion over the selection and amount of securities to be bought or sold without obtaining specific client consent. The Adviser will not have discretion over the selection of the broker to be used or the commission rates to be paid. Private Fund The Adviser, in its dual role as General Partner and Fund Advisor, exercises discretionary authority over property acquisitions, financing, operations, and dispositions pursuant to the Fund’s governing documents and fiduciary standards. All investment activity follows a disciplined underwriting process combining data-driven analysis and AI-assisted modeling with human oversight. Item 17 – Voting Client Securities The Adviser does not accept authority to vote proxies on behalf of clients as a matter of policy. Clients will receive their proxy information directly from their custodian. Clients may contact the Adviser with questions about a particular solicitation by telephone at (407) 792-3336. Item 18 – Financial Information There is no financial condition that is reasonably likely to impair the Adviser’s ability to meet its contractual commitments to its clients. The Adviser anticipates that the planning process will be completed within six months or sooner of the date of the agreement. The Adviser does not require or solicit prepayment of fees exceeding $1,200, six months or more in advance. The Adviser considers fees for services to be earned as services are provided. An SEC Registered Investment AdvisorIAB Version 2026v1_03 Last Changed 03.2026