Complete Wealth Management, LLC

Item 1 – Cover Page Complete Wealth Management, LLC www.completewealthmgmt.com Business Address: 1088 Blackjack Road, Valley View, TX 76272 Mailing Address: 624 W. University Dr., # 430, Denton, TX 76201 (940) 382-9300 September 2, 2026 This Brochure provides information about the qualifications and business practices of Complete Wealth Management, LLC. If you have any questions about the contents of this Brochure, please contact us at (940) 382-9300 or via email at jeremy@completefg.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Complete Wealth Management, LLC (“Complete Wealth Management”) is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them. Additional information about Complete Wealth Management is also available via the SEC’s website www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Complete Wealth Management is 288794. The SEC’s web site also provides information about any persons affiliated with Complete Wealth Management who are registered, or are required to be registered, as Investment Adviser Representatives of Complete Wealth Management. Complete Wealth Management ADV Part 2A September 2026 Page 1 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Item 2 – Material Changes Since our last annual amendment filing on February 18, 2025, we have made the following material changes to our business: 1. We have registered with the SEC. 2. We have revised our asset management fee schedule for new clients as of September 1, 2026. In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 90 days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting at (940) 382-9300. Complete Wealth Management ADV Part 2A September 2026 Page 2 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Item 3 – Table of Contents Item 1 – Cover Page ...........................................................................................................................1 Item 2 – Material Changes ..................................................................................................................2 Item 3 – Table of Contents .................................................................................................................3 Item 4 – Advisory Business Introduction .............................................................................................4 Item 5 – Fees and Compensation ...................................................................................................... 13 Item 6 – Performance Based Fee and Side-by-Side Management ....................................................... 17 Item 7 – Types of Client(s) ................................................................................................................ 17 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 18 Item 9 – Disciplinary Information ..................................................................................................... 24 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 24 Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ................ 25 Item 12 – Brokerage Practices .......................................................................................................... 27 Item 13 – Review of Accounts ........................................................................................................... 31 Item 14 – Client Referrals and Other Compensation .......................................................................... 31 Item 15 – Custody ............................................................................................................................ 31 Item 16 – Investment Discretion ....................................................................................................... 32 Item 17 – Voting Client Securities ..................................................................................................... 33 Item 18 – Financial Information ........................................................................................................ 33 Complete Wealth Management ADV Part 2A September 2026 Page 3 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Item 4 – Advisory Business Introduction Our Advisory Business Complete Wealth Management, LLC (“Complete Wealth Management”, “us”, “we”, “our”) is a Registered Investment Adviser (“Adviser”) which offers investment advice regarding securities, insurance, and other financial services to clients. We provide investment advice through Investment Adviser Representatives (“IAR”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all IARs are required to have educational requirements such as: a college degree, professional designation, or equivalent professional experience. Complete Wealth Management was founded in 2017 by Stacie David. Jeremy David serves as Chief Compliance Officer for Complete Wealth Management. We provide management services to individuals, high net worth individuals, small businesses, charities, foundations, trusts, and estates. Our minimum account opening balance is $250,000 which may be negotiable based upon certain circumstances. We are committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business. Services We provide various asset management and financial planning services, with an emphasis on business and retirement planning and services. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We act as a portfolio manager to wrap fee programs through Betterment for Advisors for traditional securities portfolios through a wrap fee program that includes custody and trading services provided by its affiliate, Betterment Securities. Asset Management Asset management is the professional management of securities (stocks, bonds and other securities) and assets (e.g., real estate) in order to meet your specified investment goals. With an Asset Management Account, you engage us to assist you in understanding whether any of our strategies meet your unique investment objectives. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management are based upon your investment goals and objectives, risk tolerance, and the investment portfolio you have selected. We Complete Wealth Management ADV Part 2A September 2026 Page 4 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in quarterly and annual account reviews. These reviews will be conducted in person, by telephone conference, and/or via a written inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. We will: • Review your present financial situation • Monitor and track assets under management • Provide portfolio statements, periodic rate of return reports, asset allocation statement, rebalanced statements as needed • Advise on asset selection • Provide research and information on performance and fund management changes • Build a risk management profile for you • Assist you in setting and monitoring goals and objectives • Provide personal consultations as necessary upon your request or as needed. You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change. You shall not have the ability to impose restrictions on the management of your account. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. We can also work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. We will create a formal IPS and deliver it to you upon completion. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We require you to use Charles Schwab, Betterment, or other custodians selected and approved by the firm. You will enter into a separate custodial agreement with the custodian which authorizes the custodian to take instructions from us regarding all investment decisions for your account. We will select the securities bought and sold and the amount to be bought and sold, within the parameters of the objectives and risk tolerance of your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, Complete Wealth Management ADV Part 2A September 2026 Page 5 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We may also provide you with a quarterly performance statement starting at the end of the first full calendar quarter after signing the Advisory Agreement. These statements give you additional feedback regarding performance, educate you about our long-term investment philosophy, and describe any changes in current strategy and allocation along with the reasons for making these changes. We may also recommend the use of Variable Annuity products through third party providers. The return from variable annuities can vary depending on the performance of the underlying portfolio. Indexed annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and some participation growth, if any, of a stock market index. For further details on the risks of these products, please see Item 8. We manage assets on a discretionary basis, which means you have given us the authority to determine the following with/without your consent: • Securities to be bought or sold for your account • Amount of securities to be bought or sold for your account • Broker-dealer to be used for a purchase or sale of securities for your account • Commission rates to be paid to a broker or dealer for your securities transaction. If you have not given us the authority to manage your account on a discretionary basis, then we cannot trade in your account without your express permission. Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Third-Party Money Managers We may determine that opening an account with a professional third-party money manager is in your best interests. We have contracts with several third-party money managers. These programs allow you to obtain portfolio management services that typically require higher minimum account sizes outside of the program. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by you. Due to the nature of these programs, each of the independent money Complete Wealth Management ADV Part 2A September 2026 Page 6 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing. Under these programs, we may: • Assist in the identification of investment objectives • Recommend specific investment style and asset allocation strategies • Assist in the selection of appropriate money managers and review performance and progress • Recommend reallocation among managers or styles within the program • Recommend the hiring and firing of money managers utilized by you. You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur. Use of the Betterment Platform We may determine that opening an account with Betterment is in your best interest. We offer custom asset management to our Clients through Betterment’s platform. If we participate in this offering, we will construct Custom Portfolios using our own investment methodologies, as detailed in Item 8 below, and our Clients are able to use Betterment’s automated advice features, including automatic rebalancing, dividend reinvestment, tax loss harvesting, and asset location services. Advisor, and not Betterment, is responsible for managing any goal for which a Custom Portfolio is elected on the basis of a Client’s financial situation and investment objectives. Betterment will not evaluate whether any Custom Portfolio is suitable for any Client’s individual investment objectives, either at the time of election or on an ongoing basis. In addition, Complete Wealth Management, and not Betterment, is responsible for disclosing to our Clients any limitations to Betterment’s features caused by the election of a Custom Portfolio strategy. Betterment for Advisors offers several account types to Advisors and their Clients, such as taxable investing accounts, individual retirement accounts (IRAs), and cash management accounts (Cash Reserve). If our Client also is employed by a company that utilizes Betterment’s 401(k) offering, Betterment at Work, we may also manage Client’s Betterment 401(k) account if Client delegates investment management authority of their 401(k) to us. We can also view Clients’ Betterment checking account in their Advisor Dashboard, and we can also view Clients’ health savings accounts (HSAs), if the Client has a Betterment HSA through their employer. Wrap Program Betterment for Advisors offers its investment sub-advisory services for traditional securities portfolios through a wrap fee program that includes custody and trading services provided by its affiliate, Betterment Securities. Financial Planning/Consulting We provide services such as comprehensive financial planning, estate planning, business planning and educational planning. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. Complete Wealth Management ADV Part 2A September 2026 Page 7 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. Retirement Plan Services For our firm’s Retirement Plan accounts, our service begins with an analysis of the current retirement plan structure, custodian, third-party administrator, daily record keeper, investments, managed investment strategies, and fees. The analysis is designed to determine if we are able to add value to the plan and what areas, if any, may be deficient from both a regulatory perspective and from a financial advisory perspective. We will offer you one or more of the following services: • Plan design and asset selection consultation • Develop and annually review Investment Policy Statement (“IPS”) • Develop investment menu according to the IPS • Review plan sponsor’s stated financial criteria for each investment option • Monitor each investment option according to the IPS • Quarterly portfolio statements, rate of return reports, asset allocation statements • Provide investment research and performance information on investment options • Investment option replacement guidance • Personal consultations with the plan sponsor as necessary • Develop Plan Investment Committee Charter, as needed • Fiduciary due diligence assistance Complete Wealth Management ADV Part 2A September 2026 Page 8 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  • Attendance at Plan Committee and other meetings • Annual Fiduciary Plan Review • Fiduciary education services to Plan Committee • Participant education, guidance, and enrollment • Vendor coordination assistance • Benchmarking services Plan Structure We will assist our client in evaluating the current plan’s structure to determine if a change in the design of the plan better suits the needs of plan participants. We will facilitate any changes with the appropriate parties including the third-party administrator, record keeper, and custodian as well as facilitating the execution of the required plan document amendments or new plan documents. However, we will not draft any amendments as an attorney or a TPA will need to perform this service. Investment Committee We will assist you in the establishment of the Investment Committee (if a Committee is deemed appropriate) and the establishment of a formal investment committee charter, delineating committee responsibilities and fiduciary roles. We will also serve on the Committee in a non-fiduciary capacity if needed. The Investment Committee may be charged with the fiduciary responsibility of the prudent management of the investment portfolio, selecting and retaining professional advisors to the portfolio including investment managers, investment consultants, custodians, attorneys, and clerical staff, and the establishment, execution, and interpretation of an Investment Policy Statement for the portfolio. We will assist the Investment Committee in meeting the committee’s responsibilities according to the investment committee charter, and fulfilling its fiduciary duty to the plan, including their review of service providers, third-party administration firms, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to other alternatives that are available to the client. Investment Policy Service Complete Wealth Management Investment Policy Service is designed to assist you in creating a written investment policy statement (“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals. The service is generally designed for corporate retirement plans that are managed on a non-discretionary basis. We will assist the Investment Committee with the establishment, execution, and interpretation of the Investment Policy Statement. The Investment Policy Statement serves as a guide to assist the Investment Committee in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile various factors for the account such as investment objectives, risk tolerances, projected cash flow, and demographics of your retirement plan participants. It is the client’s responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. We recommend that your professional Complete Wealth Management ADV Part 2A September 2026 Page 9 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  advisors, such as an attorney, actuary, and/or accountant, also review the IPS. The review and acceptance of the IPS is the responsibility of the plan fiduciary and your retirement program’s governing entity. Upon client’s final approval, the IPS is ready to be sent to client’s Investment Committee. It is client’s responsibility to confirm the Investment Committee’s acceptance of the IPS, and it is the Investment Committee’s responsibility to adhere to the IPS in managing the retirement program. We encourage you to review accounts periodically to verify investment committee’s compliance with the IPS. The Investment Policy Statement will be reviewed at least annually to determine whether stated investment objectives are still relevant and the continued feasibility of achieving those objectives. However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will not be updated to account for short term changes in market conditions or the economic environment. Investment Selection, Monitoring, and Replacement We will conduct research to determine allocations and to project potential ranges of returns and market values over various time periods and using various cash flows. As the financial advisor to the Plan, we will assist the Investment Committee in selecting the non-managed investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create forward looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. We have the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The plan sponsor has the responsibility and authority to make the final decision regarding what investments to include in the strategies and when to add or exclude a specific security. It is client’s responsibility to select the final mix and to determine whether to implement any strategy. We also encourage you to consult with your other professional advisors since Complete Wealth does not provide tax or legal advice that may affect asset classes or allocations used in the modeling. We will apply guidelines you supply, as directed; however, compliance with these restrictions or guidelines is client’s responsibility. We will also monitor the current non-managed investment line up including the investment’s performance, performance compared to an applicable benchmark index, fees, management changes, style and fundamental investment strategy changes, and fund composition to determine if an investment no longer meets the criterion defined in the Investment Policy Statement. If the Investment Committee Complete Wealth Management ADV Part 2A September 2026 Page 10 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  determines that a fund no longer meets the IPS criterion, we will advise the Investment Committee on possible alternatives and assist in the selection of a replacement investment. If you decide to implement any of the firm’s recommendations, we will help you open a custodial account(s) for the plan. The funds in this account will generally be held in a separate account, in the plan’s name, at an independent custodian, not with us. We use Charles Schwab as our custodian. The identity of your custodian will be communicated to you before the account is opened. The custodian will effect transactions, deliver securities, make payments, etc. You will at all times maintain full and complete ownership rights to all assets held in the account for the benefit of the plan participants. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Participant Meetings We will conduct plan participant meetings when a change is made either to the structure of the plan or if the investment lineup changes as a result of the decisions of the Investment Committee. We will detail the changes being made, how it affects the current participants, review the current investment opportunities, how participants may make changes to their investment selections, and will answer any and all questions a participant may have. We will review with the participants how to select the investments. Reporting We will send a quarterly performance report detailing the overall performance of the plan’s assets and a detailed list of the investment holdings. ERISA Fiduciary Both parties acknowledge that if the Account is subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA), the following provisions will apply: • The Adviser acknowledges that it is a “fiduciary” with respect to the Client as that term is defined under Section 3(21)(A) of ERISA. • The person signing this Agreement on behalf of the Client acknowledges its status as a “named fiduciary” with respect to the control and management of the assets held in the Account, and agrees to notify the Adviser promptly of any change in the identity of the named fiduciary with respect to the Account; • The Adviser agrees to obtain and maintain an ERISA bond satisfying the requirements of Section 412 of ERISA and include The Adviser and its members, agents and employees among those insured under that bond. When delivering ERISA fiduciary services, we will perform those services for the retirement plan as a fiduciary under ERISA Section 3(21)(A)(ii) will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. In our capacity as a 3(21) plan fiduciary, we will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time Complete Wealth Management ADV Part 2A September 2026 Page 11 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  periods and using various cash flows to assist the plan sponsor in determining the appropriate investment(s) for the retirement plan. Non-Discretionary 3(21) Fiduciary Services When we perform “3(21) Fiduciary Services,” we will act as a co-fiduciary “investment adviser” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this arrangement we are appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. We will not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. We will provide the Plan Sponsor with a sample investment policy statement. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for our investment advisory services. We offer the following 3(21) services: • Investment screening • The selection of replacement funds to which existing Plan balances may be transferred • Assisting clients to finalize a Plan’s investment lineup of funds available for investment by Plan participants and used for other administrative purposes under the Plan • Assisting clients with electing a “qualified default investment alternative” as defined in section 404(c)(5) of ERISA • Quarterly plan review meetings – including review of Investment Funds In our capacity as a 3(21) plan fiduciary, we will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. We have the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. The Client confirms that any instructions that have been given to the Adviser with regard to the Account are consistent with the governing plan documents and investment policy statements of the plan. Complete Wealth Management ADV Part 2A September 2026 Page 12 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Except as otherwise provided under ERISA the Adviser shall not be liable for any error of judgment or mistake of law or for any loss suffered by the Client in connection with the matters to which this Agreement relates except a loss resulting from the Adviser’s breach of its fiduciary duty, negligence, misconduct or bad faith. The Adviser is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended (the “Code”); The Adviser is neither a law firm nor a public accounting firm and Adviser will not provide legal or accounting advice; The Client acknowledges that the services covered by this Agreement are consultative and give no investment authority (“discretion”) or responsibility to the Adviser over any assets of the Plan or Participant regardless of how and where the assets are held. Throughout the term of this Agreement, the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held with any affiliated or unaffiliated third party. We also encourage plan sponsors to consult with other professional advisors since we do not provide tax or legal advice that may affect asset classes or allocations. We will apply any guidelines our client supplies, as directed, however, compliance with these restrictions or guidelines, is our client’s responsibility. Assets Under Management As of December 31, 2025, we provided asset management services for 564 accounts. The assets in these accounts the assets under management in these accounts totaled $132,535,166. Of these assets, $127,345,913 was managed on a discretionary basis and $5,189,253 was managed on a non-discretionary basis. Item 5 – Fees and Compensation We provide asset management and financial planning services for a fee. Either party may terminate the relationship with a thirty (30) day written notice. Upon termination of any account, any prepaid fees that are in excess of the services performed will be promptly refunded to you. Any fees that are due, but have not been paid, will be billed to you and are due immediately. Third-Party Money Managers We do not directly charge your account or charge a fee in addition to the fee charged by the third-party money manager, a fee based on the amount of assets under our management. Complete Wealth Management will receive a portion of the fee charged by the third-party money manager(s). Please refer to the third-party money managers(s)’ ADV Part 2 and other disclosure documents for a full description of the fees. Complete Wealth Management ADV Part 2A September 2026 Page 13 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Asset Management Fee Schedule Our minimum account opening balance is $250,000 which may be negotiable based upon certain circumstances. The fee charged is based upon the amount of money you invest. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged either quarterly or monthly, in advance, as specified in your agreement with us. Payments are due and will be assessed on the last day of each billing period. Our fee may be calculated using either the previous billing period ending balance of the accounts under management or the average daily balance of the prior quarter. Your billing method and frequency shall be indicated on your client agreement with us. No change in method or frequency shall be made without 30 days advance notice, in writing, detailing the changes. Fees be calculated as follows: Percentage Portfolio Size (AUM) 1.4% $0 - $250,000 1.3% $250,001-$500,000 1.2% $500,001- $1,000,000 1.0% $1,000,001 - $3,000,000 Negotiable Over $3,000,000 The fees shown above are annual fees and may be negotiable based upon certain circumstances. No increase in the annual fee shall be effective without prior written notification to you. We believe our advisory fee is reasonable considering the fees charged by other investment advisers offering similar services/programs. We may recommend the fee-based annuity products to you. This could be a fixed, index or variable annuity. Please see the disclosures in regarding these products above and details regarding the risks in item 8. There is no commission or compensation from the insurance company to the firm for the recommendation of this product. Therefore, a separate fee between 50-100 basis points will be either charged directly to your brokerage account or invoiced quarterly. This fee will be separate from, and in addition to, the asset management fee shown above. If you provide written authorization, you may charge both your annuity fee and your advisory fee to the account(s) of your choice. The fees we charge can be deducted directly from your account at the custodian. We will instruct the custodian to deduct the fees from your account at the end of the billing period. This fee will show up as a deduction on your following account statement from the custodian. If you do not want us to charge your account for the fee, you may pay the fee directly to us. We will send you an invoice detailing the fee calculation. Fees are due in full 15 days after receipt of the invoice. Financial Planning/Consulting Fees The following fee schedule applies for financial planning services: Complete Wealth Management ADV Part 2A September 2026 Page 14 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  The Financial Planning Agreement will show the fee you will pay. If the plan is implemented through us, we may receive compensation from the sale of insurance products or advisory services recommended in the financial plan. This compensation would be in addition to the financial planning fee you pay. The fees and expenses you pay for the purchase of these products may be more or less than the expenses you would pay should you decide to implement our recommendations through another investment advisory firm or broker-dealer and are typically determined by the broker- dealer or investment company sponsoring the product. Therefore, a conflict of interest may exist between our interests and your interests since we may recommend products that pay us compensation. We may have an incentive to recommend particular products based upon the potential compensation rather than your needs. This potential conflict is addressed in our Code of Ethics. Based upon your needs, we may also provide consultations throughout the year to advise and counsel you about other financial issues. We can help you with transition planning, major transaction analysis, coordinated with cash flow needs, retirement needs, estate planning needs, income tax planning, life and disability insurance needs, investment needs, and college education planning. We will charge an hourly fee of $200, which may be negotiable depending upon the nature and complexity of the client's circumstances. We can also provide an-in depth analysis of your financial situation or other defined projects as requested on a fee only basis. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Third Party Fees Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third party investment companies and other third parties. These include fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Certain strategies offered by us may involve investment in mutual funds and/or ETFs. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Our brokerage practices are discussed in more detail under Item 12 – Brokerage Practices. Third Party Fees Separate from and addition to, Betterment charges our Clients an asset-based wrap fee on amounts invested via the Betterment for Advisors platform that is tiered based on the aggregate balance of all of client accounts at Betterment (not including funds held in Betterment Cash Reserve). That wrap fee Complete Wealth Management ADV Part 2A September 2026 Page 15 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  currently ranges from 0.12% to 0.25% of account balances. This fee is lower if the total aggregate balance of all of client accounts at Betterment is higher, which presents a conflict of interest as we are incentivized to maintain more clients accounts at Betterment to obtain a lower fee for the use of the Betterment for Advisors platform. The asset-based wrap fee is charged monthly or quarterly, as determined by our election in the Betterment for Advisors platform, in arrears. The services included for the wrap fee include all of the services provided by Betterment and Betterment Securities through the Betterment for Advisors platform, including advisory services, custody of assets, execution and clearing of transactions, and account reporting. Betterment collects wrap fees directly from Clients pursuant to the terms of the sub-advisory agreement between Betterment and each Client. Clients utilizing the Betterment for Advisors platform may pay a higher aggregate fee than if the advisory, custodial, trade execution, and other services were purchased separately. We also pay a fixed monthly fee to Betterment Mutual of $100 per month. Retirement Plan Services Fees Complete Wealth Management’s standard fee includes establishing your Investment Policy Statement, reviewing your plan structure, investment management, investment selection and monitoring, fund changes, participant education and reporting. Advisory fees for the plan are paid to us by the plan, or directly from the plan sponsor, or in some cases a combination of both. These fees are generally collected by the plan record keeper or vendor and paid directly to our firm. For initial and subsequent years, the fee paid for our services will be up to .50% of the assets under management. This fee includes services as an ERISA section 3(21). The timing of fees paid is generally at the beginning of the upcoming month, based upon asset levels at the end of the preceding month. Complete Wealth Management’s advisory agreement with each plan sponsor outlines the timing of fees collected and the process of fee remittal to our firm. The standard fee schedule for the Non-Discretionary 3(21) Fiduciary Services programs (the “Programs”) are as follows: Percentage Portfolio Size (AUM) 1.0% $0 - $1,000,000 Negotiable $1,000,000+ The timing of fees paid is generally at the beginning of the upcoming month, based upon asset levels at the end of the preceding month. Complete Wealth Management’s advisory agreement with each plan sponsor outlines the timing of fees collected and the process of fee remittal to our firm. You may also incur fees related to your use of outside service providers including third-party administrators and record keepers. The fee schedule for each outside service provider varies dramatically from service provider to service provider. The service provider’s fees will also vary from plan to plan as each plan’s structure and characteristics are different from the next. Complete Wealth Management ADV Part 2A September 2026 Page 16 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  We believe our services help plan sponsors and plan fiduciaries meet their fiduciary duty to the plan and its participants. As a part of our services, we review the fees of service providers and the transparency of their fees. We will assist the plan sponsors with a review of service providers including the third-party administrator, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to alternatives that are available. Other Compensation Our IARs may recommend and sell life, disability, health, and long-term care insurance and will receive the usual and customary commissions on insurance products. These commissions may be charged to advisory clients who are paying the Firm an advisory fee to manage non-insurance assets. The Firm never charges advisory fees on insurance products. Jeremy David may receive additional compensation from sales of insurance products. Jeremy David may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products that he recommends. While Jeremy David endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest, and may affect her judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended insurance products from other insurance agents not affiliated with us. Item 6 – Performance Based Fee and Side-by-Side Management We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 – Types of Client(s) We provide portfolio management services to individuals, high net worth individuals, small businesses, charities, foundations, trusts, and estates. We also provide investment advisory services to the following types of clients: • Tax-qualified retirement plans (both defined benefit and defined contribution) that are intended to receive favorable tax-treatment under section 401(a) or 403(b) of the IRC • Non-qualified executive deferred compensation plans • Other types of retirement plan types as may be introduced to the Programs. Our minimum account opening balance is $250,000 which may be negotiable based upon certain circumstances. Complete Wealth Management ADV Part 2A September 2026 Page 17 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use Modern Portfolio Theory as part of our overall investment management discipline; the implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following: Modern Portfolio Theory (MPT) We use Modern Portfolio Theory to help select the funds we use in your account. Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk. Investment Strategies In order to perform this analysis, we use many resources, such as: • Morningstar • Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.) • Annual reports, prospectuses, filings • Company press releases and websites The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases -securities held at least a year Custom Portfolios used in the Betterment for Advisors Platform Custom Portfolios are Advisor-designed custom portfolios that we are able to construct through the Betterment Platform. A Custom Portfolio consists of a set or multiple sets of securities and allocations with underlying return and volatility assumptions that are either (i) provided by the Advisor to Betterment or (ii) defaulted to Betterment’s capital markets assumptions if the Advisor does not provide assumptions. For any Advisor who elects a Custom Portfolio, Betterment will allocate the Client’s assets in accordance with the Custom Portfolio. For Custom Portfolios, we and not Betterment are responsible for ensuring the Custom Portfolio (1) is suitable for our Clients, and (2) is constructed and managed in a manner consistent with our Client’s financial situation and investment objectives. Our Custom Portfolios • Conservative: The Conservative model seeks wealth preservation with a conservative level of volatility. Clients that are seeking wealth preservation with an emphasis on fixed income securities and no exposure to equities. Investors should have a 3-year minimum time frame. Complete Wealth Management ADV Part 2A September 2026 Page 18 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  • Conservative Plus: The Conservative model portfolio seeks to preserve wealth with approximate 85% fixed income securities, while having an approximate 15% US focused dividend paying stocks. Clients that are seeking wealth preservation with minimal risk in the stock market but are willing to accept a small amount of equities to increase short and long term performance. Investors should have a 5-year minimum time frame. • Income: The Income portfolio is seeking meaningful income and incremental longer-term growth while maintaining a conservative level of volatility. Clients that have a need for current income and are comfortable with moderate returns with an approximate 30% US equity focused position in the portfolio. Investors should have a minimum 3-year time horizon. • Balanced: The Balanced model seeks long term capital appreciation and a balance of current income while maintaining a moderate level of volatility with a focus on US stocks. Clients that are seeking to stay moderately invested in stocks and bonds with a balance of 40-60% equities in the portfolio. Investors should have a minimum of a 5-year time horizon. • Growth and Income: The Growth and Income model seeks to provide capital growth through a variety of stocks and income through dividend paying stocks and fixed income securities. Stocks will be US focused. Clients that are seeking long term growth with stocks but are interested in lowering their overall risk by investing in dividend paying stocks and realizing income regularly paid into the portfolio. Investors should have at least a 7-year timeframe. • Growth: The Growth Model seeks long term growth through a focus on US companies. Clients that are seeking to grow their assets long term but are not willing to commit greater than 85% to equities due to volatility and risk with the remainder in fixed income and cash securities. Investors should have at least a 10-year timeframe. • Aggressive Growth: The Aggressive Growth portfolio seeks long-term appreciation of capital with a focus on US companies. Clients that are seeking to maximize long term returns and understand the volatility and risk of a portfolio that maintains a near 100% equity position. Investors should have at least a 10-year time frame. Risk of Loss We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to bear. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. A list of many of the risks associated with the strategies, products and methodology we offer are listed below: Modern Portfolio Theory (MPT) Risk Modern Portfolio Theory tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance. Complete Wealth Management ADV Part 2A September 2026 Page 19 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Exchange Traded Fund (“ETF”) Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds: • The market price of the ETF’s shares may trade at a premium or a discount to their net asset value; • An active trading market for an ETF’s shares may not develop or be maintained; and • There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged Insurance Product Risk The rate of return on variable insurance products is not stable, but varies with the stock, bond and money market subaccounts that you choose as investment options. There is no guarantee that you will earn any return on your investment and there is a risk that you will lose money. Before you consider purchasing a variable product, make sure you fully understand all of its terms. Carefully read the prospectus. Some of the major risks include: • Liquidity and Early Withdrawal Risk – There may be a surrender charges for withdrawals within a specified period, which can be as long as six to eight years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. • Sales and Surrender Charges – Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero. • Fees and Expenses – There are a variety of fees and expenses which can reach 2% and more such as: o Mortality and expense risk charges o Administrative fees o Underlying fund expenses o Charges for any special features or riders. • Bonus Credits – Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods. • Guarantees – Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them. Complete Wealth Management ADV Part 2A September 2026 Page 20 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  • Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk – The possibility that an investment will go down in value, or "lose money," from the original or invested amount. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk -The possibility that an investment will go down in value, or "lose money," from the original or invested amount. Risks Related to Structured Investments • Maximum return features A structured product may contain a feature that caps the return that you can receive at maturity. If the return of the underlying asset at maturity exceeds the maximum return of the structured product, the investment may underperform a direct investment in the underlying asset. Before investing in a structured product with a maximum return, you should consider this risk of underperformance. • Market risk reduction features A structured product may contain a feature to reduce the downside market exposure to the underlying asset. Because the returns on structured products are tied to the performance of Complete Wealth Management ADV Part 2A September 2026 Page 21 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  the underlying asset, the principal amount of some structured products may be exposed to downside market risk. In this respect, structured products may differ from ordinary fixed- income debt instruments. In order to reduce this downside market exposure, structured products may include features that provide for the issuer to pay you back, at maturity, some or all of your principal even if the underlying asset declines in value. In addition, any market risk reduction feature only applies at maturity. If you are able to sell your structured product in the secondary market prior to maturity, you may have to sell it at a loss relative to your initial investment, even if your investment would not have resulted in a loss at maturity. A structured product with more favorable terms than an otherwise comparable structured product, such as a relatively greater market risk reduction feature, does not necessarily indicate that the structured product with more favorable terms is less risky or that it has a greater likelihood of a return of principal at maturity. Please note that certain structured products may not have a market risk reduction feature, in which case your principal is exposed to any decline in the value of the underlying asset. As previously noted, before investing in a structured product, you should carefully consider and understand the level of downside market exposure, if any, as well as the credit quality of the issuer. • Call Features A structured product may contain a call feature that can result in the investment being redeemed earlier than the stated maturity date. Different types of call features may be exercised at the sole discretion of the issuer (issuer callable) or may be exercised automatically (autocallable) if a specified, predetermined condition occurs. If a structured product is called prior to maturity, the payment you receive will depend upon the stated terms of the investment. If a structured product is called, you may not be able to reinvest the proceeds of the investment in a similar investment with similar risk and return characteristics. You should carefully evaluate this reinvestment risk before you make an investment in a structured product with a call feature. A structured product that is issuer-callable is more likely to be called at a time when the expected amount payable on the investment at maturity and/or at time of call is greater than the amount payable on a comparable instrument at that time. A structured product with an auto-call feature is typically called if, on specified observation dates, the underlying asset is the same price as or has appreciated from its trade date closing price. For these types of autocallable investments, the longer they remain outstanding, the less likely it is that they will be automatically called. This is because if the investment is still outstanding, the underlying asset was below its trade date price as of the last observation Complete Wealth Management ADV Part 2A September 2026 Page 22 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  date and there would be less time remaining to maturity for the underlying asset to recover to or above its trade date price. • Income Features A structured product may pay fixed, contingent or variable interest, or may not pay any interest at all over its term. If a structured product has a lower stated interest rate than that of a traditional fixed-rate bond, it is generally because that interest rate supplements a potential market-linked payment at maturity. If the structured product has a higher stated interest rate than that of a traditional fixed-rate bond, the investment will usually have some downside market exposure and/or the payment of interest may depend on a specified market condition. If a structured product pays contingent or variable interest, you may not receive any interest over the term of the investment. In general, the higher the interest rate for a structured product as compared to the yield payable on the issuer’s traditional fixed-rate bond with a similar maturity, the greater the risk of missing any contingent or variable-rate interest payments that may apply, of receiving no market-linked return at maturity and/or of incurring a loss at maturity, depending on the terms of the investment. Before investing in a structured product, you should fully understand whether or not the investment pays interest over its term and, if there are interest payments, how the interest is calculated and under what circumstances it accrues and is paid. • Other Features A structured product may contain a number of other features that can affect the return potential at maturity. Before investing in a structured product, you need to fully understand all of the features applicable to the investment and consider any risks associated with such features. For more information, please review the specific offering documents for a description of any maximum return, market risk reduction, call or other features as well as a description of any potential interest payments. • Lack of Liquidity Structured products are generally not designed to be actively traded. You should be prepared to hold your structured products to maturity. Unless the relevant offering documents specifically state otherwise, structured products are not listed on any exchange—meaning they are not readily tradable. Typically, if there is any liquidity available for a structured product, it is provided by the issuer of the investment as a service to investors. The issuer is not, however, obligated to provide a liquid secondary market, and you may not be able to sell your investment. If an issuer is making a secondary market for its structured product, it may charge a fee for doing so. Complete Wealth Management ADV Part 2A September 2026 Page 23 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  • Early Termination In addition to any call feature, a structured product may also contain other provisions described in the offering documents that allow the issuer to terminate the investment early under specified circumstances. The payout upon such an early termination event may be lower than the payout at maturity would have been. Overall Risks Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. Item 9 – Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning Complete Wealth Management or any of our IARs. We adhere to high ethical standards for all IARs and associates. Item 10 – Other Financial Industry Activities and Affiliations Neither Complete Wealth Management nor any of its management persons are registered as a broker- dealer or registered as a representative of a broker-dealer, nor does it have any pending application to register. In addition, neither Complete Wealth Management nor its management persons are affiliated with any broker-dealer. Complete Wealth Management and its management persons are not registering as a commodity pool operator, futures commission merchant, or commodity trading advisor. Complete Wealth Management ADV Part 2A September 2026 Page 24 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Other Financial Industry Affiliations The IARs of Complete Wealth Management have the following outside business activities and/or affiliations to disclose. Jeremy David, the Managing Member and Chief Compliance Officer for Complete Wealth Management, is a licensed insurance agent/broker with various companies. The sale of these products accounts for approximately 2-3 hours per week of his time. Jeremy David may recommend insurance products and may also, as an independent insurance agent, sell those recommended insurance products to clients. The sale of these products accounts for approximately 2-3 hours per week of his time. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed IARs earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. Jeremy David serves as President of Complete Financial Group, Inc. Complete Financial Group, Inc. is an in this role. insurance agency. Jeremy David spends approximately 5 hours per month Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading General Information We have adopted a Code of Ethics for all supervised persons of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended. Participation or Interest in Client Accounts Our Compliance policies and procedures prohibit anyone associated with Complete Wealth Management from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO. The following acts are prohibited: • Employing any device, scheme or artifice to defraud • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading Complete Wealth Management ADV Part 2A September 2026 Page 25 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  • Engaging in any fraudulent or deceitful act, practice or course of business • Engaging in any manipulative practices Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO. Personal Trading We may recommend securities to you that we will purchase for our own accounts. We may trade securities in our account that we have recommended to you as long as we place our orders after your orders. This policy is meant to prevent us from benefiting as a result of transactions placed on behalf of advisory accounts. Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Complete Wealth Management has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of “Access Persons”. The policy requires that an Access Person of the firm provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date the Adviser selects; provided, however that at any time that the Adviser has only one Access Person, he or she shall not be required to submit any securities report described above. We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading are met: • No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of IARs of Complete Wealth Management, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours. Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request. Complete Wealth Management ADV Part 2A September 2026 Page 26 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Conflicts of Interest Complete Wealth Management’s IARs may employ the same strategy for their personal investment accounts as it does for its clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. As part of our relationship with Betterment and Betterment Securities, Betterment may offer us services intended to help us manage and further develop our business enterprise, such as additional advisory services, access to webinars, and advice about using the Betterment for Advisors platform to grow our business. Betterment may offer different or expanded services in the future. These services could create an incentive for us to recommend that our Clients invest through the Betterment for Advisors platform. This is a potential conflict given that our interest in recommending Betterment could be influenced by our receipt of Betterment’s and/or Betterment Securities’ services to our business. Additionally, Betterment may offer discounted pricing to our Clients based on the total combined assets of all of our firm’s Clients on the Betterment for Advisors platform. Item 12 – Brokerage Practices Factors Used to Select Custodians In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We require clients use Charles Schwab, Betterment, or other approved custodians as the qualified custodian for their accounts when utilizing our asset management services. Economic Benefits Complete Wealth Management will require clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. Complete Wealth Management is independently owned and operated and not affiliated with Schwab. Schwab provides Complete Wealth Management with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds Complete Wealth Management ADV Part 2A September 2026 Page 27 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Complete Wealth Management 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 Complete Wealth Management other products and services that benefit Complete Wealth Management but may not benefit its clients’ accounts. These benefits may include national, regional or Complete Wealth Management specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Complete Wealth Management by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Complete Wealth Management 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 Complete Wealth Management’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 Complete Wealth Management’s accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to Complete Wealth Management other services intended to help Complete Wealth Management 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 Complete Wealth Management by independent third parties. Schwab Advisor Services 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 Complete Wealth Management. While, as a fiduciary, Complete Wealth Management endeavors to act in its clients’ best interests, Complete Wealth Management’s requirement that clients maintain their assets in accounts at Schwab, Betterment, or another custodian that we approve will be based in part on the benefit to Complete Wealth Management of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Soft Dollars Schwab, Betterment, other approved custodians, and other third-party managers may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under the rules. These research products and/or services will assist the IAR in its investment decision making process. Such research generally will be used to service all of the IAR’s clients, but brokerage commissions paid by the client may be used to pay for research that is not used in managing the client’s Complete Wealth Management ADV Part 2A September 2026 Page 28 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  account. The account may pay to a broker-dealer a commission greater than another qualified broker- dealer might charge to affect the same transaction where the IAR determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Because soft dollar benefits could be considered to provide a benefit to the adviser that might cause the client to pay more than the lowest available commission without receiving the most benefit, they are considered a conflict of interest in recommending or directing custodial and third-party managerial services. Complete Wealth Management mitigates these conflicts of interest through strong oversight of soft-dollar arrangements by the Chief Compliance Officer, in order to assure the soft dollar benefits serve the best interests of the client. There may other benefits from recommending Schwab, Betterment, other approved custodians, or other third party managers such as software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Other services may include, but are not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third-party service providers who provide a wide array of business-related services and technology with whom Complete Wealth Management may contract directly. Complete Wealth Management may receive seminar expense reimbursements from product sponsors which may be based on the sales of products to their clients. Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Best Execution We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, reputation and responsiveness. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for account transactions. Brokerage for Client in the Betterment Wrap Program With respect to the Betterment wrap program, Betterment Securities is responsible for execution of securities transactions and maintains custody of customer assets. Betterment Securities exercises no discretion in determining if and when trades are placed; it places trades only at the direction of Betterment. Clients should understand that the appointment of Betterment Securities as the broker for their accounts held at Betterment may result in their receiving less favorable trade executions than may be available through the use of broker-dealers that are not affiliated with Betterment. If Clients do not wish to place assets with or execute trades through Betterment Securities, then we cannot manage your accounts on the Betterment for Advisors platform. Complete Wealth Management ADV Part 2A September 2026 Page 29 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Brokerage for Client Referrals In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third party. Directed Brokerage We do not permit directed brokerage. We will require you to use the custodian of our choosing as the custodial firm. Trading Transactions for each client account generally will be affected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such Orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. Under this procedure, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. Transactions placed in an asset management account by a third-party manager will be executed through their broker-dealer or custodian. In determining best execution for these transactions, the third-party manager is looking at whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. While they look for competitive commission rates, they may not obtain the lowest possible commission rates for account transactions. The aggregation and allocation practices of mutual funds and third-party managers that we recommend to you are disclosed in the respective mutual fund prospectuses and third-party manager disclosure documents which will be provided to you. Retirement Plan Services As it relates to ERISA Plan business, our model does not involve transactional business and, consequently, we do not currently engage brokers in any transactional capacity. Best Execution We do not trade in any Plan client accounts. Trading We do not trade in individual Plan participant accounts. Qualified Retirement Plan Trading We do not accept trading authorization with respect to any participants’ plan account. Complete Wealth Management ADV Part 2A September 2026 Page 30 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  Item 13 – Review of Accounts Reviews Reviews are conducted at least annually or as agreed to by us. Reviews will be conducted by our Chief Compliance Officer Jeremy David. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Reports You will be provided with account statements reflecting the transactions occurring in the account on at least a quarterly basis. These statements will be written or electronic depending upon what you selected when you opened the account. You will be provided with paper confirmations for each securities transaction executed in the account. You are obligated to notify us of any discrepancies in the account(s) or any concerns you have about the account(s). Item 14 – Client Referrals and Other Compensation Our firm receives economic benefit from Schwab and Betterment in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab and Betterment, respectively. These products and services, how they benefit out firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of their products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Item 15 – Custody We do not have physical custody of any accounts or assets. However, we may be deemed to have custody of your account(s) if we have the ability to deduct your advisory fees from the custodian. We use Charles Schwab, Betterment, or other approved custodians as the custodian and/or broker-dealer for all your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements and compare this official custodial record to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. If you notice any discrepancies, please contact Complete Wealth Management. Complete Wealth Management ADV Part 2A September 2026 Page 31 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees and to pay them to us. You authorized the custodian to pay us directly at the onset of the relationship. Retirement Plan Services If authorized by the Plan Sponsor, we have the ability to debit fees directly from the Plan Sponsor’s bank account through the submission of a billing file to the plan custodian, however, we do not have authority to possess or take actual custody of clients’ funds or securities. Plan Sponsors and plan participants should receive at least quarterly statements from the recordkeeper and Plan Sponsors and participants should carefully review such statements. Standing Letter of Authorization Complete Wealth Management is deemed to have custody of client funds or securities as a result of maintaining standing letters of authorization (SLOA) for the purpose of distributing funds from a client’s account. For those accounts in which we have the ability to initiate distributions from a client’s account, via journal, ACH or wire to a third party, which is an account held in the name of someone other than the client, we will ensure the following conditions have been met in order for us to be in compliance with SEC and State Custody Rules and ensure the safe keeping of our client’s funds: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. Item 16 – Investment Discretion We usually receive discretionary authority from you at the beginning of an advisory relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account. Complete Wealth Management ADV Part 2A September 2026 Page 32 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC  When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Prior to assuming discretionary authority, clients must execute the Advisory Agreement. Execution of the Advisory Agreement grants us the authority to determine, without obtaining specific client consent, both the amount and the type of securities to be bought and sold to help achieve the client account objectives. As further described in Item 4 above, under 3(21) Fiduciary Services, in providing 3(21) fiduciary services we exercise limited discretion over Plan assets in that we make investment recommendations to Plan Sponsors, but the Plan Sponsor may or may not implement the recommendation(s). Qualified Retirement Plan Advisory Services Our recommendations regarding our 3(21)-qualified retirement plan consulting services are made on a non-discretionary basis. The plan sponsor retains the decision-making authority over the plan. When recommending securities, we observe the investment policies, limitations, and restriction set by the plan and plan sponsor. Item 17 – Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies. The custodian will forward you copies of all proxies and shareholder communications relating to your account assets. Item 18 – Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of five hundred dollars and more than six months in advance of advisory services rendered. Complete Wealth Management ADV Part 2A September 2026 Page 33 of 33 © 2010 – 2026 Red Oak Compliance Solutions LLC