COLUCCI WEALTH MANAGEMENT LLC

FORM ADV PART 2A DISCLOSURE BROCHURE Colucci Wealth Management LLC 145 Orinoco Dr., #1 Brightwaters, NY 11718 (212) 763-4840 April 2026 This disclosure brochure (“Brochure”) provides information about the qualifications and business practices of Colucci Wealth Management LLC (hereinafter “Colucci Wealth,” the “Firm,” “we,” “us,” or similar designations). If you have any questions about the contents of the Brochure, please contact the Firm at (212) 763- 4840 . The information in the Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. 1  Additional information about the Firm is available on the SEC's website at www.adviserinfo.sec.gov. Colucci Wealth Management LLC is an investment adviser registering with the SEC. Registration with the SEC or any state securities authority does not imply any level of skill or training. 2  Item 2. Material Changes In this Item, Colucci Wealth is required to discuss any material changes that have been made to the brochure since the last annual amendment. Colucci Wealth has the following to disclose in response to this item: • Colucci Wealth has amended Item 10 to disclose that John Colucci also serves as an investment adviser representative of Alden Capital Management LLC. Item 3. Table of Contents Item 1. Cover………… ………………………………….………………………………………… 1 Item 2. Material Changes ....................................................................................................................... 2 Item 3. Table of Contents ...................................................................................................................... 2 Item 4. Advisory Business ..................................................................................................................... 2 Item 5. Fees & Compensation ................................................................................................................ 6 Item 6. Performance-Based Fees & Side-by-Side Management ........................................................... 8 Item 7. Types of Clients ......................................................................................................................... 8 Item 8. Methods of Analysis, Investment Strategies, & Risk of Investment Loss ................................ 8 Item 9. Disciplinary Information ......................................................................................................... 12 Item 10. Other Financial Industry Activities & Affiliations ................................................................ 13 Item 11. Code of Ethics, Participation or Interest in Client Transactions, & Personal Trading .......... 13 Item 12. Brokerage Practices ............................................................................................................... 14 Item 13. Reviews of Accounts ............................................................................................................. 17 Item 14. Client Referrals & Other Compensation ............................................................................... 17 Item 15. Custody .................................................................................................................................. 17 Item 16. Investment Discretion ............................................................................................................ 18 Item 17. Voting Client Securities (Proxy Voting) ............................................................................... 18 Item 18. Financial Information ............................................................................................................ 18 Item 4. Advisory Business Description of Colucci Wealth Colucci Wealth was launched in January 2026 to provide a broad range of investment advisory services to its clients. The Firm is wholly-owned by John Colucci. Colucci Wealth offers a variety of advisory services, which include investment management and financial planning services. Prior to Colucci Wealth rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). While this brochure generally describes the business of Colucci Wealth, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons 3  occupying a similar status or performing similar functions), employees, and other persons who provide investment advice on the Firm’s behalf and are subject to the Firm’s supervision or control. Description of Services The Firm offers a broad range of services as described below in more detail. Investment Management and Wealth Management Services Colucci Wealth offers investment management services to its clients, typically through a wealth management arrangement that combines both investment management services and financial planning services, which are described in more detail below. Colucci Wealth can also provide investment management services on a stand-alone basis to clients. Colucci Wealth manages client investment portfolios on a discretionary or non-discretionary basis. Discretionary investment management services allow the Firm to implement its recommendations without prior consent from the client. Non-discretionary investment management services require the Firm to obtain prior consent from the client before implementing its recommendations. Utilizing information obtained regarding the client’s objectives, goals, risk tolerance, time horizon, guidelines, restrictions, and other relevant criteria, the Firm will construct portfolios primarily comprised of individual stocks and bonds, exchange-traded funds, and options utilizing the investment methodologies and strategies described below in Item 8. Where appropriate, Colucci Wealth also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage Colucci Wealth to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Colucci Wealth directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s sponsor. Financial Planning Services Colucci Wealth offers clients a broad range of financial planning services, both as part of our combined wealth management service offering described above or on a stand-alone basis depending on the client’s preference. Financial planning generally includes advice that addresses one or more areas such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, investment portfolio design, insurance needs analysis, wealth transfer planning, and business succession planning. This service includes gathering information about the client’s net worth, income, expenses, taxes, investments, retirement plans, insurance, goals, concerns and objectives, as appropriate. 4  The offering of financial planning services does not include the preparation of income tax, gift, or estate tax returns or the preparation of any legal documents, including wills or trusts. Financial planning services do not include tax or legal advice. Clients are responsible for accepting or rejecting the Firm’s recommendations and implementing such recommendations. Where agreed upon by the Firm, the client can arrange for assistance from the Firm in implementing its recommendations, but clients should understand that a conflict of interest exists where the Firm recommends itself to implement such recommendations as this could result in more overall compensation payable by the client to the Firm. In performing these services, Colucci Wealth is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants) and is expressly authorized to rely on such information. Colucci Wealth recommends certain clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage the Firm to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Colucci Wealth under a financial planning engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firm’s recommendations and/or services. As noted above, the Firm tailors its investment advisory services to the specific needs and circumstances of its clients. Wrap Fee Programs Colucci Wealth does not provide services through a wrap fee program. Assets Under Management As of the date of this filing, Colucci Wealth has $80,796,246 in assets under management, all of which were managed on a discretionary basis. Item 5. Fees & Compensation The following sections describe the fees charged by the Firm for its services as well as additional expenses to be borne by clients in connection with services rendered. Investment Management and Wealth Management Fees Colucci Wealth offers investment management and Wealth Management services for an annual fee based on the amount of assets under the Firm’s management. This fee is typically one percent (1.0%) of the client’s assets under management unless such management fee is reduced by Colucci Wealth. The Firm may charge clients an equivalent or lower rate for assets advised by the Firm that are held away from the primary custodian. 5  Fees for investment management and wealth management services are billed quarterly in arrears based on the market value of the client’s assets as of the last day of the applicable quarter. Fees are not prorated for additions or withdrawals of capital during a quarter. The Firm may enter into fee arrangements with clients on terms that may vary from those described above including fees charged on a different basis (i.e., not based on assets under management), fees charged at different times or frequency, or fees based on different valuations of assets. In general, clients grant the Firm authority to deduct fees for investment management and wealth management services directly from the accounts under the Firm’s management. However, clients can be invoiced for such services as well if agreed upon by the Firm. Financial Planning Fees The firm offers stand-alone financial planning services for an initial retainer starting from $5,000 but may be higher based on the client’s financial planning needs and the complexity of the arrangement. Additional work to be performed beyond the initial scope of work will be charged at an hourly rate of $500 per hour or more. Clients pay the initial retainer prior to Colucci Wealth’s performance of the services, and additional hourly fees are payable by clients upon completion of the financial planning engagement. Fee Discretion COLUCCI Wealth may , in its sole discretion, negotiate to charge lesser fees based upon certain criteria, such as the overall scope of services to be provided to the client, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, and pro bono activities. Termination of Advisory Relationship In the event that a client terminates its Advisory Agreement prior to the end of a billing period or the end of an engagement, the Firm’s fees will be charged for the final billing period based on the market value of the portfolio as of the effective date of termination. Fees will be prorated for the final billing period and due as of the effective date of termination. If the Firm has been paid any amounts in advance, the Firm will refund any unearned fees to clients. Additional Fees and Expenses In addition to the advisory fees paid to Colucci Wealth, clients also incur certain charges imposed by third parties, such as fees payable to fund managers, broker-dealers, custodians, trust companies, banks, and other financial institutions (collectively “Financial Institutions”). These additional charges include, among others, securities brokerage commissions, mark-ups and mark-downs on fixed-income transactions, and other transaction costs; custodial fees; reporting charges; margin costs; charges imposed directly by a mutual fund, ETF, or other fund in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, and other fund expenses); deferred sales charges; odd-lot differentials; 6  transfer taxes; wire transfer and electronic fund fees; and other fees and taxes on brokerage accounts and securities transactions. Item 6. Performance-Based Fees & Side-by-Side Management Colucci Wealth does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients Types of Clients Colucci Wealth offers investment management services to individuals, high net worth individuals, families, trusts, estates, and businesses. Minimum Account Requirements Generally, the Firm requires clients to maintain a minimum of $1,000,000 in assets under management to maintain an investment advisory relationship with the Firm, but the Firm reserves the right to waive or reduce such minimum in its sole and absolute discretion. Item 8. Methods of Analysis, Investment Strategies, & Risk of Investment Loss Investing in securities involves a risk of loss that clients should be prepared to bear. There is no guarantee that any specific investment or strategy will be profitable for a particular client. Methods of Analysis and Investment Strategies Colucci Wealth’s investment methodology begins with strategic allocation of client assets among asset classes based on the client’s investment objectives, risk tolerance, time horizon, and other factors. Colucci Wealth will then construct portfolios primarily utilizing strategies designed to achieve the client’s goals, customized to the needs of each client. Colucci Wealth utilizes the following investment strategies, as applicable, when seeking to achieve the client’s objectives: ● Growth Strategy: This strategy focuses on Investing in positions for capital appreciation. ● Income Strategy: This strategy focuses on building out a portfolio with the goal of generating strong income for clients. 7  ● Growth of income strategy: This strategy focuses on investing for income with the prime focus on companies that have a dividend increase track record. When selecting individual securities, Colucci Wealth focuses on fundamental and technical analysis. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps Colucci Wealth in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. Colucci Wealth monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Colucci Wealth will be able to accurately predict such a reoccurrence. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to Colucci Wealth’s investment management activities. General Economic Conditions A client’s portfolio could be adversely affected from time to time by such matters as changes in general economic, industrial and international conditions, changes in tax laws, prices and cost and other factors of a general nature that are beyond the control of Colucci Wealth. Geopolitical and other events (e.g., natural disasters, pandemics, war, terrorism, and trade wars) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism and related geopolitical events have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and world economies and markets. Market Risks 8  Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Colucci Wealth’s recommendations and/or investment decisions will depend to a great extent upon the future course of price movements of equity securities and other investments. Volatility Risks The prices and values of investments can be highly volatile and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Interest-Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Use of Margin Colucci Wealth will, as appropriate, utilize margin borrowing in the management of a client’s portfolio. While margin borrowing can enhance returns for a client, such borrowing can also result in increased losses due to the use of borrowed funds. Cash-Management Risks Colucci Wealth is authorized to invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments Where appropriate, Colucci Wealth will purchase for clients positions in common stocks of U.S. and non- U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non- U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization, and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. 9  Fixed Income Securities Fixed income securities are subject to the risk of the issuer’s or a guarantor’s inability to meet principal and interest payments on its obligations. Additionally, the value of fixed-income securities is impacted by factors such as interest rates as well as market and economic factors. Mutual Funds and 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 actual 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 index-based ETFs and potentially 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 20,000 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. Real Estate Investment Trusts The Firm may recommend an investment in, or allocate assets among, various real estate investment trusts (“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities. REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or residential developments, which inherently subject REIT investors to the risks associated with a downturn in the real estate market. Investments linked to certain regions that experience greater volatility in the local real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity and counterparty risk. Cybersecurity Risks 10  The information and technology systems of Colucci Wealth and key service providers to Colucci Wealth and its clients may be vulnerable to potential damage or interruption from computer viruses; network failures; computer and telecommunication failures; infiltration by unauthorized persons and security breaches; usage errors by their respective professionals; power outages; and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although Colucci Wealth has implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, it may be necessary for Colucci Wealth to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of Colucci Wealth or its clients’ accounts and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information. Item 9. Disciplinary Information Colucci Wealth does not have any disciplinary actions to report in response to this item. Item 10. Other Financial Industry Activities & Affiliations Investment Adviser Representative of Another Advisory Firm In addition to serving as an investment adviser representative of Colucci Wealth, John Colucci also serves as an investment adviser representative of Alden Capital Management LLC. Certain conflcits of interest exist as a result of such an arrangement including the fact that Mr. Colucci may not devote his entire time rendering advisory services to clients of Colucci Wealth as well as the fact that Mr. Colucci may recommend the services of Alden Capital Management LLC to certain persons because this could result in more overall compensation payable to Mr. Colucci. Nonetheless, Mr. Colucci does not recommend the advisory services of Colucci Wealth to clients of Colucci Wealth. Licensed Insurance Agents John Colucci is a licensed insurance agent and offers certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that Colucci Wealth recommends the purchase of insurance products where John Colucci is entitled to insurance commissions or other additional compensation. Colucci Wealth has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations. 11  Item 11. Code of Ethics, Participation or Interest in Client Transactions, & Personal Trading Colucci Wealth has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Colucci Wealth’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of Colucci Wealth’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household) a transaction in that security unless: the transaction has been completed; the transaction for the Supervised Person is completed as part of a batch trade with clients; or ● ● ● a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments; (iii) shares issued by money market funds; and (iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Colucci Wealth to request a copy of its Code of Ethics. Item 12. Brokerage Practices Recommendation of Broker-Dealers and Custodians for Client Transactions Generally, Colucci Wealth recommends that clients utilize the custody, brokerage, and clearing services of Charles Schwab & Co, Inc., through its Schwab Advisor Services division (“Schwab”) for investment management accounts. The final decision to custody assets with Schwab is at the discretion of the client. Colucci Wealth is independently owned and operated and not affiliated with Schwab. Schwab provides Colucci Wealth with access to its institutional trading and custody services, which are typically not available to retail investors. 12  Factors which Colucci Wealth considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research, and service. Schwab enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. The Firm has a duty to ensure client brokerage transactions receive “best execution”. However, clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Colucci Wealth determines that the commissions are reasonable in relation to the value of the brokerage and research services received. 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 Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Colucci Wealth seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services that assist Colucci Wealth in its investment decision-making process. Such research will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services, as well as the allocation of the benefit of such investment research products and/or services, poses a conflict of interest because Colucci Wealth does not have to produce or pay for the products or services. Colucci Wealth periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions Colucci Wealth receives without cost from Schwab administrative support, computer software, and related systems support, as well as other third-party support as further described below (together “Support”), which allow Colucci Wealth to better monitor client accounts maintained at Schwab and otherwise conduct its business. Colucci Wealth receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The Support is not provided in connection with securities transactions. Clients should be aware that Colucci Wealth’s receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits may influence the Firm’s choice of one broker-dealer over another that does not furnish similar software, systems support, or services. In fulfilling its duties to its clients, Colucci Wealth endeavors at all times to put the interests of its clients first and has determined that the recommendation of Schwab is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, Colucci Wealth receives the following benefits from Schwab: (i) receipt of duplicate client confirmations and bundled duplicate statements; (ii) access to a trading desk that exclusively services its institutional traders; (iii) access to block trading, which provides the ability to aggregate securities 13  transactions and then allocate the appropriate shares to client accounts; and (iv) access to an electronic communication network for client order entry and account information. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a certain amount of an adviser’s client assets are maintained in accounts at Schwab Advisor Services. Nonetheless, this arrangement creates a conflict of interest, as it provides an incentive for the Firm to recommend Schwab’s services to its clients in order to continue receiving such services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research (including in the form of advice, analyses, and reports), and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset- based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional, or Firm-specific educational events organized and/or sponsored by Schwab. Other potential benefits may include occasional business entertainment of Colucci Wealth personnel by Schwab personnel, including meals, invitations to sporting events (including golf tournaments), and other forms of entertainment, some of which may accompany educational opportunities. Other products and services assist Colucci Wealth in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information, and other market data; facilitate payment of the Firm’s fees from its clients’ accounts; and assist with back-office training and support functions, recordkeeping, and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm’s accounts, including accounts not maintained at Schwab. Schwab also makes available to Colucci Wealth other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance, and marketing. In addition, Schwab may make available, arrange, and/or pay vendors for these types of services rendered to the Firm by independent third parties. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to the Firm. Although, as a fiduciary, Colucci Wealth endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefits received and not solely on the nature, cost, or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. 14  Client Referrals from Brokers Colucci Wealth does not consider, in selecting or recommending broker-dealers, whether Colucci Wealth receives client referrals from the broker-dealer. Directed Brokerage In general, Colucci Wealth generally does not permit clients to direct brokerage transactions to be executed with brokers of the client’s choosing. Nonetheless, if Colucci Wealth were to accommodate a client by allowing for directed brokerage, the client will be responsible for negotiating terms and arrangements for the account with that Financial Institution and Colucci Wealth will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Colucci Wealth (as described above). As a result, the client may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Colucci Wealth may decline a client’s request to direct brokerage if, in Colucci Wealth’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client will generally be effected independently, unless Colucci Wealth decides to purchase or sell the same securities for several clients at approximately the same time. Colucci Wealth may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Colucci Wealth’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions generally will be averaged as to price and allocated among Colucci Wealth’s clients pro rata in relation to the purchase and sale orders placed for each client on any given day. To the extent that Colucci Wealth determines to aggregate client orders for the purchase or sale of securities, including securities in which Colucci Wealth’s Supervised Persons may invest, Colucci Wealth does so in accordance with applicable rules promulgated under the Investment Advisers Act of 1940 and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Colucci Wealth does not receive any additional compensation or remuneration as a result of the aggregation. Item 13. Reviews of Accounts Account Reviews Client portfolios are reviewed at least annually by Colucci Wealth’s CIO, but account reviews are typically conducted more frequently. 15  Account Statements and Reports Clients are provided with regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Colucci Wealth related to their accounts. Item 14. Client Referrals & Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Please see a description of economic benefits received by the Firm in Item 12 above. Compensation for Client Referrals Colucci Wealth does not currently compensate third parties for client referrals. Item 15. Custody Colucci Wealth is deemed to have custody of client funds and securities where the Firm is authorized to deduct its advisory fees directly from client accounts. As such, Colucci Wealth is required to comply with the requirements set forth in the Custody Rule under the Advisers Act which requires, among other things, that client funds and securities be maintained with a qualified custodian. The custodians or broker-dealers that serve as qualified custodians on behalf of Colucci Wealth’s clients have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account, including the amount of advisory fees paid directly to Colucci Wealth. In addition, as discussed in Item 13 above, Colucci Wealth may also send periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the custodian or broker-dealer and compare them to the reports received from Colucci Wealth. Item 16. Investment Discretion Colucci Wealth is given discretionary authority to manage each client’s account. Colucci Wealth is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking client consent. Colucci Wealth is given this authority through a limited power-of-attorney included in the Advisory Agreement with the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Colucci Wealth takes discretion over the following activities: ● The securities to be purchased or sold; ● The amount of securities to be purchased or sold; and ● When transactions are done. 16  Item 17. Voting Client Securities (Proxy Voting) Colucci Wealth accepts the authority to vote a client’s securities (i.e., proxies) on their behalf. When Colucci Wealth accepts such responsibility, it will only cast proxy votes in a manner consistent with the best interest of its clients. Absent special circumstances, which are fully-described in the Firm’s Proxy Voting Policies and Procedures, all proxies will be voted consistent with guidelines established and described in Colucci Wealth’s Proxy Voting Policies and Procedures, as they may be amended from time to time. Clients may contact Colucci Wealth to request information about how the Firm voted proxies for that client’s securities or to get a copy of Colucci Wealth’s Proxy Voting Policies and Procedures. A brief summary of Colucci Wealth’s Proxy Voting Policies and Procedures is as follows: • Colucci Wealth’s CIO will be responsible for monitoring corporate actions, making voting decisions in the best interest of clients, and ensuring that proxies are submitted in a timely manner. • The CIO will vote proxies according to Colucci Wealth’s then current Proxy Voting Guidelines. Currently, proxy guidelines dictate voting proxies as recommended by company management unless Colucci Wealth has a compelling reason to vote otherwise. • Clients cannot direct Colucci Wealth’s vote on a particular solicitation but can revoke the Firm’s authority to vote proxies. In situations where there is a conflict of interest in the voting of proxies due to business or personal relationships that Colucci Wealth maintains with persons having an interest in the outcome of certain votes, the Firm takes appropriate steps to ensure that its proxy voting decisions are made in the best interest of its clients and are not the product of such conflict. Item 18. Financial Information Colucci Wealth does not have any financial condition or impairment that would prevent the Firm from meeting its contractual commitments to clients. The Firm does not take physical custody of client funds or securities or serve as trustee or signatory for client accounts, and it does not require the prepayment of more than $1,200 in fees six or more months in advance. The Firm has not filed a bankruptcy petition at any time in the past ten years. 17