Continuum Wealth Advisors, LLC

Continuum Wealth Advisors, LLC Form ADV Part 2A - Disclosure Brochure Effective: July 14th 2026 This Form ADV 2A ("Disclosure Brochure") provides information about the qualifications and business practices of Continuum Wealth Advisors, LLC ("Continuum" or the "Advisor"). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (518) 583-4050 or by email at info@contwealth.com. Continuum is a registered investment advisor with the U.S. Securities and Exchange Commission ("SEC"). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Continuum to assist you in determining whether to retain the Advisor. Additional information about Continuum and its Advisory Persons is available on the SEC's website at www.adviserinfo.sec.gov by searching with the Advisor's firm name or firm CRD# 152895. Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Continuum. For convenience, the Advisor has combined these documents into a single disclosure document. Continuum believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Continuum encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes Since the last annual update, Continuum has updated this Disclosure Brochure to provide additional disclosure regarding its use of unaffiliated third-party money managers, model providers, managed account platforms, and similar investment management providers. These updates include additional disclosure regarding Continuum’s due diligence and oversight of unaffiliated managers, the use of managed account platforms available through custodians, the potential use of options strategies by certain unaffiliated managers, and the fees and expenses that apply when Client assets are managed by an unaffiliated manager. Continuum has also clarified that assets managed by certain unaffiliated managers may be subject to a reduced Continuum advisory fee, in addition to fees charged by the unaffiliated manager, platform, custodian, or other service providers. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Continuum. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 152895. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (518) 583-4050 or by email at info@contwealth.com. Page 2 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Item 3 - Table of Contents Item 1 - Cover Page ................................................................................................................................................................. 1 Item 2 - Material Changes ....................................................................................................................................................... 2 Item 3 - Table of Contents ....................................................................................................................................................... 3 Item 4 - Advisory Services ...................................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................ 4 B. Advisory Services Offered ............................................................................................................................................. 4 C. Client Account Management.......................................................................................................................................... 7 D. Wrap Fee Programs ...................................................................................................................................................... 7 E. Assets Under Management ........................................................................................................................................... 7 Item 5 - Fees and Compensation ............................................................................................................................................ 7 A. Fees for Advisory Services ............................................................................................................................................ 7 B. Fee Billing ...................................................................................................................................................................... 9 C. Other Fees and Expenses ........................................................................................................................................... 10 D. Advance Payment of Fees and Termination ................................................................................................................ 10 E. Compensation for Sales of Securities .......................................................................................................................... 11 Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................................... 11 Item 7 - Types of Clients ....................................................................................................................................................... 11 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................ 12 A. Methods of Analysis .................................................................................................................................................... 12 B. Risk of Loss ................................................................................................................................................................. 12 Item 9 - Disciplinary Information .......................................................................................................................................... 14 Item 10 - Other Financial Industry Activities and Affiliations ............................................................................................. 14 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................... 15 A. Code of Ethics ............................................................................................................................................................. 15 B. Personal Trading with Material Interest ........................................................................................................................ 15 C. Personal Trading in Same Securities as Clients .......................................................................................................... 15 D. Personal Trading at Same Time as Client ................................................................................................................... 15 Item 12 - Brokerage Practices .............................................................................................................................................. 16 A. Recommendation of Custodian[s] ................................................................................................................................ 16 B. Aggregating and Allocating Trades .............................................................................................................................. 17 Item 13 - Review of Accounts ............................................................................................................................................... 17 A. Frequency of Reviews ................................................................................................................................................. 17 B. Causes for Reviews ..................................................................................................................................................... 17 C. Review Reports ........................................................................................................................................................... 18 Item 14 - Client Referrals and Other Compensation ........................................................................................................... 18 A. Compensation Received by Continuum ....................................................................................................................... 18 B. Compensation for Client Referrals ............................................................................................................................... 18 Item 15 - Custody................................................................................................................................................................... 19 Item 16 - Investment Discretion ............................................................................................................................................ 19 Item 17 - Voting Client Securities ......................................................................................................................................... 19 Item 18 - Financial Information ............................................................................................................................................. 19 Page 3 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Item 4 – Advisory Services A. Firm Information Continuum Wealth Advisors, LLC (“Continuum” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of New York. Continuum was founded in 2010, and is primarily owned and operated by Timothy Smith (Chief Executive Officer). The Chief Compliance Officer of Continuum is Jennifer Henry. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Continuum. B. Advisory Services Offered Continuum offers investment advisory services to individuals, high net worth individuals, trusts, estates, and retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Continuum’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Continuum may provide Clients with wealth management services, which generally includes a broad range of comprehensive financial planning services in connection with discretionary management of investment portfolios. These services are described below. Investment Management Services – Continuum provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary or non-discretionary investment management and related advisory services. Continuum works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Continuum will then construct a portfolio primarily consisting of mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and/or independent investment managers (“Independent Managers”) to achieve the Client’s investment goals. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Continuum’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Continuum will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Continuum evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Continuum may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Continuum may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Continuum may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Page 4 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  At no time will Continuum accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee- based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers and Managed Account Platforms When deemed to be in the Client’s best interest, Continuum may recommend that all or a portion of a Client’s portfolio be implemented through one or more unaffiliated third-party money managers, model providers, sub-advisers, managed account platforms (“SMA Programs”), turnkey asset management platforms, or similar investment management providers, each referred to in this Disclosure Brochure as an “Independent Manager.” Independent Managers may be accessed directly or through platforms made available by custodians or other third-party service providers. Continuum’s role with respect to Independent Managers may include recommending or selecting an Independent Manager, assisting the Client in establishing investment objectives and restrictions, allocating or reallocating assets to or from an Independent Manager, reviewing the Independent Manager’s investment strategy and disclosures, monitoring the continued appropriateness of the Independent Manager for the Client, and coordinating with the Client, Independent Manager, platform, and custodian as appropriate. Prior to recommending an Independent Manager, Continuum conducts due diligence that may include, as applicable, review of the Independent Manager’s registration status, Form ADV or other disclosure documents, investment strategy, fee schedule, disciplinary history, background information, platform materials, marketing materials, operational capabilities, and other information Continuum deems relevant. Continuum does not rely solely on the availability of an Independent Manager through a custodian or managed account platform as a substitute for Continuum’s own due diligence review. The availability of an Independent Manager through a custodian or platform does not mean that the custodian or platform has determined that the Independent Manager is suitable for any particular Client. In certain instances, the Client may be required to authorize and enter into an investment management agreement, account agreement, platform agreement, options agreement, or similar document with the Independent Manager, custodian, or platform. The Independent Manager may have discretionary authority over the portion of the Client’s account allocated to the Independent Manager, subject to the terms of the applicable agreement and any reasonable restrictions accepted by the Independent Manager. Certain Independent Managers may utilize investment strategies that include options transactions, including covered options strategies. Clients participating in such strategies may be required to obtain the appropriate level of options trading approval from the custodian before assets can be managed pursuant to the strategy. Continuum will consider the use of an Independent Manager, including any options-based strategy, in light of the Client’s investment objectives, risk tolerance, financial circumstances, liquidity needs, and other relevant information provided by the Client. Page 5 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Before entering into an agreement with an Independent Manager, the Client will receive, as applicable, the Independent Manager’s Form ADV Part 2A or other disclosure brochure, fee schedule, investment management agreement, platform documents, and other relevant disclosures. Participant Account Management – As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client account without having access through the Client’s credentials. This independent advisor access ensures that the Advisor will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is not affiliated with the platform in any way and receives no compensation from the platform. A link will be provided to the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access. Financial Planning Services – Continuum provides a variety of financial planning services to Clients as a part of the Advisor’s wealth management service. Clients may also engage the Advisor separately for financial planning services, pursuant to a written agreement. Financial plans are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Continuum may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. The Advisor may also recommend a third party for estate planning services in the context of Continuum’s financial planning service. The Advisor does not receive any compensation from recommending this third party. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction[s] through the Advisor. 401(k) and Profit-Sharing Plan Platform Continuum will provide fiduciary and non-fiduciary services to plans. Continuum will work with plan sponsors and third-party administrators to ensure that the objectives for the plan participants are achieved. Non-discretionary investment advice regarding asset classes and investment alternatives Page 6 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  available for the plan will be provided to the plan sponsor in accordance with the plan’s investment policies and objectives. However, it is up to the plan sponsor to make the final decisions regarding the initial selection, retention, removal and/or addition of investment options. Continuum acts as the client relationship manager for plan participants, providing information and answering questions including, but not limited to, account balances, loans, beneficiary designations and rollovers. They act as the liaison, when needed, with the third-party administrator. C. Client Account Management Prior to engaging Continuum to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Continuum, in connection with the Client, will develop a strategy to achieve the Client’s goals and objectives. • Asset Allocation – Continuum will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Continuum will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Continuum will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Continuum does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2025, Continuum manages approximately $345,582,814 in Client assets, $337,567,211 of which are managed on a discretionary basis and $8,015,603 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more agreements with the Advisor. A. Fees for Advisory Services Wealth Management Services For Clients engaged for comprehensive wealth management services, the Client will be charged a single combined investment advisory fees for investment management and financial planning. Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range from 0.60% to 1.00% annually based on the following tiered schedule: Assets Under Management Up to $2,000,000 $2,000,001 to $3,000,000 Annual Rate 1.00% 0.90% Page 7 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  $3,000,001 to $5,000,000 $5,000,001 to $7,500,000 $7,500,001 and over 0.80% 0.70% 0.60% The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Continuum will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, Continuum may implement all or a portion of a Client’s investment portfolio through one or more Independent Managers. For assets managed by an Independent Manager, Continuum’s advisory fee may be charged at a reduced rate, as set forth in the Client’s investment advisory agreement, fee schedule, account application, or separate written addendum. Unless otherwise agreed in writing, this reduced advisory fee applies only to the assets managed by the applicable Independent Manager and does not apply to assets managed directly by Continuum, which remain subject to Continuum’s standard fee schedule above. In addition to Continuum’s advisory fee, the Client may pay separate fees and expenses charged by the Independent Manager, platform, custodian, broker-dealer, mutual funds, exchange-traded funds, or other investments or service providers used in connection with the account. The Independent Manager’s fees are separate from Continuum’s advisory fee unless otherwise stated in writing. The total blended fee, including Continuum’s advisory fee and the Independent Manager’s fee, will not exceed 1.00% annually. Continuum does not receive compensation, referral fees, solicitor fees, revenue sharing, or other compensation from Independent Managers in connection with recommending or selecting an Independent Manager. Continuum has a conflict of interest because it charges an advisory fee on assets allocated to Independent Managers. Continuum may also have a financial incentive to recommend that assets remain under Continuum’s advisory relationship. Continuum addresses this conflict by recommending Independent Managers only when Continuum believes the arrangement is in the Client’s best interest based on the Client’s objectives, circumstances, and needs. Financial Planning Services – As noted in Item 4, the Advisor offers its financial planning services as a part of its wealth management services. Clients may choose to engage the Advisor separately for a fixed fee engagement ranging up to $4,500. Fees are negotiable depending on the nature and complexity of each Client’s circumstances. An estimate for total costs will be provided to the Client prior to engaging for financial planning services 401(k) and Profit-Sharing Plan Platform Fees for employer-sponsored plans are based on assets under management as negotiated with the Plan Sponsor and typically range up to 0.50% of plan assets under management. The stated fees are Page 8 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  charged quarterly in advance or arrears, based on the market value of the total plan assets and pursuant on the terms of the investment advisory agreement. All internal fees charged by ETFs, mutual funds and closed end funds are separate and distinct from the fees charged by Continuum. Continuum does not at any time act as the custodian or third-party administrator for any retirement plan or employer sponsored plan Client. B. Fee Billing Wealth Management Services Investment advisory fees will be calculated by the Advisor and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate, based on the tiered schedule above, divided by 4) to the total assets under management with Continuum at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Continuum directly from their accounts held by the Custodian as part of the agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include Continuum’s advisory fee, the Independent Manager’s investment management fee, platform fees, custodial fees, brokerage charges, transaction costs, and other applicable expenses. Continuum’s advisory fee may be deducted from the Client’s account by the custodian, billed by Continuum, or collected through another method authorized by the Client in writing. The Independent Manager’s fee may be calculated and deducted separately by the Independent Manager, custodian, or platform, depending on the terms of the applicable Independent Manager, custodial, and platform documents. Clients should review account statements, invoices, and applicable disclosure documents to understand the total fees and expenses paid in connection with Independent Manager accounts. Continuum’s reduced advisory fee, if applicable, will be described in the Client’s agreement, fee schedule, account application, or separate written addendum.Financial Planning Services – Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. 401(k) and Profit-Sharing Plan Platform Similar to wealth management services described above, investment advisory fees will either be automatically deducted from the Client account by the Custodian or may be invoiced to the Client and paid by check or other method. If directly deducting, the Client authorizes the plan’s custodian or record keeper to remit the fees directly to the Advisor from the plan’s assets and the Advisor shall send an invoice to the plan’s custodian indicating the amount of the fees to be deducted from the Client Account[s] at the respective quarter end date. The amount due in all cases is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Continuum at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients may provide written authorization permitting Continuum to be paid Page 9 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Continuum, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The investment advisory fee charged by Continuum is separate and distinct from these custody and execution fees. In addition, all fees paid to Continuum for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Continuum, but would not receive the services provided by Continuum which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Continuum to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. Accounts managed by Independent Managers may incur additional fees and expenses, including Independent Manager fees, managed account platform fees, custodial fees, brokerage charges, transaction charges, options-related fees, margin or options approval-related costs, and internal expenses of mutual funds, ETFs, or other investment products used by the Independent Manager. These fees are separate from Continuum’s advisory fee. Clients should review the Independent Manager’s disclosure brochure, fee schedule, custodial documents, platform documents, and account statements to understand the total cost of the arrangement. D. Advance Payment of Fees and Termination Wealth Management Services Continuum is compensated for its services in advance of the quarter in which wealth management services are rendered. Either party may terminate the investment advisory agreement with Continuum, at any time, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s agreement with the Advisor is non- transferable without the Client’s prior consent. Use of Independent Managers – In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager. Continuum will assist the Client with the termination and transition as appropriate. Page 10 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Financial Planning Services – Continuum is compensated for its financial planning services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is non- transferable without the Client’s prior consent. 401(k) and Profit-Sharing Plan Platform Continuum is compensated for its 401(k) and profit-sharing plan services in advance or arrears of the quarter in which services are rendered. Either party may terminate the investment advisory agreement with Continuum, at any time, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities Continuum does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with Continuum. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Advisory Persons are not required to offer the products of any particular insurance company. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Item 6 – Performance-Based Fees and Side-By-Side Management Continuum does not charge performance-based fees for its investment advisory services. The fees charged by Continuum are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Continuum does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Continuum provides investment advisory services to individuals, high net worth individuals, trusts, estates, retirement plans. Continuum generally requires a minimum relationship size of $500,000. The minimum relationship size may be waived at the sole discretion of the Advisor. Additionally, certain Independent Managers may impose minimums for their investment strategies. Page 11 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Continuum primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Continuum are derived from numerous sources, including financial media companies, third- party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Continuum generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Continuum will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Continuum may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Independent Manager Due Diligence When recommending or selecting an Independent Manager, Continuum considers factors such as the Independent Manager’s registration status, investment strategy, portfolio management process, risk controls, experience, disciplinary history, fees and expenses, disclosure documents, operational capabilities, trading authority, platform requirements, and the manner in which the strategy fits within the Client’s overall portfolio. Continuum also considers whether the Independent Manager’s strategy is appropriate in light of the Client’s investment objectives, risk tolerance, time horizon, liquidity needs, tax considerations, and other relevant circumstances. Continuum’s due diligence and monitoring do not guarantee the future performance of any Independent Manager or eliminate the risks associated with the Independent Manager’s strategy. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Continuum will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the Page 12 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Independent Manager Risk Continuum may recommend that all or a portion of a Client’s assets be managed by an Independent Manager. The use of an Independent Manager involves risks, including the risk that the Independent Manager’s strategy will underperform, that the Independent Manager will deviate from its stated investment process, that the Independent Manager’s investment decisions will be unsuccessful, or that the Independent Manager’s services may not remain appropriate for the Client. Continuum’s review and monitoring of an Independent Manager does not guarantee the performance of the Independent Manager or prevent losses in the Client’s account. Managed Account Platform Risk Certain Independent Managers may be accessed through custodial or third-party managed account platforms. These platforms may impose operational, trading, documentation, account minimum, options approval, or other requirements. Platform availability does not mean that the platform or custodian has determined that an Independent Manager or strategy is suitable for any particular Client. Platform or custodial limitations, technology issues, trading restrictions, or delays may affect account implementation, trading, reporting, or the termination of an Independent Manager strategy. Options Risk Certain Independent Managers may use options strategies, including covered options strategies. Options involve risks that may not be present in traditional equity or fixed income investments. These risks include, but are not limited to, market risk, liquidity risk, volatility risk, assignment risk, counterparty or clearing risk, tax risk, and the risk that the strategy may limit upside participation or increase losses depending on market conditions. Covered options strategies may generate income, but they can also result in the sale of an underlying security at a price below its current market value, Page 13 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  reduce participation in gains, or create tax consequences. Options strategies are not appropriate for all Clients, and Clients may be required to obtain the appropriate level of options trading approval from the custodian before participating in such strategies. Strategy-Specific Risk Independent Managers may use strategies that differ from Continuum’s standard investment approach. These strategies may involve more frequent trading, concentrated positions, options, or other techniques that create risks different from, or greater than, those associated with Continuum’s traditional long-term investment strategies. Clients should review the Independent Manager’s disclosure documents and discuss the risks of any Independent Manager strategy with Continuum before participating. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Continuum or its owner. Continuum values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov and can be found by searching with the Advisor’s firm name or firm CRD# 152895. Item 10 – Other Financial Industry Activities and Affiliations Insurance License As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with Continuum. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Advisory Persons are not required to offer the products of any particular insurance company. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Continuum Tax Advisors, LLC Timothy Smith and David Rath partially own Continuum Tax Advisors, LLC (“Continuum Tax”), an affiliated entity that provides tax preparation services to Clients. Tax preparation services are separate and distinct from the advisory services offered to Clients and based on the unique needs of each Client. The time devoted to tax preparation generally increases during tax season. Clients are not obligated to engage Continuum Tax for these services in order to have an advisory relationship with the Advisor. Use of Independent Managers As noted in Item 4, Continuum may implement all or a portion of a Client’s investment portfolio with one or more Independent Managers. Continuum does not receive compensation, referral fees, revenue sharing, solicitor fees, or other compensation from Independent Managers in connection with Page 14 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  recommending or selecting an Independent Manager. Continuum only receives its advisory fee as described in Item 5. The use of Independent Managers presents certain conflicts of interest. For example, Continuum has a financial incentive to recommend or retain assets under its advisory relationship because Continuum charges an advisory fee on those assets, including assets managed by an Independent Manager. In addition, the Client may pay both Continuum’s advisory fee and separate fees charged by the Independent Manager, platform, custodian, or other service providers. Continuum addresses these conflicts by reviewing the fees, services, strategy, and risks of an Independent Manager and recommending or continuing the use of an Independent Manager only when Continuum believes the arrangement is in the Client’s best interest. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Continuum has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with Continuum (“Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Continuum and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Continuum Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (518) 583- 4050 or via email at info@contwealth.com. B. Personal Trading with Material Interest Continuum allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Continuum does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Continuum does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Continuum allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted, consistent with Section 204A of the Investment Advisers Act of 1940, a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of Continuum have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Continuum requiring reporting of personal securities trades pursuant to its Code of Ethics. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Continuum allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client Page 15 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  orders or traded afterward. At no time will Continuum, or any Supervised Person of Continuum, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Continuum does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Continuum to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Continuum does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Continuum does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Continuum. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Continuum may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation and/or the location of the Custodian’s offices. Continuum will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”) a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Continuum maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: Brokerage Practices for Independent Manager and SMA Accounts For accounts or assets managed through an Independent Manager or SMA program, trading and brokerage practices may be determined by the Independent Manager, SMA Manager, platform provider, custodian, or applicable program documentation. The SMA Manager may have discretion to place trades, direct trades, rebalance accounts, aggregate orders, or implement model portfolio changes for accounts enrolled in the program. Continuum may not control the timing, execution, or allocation of individual trades placed by an SMA Manager. Continuum will review the brokerage and trading practices of Independent Managers and SMA Managers as part of its due diligence and ongoing oversight process. However, clients should understand that the use of an SMA program may limit Continuum's ability to seek alternative execution venues or negotiate trading terms for trades placed by the SMA Manager. 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Continuum does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor does receive certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Continuum does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – Except for accounts or assets managed through an Independent Manager or SMA program, Clients are generally serviced on a “directed brokerage basis,” where Continuum will place trades within the established account[s] at the Custodian designated by the Client. For accounts or assets managed through an Independent Manager or SMA program, brokerage and trading practices may be determined by the Independent Manager, SMA Manager, platform provider, custodian, or applicable program documentation. Further, Client accounts are traded within their Page 16 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Continuum will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian, Independent Manager, SMA Manager, platform provider, or other applicable trading party, as applicable. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Continuum will execute its transactions through the Custodian as directed by the Client. Continuum may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage particular Client accounts. Where an Independent Manager or SMA Manager is responsible for trading client accounts, such manager may aggregate, allocate, or implement trades according to its own trading policies and procedures. Continuum will seek to understand and periodically review the manager's trading practices, but Continuum may not be responsible for the manager's day-to-day trade aggregation, allocation, or execution decisions. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by members of the Investment Review Team of Continuum. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Continuum if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. Review of Independent Manager and SMA Accounts For Client accounts or assets managed through an Independent Manager or SMA program, Continuum will periodically review the account, the continued suitability of the manager or strategy, and the services provided by the Independent Manager or SMA Manager. Such reviews may include consideration of performance, holdings, investment strategy, risk profile, fees, client objectives, restrictions, manager disclosures, operational issues, and any material changes reported by the manager or otherwise identified by Continuum. Continuum's review of SMA accounts is generally focused on the suitability and oversight of the SMA program and manager, rather than day-to-day selection or trading of individual securities within the SMA strategy. Additional reviews may be conducted as a result of client requests, material market Page 17 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  events, changes in a client's financial situation, changes in the manager's strategy or personnel, regulatory disclosures, or other information that Continuum determines to be relevant. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Continuum Participation in Institutional Advisor Platform Continuum has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Continuum. As a registered investment advisor participating on the Schwab Advisor Services platform, Continuum receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services to Continuum that may not benefit the Client, including: educational conferences and events, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Continuum believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Continuum does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Page 18 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com  Item 15 – Custody Continuum does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Continuum exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Continuum to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by Continuum to ensure accuracy, as the Custodian does not perform this review. For accounts managed by an Independent Manager, the Independent Manager, custodian, or platform may deduct the Independent Manager’s fees or platform fees from the Client’s account pursuant to the Client’s written authorization and the applicable Independent Manager, custodial, or platform documents. Continuum’s custody disclosure relates to Continuum’s authority to deduct its advisory fees and does not address custody that may arise from the authority granted to an Independent Manager, custodian, or platform under separate agreements with the Client. Item 16 – Investment Discretion Continuum typically has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, restrictions, or limitations previously set forth by the Client and agreed to by Continuum. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an agreement containing all applicable limitations to such authority. All discretionary trades made by Continuum will be in accordance with each Client's investment objectives and goals. For accounts or assets enrolled in an Independent Manager or SMA program, discretionary authority may be exercised by the Independent Manager or SMA Manager pursuant to the applicable client authorization, investment management agreement, program agreement, custodial documentation, or other relevant documents. In such cases, the Independent Manager or SMA Manager may make day- to-day investment decisions, including purchases, sales, and rebalancing, for the assets enrolled in the program. Continuum remains responsible for evaluating the suitability of the manager or SMA program for the Client and for conducting ongoing oversight of the manager, but Continuum may not make the day-to-day investment decisions for assets managed by the Independent Manager or SMA Manager. Item 17 – Voting Client Securities Continuum does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Continuum, nor its management, have any adverse financial situations that would reasonably impair the ability of Continuum to meet all obligations to its Clients. Neither Continuum, nor any of its advisory persons, have been subject to a bankruptcy or financial compromise. Continuum is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Page 19 Continuum Wealth Advisors, LLC 18 Division Street, Suite 207B, Saratoga Springs, NY 12866 Phone: (518) 583-4050 * Fax: (518) 587-5303 http://www.contwealth.com